The Website and the offerings therein are intended only for accredited investors (for persons residing in the U.S.), and for persons residing abroad in jurisdictions where exemptions from securities registration apply. Securities offered on the Website are offered through RealCadre LLC (successor to RealCadre Company, Inc.) (“RealCadre”), a registered broker/dealer and member FINRA and SIPC and an affiliate of Cadre Web Host. Information on all FINRA member broker-dealers can be found on FINRA's BrokerCheck. Cadre Web Host, along with its affiliates (including RealCadre) and its and their directors, officers, advisors and employees shall herein be referred to collectively as “Cadre”. Several officers and employees of Cadre Web Host are registered representatives of RealCadre. Thus, Cadre Web Host, and those of its officers and employees that are registered representatives of RealCadre, will realize compensation through RealCadre as a result of any transaction closed via the Website.
Cadre grants you a limited right to use the Website. The individual user shall not use the Website in any way that is fraudulent or unlawful. Your right to use the Website is subject to your agreement to abide by the Terms and Conditions of Use in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Website. At any time and for any reason Cadre may revoke your right to use all or any portion of the Website. Cadre reserves the right to make changes to the Website and the Terms and Conditions of Use at any time without prior notice to you. For this reason, each time you use the Website, you should visit and review the then-current Terms and Conditions of Use that apply to your use of the Website. The Website and the Content is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. As a condition of your use of the Website, you agree to indemnify and hold Cadre and its Associates (defined below) harmless from and against any and all claims, losses, liability, costs and expenses (including but not limited to attorney’s fees), as incurred, arising from your use of the Website or related services or from your violation of the Terms and Conditions of Use.
EACH TIME YOU USE THE WEBSITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE THESE TERMS AND CONDITIONS IN CURRENT FORM. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS STATED HEREIN, DO NOT USE THE WEBSITE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS OF USE, YOU AGREE THAT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE WEBSITE. YOUR COMPLIANCE WITH THESE TERMS AND CONDITIONS OF USE IS A CONDITION TO YOUR RIGHT TO ACCESS THE WEBSITE. YOUR BREACH OF ANY PROVISION OF THESE TERMS AND CONDITIONS OF USE WILL AUTOMATICALLY, WITHOUT THE REQUIREMENT OF NOTICE OR OTHER ACTION, REVOKE AND TERMINATE YOUR RIGHT TO ACCESS THE WEBSITE AND YOU WILL BE FULLY LIABLE FOR CONVERSION, MISAPPROPRIATION, TRESPASS TO CHATTELS AND ALL OTHER CLAIMS AND CAUSES, REGARDLESS OF THE IDENTITY OF CLAIMANT OR INJURED PARTY, ARISING FROM OR RELATING TO YOUR CONTINUED USE OF THE WEBSITE AFTER SUCH BREACH.
Cadre Cash LLC, an affiliate of the Cadre Web Host, offers Cadre Cash which facilitates the opening and managing of Cadre Cash Accounts (“Cash Account”). Neither Cadre Cash LLC nor Cadre is a bank and we do not directly transmit funds to or from your Cash Account.
This FDIC Multi-Bank Program Disclosure (“Disclosure”) describes services offered or made available to you by Synapse accessible, either currently or in the future, by Synapse’scustomers (including Cadre Cash LLC, each a “Platform”) whether accessed through Synapse directly or Platform’s website or mobile application. The words “I,” “you” and “your” mean any individual or entity who accepts this Disclosure.
If you have opened an account at Evolve Bank & Trust (“Account”) through a Platform, your Account may be eligible to participate in a program designed to increase the FDIC insurance coverage for the funds held in your Account. Platform has partnered with Synapse Financial Technologies, Inc. (“Synapse”) to offer you the ability to increase the FDIC insurance coverage of your funds held in your eligible Account up to $750,000 (“FDIC Multi-Bank Program”). In order to make the FDIC Multi-Bank Program available to users like you, each Platform, acting through Synapse as its agent, will open custodial accounts at each Program Bank in which each Platform will hold the funds for the benefit of users like you who have opted into the FDIC Multi-Bank Program (“Platform FBO Accounts”). Under the FDIC Multi-Bank Program and with your authorization, Synapse, as the Platform’s agent and acting upon your instructions, will automatically transfer funds in and out of Platform FBO Accounts in an effort to maximize your potential FDIC insurance coverage.
If you opt into the Multi-Bank Program, you authorize and appoint Platform to move funds through its agent, Synapse, held in your associated Account at Evolve Bank & Trust to and from Platform FBO Accounts in which funds are held for your benefit and the benefit of other Platform users at one or more Program Banks.
Currently, the banks that participate in this FDIC Multi-Bank Program are I-Bank and First Horizon Bank (“Program Banks”). To the extent additional banks agree to participate in this FDIC Multi-Bank Program, Synapse or Platform will inform you of the additional Program Banks at least 30 days in advance of any additional bank coming onboard. If Platform ends its relationship with a Program Bank, Platform or Synapse will inform you and will transfer your funds to another Program Bank. Your continued participation in the FDIC Multi-Bank Program after being informed of any changes to the participating Program Banks constitutes your acceptance of such changes and transfers.
Through this FDIC Multi-Bank Program, you will not have a direct account relationship with the Program Banks. You will not receive any passbook, certificate, or other evidence of ownership related to Platform FBO Accounts. Ownership of Platform FBO Accounts will be evidenced by a book-entry on the account records of each Program Bank and by records maintained by Platform through Synapse as agent. Platform will hold your funds for your benefit within Platform FBO Accounts at each Program Bank and make deposits to and withdrawals from such accounts. All transactions with respect to your funds held in Platform FBO Accounts must be directed by Platform or Synapse and all information concerning your funds held at Platform FBO Accounts can only be obtained from Platform or Synapse. The Program Banks have no obligation to or provide you with information or to accept instructions from you with respect to your funds held in a Platform FBO Account.
The funds held in a Platform FBO Account will be eligible for pass-through FDIC insurance. However, your funds that exceed FDIC Insurance limits will not be eligible for pass-through FDIC Insurance while they are being transferred between Program Banks. This means your funds will only receive pass-through FDIC insurance once the funds arrive at a Program Bank.
Your funds may be divided in up to three (3) different banks, including the bank with which you opened your associate account, and you may be eligible for up to $750,000 of FDIC insurance (three banks, $250,000 per bank). If the number of available Program Banks changes, or you elect not to use, and/or have existing assets at, one or more of the available program banks, the actual amount of FDIC coverage could be lower. For more information on FDIC insurance coverage, please visit www.FDIC.gov.
To the extent you opt into this program in connection with multiple Platforms, your FDIC coverage is based on your aggregate account deposits and assets by ownership category and not by Platform. Specifically, if you opt into the FDIC Multi-Bank Program through more than one Platform, you are not entitled to FDIC coverage for each Platform. You are responsible for monitoring the total amount of deposits and assets that you hold in the same ownership capacity with any one Program Bank (including an Excess Bank, as applicable), directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available.
Once your Account reaches the deposit limit of $250,000.00, Synapse, acting on behalf of Platform, will transfer any funds in such Account in excess of the deposit limit to a Program Bank.
In order to maximize FDIC insurance, Platform, through its agent, Synapse, may transfer your funds between Program Banks and Excess Banks.
In the event the funds in your Account go below $250,000.00 or you request a transfer from your Account in excess of $250,000.00, Synapse, acting on behalf of Platform, will transfer any surplus amounts at a Program Bank to your Account.
Funds can only be debited by you directly from your Account. You understand and acknowledge that there will be a delay in accessing your funds that have already been transferred to a Program Bank. These funds will only be available by you for withdrawal once the transfer has settled from the Program Bank to your Account. For example, if you have $250,000.00 in your Account and $50,000.00 in the FDIC Multi-Bank Program for a total of $300,000.00, and you request to withdraw $300,000.00 from your Account, your withdrawal request will be delayed until the $50,000.00 arrives at your Account.
In the event all Program Banks have reached their respective deposit limits of $250,000, your funds will be transferred to Program Banks that will accept your funds without limit (each an “Excess Bank”). Currently, First Horizon Bank is the only participating Excess Bank.
You may opt out of the Multi-Bank Program or opt out of having your funds transferred to one or more of the Program Banks or you may change a previous decision to opt out of deposits to a specific Program Bank. If you decide to opt out of the Multi-Bank Program, you understand that your underlying account at Evolve will be closed.
You will not receive interest or any other earnings on funds held in Platform FBO Accounts and you agree that any interest that may be earned on funds in a Platform FBO Accounts are owned by Platform.
Funds held at each Program Bank will be reflected jointly with your Account statement.
Neither Platform nor Synapse will charge you any fees for participating in the FDIC Multi-Bank Program. However, you may be responsible for paying fees to Platform as provided in your agreement with Platform. You should refer to your agreement with Platform to understand how fees are charged.
If your Account is closed for any reason, your access to the Multi-Bank Program through Platform will be terminated. Synapse and each Program Bank reserves the right to terminate your access to the FDIC Multi-Bank Program at any time in its sole discretion. If your access to the FDIC Multi-Bank Program is terminated for any reason, any funds at a Program Bank or Excess Bank shall be returned to the primary account held at Evolve Bank and Trust.
Synapse or Cadre Cash LLC may make changes to this Disclosure at any time and from time to time. You agree to any such changes by continued participation in the FDIC Multi-Bank Program. If you do not accept changes to this Disclosure, you must opt out of Multi-Bank Program.
All questions regarding EFT transactions or your Cash Account can be directed to firstname.lastname@example.org. Cadre Cash LLC can be your point of contact to resolve issues and errors relating to transactions and your account balance. To report complaints regarding Bank or with the services provided by Synapse, you can email email@example.com.
The following disclosures are made in accordance with the federal law regarding electronic payments, deposits, transfers of funds and other electronic transfers to and from your account(s). There may be limitations on account activity that restrict your ability to make electronic fund transfers. Any such limits are disclosed in the appropriate agreements governing your account.
”Electronic Fund Transfer” means any transfer of funds, other than a transaction originated by check, draft or similar paper instrument, that is initiated through an electronic device or computer to instruct us to debit or credit an account. Electronic Fund Transfers include such electronic transactions as direct deposits or withdrawals of funds, transfers initiated via telephone, website or mobile application.
You are liable for all Electronic Fund Transfers that you authorize, whether directly or indirectly.
Tell us at once if you believe your account or access information is lost or stolen or has been or may be subject to unauthorized Electronic Fund Transfers. Contact us immediately to keep your possible losses to a minimum. You could lose all the money in your account(s). If you tell us within two (2) business days after learning of the loss or theft of your account access device, or after learning of any other unauthorized transfers from your account involving your account access device, you can lose no more than $50 if Electronic Fund Transfers are made without your permission. For these transactions, if you DO NOT tell us within two (2) business days after learning of the loss, theft or unauthorized use, and we can establish that we could have prevented the unauthorized transfer(s) if you had told us in time, you could lose as much as $500. Also, if your periodic account statement shows unauthorized transfers and you DO NOT tell us within sixty (60) days after the statement was delivered to you, you may not get back any money you lose after the sixty (60) day period if we can prove that we could have prevented the unauthorized transfer(s) if you had told us in time. If an extenuating circumstance (such as extended travel or hospitalization) prevents you from promptly notifying us of a suspected lost or stolen access device or of any other suspected unauthorized transfer(s), the time periods specified in this section may be extended for a reasonable period.
Cadre reserves the right to cancel or suspend transactions due to fraud or compliance related concerns
You may not violate or attempt to violate the security of the Website. Tampering with any portion of the Website, providing untruthful or inaccurate information, misrepresenting your identity, or conducting fraudulent activities on the Website, whether or not through the use of agents, are prohibited and constitute a breach of these Terms and Conditions of Use.
You are prohibited from violating or attempting to violate the security of the Website, including, without limitation, (a) accessing data not intended for you or logging onto a server or an account which you are not authorized to access; (b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users; (c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (d) attempting to interfere with service to any user, host or network, including, without limitation, via means of submitting a virus to the Website, overloading, "flooding," "spamming," "mailbombing" or "crashing;" (e) sending unsolicited email, including promotions and/or advertising of products or services; (f) forging any TCP/IP packet header or any part of the header information in any email or posting; (g) using or attempting to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search the Website other than the search engine and search agents available on the Website and other than generally available third party web browsers; (h) reverse engineering, decompiling or disassembling the underlying software; (i) removing any notices, warnings, labels, annotations or instructions from any portion of the Website or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or (j) otherwise invading the privacy of, obtaining the identity of, or obtaining any personal information about any user of the Website.
Any violations of system or network security including attempts to intentionally access a computer without authorization or exceed your authorized access level may result in civil and criminal charges, including but not limited to charges under the Computer Fraud and Abuse Act (18 U.S.C. §1030). Cadre may investigate occurrences that might involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. We may, without prior notice or warning of any kind, restrict or terminate the access of any and all users to the Website if we reasonably conclude that such restriction or termination is necessary to prevent, or prevent the further spread, of a virus, security breach or system malfunction.
When accessing the Website, users should be aware that the internet is generally not regarded as a secure environment, and that data sent via the internet can be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Data sent via the internet may be transmitted across international borders even though both sender and receiver are located in the same country. Cadre does not accept any responsibility or liability for the security of data while in transit via the internet.
The Website may contain certain links. Activating links on the Website may cause individual users to leave the Website. Such links are provided solely for individual users’ convenience and information. Cadre has not reviewed any of the websites linked with or connected to the Website and using links on or to the Website is at each individual user’s own risk.
You may download or copy Content only to the extent such download is expressly permitted in writing on the Website. No right, title or interest in any downloaded materials or software is transferred to you as a result of any such downloading or copying. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Content, the Website or any related software.
“Cadre” is the trade name for Cadre. We have trademarks in “Cadre”, terms that include the phrase ‘Cadre’, and certain other terms. Nothing on the Website shall be interpreted as granting any license or right to use any image, trademark, trade dress, logo or service mark on the Website. Anything transmitted to the Website by you becomes Cadre’s property and may be used by us for any lawful purpose. Cadre reserves all rights with respect to copyright and trademark ownership of all material on the Website, and will enforce such rights to the full extent of the law.
Unless otherwise noted, all Contents are copyrights, trademarks, trade dress and/or other intellectual property owned, controlled or licensed by Cadre or by third parties who have licensed their materials to Cadre and are protected by U.S. and international copyright laws. The compilation of all Contents on the Website is the exclusive property of Cadre and is also protected by U.S. and international copyright laws.
The Website, including all Information, is owned by or licensed to Cadre and is subject to and protected by various intellectual property rights, including but not limited to copyright, trade secrets, trademarks, service marks, brand names and other proprietary rights whether under contract, statute or any similar provisions (“IP Rights”). All IP Rights are and shall remain the exclusive property of Cadre, its respective third party licensors or third parties to whom it is attributed and in using the Website individual users shall not obtain any rights, title or other interest in or to any information on the Website or related IP Rights. Subject to the above, individual users are entitled to view the Information on the Website and to copy and print such information for personal use. Individual users are not permitted to sell or distribute or otherwise deal with the Information on the Website or any deviations of such information without the prior written consent of Cadre.
The Information has been prepared solely for purposes of information. The Information is in summary form for convenience of presentation and under no circumstances should the Information be used or considered as an offer to sell or the invitation or solicitation of an offer to buy any product or service offered by Cadre. No such offer or invitation or solicitation will be made prior to the delivery of definitive documentation relating to the specific securities being offered. Before making an investment decision with respect to any investment, potential investors are advised to carefully read the related final documentation and offering memorandum documents (the “Documents”). Further, Cadre does not give or offer any business advice, investment advice, tax or legal advice to anyone using this Website, accordingly, potential investors are advised to consult with their tax, legal and financial advisors with respect to any investment.
Nothing herein shall be relied upon as a promise or representation as to past or future performance. The Website may contain forward-looking statements. In some cases, you can identify forward-looking statements by terminology such as “may,” “will,” “should,” “expects,” “plans,” “anticipates,” “believes,” “targeted,” “projected,” “underwritten,” “estimates,” “predicts,” “potential,” or “continue” or the negative of these terms or other comparable terminology. These forward-looking statements include, but are not limited to, statements concerning the company, property, risk factors, plans and projections. Forward-looking statements are subject to various risks and uncertainties. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Cadre undertakes no obligation to update or review any forward-looking statement, whether as a result of new information, future developments or otherwise. None of Cadre, the issuer nor any other person or entity assumes responsibility for the accuracy and completeness of forward-looking statements. Investors should conduct their own due diligence and not rely on the financial assumptions or estimates that are displayed on the Website. Investments displayed on the Website are not bank deposits, are not insured by the FDIC or by any other Federal government agency, are not guaranteed by Cadre, and may lose value. Investment opportunities posted on this website are “private placements” of securities that are not publicly traded, are subject to holding period requirements, and are intended for investors who do not need a liquid investment.
BY USING THE WEBSITE, YOU EXPRESSLY AGREE THAT SUCH USE IS AT YOUR SOLE RISK. THE WEBSITE AND RELATED SERVICES ARE PROVIDED ON AN "AS IS", "AS AVAILABLE" AND “WITH ALL FAULTS” BASIS. NEITHER CADRE NOR ANY OF ITS RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, THIRD-PARTY CONTENT PROVIDERS, DESIGNERS, CONTRACTORS, DISTRIBUTORS, MERCHANTS, SPONSORS, LICENSORS OR THE LIKE (COLLECTIVELY, "ASSOCIATES") WARRANT THAT USE OF THE WEBSITE OR RELATED SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. NEITHER CADRE NOR ITS ASSOCIATES WARRANT THE ACCURACY, INTEGRITY, COMPLETENESS, AVAILABILITY OR TIMELINESS OF THE CONTENT PROVIDED IN THE WEBSITE OR THE MATERIALS OR SERVICES OFFERED IN THE WEBSITE NOW OR IN THE FUTURE. CADRE AND ITS ASSOCIATES SPECIFICALLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF THE WEBSITE, INFORMATION ON THE WEBSITE OR THE RESULTS OBTAINED FROM USE OF THE WEBSITE OR RELATED SERVICES. CADRE AND ITS ASSOCIATES ACCEPTS NO RESPONSIBILITY FOR UPDATING ANY PARTY OF THE WEBSITE OR THE CONTENT THEREIN.
UNDER NO CIRCUMSTANCES WILL CADRE OR ITS ASSOCIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR OTHER INDIRECT DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, TRADING LOSSES, UNAUTHORIZED ACCESS, SYSTEMS FAILURE, COMMUNICATIONS LINE FAILURE, INTERNET FAILURE OR DAMAGES THAT RESULT FROM USE OR LOSS OF USE OF THE WEBSITE, CONTENT, INCONVENIENCE OR DELAY. THIS IS TRUE EVEN IF CADRE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.
Any Content downloaded or otherwise obtained through the Website is done at your own discretion and risk and you are solely responsible for any damage to your computer or other electronic system or loss of data that results from the download of any such Content. The foregoing limitation of liability will apply in any action, whether in contract, tort or any other claim, even if an authorized representative of Cadre has been advised of or should have knowledge of the possibility of such damages.
The information and opinions are subject to change without notice and does not purport to be complete.
References on this Website to any names, marks, products or services of third parties, or hypertext links to third party websites or information or Content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply our endorsement, sponsorship or recommendation of the third party, its information, materials or services. We are not responsible for the practices or policies of such third parties, nor the Content of any third party sites, and do not make any representations regarding third party materials or services, or the Content or accuracy of any material on such third party sites. If you decide to link to any such third party sites, you do so entirely at your own risk.
An unfortunate consequence of our reputation is the misuse of our name, brands and reputation by imposters and frauds publishing fake web sites and engaging in "phishing" scams seeking personal or confidential information.
When communicating with Cadre through digital media, please:
If you have any questions about the above, please contact Cadre at firstname.lastname@example.org.
Nothing contained in these Terms and Conditions of Use is intended to modify or amend any other written agreement you may have with Cadre (including without limitation any customer agreement, participation agreement, operating agreement, investment agreement or account agreement) (“Other Agreements”) if any, that may currently be in effect. In the event of any inconsistency between these Terms and Conditions of Use and any Other Agreements, the Other Agreements will govern. Some pages within the Website contain supplemental terms and conditions and additional disclosure and disclaimers, which are in addition to these Terms and Conditions of Use. In the event of a conflict, the supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.
Headings used in these Terms and Conditions of Use are for reference purposes only and in no way define or limit the scope of the section. These Terms and Conditions of Use are governed by the laws of New York. Subject to the next section of the Terms and Conditions regarding arbitration, any claim related to any dispute arising as a result of the Website or under these Terms and Conditions of Use will be made before a court of competent jurisdiction located in New York. If any provision of these Terms and Conditions of Use is held to be unenforceable, such provision will be reformed only to the extent necessary to make it enforceable. The failure of Cadre to act with respect to a breach of these Terms and Conditions of Use by you or others does not constitute a waiver and will not limit Cadre’s rights with respect to such breach or any subsequent breaches.
By using the Website, you agree that Cadre, at its sole discretion, may require you to submit any disputes arising from the use of the Website, related services or these Terms and Conditions of Use concerning or, including disputes arising from or concerning their interpretation, violation, nullity, invalidity, non-performance or termination, as well as disputes about filling gaps in this contract or its adaptation to newly arisen circumstances, to final and binding arbitration under the International Rules of Arbitration of the American Arbitration Association, by one or more arbitrators appointed in accordance with the said rules. Not with standing these rules, however, such proceeding shall be governed by the laws of the state as set forth in the previous section.
Cadre has developed a Business Continuity Plan that describes how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us: If after a significant business disruption you cannot contact us as you usually do at 646-661-7677, you should call our alternative number 646-650-5732, email us at email@example.com or go to our website at cadre.com.
Our Business Continuity Plan: We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting our books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our objective is to restore operations and be able to complete any ongoing transactions within 1 business day. Your orders could be delayed during this period.
Our Business Continuity Plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Varying Disruptions: Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within two business days. In either situation, we plan to continue in business and notify you through our website cadre.com or via email at firstname.lastname@example.org, or our customer emergency number, 646-661-7677 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information: If you have questions about our business continuity planning, you can contact us at 646-661-7677 or email@example.com.
Cadre’s Business Continuity Plan is subject to change at any time, in Cadre’s sole discretion.
In the course of serving or otherwise interacting with our current, former and prospective clients and other individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”), Cadre may obtain personal information about such individuals. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use and otherwise process the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the terms “Cadre,” “we,” “us” and “our” refer to Quadro Partners, Inc. and its affiliates. For purposes of this policy, “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information.
Finally, in the provision of financial services to you, and subject to compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., archived email monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
If you deal with Cadre in your individual capacity (e.g., as a private client), as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):
Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: (A) social security number, driver’s license number, state identification card, and passport number; (B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; (C) precise geolocation; and (D) your biometric information for the purpose of uniquely identifying you. This policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” personal information.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we endeavor to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.
Our Website is not intended for children and we do not knowingly collect personal information relating to children (including any minors under the age of 16).
We may use your personal information to:
If your relationship with Cadre ends, Cadre will continue to treat your personal information, to the extent we retain it, as described in this policy.
You may opt out of receiving promotional communications at any time by following the “unsubscribe” instructions found within Cadre email updates or changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.
We may process some of your personal information, including “sensitive” personal information, for purposes of automated decision-making and profiling. For example, in connection with our entering into, or the performance of, our contracts with you, we may collect your investor preferences and use that information to profile you for specific assets based on your investment objectives, time horizon, risk tolerance, etc.
We do not use or otherwise process your “sensitive” personal information other than as described herein.
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Cadre may be given, or given access to, your personal information. For example, one Cadre entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Cadre is provided below, under the section entitled “Information Security: How We Protect Your Privacy.”
Cadre does not disclose your personal information to third parties, except as described in this policy. We may disclose your personal information as follows:
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
You should know that Cadre does not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising.
We will keep your personal information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy, information about which you can request by contacting us. When determining the relevant retention periods, we take into account a variety of factors, including, but not limited to, the following:
Cadre is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Cadre employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to appropriate standards of privacy. We also maintain physical, electronic and procedural safeguards designed to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our service providers’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies and cookie policies on those linked websites. We are not responsible for any linked websites.
The following additional information will be of interest to you as a visitor to this Website:
The recipients of your personal information pursuant to this policy may be located in the United States or elsewhere, and certain of such recipients’ respective countries may have different data privacy laws and protections than your home country. We may transfer your personal information outside of your home country, including to our affiliates in other countries, for the purposes set out in this policy. Any transfer of your personal information to recipients in a third country will be made subject to appropriate safeguards or applicable derogations provided for under applicable law. Further information on such safeguards or derogations can be obtained by contacting us using the contact information below.
What Rights Do I Have?
Under the EU’s General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), individuals located in the European Economic Area (“EEA”) or the UK, as applicable, have certain additional rights with respect to their personal data. For purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable. For the purposes of applicable data privacy legislation, Cadre is a “controller” of such individuals’ personal data.
Under certain conditions, you may have the right to:
Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, Cadre may process and retain personal data pursuant to a legal obligation or another legitimate interest under the GDPR or UK GDPR, to protect your vital interests, the interests of Cadre, or those of another person, or where necessary for the performance of a contract with you for provision of our services. If we have obtained your consent, then you may withdraw it any time by contacting us.
These rights are not absolute and each is subject to certain exceptions or qualifications.
How May I Exercise My Individual Rights?
Residents of the EEA or UK may contact our Data Protection Officer with questions or requests regarding their personal data using the contact information below. Please note that Cadre may request additional information from you to verify your identity before we disclose any personal or account information.
Who Can I Contact at Cadre Regarding Data Protection Issues?
Cadre has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him/her by emailing firstname.lastname@example.org and addressing your questions or concerns to the Data Protection Officer. If you are not satisfied with any response that we have provided, or if you otherwise wish to raise a concern or issue about our data processing practices, you may contact your local data protection authority. For example, in the UK you should contact the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
What Rights Do I Have?
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), residents of the state of California have certain rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given to such term under the CCPA. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.
Under the CCPA you may have the right to:
We will not discriminate against any California resident who exercises the rights set forth in this section.
These rights are not absolute and each is subject to certain exceptions or qualifications.
How May I Exercise My Individual Rights?
You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, you may contact us using the contact information below. Please note that Cadre may request additional information from you to verify your identity before we disclose any personal or account information.
For consumers with disabilities who need to access this policy in an alternative format, please contact us using the contact information below.
This policy provides a general statement of the ways in which Cadre processes and protects your personal information. You may, however, in connection with specific products or services offered by Cadre, be provided with privacy policies or statements that supplement this policy. In the event of a conflict between the terms of this policy and such supplemental privacy policies or statements, such supplemental privacy policies or statements will govern in relation to your use of such products or services. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Website. This version of the policy is effective March 1, 2023. If you require further information regarding our privacy policies and practices please contact email@example.com or firstname.lastname@example.org.
Statement on Cookies
Cookies at Cadre and How We Use Them
We may use cookie technology to collect certain aggregate and non-personal information when you visit our Website. “Clickstream” data (e.g., information regarding which of our Website pages you access, the frequency of such access, and your product and service preferences) may be collected by Cadre itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Website or when you view an advertisement we have placed on another Website. Clickstream data and similar information may be shared internally within Cadre and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Website; and as otherwise permitted by applicable law or regulation. If you are a Cadre client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
Cadre.com (the “Website”) is a private, confidential website intended solely for the limited use for which you (and, if applicable, your organization) have been given access. By accessing the Website, the pages contained on it, and the content, information and materials contained or described herein (together the “Information”), you agree that the Website and the Information are of a confidential nature, that you will hold and treat it in the strictest confidence, and that you will not disclose the Information to any other person or entity without the prior written authorization of Cadre, nor will you use the Information in any fashion or manner detrimental to the interest of Cadre (as defined in the Terms and Conditions of Use) or any deal sponsors that have listed investment opportunities on the Website (Cadre and such deal sponsors, each, a “Disclosing Party”). You agree to promptly notify Cadre of any unauthorized use or disclosure of any Information, and you shall be responsible for any breach of your confidentiality obligations as set forth in this User Confidentiality Policy by your employees and agents. Due to the unique nature of the Information, you agree that any breach or threatened breach of this User Confidentiality Policy will cause not only financial harm to the Disclosing Parties, but also irreparable harm for which money damages will not be an adequate remedy. Therefore, any Disclosing Party shall be entitled, in addition to any other legal or equitable remedies, to an injunction or similar equitable relief against any such breach or threatened breach of this User Confidentiality Policy without the necessity of posting any bond.
“Invest in the asset class that has outperformed the S&P 500 over the last 20 years” refers to the cumulative return (with full reinvestment of dividends) of an investment in the FTSE NAREIT US Real Estate Equity REITs index as compared to investment in the S&P 500 (using S&P Total Return data from CBOE) for the period from December 2000 - December 2018. Investments with Cadre are in private real estate interests and are materially different from investment in US equity REITs; real estate return data should not be used to estimate the return of Cadre investments.