Full Disclosure

 

Date Last Revised:

April 1st, 2020

 

TERMS OF USE:

 

OVERVIEW AND ACCEPTANCE OF TERMS OF USE:

Please read these terms of use (as amended from time to time, “Terms of Use”) carefully before using the website located at www.EquityLockCommercial.com (the “Site”). If you do not agree with these Terms of Use, you are not granted permission to use the Site. Your access and use of the Site is governed by the terms, conditions and disclaimers set forth in these Terms of Use. The Site is owned and operated by PRIVATE PLACEMENT MARKETS, LLC (a Delaware Limited Liability Company). By accessing and/or using the Site, you expressly agree to the terms, conditions and disclaimers set forth in these Terms of Use, Disclaimers and the Privacy Policy. The use of the Site is governed by this Terms of Use. This Terms of Use, in addition to any additional rules, policies and procedures governing use of and/or access to the Site may be modified and/or updated by PRIVATE PLACEMENT MARKETS, LLC at any time and without any notice. By accessing and using the Site, you agree to review the most current version of this document prior to such use, and your continued use of the Site constitutes your acknowledgment and agreement to the most recent Terms of Use, Disclaimers, Privacy Policy and applicable rules, policies and procedures.

INFORMATIONAL AND NO INVESTMENT ADVICE:

PRIVATE PLACEMENT MARKETS, LLC AND ITS AFFILIATES ARE NOT BROKERS, DEALERS, INVESTMENT ADVISERS, REGISTERED EXCHANGE ADVISORS, LEGAL ADVISORS OR TAX ADVISORS. NEITHER PRIVATE PLACEMENT MARKETS, LLC NOR ANY OF ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES OR AGENTS PROVIDES ANY LEGAL, TAX, INVESTMENT OR FINANCIAL ADVICE. PPM (including any of PRIVATE PLACEMENT MARKETS, LLC's affiliates, officers, directors, employees and agents) (i) is not a broker-dealer, is not registered as a broker-dealer under Section 15 of the Securities Exchange Act of 1934 (the “Exchange Act”), does not offer or sell any securities and does not engage in the execution of securities transactions of third parties through the Site or otherwise; (ii) is not a registered securities exchange under the Exchange Act; (iii) is not an investment adviser and is not registered as an investment adviser with the United States Securities and Exchange Commission or any state authority; and (iv) is not a financial or tax advisor and does not offer legal, tax, financial or investment advice to any user of its services. The materials on the Site, including, without limitation, news articles, informational materials, webinars, videos, descriptions and any other information have been prepared for informational purposes only and do not constitute financial, legal, tax or any other advice. None of the information contained in the publicly available portions of the Site constitutes an offer, recommendation or solicitation, to buy or sell any securities or the provision of any investment advice. PRIVATE PLACEMENT MARKETS, LLC does not receive compensation that is contingent on the outcome or completion of any securities transaction.

FORWARD-LOOKING AND CAUTIONARY STATEMENTS:

Except for historical information and discussions, statements set forth throughout the Site may constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995 or other applicable laws. These statements involve a number of risks, uncertainties, and other factors that could cause actual results to differ materially as disclosed on the materials provided on and through the Site.

PROPRIETARY RIGHTS:

All right, title and interest in the Site and any content contained herein is the exclusive property of PRIVATE PLACEMENT MARKETS, LLC or its affiliates, and is protected by United States copyright laws and international treaty provisions. The Site contains the copyrighted material, trademarks and other proprietary information of PRIVATE PLACEMENT MARKETS, LLC. All content, trademarks, services marks, trade names, logos and icons are proprietary to PRIVATE PLACEMENT MARKETS, LLC or its affiliates, licensors or agents (including third party service providers). Other third-party products and brand names may be trademarks or registered trademarks of their respective owners, and may not be affiliated with PRIVATE PLACEMENT MARKETS, LLC. Nothing contained on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on the Site without the express prior written permission of PRIVATE PLACEMENT MARKETS, LLC or such third party that may own the trademarks displayed on the Site. Your use of the trademarks displayed on the Site, or any other content on the Site, except as expressly provided on the Site, is strictly prohibited. Copyright in the pages and in the screens of the Site, and in the information and material therein, is proprietary material owned by, or used with permission by, PRIVATE PLACEMENT MARKETS. LLC unless otherwise indicated. The unauthorized use of any material on the Site may violate numerous statutes, regulations and laws, including, but not limited to, copyright, trademark, trade secret or patent laws. Registered users of the Site may view, download and print information and materials on the Site for personal and internal business use only, provided that all hard copies contain all copyright and other applicable notices. All users may not reproduce, modify, copy, alter in any way, distribute, sell, resell, transmit, transfer, license, assign, create derivative works from or publish any information obtained from the Site. All users will not use the Site at any time for any purpose that is unlawful or prohibited and will comply with any applicable local, state, national or international laws or regulations when using the Site. Pursuant to Section 512(c)(2) of the U.S. Copyright Law, PRIVATE PLACEMENT MARKETS, LLC designates the following agent to receive notifications of claimed infringement: OPERATIONS@EQUITYLOCKCOMMERCIAL.COM.

 

USE OF SITE:

Unauthorized use of the Site, including but not limited to, unauthorized entry into the Site and/or PRIVATE PLACEMENT MARKETS, LLC’s systems, misuse of any information, is strictly prohibited. You may not use the Site in any manner that could damage, disable, overburden, or impair any PRIVATE PLACEMENT MARKETS, LLC site (including the Site) or service or interfere with any other party’s use and enjoyment of any PRIVATE PLACEMENT MARKETS, LLC site or service. You may not attempt to gain unauthorized access to any PRIVATE PLACEMENT MARKETS, LLC site (including the Site) or service, computer systems or networks connected to any PRIVATE PLACEMENT MARKETS, LLC site or service, through hacking, password mining or any other means. We reserve the right to suspend or cancel your access, account and password if such are provided without receiving such notice from you, if we suspect that it is being used in an unauthorized or fraudulent manner. Notwithstanding the above, if you have an account on the Site you are responsible for monitoring your account and should promptly report any unauthorized (e.g., if you believe someone has used your membership information to access the Site without your authorization) or suspicious activity in your account to us immediately at OPERATIONS@EQUITYLOCKCOMMERCIAL.COM. PRIVATE PLACEMENT MARKETS, LLC reserves the right to terminate, at any time, any user’s access to the Site, without giving notice or a reason for such termination to the user. 

DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITY:

ALL INFORMATION CONTAINED ON THE SITE IS PROVIDED TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS, AND PRIVAE PLACEMENT MARKETS, LLC (INCLUDING ANY OF PRIVATE PLACEMENT MARKETS, LLC’s AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) EXPRESSLY DISCLAIMS MAKING ANY EXPRESS OR IMPLIED WARRANTIES WITH RESPECT TO THE FITNESS OF THE INFORMATION CONTAINED HEREIN FOR ANY PARTICULAR USAGE, ITS MERCHANTABILITY OR ITS APPLICATION OR PURPOSE. ADDITIONALLY, PRIVATE PLACEMENT MARKETS, LLC (INCLUDING ANY OF PRIVATE PLACEMENT MARKETS, LLC's AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) MAKES NO REPRESENTATIONS, WARRANTIES OR GUARANTEES, EXPRESS OR IMPLIED, REGARDING THE ACCURACY, RELIABILITY, TIMELINESS OR COMPLETENESS OF THE INFORMATION CONTAINED ON THE SITE, WHETHER OR NOT SUCH INFORMATION IS PROVIDED BY PPM OR A THIRD PARTY, AND EQUITY LOCK RESIDENTIAL (INCLUDING ANY OF PRIVATE PLACEMENT MARKETS, LLC's AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) EXPRESSLY DISCLAIMS ANY WARRANTIES OF NON-INFRINGEMENT. IN NO EVENT WILL PRIVATE PLACEMENT MARKETS, LLC (INCLUDING ANY OF PRIVATE PLACEMENT MARKETS, LLC AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) BE RESPONSIBLE OR LIABLE FOR THE CORRECTNESS OR COMPLETENESS OF ANY MATERIAL OR INFORMATION PROVIDED ON THE SITE OR FOR ANY DAMAGE OR LOST OPPORTUNITIES RESULTING FROM USE OF THIS DATA. YOU ASSUME TOTAL RESPONSIBILITY AND RISK FOR YOUR USE OF THIS SITE.

NEITHER PRIVATE PLACEMENT MARKETS, LLC NOR ANY OF ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES OR AGENTS WILL BE LIABLE TO YOU OR ANY THIRD PARTY, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE) OR OTHERWISE FOR ANY DIRECT OR INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES OR ANY OTHER DAMAGES OF ANY KIND ARISING IN WHOLE OR IN PART FROM YOUR ACCESS TO, OR INABIITY TO ACCESS, OR USE OF, OR INABILITY TO USE, THE SITE, EVEN IF PRIVATE PLACEMENT MARKETS, LLC (INCLUDING ANY OF PRIVATE PLACEMENT MARKETS, LLC's AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THIS LIMITATION OF LIABILITY INCLUDES, WITHOUT LIMITATION, THE TRANSMISSION OF ANY VIRUSES OR OTHER CONTAMINATING OR DESTRUCTIVE PROPERTIES WHICH MAY INFECT YOUR COMPUTER OR OTHER EQUIPMENT, FAILURE OF MECHANICAL OR ELECTRONIC EQUIPMENT OR COMMUNICATION LINES OR OTHER CONNECTIVITY ISSUES, UNAUTHORIZED ACCESS, OR ANY FORCE MAJEURE. PRIVATE PLACEMENT MARKETS, LLC (INCLUDING ANY OF PPM’S AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS) CANNOT AND DOES NOT GUARANTEE CONTINUOUS, UNINTERRUPTED OR SECURE ACCESS TO THE SITE.

USE OF LINKS AND THIRD PARTY WEBSITES:

The Site contains links to third party websites. These links are provided only as a convenience. If you leave the Site via a link contained herein, and view content that is not provided by PRIVATE PLACEMENT MARKETS, LLC, you do so at your own risk. The content to which you link will not have been developed, checked for accuracy or otherwise reviewed by PRIVATE PLACEMENT MARKETS, LLC. PRIVATE PLACEMENT MARKETS, LLC (including any of PRIVATE PLACEMENT MARKETS’s affiliates, officers, directors, employees and agents) does not control these other sites or services and makes no representations or endorsements whatsoever concerning those sites or services. The fact that PRIVATE PLACEMENT MARKETS, LLC has provided a link to a site is not an endorsement, authorization, sponsorship or affiliation with respect to such site, its owners, or its providers. You agree that under no circumstances will you hold PRIVATE PLACEMENT MARKETS, LLC (including any of PRIVATE PLACEMENT MARKETS, LLC’s affiliates, officers, directors, employees and agents) liable for any loss or damage caused by use of or reliance on any content, goods or services available on other sites. Certain portions of the Site contain information provided by third parties, and PRIVATE PLACEMENT MARKETS, LLC (including any of PRIVATE PLACEMENT MARKETS, LLC's affiliates, officers, directors, employees and agents) does not endorse or guarantee any such third party information for any purpose, including but not limited to accuracy, legality, appropriateness, non-infringement or fitness for any particular purpose. You acknowledge and agree that PRIVATE PLACEMENT MARKETS, LLC (including any of PRIVATE PLACEMENT MARKETS, LLC's affiliates, officers, directors, employees and agents) is not responsible for any third party information, products or services or third party websites accessed through the Site and does not make any representations or warranties regarding any such third party content. Any and all postings of information, documents and/or other materials to the Site by third parties are the sole responsibility of the person(s) who originated such information, documents and/or other materials, and PRIVATE PLACEMENT MARKETS, LLC (including any of PRIVATE PLACEMENT MARKETS, LLC’s affiliates, officers, directors, employees and agents) does not control and may not monitor such content. PRIVATE PLACEMENT MARKETS, LLC reserves the right at all times, but is under no obligation, to remove any of such third party information, documents and/or other materials on the Site.

GOVERNING LAW AND ARBITRATION:

This Terms of Use is governed by and construed in accordance with the laws of the state of California, without regard to conflicts of laws provisions. Unless otherwise agreed in writing by you and us, any dispute or claim relating to your relationship with PRIVATE PLACEMENT MARKETS, LLC or its affiliates and/or use of the Site will be submitted to arbitration in Los Angeles County, California in accordance with the rules of the American Arbitration Association as the exclusive remedy for such claim or dispute. Such arbitration must be commenced within one (1) year after the claim or cause of action arises. Sole and exclusive jurisdiction for any action, or proceeding arising out of or related to your relationship with PRIVATE PLACEMENT MARKETS, LLC or its affiliates and/or use of the Site that is not governed by an applicable arbitration clause will be in an appropriate state or federal court located in the County of Los Angeles, State of California and you unconditionally waive your right to a jury trial. If any provision in this Terms of Use is held to be invalid or unenforceable, then the remaining provisions will continue in full force and effect.

 

ADDITIONAL INFORMATION ABOUT EQUITY LOCK COMMERCIAL - VALUE PROTECTION:

PRIVATE PLACEMENT MARKETS, LLC (the "Company", "we", and "us") is not an insurance company and does not issue any contracts or policies of insurance against any losses. EQUITYLOCK COMMERCIAL - VALUE PROTECTION products are contracts to hedge against risks, not investment contracts or contracts of insurance. Although they are designed to mitigate risks associated with declines in certain real estate market sectors, EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts do not eliminate all risks of real estate ownership. At the same time, although they are designed to manage the risks of drops in housing values, they may entitle you to payments even if your home does not decline in value. Because of the way our EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts are structured, you may be entitled to contractually defined payments even if you sell the Subject Property at a profit, just as you may be entitled to no payments even if you sell the Subject Property at a price lower than its original value or if the Subject Property's equity is impaired before or upon resale. Your rights to receive payments under an EQUITYLOCK COMMERCIAL - VALUE PROTECTION contract depends on a geographically-defined index of real estate values, not on changes in the Subject Property's value in particular. EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts have not been reviewed, endorsed or approved by any federal, state or local government regulators, including securities or insurance regulators of the federal government or any state, and PRIVATE PLACEMENT MARKETS, LLC is not a regulated insurance or investment company.

We can offer the risk-reducing benefits of EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts by analyzing extensive data on real estate values, real estate turnover rates, and other demographic and financial data, and making future projections on the basis of that information. The historical data we use and upon which we make projections has been obtained from industry recognized sources as well as proprietary calculations that we regard as generally reliable, but PRIVATE PLACEMENT MARKETS, LLC does not guarantee the accuracy of the underlying data or computations based thereon. Past information related to real estate markets is not a guarantee of future market performance, and PRIVATE PLACEMENT MARKETS, LLC makes no guarantee about the direction of any real estate values, including values in the market where you own the Subject Property. We regard our data collections and analysis as confidential. The Company reserves the right to reject applicants for EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts or to charge different prices for those contracts on the basis of supply and demand forces, our own assessment of risks or other information.

When PRIVATE PLACEMENT MARKETS, LLC sells EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts, it maintains a portion of the purchase price in reserve accounts designed to provide sufficient funds to satisfy the Company’s contractual obligations assuming significant and sustained drops in real estate values in all geographic markets. Although we maintain reserves in investment accounts in order to cover likely obligations under EQUITYLOCK COMMERCIAL - VALUE PROTECTION contracts, those funds are the property of PRIVATE PLACEMENT MARKETS, LLC and you do not retain any legal or beneficial rights in those investments. Once you purchase an EQUITYLOCK COMMERCIAL - VALUE PROTECTION contract, the money you pay for that contract becomes the property of PRIVATE PLACEMENT MARKETS, LLC. We do not guarantee any particular return on our investments and hold and direct those investments strictly for our own purposes (including our own projections of necessary reserves) in a manner designed to cover any payout requests and to cover other Company expenses, and not in the capacity as a money manager or fiduciary for EQUITYLOCK COMMERCIAL - VALUE PROTECTION contract holders. PRIVATE PLACEMENT MARKETS, LLC does not act as a fiduciary for any particular EQUITYLOCK COMMERCIAL - VALUE PROTECTION contract holder, or for contract holders in the aggregate.
 

PRIVATE PLACEMENT MARKETS, LLC may maintain relationships or accounts with real estate brokers, listing agents, escrow agents, and other real estate professionals in your area or elsewhere; with mortgage lenders, banks, money managers, investment professionals or other financial institutions; and with real estate developers or others with interests related to commercial or residential real estate. These relationships are useful in making PRIVATE PLACEMENT MARKETS, LLC products and/or services available to real estate owners like you. The interests of these individuals and institutions may not always align with your own interests, either in relation to your interest in the Subject Property, the real estate values where the Subject Property is located, your EQUITY LOCK COMMERCIAL - VALUE PROTECTION contract, or otherwise.

 

PRIVACY POLICY:

PRIVATE PLACEMENT MARKETS, LLC (“us”, “we”, or “our”), operates the https://www.EquityLockCommercial.com website (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from https://www.EquityLockCommercial.com.

Definitions:

Service

Service is the https://www.EquityLockResidential.com website operated by PRIVATE PLACEMENT MARKETS, LLC.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

 

TYPES OF DATA COLLECTED:

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address;

  • First name and last name;

  • Phone number;

  • Address, State, Province, ZIP/Postal code, City; and

  • Cookies and Usage Data.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

 

You can enable or disable location services when you use our Service at any time by way of your device settings.

 

Tracking Cookies Data

We may use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we  may use are as follows:

  • Session Cookies. We use Session Cookies to operate our Service.

  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies. We use Security Cookies for security purposes.

Use of Data:

We may use the collected data for various purposes, including, without limitation:

  • To provide and maintain our Service;

  • To notify you about changes to our Service;

  • To allow you to participate in interactive features of our Service when you choose to do so;

  • To provide customer support;

  • To gather analysis or valuable information so that we can improve our Service;

  • To monitor the usage of our Service;

  • To detect, prevent and address technical issues; and

  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

 

Legal Basis for Processing Personal Data under the General Data Protection Regulation (“GDPR”)

If you are from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data for the following reasons, among others:

  • We need to perform a contract with you;

  • You have given us permission to do so;

  • The processing is in our legitimate interests and it is not overridden by your rights; and

  • To comply with the law.

Retention of Data

We may retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We may retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We may also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the United States and process it therein. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country, unless there are adequate controls in place including the security of your data and other personal information.

 

Mr. Steve Muehler

Founder & Senior Managing Member

Private Placement Markets, LLC

101 California Street

San Francisco, California 94111

Phone: (877) 259-8066

Email: Steve@PPMSecurities.com

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Important Legal Notice and Disclaimer: EquityLock Commercial is a Registered Tradename of Private Placement Markets, LLC. Private Placement Markets, LLC and its affiliates and subsidiaries (collectively, the “Company”) are not a broker-dealer or an investment adviser. The Company does not provide investment advice or sell securities or execute securities transactions on behalf of third parties. The Company does not advise any user on the merits or advisability of any investment or securities offering, nor does the Company provide any legal, tax, investment, or transactional advisory advice or services. The information provided on the website is not intended to be an offer, solicitation or recommendation by the Company to buy or sell any investment instruments or enter into any other type of transaction, nor shall it be considered investment advice. Your access and/or use of this website constitutes acceptance of the Terms of Use, Disclaimer and Privacy Policy.   real estate

EQUITYLOCK COMMERCIAL

a Division of Private Placement Markets 

Steve Muehler, Founder & Managing Member

101 California Street, San Francisco, California 94111

Phone: (877) 259-8066

Email: Steve@PPMSecurities.com

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