Privacy Policy

We collect Personal Information (defined below) about REIT clients such as you, from the following sources:

• Information we receive from you on applications, subscription agreements or other forms;
• Information about your transactions with us or others;
• Information we receive from third parties such as broker/dealers, transfer agents, financial advisors and custodians.

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual and includes nonpublic information about you that we obtain in connection with providing a financial product or service to you (“nonpublic personal information”). Personal Information we collect includes:

• Name
• Postal address
• Telephone number
• Email address
• Social Security number, tax identification number, passport number, or any similar number or other government-issued ID
• Date of birth
• Online account information, such as username and password
• Employment information, such as employer, dates of employment, title and role
• Financial and investment information, including information and choices concerning your current investments, account balances, transactional history, assets, income, beneficiary information, personal bank account information, tax­ related information, and your broker/dealer, financial advisor and custodian
• Information to request a repurchase under exigent circumstances, such as physical or mental condition, impairment or illness; death certificate; government documentation of disability; physician certification; spouse name, employment information and income; dependents’ names and ages; and expenses.

In connection with providing our services to you, we disclose your Personal Information to our affiliates, our third-party service providers who provide services on our behalf, and as otherwise described in this Privacy Policy.

We use the information we collect about you and your account to help us better serve your investment needs, to respond to your inquiries, fulfill your requests, personalize your experience on our website, suggest services or educational materials that may be of interest to you, and for our internal business purposes (e.g., data analysis, audits, fraud monitoring and prevention, developing new products)

Depending upon the services you engage us for and as part of our internal business activities, we may disclose your nonpublic personal information to nonaffiliated third parties (such as financial service providers) to process transactions on our behalf, maintain accounts, provide requested products and services, respond to court orders and legal investigations and report information to credit bureaus.

We will also use and disclose your Personal Information as we believe to be necessary or appropriate (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (bl to enforce our terms and conditions; (c) to protect our rights, privacy, safety or property, and/or that of you, or others; or (d) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

FORMER CUSTOMERS

If you terminate your relationship with us, this Privacy Policy (as it may be modified in the future) will continue to apply to your nonpublic personal information after that time, and we will retain nonpublic personal information in accordance with federal law and our records retention policies.

CONFIDENTIALITY AND SECURITY

We maintain physical, electronic and procedural safeguards designed to protect Personal Information within our organization. We also endeavor to restrict access to your personal and financial data to authorized associates who have a need for these records for their job function. Please do not send any personal, financial, or other sensitive information to us in non-secure e-mails.

We reserve the right to make changes to this Privacy Policy from time-to-time and in our sole discretion. The “Last Updated” line at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Website. You are responsible for regularly checking this Website and becoming aware of any updates.

SOCIAL SECURITY NUMBERS

We may request that you provide us with your Social Security number in order to provide you with our services and facilitate any of your requests with respect to our investment programs and products We only use and disclose such information to facilitate your requests, prevent fraud or other harm, and to comply with legal, audit, insurance and other similar requirements, and otherwise in accordance with applicable law. We take the confidentiality of this information very seriously (see also Confidentiality and Security above) and have policies in place to limit access to such information on a need-to know basis. We also have policies, processes and agreements in place to require that our employees and service providers treat such information accordingly.

CHILDREN’S ONLINE PRIVACY

We do not knowingly request or solicit any Personal Information from anyone under the age of 13 on or through the Website. If you are a minor child, please do not provide us with any personal information. If you are the parent or legal guardian of a child that you believe has provided us with such Personal Information online, please contact us immediately to have such information deleted from our system.

DO NOT TRACK

At this time, our Website does not honor Do Not Track signals from internet web browsers because there are not universal standards for doing so.

CONTACTING US

If you have any questions about this Privacy Policy, please contact Kris Ellwanger at privacy@silarealtytrust.com or 813.287.0101.

Last Updated: 11/17/20