Last Updated: August 16, 2023
THE SITE IS NOT INTENDED FOR CHILDREN AND THE COMPANY DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF THE COMPANY LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO THE COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).
The Company and its affiliated funds and advisers, handles your personal information in accordance with applicable federal law and regulations. We have the responsibility to explain how we collect, share, and protect your information. It is essential for you to carefully read and understand this notice.
The specific types of personal information we collect and share depend on the product or service you have with us. This may include details such as your Social Security number, income, assets, risk tolerance, and transaction history.
Sharing personal information is necessary for companies such as ours to conduct their everyday operations. Below, we outline the reasons for which the Company may share your information and whether you have the option to limit this sharing:
- For our everyday business purposes, such as processing transactions, managing your accounts, or complying with legal requirements.
- We do not share your personal information for marketing purposes or for joint marketing with other financial companies.
- We also do not share your information with non-affiliates to market to you.
Regarding the protection of your personal information, the Company takes security seriously and employs measures to prevent unauthorized access and use. These measures comply with federal laws and include computer safeguards, secure files, and secured buildings.
In terms of collecting your personal information, we gather it during various interactions, such as meetings to discuss our business, completion of a Subscription Agreement, and communication related to your investments.
PERSONAL INFORMATION COLLECTED IN THE PAST 12 MONTHS
We collect, process, and store various types of Personal Information.
Personal Information we collect may include your name, email addresses, postal addresses, postal codes, user Internet Protocol (IP) addresses, social security/insurance number, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name, and password (if you choose to become a registered user of the Site or our products and services), emergency contact information, biometric information or biometric identifiers (if you choose to schedule a self-guided tour and/or use our identity verification services), and other information either desirable or necessary to provide quality services to our residents and visitors. We may also collect information about you such as your use of the Site and communication preferences.
Your Personal Information may be retained for as long as you use the Site or our products and services. Retention periods may be extended if we are required to preserve your personal information because of litigation, investigations, and other similar proceedings, or if a longer retention period is required or permitted by applicable law. We do not and will not sell your Personal Information.
Additional Information about How We Collect and Share Your Personal Information. With respect to each of the categories of data above, we may also collect and share Personal Information with third parties to comply with legal obligations; when we believe in good faith that applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites and mobile apps, or the public. With respect to biometric information or biometric identifiers, we may disclose such data to our technology service providers for the purpose of verifying your identity. We may also share Personal Information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger, or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
PERSONAL INFORMATION WE WILL CONTINUE TO COLLECT
We will continue to collect the same categories of Personal Information listed above, for the same purposes.
This Site uses Lead Attribution or Marketing Attribution to assess the conversions of different channels that generate leads.
You can choose to delete existing cookies, allow or block cookies, and set preferences for certain websites in your browser’s settings. Please note you may not be able to use the full functionality of the Site if you choose to block all cookies.
EMAIL AND TEXT MANAGEMENT. You may receive emails and texts from the Company for a variety of reasons. We respect your desire to manage email and text correspondence. If you have an account with the Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with information relating to important transactional or administrative information.
ACCESSING, REVIEWING, AND CHANGING YOUR CONTACT INFORMATION. As an account holder, you can see, review and change most of the contact information associated with your Account Profile by logging into your account and editing your Account Profile. For assistance, you may contact us using one of the methods listed below. With some exceptions, you have the right to see what Personal Information we hold about you. We can help you identify what records we might have about you. We may need to confirm your identity before providing you with this access, and if we cannot verify your identity with the degree of certainty required, we will not be able to respond to your request. If we cannot give you access, we will tell you within 45 days of receipt of your request and provide you with a reason, as best we can, as to why we cannot give you access.
PERSONAL INFORMATION OF MINORS. Our Sites are not directed to minors under the age of 16 and we do not knowingly collect Personal Information from minors. We may collect the Personal Information of minors, provided by parents or guardians, in connection with the application and rental of a unit, or the provision of property management services. We do not sell the Personal Information of minors.
CALIFORNIA RESIDENTS’ RIGHTS. The California Consumer Privacy Act (CCPA) may apply to California residents whose Personal Information is collected by certain websites. If the CCPA applies to us, California residents may request to know about Personal Information collected about them and request the deletion of that Personal Information. These rights are subject to certain exceptions, including without limitation, for Personal Information subject to the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act. If we are subject to the CCPA, you can learn more about these rights and our processes for consumer requests by contacting us using one of the methods listed below. If you exercise any of the rights afforded to you by the CCPA, we will continue to treat you fairly.
Right to request disclosure of information we have collected about you
If the CCPA applies to us and to your information, you can submit a request to us for the following personal information we have collected:
- The categories of personal information we’ve collected about you.
- The categories of sources from which we collected the personal information.
- The business or commercial purposes for which we collected or sold the personal information.
- The categories of third parties with which we shared the personal information.
- The specific pieces of personal information we collected about you.
- The categories of personal information (if any) that we have sold about you, the categories of third parties to which we sold that information, and the category or categories of personal information sold to each third party.
- The categories of personal information that we disclosed about you for business purposes.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Right to request the deletion of personal information we have collected from you
Upon request, we will delete the personal information we have collected about you that is covered by the CCPA unless a relevant exception to the right to deletion applies.
Do Not Track. “Do Not Track” is a privacy preference that users can set in certain web browsers. We do not respond to browsers or do not track signals.
ACCESSIBILITY. We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us using one of the methods below.