1Who We Are
SOA Income Fund is a private real estate income fund sponsored by Storage of America. The fund is offered only to verified accredited investors under Rule 506(c) of Regulation D of the Securities Act of 1933. This Privacy Policy applies to information collected by SOA Income Fund through the Site, our investor-onboarding process, and our related marketing activities. Storage of America (the sponsor and operating company) maintains its own separate privacy policy at storageofamerica.com/privacy-policy/, which governs its self-storage business.
2Information We Collect
2.1 Information You Provide Directly
We collect information you voluntarily submit, including when you:
- Complete the investor-interest form on the Site
- Request a copy of the Private Placement Memorandum (PPM), subscription documents, or other offering materials
- Schedule or participate in a call, meeting, or video conference with our team
- Submit accredited-investor verification materials
- Fund an investment through a wire, ACH, check, or self-directed IRA (SDIRA) custodian
- Correspond with us by email, phone, text message, or postal mail
- Sign up for updates, newsletters, or investor communications
The information we collect in these contexts may include:
- Contact information: name, email address, phone number, mailing address
- Investor profile information: investment experience, investment amount, funding source (personal, entity, SDIRA), preferred contact method
- Accreditation verification information: income, net worth, professional licenses, or third-party verification letters from a CPA, attorney, registered investment adviser, or broker-dealer, as permitted under SEC Rule 506(c)
- Financial and account information: bank account or wire instructions, custodian account numbers (for SDIRA investments), tax identification number (SSN or EIN) required for IRS Form 1099 tax reporting and IRS Form W-9
- Entity information: entity name, jurisdiction, formation documents, and information about beneficial owners for entity investors
- Communications: the content of emails, messages, call notes, and any documents you send us
2.2 Information Collected Automatically
When you visit the Site, we and our third-party service providers automatically collect certain information through cookies, pixels, tags, and similar technologies, including:
- IP address and approximate geographic location
- Browser type, device type, operating system, and screen size
- Pages viewed, links clicked, scroll depth, and time spent on the Site
- Referring URL and search terms used to find the Site
- Session recordings and click/heatmap data (via Microsoft Clarity)
- Ad-attribution identifiers (via Google Ads, Meta Pixel, and Google Analytics 4)
2.3 Information From Third Parties
We may receive information about you from:
- SDIRA custodians (such as Preferred Trust Company) when you use a self-directed IRA to invest
- Accreditation-verification services that confirm your accredited-investor status on our behalf
- Referral sources, including existing investors, financial advisers, and business partners who introduce you to the fund
- Public and commercial databases used for identity verification, anti-money-laundering (AML) checks, and background diligence
- Ad and analytics platforms (Google, Meta) that provide aggregated campaign and audience data
3How We Use Your Information
We use the information we collect to:
- Respond to your inquiries and provide requested offering materials
- Verify your accredited-investor status as required by SEC Rule 506(c)
- Process, administer, and service your investment in the fund
- Distribute monthly income payments, capital returns, and issue annual IRS Form 1099 tax reporting
- Communicate with you about your investment, fund performance, capital calls, and reporting
- Comply with legal, tax, regulatory, AML/KYC, and audit obligations
- Measure and improve our marketing campaigns, ad performance, and Site experience
- Retarget prospective investors and build lookalike audiences on advertising platforms, in compliance with Rule 506(c) general-solicitation rules
- Detect, prevent, and respond to fraud, security incidents, and unauthorized activity
- Enforce our terms and protect the rights, property, or safety of SOA Income Fund, our investors, and others
We do not sell your personal information.
4Cookies and Tracking Technologies
The Site uses cookies and similar technologies from the following providers:
- Google Analytics 4 (property G-SET96GJDS8) — traffic analytics and conversion measurement
- Google Ads (AW-18242053802) — ad attribution and conversion tracking
- Meta Pixel (1375475717823493) — Meta ad attribution, retargeting, and lookalike audiences
- Microsoft Clarity — session recordings, heatmaps, and behavioral analytics
- HubSpot — form submission, lead tracking, and CRM cookies for our embedded investor-interest form
You can control cookies through your browser settings, and you can opt out of specific advertising technologies here:
- Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout/
- Google Ads personalization: https://adssettings.google.com
- Meta ad preferences: https://www.facebook.com/adpreferences/
- Network Advertising Initiative: http://www.networkadvertising.org/choices/
- Digital Advertising Alliance: https://optout.aboutads.info/
Disabling cookies may affect the functionality of the Site, including the ability to submit our investor-interest form.
6Legal Basis and Compliance Notes
6.1 SEC Rule 506(c) — Accredited-Investor Verification
Because SOA Income Fund is offered under Rule 506(c), we are legally required to take reasonable steps to verify that every investor is an accredited investor. This may involve reviewing sensitive financial documents (tax returns, brokerage statements, W-2s) or accepting a written third-party verification letter. We handle this information with a heightened standard of care, retain it only as long as required by SEC recordkeeping rules, and use it solely for verification and compliance purposes.
6.2 AML/KYC and Anti-Fraud
We collect and use certain information (including government-issued identification, tax identification numbers, and source-of-funds information) to comply with anti-money-laundering, know-your-customer, and sanctions-screening obligations that apply to private investment funds.
6.3 Tax Reporting
We are required to collect a completed IRS Form W-9 (or W-8 series for non-U.S. persons) and to issue annual IRS Form 1099 tax reporting to investors. Tax information is shared with the IRS and applicable state tax authorities as required by law.
7Data Retention
We retain personal information for as long as it is needed to fulfill the purposes described in this Privacy Policy, including:
- The full duration of your investment in the fund
- Any post-redemption period required for tax reporting, capital-return processing, and investor communications
- Additional periods required by SEC, IRS, state, or other regulatory recordkeeping rules (which generally require records to be retained for a minimum of six years for private-fund offerings, and longer for tax and AML records)
Requests that would require us to delete information we are legally required to retain (for example, Form 1099 tax records or SEC-required investor-verification files) will be honored only after those retention periods lapse.
When information is no longer required, we securely delete or anonymize it.
8Data Security
We take reasonable and appropriate administrative, technical, and physical steps to protect the information you provide, including SSL/TLS encryption for the Site, access controls on our CRM and document systems, and vendor-security review of third-party service providers. However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you provide information to us at your own risk.
If we become aware of a security incident affecting your personal information, we will notify you as required by applicable law.
9Your Rights and Choices
Depending on where you reside, you may have certain rights regarding your personal information, including:
- Access — request a copy of the personal information we hold about you
- Correction — ask us to correct inaccurate or incomplete information
- Deletion — request deletion, subject to legal, tax, and regulatory retention obligations
- Opt-out of marketing — unsubscribe from marketing emails using the link in each message, or contact us directly
- Opt-out of targeted advertising — use the ad-platform opt-out links in Section 4
- Do Not Sell/Share — we do not sell your personal information; if you are a California resident, you may still submit a request confirming this
To exercise any of these rights, contact us using the details in Section 13. We will respond within the timeframe required by applicable law. We may need to verify your identity before fulfilling certain requests.
10California, Colorado, Virginia, and Other State Residents
If you are a resident of California (CCPA/CPRA), Colorado (CPA), Virginia (VCDPA), Connecticut (CTDPA), Utah (UCPA), or another state with a comprehensive privacy law, you have the specific rights described in Section 9, plus the right to appeal a denial of a rights request. To submit a request or appeal, contact us at the address in Section 13.
We do not use personal information for automated decisions that produce legal or similarly significant effects about you.
11Children's Privacy
The Site and the fund are intended solely for accredited investors, who are adults. We do not knowingly collect personal information from anyone under the age of 18, and the offering is not available to minors.
12Third-Party Sites and Links
The Site may link to third-party websites, including storageofamerica.com, SDIRA custodian sites, and payment or e-signature platforms. This Privacy Policy does not apply to information collected by those third parties. We encourage you to review each site's privacy policy before submitting information.
13Contact Us
If you have questions about this Privacy Policy, want to exercise any privacy right, or want to update your information, contact us at:
SOA Income Fund
Attn: Investor Relations
PO Box 277, McCordsville, IN 46055
Email: CBada@storageofamerica.com
Website: https://soaincome.com
14Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, our services, or applicable law. When we do, we will revise the "Last Updated" date at the top of this page. Material changes will be communicated through the Site or by email to current investors. We encourage you to review this Privacy Policy regularly.
This Privacy Policy is provided for informational purposes and does not constitute legal advice. It should be reviewed by qualified securities and privacy counsel before publication to confirm it aligns with the fund's operating documents, subscription agreement, and applicable federal and state law.