Universal Pacific 1031 Exchange Privacy Policy

Last Updated: 3/26/2026

Effective Date: 3/26/2026

Universal Pacific 1031 Exchange (“Universal Pacific,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal information entrusted to us. As a Qualified Intermediary facilitating 1031 tax-deferred exchanges, we understand the sensitive nature of the financial and real estate data we handle.

This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information when you visit https://www.universalpacific1031.com (the “Website”), use our services, or otherwise interact with us. It also explains your rights and choices regarding your personal information.

By accessing or using our Website or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Website or services.

1. Information We Collect

We collect the following categories of information:

1.1 Information You Provide Directly

When you contact us, request a consultation, or engage our services as a Qualified Intermediary, we may collect:

• Identity Information: Full legal name, date of birth, Social Security Number or Tax Identification Number (as required by IRS regulations for 1031 exchange transactions)
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details (for exchange fund wiring), property values, mortgage information, transaction amounts, tax records, and exchange documentation
• Property Information: Addresses, descriptions, and valuations of relinquished and replacement properties
• Professional Information: Your role (e.g., investor, broker, attorney, CPA), company name, and professional license numbers where relevant
• Communications: Records of correspondence, phone calls, and emails between you and our team

1.2 Information Collected Automatically

When you visit our Website, we automatically collect:

• Device and Browser Information: Browser type and version, operating system, device type, and screen resolution
• Usage Data: Pages visited, time spent on pages, click patterns, referring URLs, and exit pages
• Network Information: IP address and approximate geographic location derived from your IP address
• Cookies and Similar Technologies: See Section 7 (Cookies and Tracking Technologies) below for details

1.3 Information from Third Parties

We may receive information about you from:

• Real estate professionals: Brokers, agents, attorneys, and CPAs involved in your exchange transaction
• Title and escrow companies: Settlement officers facilitating property closings
• Financial institutions: Banks and lenders involved in your transaction
• Public records: County recorder offices and other publicly available real estate databases

2. How We Use Your Information

We use the information we collect for the following purposes:

• Facilitating 1031 Exchanges: Preparing Exchange Agreements, coordinating assignments, holding and disbursing exchange funds, and ensuring IRS compliance throughout your transaction
• IRS and Tax Compliance: Filing required tax documents (e.g., IRS Form 1099-S), maintaining transaction records as mandated by federal tax law, and complying with reporting obligations
• Communication: Responding to your inquiries, providing transaction status updates, sending deadline reminders (45-day identification, 180-day exchange period), and delivering important notices about your exchange
• Security and Fraud Prevention: Verifying identities, preventing unauthorized access to exchange funds, detecting fraudulent activity, and maintaining the security of segregated exchange accounts
• Service Improvement: Analyzing Website usage to improve our online experience, evaluating the effectiveness of our content, and enhancing our service offerings
• Legal Compliance: Meeting obligations under federal, state, and local laws, responding to lawful requests from government authorities, and defending legal claims

We do not use your personal information for automated decision-making or profiling.

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your personal information with the following categories of recipients, solely as necessary to facilitate your exchange or comply with legal obligations:

• Settlement and Title Companies: To coordinate the closing of relinquished and replacement properties
• Financial Institutions: To facilitate the wiring of exchange funds to and from segregated exchange accounts
• Legal and Tax Professionals: Your designated attorneys, CPAs, and tax advisors, at your direction
• Real Estate Professionals: Brokers and agents involved in your transaction, as necessary to complete the exchange
• Government Authorities: The IRS and state tax agencies, as required by law (e.g., Form 1099-S reporting)
• Service Providers: Third-party vendors who assist with our Website operations, IT security, data storage, and business administration, subject to confidentiality agreements
• Legal Proceedings: When required by law, subpoena, court order, or to protect our legal rights

We require all third-party recipients to handle your information in accordance with applicable privacy laws and to use it only for the purposes for which it was shared.

4. Sensitive Financial Data Protection

Given the nature of our services, we implement enhanced protections for financial and transaction data:

• Segregated Exchange Accounts: All exchange funds are held in dedicated, segregated bank accounts — never commingled with operating funds or other client funds
• Written Authorization Required: No exchange funds are released without written authorization from the exchanger
• Multi-Layered Access Controls: Access to financial data and exchange accounts is restricted to authorized personnel only, with multi-layered authorization protocols
• Encryption: All sensitive data transmitted to and from our Website is protected using industry-standard TLS/SSL encryption
• Errors & Omissions Insurance: We maintain $2 million in E&O insurance coverage as an additional layer of protection
• Internal Controls: Our exchange processes are reviewed and documented by licensed CPAs to ensure compliance and accuracy

5. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Exchange Transaction Records: We retain records related to your 1031 exchange for a minimum of seven (7) years from the date of the transaction, consistent with IRS recordkeeping requirements and the potential for audit
• Tax Reporting Documents: Retained for a minimum of seven (7) years in accordance with IRS guidelines
• Website Usage Data: Retained for up to twenty-four (24) months
• Marketing Communications: Retained until you opt out, plus a reasonable period to process your request
• Consultation Inquiries: If you request a consultation but do not proceed with an exchange, your contact information is retained for up to twelve (12) months unless you request deletion

After the applicable retention period, your personal information is securely deleted or anonymized.

6. Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, or disclosure. These measures include:

• TLS/SSL encryption for all data in transit
• Encrypted storage for sensitive financial data at rest
• Role-based access controls limiting data access to authorized personnel
• Regular security assessments and vulnerability testing
• Employee training on data protection and privacy compliance
• Secure disposal procedures for physical and electronic records

While we take reasonable measures to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to protecting your data to the highest commercially reasonable standard.

7. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to enhance your browsing experience and analyze Website traffic.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Website to function properly (e.g., session management, security features). These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our Website by collecting anonymous usage data. We use Google Analytics for this purpose.
• Functional Cookies: Remember your preferences and settings to provide a more personalized experience.

7.2 Third-Party Analytics

We use Google Analytics to collect aggregated, anonymous data about Website usage. Google Analytics uses cookies to track interactions. You can learn more about how Google uses your data at https://policies.google.com/privacy and opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on at https://tools.google.com/dlpage/gaoptout.

7.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. However, blocking certain cookies may affect the functionality of our Website. For more information on managing cookies, visit https://www.allaboutcookies.org.

8. Your Privacy Rights

8.1 Rights for All Users

Regardless of where you reside, you may:

• Request access to the personal information we hold about you
• Request correction of inaccurate personal information
• Opt out of marketing communications at any time
• Request deletion of your personal information, subject to legal retention requirements

8.2 California Residents — Your Rights Under the CCPA/CPRA

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with the following rights:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which that information was collected, the business purpose for collecting the information, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request that we delete your personal information, subject to certain legal exceptions (such as IRS recordkeeping requirements).
• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sale or Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.
• Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information (such as Social Security Numbers or financial account details), we use it only as necessary to facilitate your 1031 exchange and comply with tax law — not for profiling or advertising. You have the right to limit the use and disclosure of your sensitive personal information to what is necessary to perform our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

Categories of Personal Information Collected (per CCPA):

How to Exercise Your California Rights:

Submit a verifiable consumer request by contacting us using the methods listed in Section 12 below. We will verify your identity before processing your request. You may also designate an authorized agent to submit requests on your behalf, provided the agent has your signed written authorization.

We will respond to verifiable requests within 45 calendar days of receipt. If we require additional time (up to an additional 45 days), we will notify you in writing.

8.3 Residents of Other States with Privacy Laws

If you reside in Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have similar rights under your state’s privacy law, including the right to access, correct, delete, and opt out of certain data processing. To exercise these rights, please contact us using the information in Section 12.

9. Do Not Sell or Share My Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

If you wish to confirm this or exercise any related opt-out right, please contact us using the information in Section 12 below.

10. Children’s Privacy

Our Website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take prompt steps to delete that information. If you believe a child has provided us with personal information, please contact us immediately using the information in Section 12.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will update the “Last Updated” date at the top of this page and, where appropriate, provide notice on our Website. We encourage you to review this Privacy Policy periodically.

12. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have a concern about how we handle your personal information, please contact us:

Universal Pacific 1031 Exchange 1180 S. Beverly Drive, Suite 500 Los Angeles, CA 90035

Phone: (424) 469-8111

Email: [email protected]

Privacy Rights Requests: To submit a formal request to access, delete, or correct your personal information, please email [email protected] with the subject line “Privacy Rights Request” and include your full name and sufficient information for us to verify your identity and locate your records.

We aim to respond to all privacy inquiries within 10 business days and to complete verifiable consumer requests within the timeframes required by applicable law.

13. Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify affected individuals and relevant authorities in accordance with applicable federal and state breach notification laws. Notification will include a description of the incident, the types of information involved, steps we are taking in response, and recommendations for how you can protect yourself.

Universal Pacific 1031 Exchange is headquartered in Los Angeles, California. This Privacy Policy is governed by the laws of the State of California and the United States of America.