Important Disclosures

1. Privacy Policy

Your Privacy and Trust is Important to Us.
In this privacy policy (“Privacy Policy”), we describe how, LEX Markets Corp. and its affiliates, including LEX Markets LLC (together “LEX,” “we,” “us,” or “our”), collect, use and disclose any personal information you provide to us when using the site, services, and applications offered by LEX (the “Services”) on and through https://www.lex-markets.com (collectively, the “Site”). By accessing the Site or using the Services, you acknowledge and consent to our practices described below. Your access to the Site, use of the Services, this Privacy Policy and all defined terms used herein, are subject to and governed by our Terms of Service (as applicable).We value your trust in us. Please carefully review this Privacy Policy to learn about choices available to you regarding our use of your information.

It’s Your Information.  See How We Collect It.
We collect information that may personally identify you (“Personally Identifiable Information”), such as when you sign up for an account on the Site, complete a property application form or open an investor account, provide payment instructions, fill out bank form information, comment, provide your passport or similar identifying information or documents.Personally Identifiable Information may include, among other things, your email address, name, phone number, birthday, address, investment experience, and your educational or professional history. If you choose to utilize our Site and Services from our Site, we will collect payment information from you, such as financial account information, and we may collect information to verify your income or net-worth. Please note that we do not store your financial information. If you choose to add an investment entity to your account, we will also collect information about the entity. The decision to provide this information is optional; however, if you decide not to register or provide such information, you may not be able to use certain features of the Site or the Services.We may automatically collect information that does not identify an individual user, such as IP (internet protocol) address, ISP (internet service provider), the web browser used to visit the Site, the time the Site is visited, which web pages were visited on the Site, a mobile device-type identifier, and other anonymous Site usage data. We may use third-party analytics services which provide us with a clearer picture of how you use the Site, such as where you click on the Site, non-sensitive text entered into the Site, and mouse movements.We also may use cookies and web beacons. Most web browsers are initially set up to accept cookies, but you can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Site may not work if you delete or disable cookies. If you choose to make an account, we provide private messaging services between registered-users of the Site; while we do not monitor these messages, we will periodically select a few to review for compliance and audit purposes; therefore, you should assume any message you send through the Site may later be accessed by our staff or our regulators for compliance or audit purposes.

Understand How We Share and Use Your Information
We may share information you provide to us amongst our affiliated parties and service providers. If the Services you use are exclusively provided by one of the entities, you have the right to limit the other affiliated entities from contacting you for marketing purposes (“Affiliate Marketing”), please see Your Choice About Your Information below for details.In order to provide efficient, reliable and independent services, we may be required to share such Personally Identifiable Information with third-party service providers. For example, we may share such details with a third-party custodian of securities or entity that verifies your identify, in order to facilitate and enable effective and efficient provision of our Services to you. You are welcome to contact us at legal@lex-markets.com for name and privacy policies of each such third-party service provider.Unless otherwise agreed to in a separate agreement, we provide the Personally Identifiable Information on a confidential basis to non-affiliated companies we engage as vendors or agents (i) to facilitate the Services provided on our site, such as escrow agents, transfer agents, counsels, advisors, accountants, banks and other financial service providers, and (ii) to service our operation, such as maintaining software or servers, designing or implementing marketing initiatives on our behalf, or conducting audit or testing of any aspect of our operation or Services. Information will be shared with such parties only to the extent reasonably necessary for them to perform services for us or on our behalf and pursuant to confidentiality obligations, or in response to information requests, subpoenas, court orders, or legal process, from law enforcement agencies, self-regulatory organizations, state, federal and foreign regulators.We do not sell your personal information to third-parties.  

Your Choices About Your Information
You may decline to submit Personally Identifiable Information through the Services, in which case Republic may not be able to provide certain Services to you. In addition, you may update or correct your account information and email preferences at any time by logging into your account. If you would like us to remove or amend your Personally Identifiable Information from our database, please send a request to legal@lex-markets.com; please note, as many of the Services we provide are regulated, we will not be able to remove Personally Identifiable Information we are required to retain for audit purposes.Note also that this Privacy Policy provides a general statement of the ways in which we protect your personal information. You may, however, in connection with specific products or services offered by us, be provided with privacy policies or statements that supplement this policy.

Your California Privacy Rights
California’s “Shine The Light” law permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personally Identifiable Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please mail your request to us in writing at 25 W 39th Street, 8TH FL. New York, NY 10018.

For European Union Visitors
We currently do not cater our Services to, nor expect to receive any traffic from, visitors residing in the European Union (“EU Visitors”). Accordingly, we do not collect or store personal data belonging to EU Visitors.Due to LEX’s regulated status, we currently only cater our Services to US persons, and therefore do not expect to have any EU Visitors on our Site. However, should an EU Visitor visit our Site, we voluntarily adopt certain provisions from the European Union’s General Data Privacy Regulation 2016/679 (“GDPR”).By accessing this Site, EU Visitors; (i) agree to consent to the Terms of Service; (ii) will be informed of any instance where LEX becomes aware of a data breach, when it is likely to result in a risk for EU Visitors rights and freedoms, notwithstanding that this provision shall in no way affect your inability to find LEX liable for the negligence of its employees, partners, agents, third-party providers; (iii) will be able to request a copy of the personal data we collect, free of charge, in an electronic format that is “portable” (as defined by the GDPR), (iv) may contest the validity of the data LEX holds and ask for it to be amended; (v) will be able to request LEX to remove their data from the Site pursuant to Section 17 of the GDPR, however due to LEX’s regulated status, while we may remove data from publicly searchable parts of the Site (i.e. mark said data as “restricted data”), however, by using the Services, you expressly agree to allow us to maintain all necessary data to meet its regulatory obligations, specifically to the U.S. Securities and Exchange Commission, Financial Industry Regulatory Authority and any other agency authorized by law to monitor and regulate LEX.EU Visitors should be aware that; (i) LEX requires all third-party data processors that it uses to inform them of any instance they become aware of a data breach, when it is likely to result in a risk to your rights and freedoms; (ii) LEX makes appropriate inquiries into the data privacy protections and policies of all third-party providers LEX engages; (iii) LEX will not sell your data for marketing purposes and will not utilize your data for direct marketing; (iv) LEX’s Site is designed for data privacy and security. LEX is always working to improve its data privacy and protection mechanisms, both by monitoring existing policies, procedures and programs, as well as assessing and developing new ones.All such requests can be made in writing to: 25W 39th Street, 8TH FL. New York, NY 10017, USA

We May Change Our Privacy Policy
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you consent to such changes.

How We Secure and Store Your Information
We use commercially reasonable efforts to follow generally accepted standards to protect Personally Identifiable Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as bank account information) on our Site, we encrypt the transmission of that information using secure socket layer technology (SSL). From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is free of risk. Therefore, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We disclaim all responsibility and liability for unauthorized access to our servers and systems.We will retain your information for as long as your account is active or is needed to provide you the Services and may retain your data after you discontinue use of the Services. We will retain and use your information as necessary to comply with our legal obligations, including to meet our regulatory obligations, to resolve disputes, and to enforce our agreements.You may opt out of certain cookies tracking: The Site uses tools to facilitate the collection of information. For example, the Site uses Google Analytics, if you wish to disable Google Analytics from all websites you visit (not limited to this Site), you can follow this link. You can read the other relevant privacy policies here , here , here and here. Please contact us if you wish to opt out of any of the tools we use. Please note, we reserve the right to add more tools or disable tools and will update this Privacy Policy to reflect these changes. Your request to disable or your disabling of tools may limit your ability to access and utilize the Site.This site is protected by reCAPTCHA and the Google Privacy policy and Terms of Service apply.

We Encourage You to Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us at legal@lex-markets.com.

Effective Date
This Privacy Policy was last updated on November 1, 2019.

2. Terms of Use

Welcome to LEX-Markets.com. By using this site, you agree to comply with and be bound by the terms and conditions of use. Please review these terms and conditions carefully. Please feel free to exit this site in the event that you do not agree to these terms and conditions.

Terms of Use Dated January 27, 2020.

1. Agreement.

This Term of Use agreement (Agreement) specifies the terms and conditions for access to and use of www.LEX-Markets.com (Site) and describe the terms and conditions applicable to your access of and use of the Site. This Agreement may be modified at any time by LEXMarkets Corp., effective upon posting of the modified Agreement. We encourage you to view the most recent version of these terms at any time by visiting www.lex-markets.com/terms-of-use. Each use by you shall constitute and be deemed your unconditional acceptance of this Agreement.

2. Privacy.
Your visit to our site is also governed by our Privacy Policy. Please review our Privacy Policy at www.lex-markets.com/privacy-policy.

3. Ownership.
All content included on this site is and shall continue to be the property of LEX Markets Corp. or its content suppliers and is protected under applicable copyright, patent, trademark, and other proprietary rights. Any copying, redistribution, use or publication by you of any such content or any part of the Site is prohibited, except as expressly permitted in this Agreement. Under no circumstances will you acquire any ownership rights or other interest in any content by or through your use of this Site.

4. Intended Audience.
This website is for adults only. This website is not intended for anyone under the age of 18.

5.Trademarks.
“LEX”, “Don’t Buy Brands, Buy Buildings” and similar marks are either trademarks or registered trademarks of LEX Markets Corp. Other product and company names mentioned on this Site may be trademarks of their respective owners.

6. Site Use.
LEX Markets Corp. grants you a limited, revocable, nonexclusive license to use this site solely for your own personal use and not for republication, distribution, assignment, sublicense, sale, preparation of derivative works, or other use. You agree not to copy materials on the site, reverse engineer or break into the site, or use materials, products or services in violation of any law. The use of this Site is at the discretion of LEX Markets Corp. and we may terminate your use of this website at any time for any reason.

7. Compliance with Laws.
You agree to comply with all applicable laws regarding your use of the Site. You further agreed that information provided by you is truthful and accurate to the best of your knowledge. You further agree to all applicable background, investor qualification or other similar due diligence steps that LEX may need to conduct in connection with the services offered on LEX-Markets.com.

8. Indemnification.
You agree to indemnify, defend and hold LEX Markets Corp. and our partners, employees, and affiliates, harmless from any liability, loss, claim and expense, including reasonable attorney's fees, related to your violation of this Agreement or use of theSite.

9. Disclaimer.
THE INFORMATION ON THIS SITE IS PROVIDED ON AN “AS IS,” “AS AVAILABLE” BASIS. YOU AGREE THAT USE OF THIS SITEIS AT YOUR SOLE RISK. LEX MARKETS CORP. DISCLAIMS ALL WARRANTIES OF ANY KIND,INCLUDING BUT NOT LIMITED TO ANY EXPRESS WARRANTIES, STATUTORY WARRANTIES, ANDANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE,AND NON-INFRINGEMENT. TO THE EXTENT YOUR JURISDICTION DOES NOT ALLOW LIMITATIONS ON WARRANTIES, THIS LIMITATION MAY NOT APPLY TO YOU. YOUR SOLE AND EXCLUSIVE REMEDY RELATING TO YOUR USE OF THE SITE SHALL BE TO DISCONTINUE USING THE SITE.

10. Regulatory Disclosure.
(a)  Notwithstanding anything to the contrary in these Terms of Use, in no event shall anything in these Terms of Use be deemed to be a waiver, and we will not assert there has been a waiver, that would not be permissible underSection 14 of the Securities Act of 1933, Section 29(a) of the SecuritiesExchange Act of 1934, or any other applicable provision of federal and state securities laws.

(b) LEX-Markets.com has been designed for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security. Such offers can only be made pursuant to a qualified investor receiving official offering documentation where lawful under applicable law.

(c) The information contained on the LEX-Markets.com web site has been prepared by LEX Markets without reference to any particular user’s investment requirements or financial situation. Potential investors are encouraged to consult with professional tax, legal, and financial advisors before making any investment into a securities offering. An investment in new issues of securities would be speculative and would involve a high degree of risk. Investors must be prepared to bear the economic risk of such an investment for an indefinite period of time and be able to withstand a total loss of their investment. Please consider carefully the investment objectives, risks, transaction costs, and other expenses related to an investment prior to deciding to invest.

(d) YOU MUST CAREFULLY REVIEW THE RELEVANT OFFERING CIRCULAR AND SUBSCRIPTION DOCUMENTATION BEFORE DECIDING TO INVEST. LEX Markets has created this web site solely for the purpose of providing interested parties with an introduction to the business of LEXMarkets in order for the interested party to evaluate whether to proceed with amore in-depth investigation of any offerings obtainable through a registered representative. This site is not, and under no circumstances is it to be construed as, an offer to sell the securities of any company, which may only be made at the time a qualified offeree receives the relevant confidential offering documentation, which contain important information about the investment and the risks of investing in it. Any potential offer would not be valid in a jurisdiction where the offer or sale of the securities is unlawful.

(e) Past performance is no guarantee of future results. An investor can lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Investment decisions should be based on an individual’s own goals, time horizon, and tolerance for risk.

(f) The information contained herein is provided for informational and discussion purposes only and is not, and may not be relied on in any manner as legal, tax, or investment advice, or as an offer to sell or a solicitation of an offer to buy an interest in any security. Such an offer can only be made by providing qualified investors at their request Offering Documentation, which will be furnished to qualified investors for their consideration in connection with any such offering. The information contained herein will be qualified in its entirety by reference to the Offering Documents, other agreements, and documents referred to therein, which contain additional information about the investment objective, terms, risks, and conditions of an investment. Nothing contained herein shall be deemed to be binding against, or to create any obligations or commitment on the part of, any potential investor, the offering sponsors, or their respective affiliates. No person has been authorized to give any information or make any representation or warranty regarding the subject matter hereof, either express or implied, and, if given or made on this website, in other materials, or orally, such information, representation, or warranty cannot and should not be relied upon, nor is any representation or warranty made as to the accuracy, content, suitability, or completeness of the information, analysis, or conclusions, or any information furnished in connection herewith contained on this website.

12. Limitation of Liability.
UNDER NO CIRCUMSTANCES WILL LEX MARKETS BE LIABLE OR RESPONSIBLE FOR ANY DIRECT, INDIRECT, INCIDENTAL,CONSEQUENTIAL (INCLUDING DAMAGES FROM LOSS OF BUSINESS, LOST PROFITS,LITIGATION, OR THE LIKE), SPECIAL, EXEMPLARY, PUNITIVE, OR OTHER DAMAGES, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN ANY WAY RELATING TO THE SITE, YOUR SITE USE, OR THE CONTENT, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. YOUR SOLE REMEDY FOR DISSATISFACTION WITH THE SITE AND/OR CONTENT IS TO CEASE ALL OFYOUR SITE USE.You may have additional rights under certain laws (including consumer laws) which do not allow the exclusion of implied warranties, or the exclusion or limitation of certain damages. If these laws apply to you, the exclusions or limitations in this Agreement that directly conflict with such laws may not apply to you.

13. Use of Information.
LEX Markets reserves the right, and you authorize us, to use and assign all information regarding site uses by you and all information provided by you in any manner consistent with our Privacy Policy.

14. Copyrights and Copyright Agent.
If you believe your work has been copied in a way that constitutes copyright infringement, or your intellectual property rights have otherwise been violated, please provide a notice containing all of the following information to our Copyright Agent: (a) An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other intellectual property interest; (b) A description of the copyrighted work that you claim has been infringed; (c) A description of where the material that you claim is infringing is located on the Site; (d) Your address, telephone number, and e-mail address; (e) A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and (f) A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf. Our Copyright Agent for Notice of claims of copyright infringement on the Site is the Contact Information listed in paragraph 19 below.

15. Applicable Law.
You agree that the laws of the state of New York, without regard to its conflicts of laws provisions will govern these Terms and Condition of Use and any dispute that may arise between you and LEX Markets Corp. or its affiliates.

16. Severability.
If any provision of thisAgreement shall be adjudged by any court of competent jurisdiction to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that this Agreement will otherwise remain in full force and effect.

17. Waiver.
The failure of LEX-Markets Corp. to exercise or enforce any right or provision of this Agreement shall not operate as a waiver of such right or provision. Any waiver of this Agreement by LEX-Markets Corp. must be in writing and signed by an authorized representative of LEX-Markets Corp.

18. Termination.
LEX Markets Corp. may terminate this Agreement at any time, with or without notice, for any reason.

19. Contact Information.
LEX Markets Corp.
25 W. 39th Street, FL. 8
New York, NY 10018
T. (212) 655-9816
E. LEGAL@LEX-MARKETS.COM 

20. Relationship of the Parties.
 
Nothing contained in this Agreement or your use of the Site shall be construed to constitute either party as a partner, joint venturer, employee or agent of the other party, nor shall either party hold itself out as such.  Neither party has any right or authority to incur, assume or create, in writing or otherwise, any warranty, liability or other obligation of any kind, express or implied, in the name of or on behalf of the other party, it being intended by both parties that each shall remain independent contractors responsible for its own actions.

21. Entire Agreement.
These Terms of Use constitutes the entire agreement between you and LEX Markets Corp. and governs the terms and conditions of your use of the Site, and supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and LEX Markets Corp. with respect to this Site.  Notwithstanding the foregoing, you may also be subject to additional terms and conditions, posted policies (including but not limited to the Privacy Policy), guidelines, or rules that may apply when you use the website.  LEX Markets may revise this Terms of Use at any time by updating this Agreement and posting it on the Site.  Accordingly, you should visit the Site and review the Terms of Use periodically to determine if any changes have been made. Your continued use of this website after any changes have been made to the Terms of Use signifies and confirms your acceptance of any such changes or amendments to the Terms of Use.

22. Questions?
To find out more about the services offered by LEX, please visit www.lex-markets.com.

3. Form CRS - Retail Customer Relationship Summary

1. Introduction
LEX Markets LLC (“LEX”) is a broker-dealer registered with the SEC and FINRA, and is a member of the Securities Investor Protection Corporation (SIPC). Additional information about LEX is available at https://brokercheck.finra.org/. This document sets forth certain disclosures and other information about the brokerage services LEX offers its retail customers. 

2. Relationships and Services
What investment services and advice can you provide me?
LEX provides investment services and advise solely with respect to the commercial real estate securities LEX offers as placement agent (the “LEX Securities”). You cannot invest in any securities other than LEX Securities through LEX. 
LEX provides an electronic user interface (the “LEX UI”) for investors to research and choose themselves which LEX Securities they would like to invest in. LEX does not provide any individualized advice or recommendations as to which LEX Securities are best suited for any particular investor, or as to whether LEX Securities are suitable for any particular investor at all. Any investment advice or recommendations contained on the LEX UI are applicable to all investors generally, and include numerous risk factors and disclaimers. 
LEX does not monitor its customers investments and does not accept discretionary authority to act on its customers’ behalf. Each LEX customer must make all investment decisions on his or her own behalf. 
LEX does not require any minimum balance to open an account. LEX Securities are initially priced at $100 per share and an investor is permitted to purchase only one share. 
Additional information about LEX and its services is available at https://www.LEX-Markets.com/.
“Given my financial situation, should I choose a brokerage service? Why or whynot?”
LEX offers only a narrow range of brokerage services and is intended for use only by investors wishing to invest in commercial real estate who are comfortable making their own investment decisions. If you would like to invest in other types of securities or would like individualized assistance in selecting your investments, you should use a different brokerage service.
“How will you choose investments to recommend to me?”
LEX does not choose or recommend any particular investments for any particular customer. All offerings and recommendations made by LEX are directed to all investors generally. 
“What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?”
LEX’s financial professionals are each licensed by FINRA and have successfully completed various qualification examinations to obtain those licenses. Additional information about LEX’s leadership team’s experience is available at https://www.LEX-Markets.com/.

3. Fees, Costs, Conflicts, and Standard of Conduct
“What fees will I pay?”
LEX earns revenue from three sources: (a) placement fees for its work on initial offerings of LEX Securities; (b) annual platform fees charged to issuers to have their shares included on the LEX platform; and (c) access fees charged to brokers who execute secondary trades on LEX’s Alternative Trading System (ATS).
Retail investors do not pay placement fees; those fees are paid by an affiliate of each issuer and are “no load” to the purchasers of LEX Securities. Retail investors pay platform fees indirectly; those fees are paid by each issuer, reducing the quarterly dividends paid to the holders of LEX Securities, which include retail investors. Retail investors may pay access fees for secondary trades on the LEX ATS, depending on whether their broker passes those fees along to their customers. For LEX’s brokerage customers, LEX absorbs the access fees charged by the LEX ATS and does not pass them along to brokerage customers. 
LEX does not charge any trading commissions other than the fees described above. 
You will pay the above fees and costs whether you make or lose money on your investments. The above fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. 
“Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?”
If you give LEX $10,000 to invest, 100% of that amount will be invested in LEX Securities held in your name. If the LEX Security you invest in pays 6% in annual income/dividends, that amount will be net of an additional 1% platform fee that the issuer of that LEX Security pays to LEX (in the absence of the platform fee, the LEX Security would have paid 7% in annual income/dividends). 
“What are your legal obligations to me when providing recommendations? How else does your firm make money and what conflicts of interest do you have?” 
LEX does not provide any individualized recommendations to any investors. LEX is not affiliated with any issuers of LEX Securities. LEX does not buy or sell any LEX Securities for its own account. LEX does not make money from any activities of the issuers or of LEX’s retail customers other than as set forth above. 
“How might your conflicts of interest affect me, and how will you address them?”
LEX has structured its business model to minimize conflicts of interest. LEX makes nearly all of its money from issuers, not from retail investors, and LEX Securities are deliberately structured to minimize costs to investors. 
“How do your financial professionals make money?”
LEX’s financial professionals are paid salaries plus discretionary bonuses. They are not compensated based on transaction volume. 
4. Disciplinary History
“Do you or your financial professionals have legal or disciplinary history?”
No. Current reports of any legal or disciplinary history of LEX’s financial professionals are available at https://brokercheck.finra.org/.
“As a financial professional, do you have any disciplinary history? For what type of conduct?”
No. Current reports of any legal or disciplinary history of LEX’s financial professionals are available at https://brokercheck.finra.org/.

5. Additional Information
Additional information about LEX and the most current version of this Form CRS is available at https://www.LEX-Markets.com/ or by calling 212-655-9816.
“Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?”
LEX customers do not have dedicated representatives. If you have any questions or concerns about the brokerage services offered by LEX, please email support@LEX-Markets.com.