Last Updated: February 4, 2025

1. Introduction

Akshar REI, Inc. (“Akshar REI”) acts as a fundraising entity for Lotus Hotel, Inc. (“Lotus Hotel”), which is registered under SEC Rule 506(b) for private placement offerings. This statement explains how we collect, use, and protect investor information.

2. Information We Collect

  • Verify investor accreditation or qualifications
  • Process investment transactions
  • Maintain investor records
  • Meet compliance requirements
  • Facilitate investor communications

3. Data Storage & Security

We store all investor information securely through a CRM system with:

  • Google Cloud Platform storage
  • End-to-end encryption
  • Multi-factor authentication
  • Regular security updates and monitoring
  • Automated backups

4. Access & Control

  • Access limited to authorized Akshar REI and Lotus Hotel personnel
  • No third-party providers without consent
  • All access logged and monitored
  • Regular access reviews

5. Investor Rights

You may:

  • Request access to your personal information
  • Correct inaccurate data
  • Receive copies of investment documentation
  • Request details on data usage
  • Opt out of non-essential communications
  • Review your investment status

6. Data Retention

  • Investment documents: 5 years post-investment
  • Accreditation verification: 5 years from last investment
  • Communications: 5 years
  • Tax documents: 7 years
  • Transaction records: minimum 5 years

7. Breach Notification

If a data breach occurs:

  • Investors will be notified within 72 hours
  • Notification will include details of the breach, affected data, and recommended actions
  • Regulatory authorities will be notified as required

8. Permitted Disclosures

Information may be disclosed only:

  • As required by law or regulators
  • To process transactions
  • With explicit investor consent
  • Within Akshar REI and Lotus Hotel when necessary

9. Investor Categories

This statement applies to:

  • Accredited investors
  • Up to 35 sophisticated non-accredited investors
  • Prospective investors during qualification

10. Compliance

We comply with:

  • SEC Rule 506(b)
  • Federal and state privacy laws
  • Anti-money laundering regulations
  • Investment Company Act requirements

11. Modifications

  • Notice will be provided for material changes
  • Updates distributed electronically
  • Consent may be required for significant changes

12. Contact Information

  • Privacy inquiries: [AksharREI.com Privacy Officer]
  • Investment matters: Lotus Hotel Investor Relations via [AksharREI.com] or [Lotushotelinc.com]

13. Acknowledgment

By accepting this statement, investors agree to:

  • The collection and use of information as described
  • Security measures in place
  • Their rights regarding confidentiality
  • The relationship between Akshar REI and Lotus Hotel