This Privacy and Cookie Policy (this “Policy”) describes the ways in which GFG Real Estate Asset Management, LLC, Inc., a Delaware corporation (“GFG Real Estate Asset Management, LLC”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your access to the website accessed via https://www.gfgam.com (the “Website”) and the information, content and features provided through the Website (the “Services”). Throughout this Policy, “you” refers to the individual or entity that is visiting the Website or otherwise interacting with us. By accessing the Website, you consent to the use of your information as set forth in this Policy. If you are a customer of GFG Real Estate Asset Management, LLC or an end user accessing an investor portal, additional and/or different privacy terms may apply to you, as indicated at the time you set up an account to access the restricted portions of the Website.

GFG Real Estate Asset Management, LLC may provide customers services in the form of cloud products and services where GFG Real Estate Asset Management, LLC provides technology. This Policy does not apply to the extent we are acting as a service provider or data processor, as defined by applicable law. For detailed privacy information related to a GFG Real Estate Asset Management, LLC customer who uses our products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Policy. For more information, please also see Section 6 (Notice to European Residents: General Data Protection Regulation) and Section 7 (Notice to California Residents: California Consumer Privacy Act) below.

1. This Policy.
   
   1. Scope. GFG Real Estate Asset Management, LLC provides you access to the Website and the Services, subject to the Website’s Terms of Use. In the course of providing access to the Website and the Services GFG Real Estate Asset Management, LLC may collect “Personal Information,” which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). GFG Real Estate Asset Management, LLC does not collect your Personal Information except to allow you to access the Website and to provide the Services or as specifically set forth in this Policy.
   2. Changes to this Policy. GFG Real Estate Asset Management, LLC reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material GFG Real Estate Asset Management, LLC may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes. You will be directed to the applicable Policy upon your creation of an account which allows you access to any restricted portion of the Website.
2. Collection of Information.
   
   1. Information that You Provide. GFG Real Estate Asset Management, LLC collects any information that you voluntarily provide, including when you submit information requesting a demonstration, joining the e-mail list, applying for a job or when you use the Services available through the Website. Information that you may provide includes your email address, name, phone number, location, details of your education, online social accounts and professional resume or CV. GFG Real Estate Asset Management, LLC may also collect information that you provide by electronic mail, telephone or other means.
   2. Automatically Collected Information. GFG Real Estate Asset Management, LLC may automatically collect certain technical information from your computer or mobile device when you use the Website, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. This information allows GFG Real Estate Asset Management, LLC to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Website and the Services.
   3. Information about Legal and Other Materials. In addition, GFG Real Estate Asset Management, LLC may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the Website, including the Website’s Terms of Use and this Policy.
   4. Cookies. GFG Real Estate Asset Management, LLC may collect this information using “cookies,” which are small text files that the Website saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the Website. GFG Real Estate Asset Management, LLC may also collect information from the Website and the email list using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help GFG Real Estate Asset Management, LLC compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy.
   5. Cross-Site Tracking. GFG Real Estate Asset Management, LLC does not utilize technical measures in the Website to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise. The Website does utilize third-party application programming interfaces controlled by third parties, such as marketing tracking services, that may attempt to track your activity across other sites that utilize those interfaces.
3. Use and Disclosure of Information. GFG Real Estate Asset Management, LLC may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:
   
   1. Accessing the Website and Providing and Improving the Services. GFG Real Estate Asset Management, LLC uses your Personal Information to provide you with the Services, or products, services or information related to the Website:***- To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
      • To assist you in completing a transaction or order;
      • To prepare and process invoices and payments;
      • To respond to queries or requests and to provide support;
      • To create, manage and audit our customer accounts;
      • To maintain functionality of our Services and products;
      • To provide you information regarding our Services and products;
      • To notify you about changes to our Services and products;
      • To administer any promotion, contest, survey, or competition; and
      • To offer our products and services to you in a personalized way and to customize your experience when using the Website.
      The legal basis for such use is the Website’s Terms of Use and this Policy.***
   2. Analysis. GFG Real Estate Asset Management, LLC uses your Personal Information for improving the quality of the Website and/or the Services and for internal research and development, including by (i) combining or aggregating any of the information collected through the Website or elsewhere for internal research and development, and for generating and analyzing statistics about your use of the Website and user demographics and traffic patterns; and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. The legal basis for such use is the Website’s Terms of Use and this Policy, and GFG Real Estate Asset Management, LLC’s legitimate interest in improving the Website and Services.
   3. Marketing. If you submit your information to GFG Real Estate Asset Management, LLC, GFG Real Estate Asset Management, LLC may provide you with information about the Website, Services or required notices. In addition, GFG Real Estate Asset Management, LLC may use collected information for delivering marketing communications that may be of interest to you. GFG Real Estate Asset Management, LLC does not sell or share your Personal Information with other companies so that they can market to you. You have the right to ask GFG Real Estate Asset Management, LLC not to process your Personal Information for marketing purposes. GFG Real Estate Asset Management, LLC will usually inform you (before collecting your information) if it intends to use your information for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms GFG Real Estate Asset Management, LLC uses to collect your information. You can also exercise the right at any time by contacting GFG Real Estate Asset Management, LLC at info@gfgam.com, or clicking “unsubscribe” at the bottom of the GFG Real Estate Asset Management, LLC marketing communications.
   4. Security. GFG Real Estate Asset Management, LLC may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue GFG Real Estate Asset Management, LLC’s legitimate interests in ensuring the security of the Website and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website; and when GFG Real Estate Asset Management, LLC believes in good faith that disclosure is necessary (A) to protect GFG Real Estate Asset Management, LLC’s rights or other users of the Website, the integrity of the Website, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website.
   5. Service Providers. GFG Real Estate Asset Management, LLC engages third-party service providers (such as hosting providers and analytics and security providers) to assist in operating and marketing the Services. GFG Real Estate Asset Management, LLC’s engagement of third-party service providers is often necessary for GFG Real Estate Asset Management, LLC to provide the Services to you, particularly where such third-party service providers ensure that the Website and Services are operating and secure. In other cases, GFG Real Estate Asset Management, LLC has a legitimate interest in third-party service providers that can help improve the Website and the Service.
   6. Other Disclosure. GFG Real Estate Asset Management, LLC may disclose Personal Information about you to others: (a) if GFG Real Estate Asset Management, LLC has your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the GFG Real Estate Asset Management, LLC terms and conditions or policies; or (d) as necessary to resolve disputes, pursue available legal remedies or defend legal claims. GFG Real Estate Asset Management, LLC may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of GFG Real Estate Asset Management, LLC’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that GFG Real Estate Asset Management, LLC transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.
4. Storage.
   
   1. Jurisdiction. Information collected through the Website will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you consent to such transfer to, storage in and processing within the United States.
   2. Security. GFG Real Estate Asset Management, LLC is committed to protecting your information from unauthorized access, use or disclosure. The Website and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the Website; however, no information or communication Website can be 100% secure, so GFG Real Estate Asset Management, LLC cannot guarantee the absolute security of your information. In addition, GFG Real Estate Asset Management, LLC is not responsible for the security of information that you transmit to the Website over networks that GFG Real Estate Asset Management, LLC does not control, including the Internet and wireless networks.
   3. Retention. GFG Real Estate Asset Management, LLC will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information GFG Real Estate Asset Management, LLC holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). GFG Real Estate Asset Management, LLC also collects and retains information through the Website in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page. If you are a customer of GFG Real Estate Asset Management, LLC or an end user accessing the Services through an investor portal, your data may be subject to a different privacy policy and your data will be retained in accordance with terms applicable to such access to the services.
5. Cookie Policy. This section provides GFG Real Estate Asset Management, LLC’s cookie policy and describes how GFG Real Estate Asset Management, LLC uses Cookies and similar technologies. For more information on GFG Real Estate Asset Management, LLC’s general data privacy practices, please see the full Policy.
   
   1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. GFG Real Estate Asset Management, LLC uses cookies, web beacons and similar technologies (“Cookies”) to enhance your user experience, understand your usage of the Website and Services and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that GFG Real Estate Asset Management, LLC places on your device because it is necessary for the performance of the Website or Services. GFG Real Estate Asset Management, LLC uses “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.
   2. Use. Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. GFG Real Estate Asset Management, LLC uses Cookies for the following purposes:
      
      1. To enable and support security features, prevent fraud, and protect your data from unauthorized access.
      2. To enable features and help us provide you with personalized content.
      3. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.
   3. Third-Party Cookies. GFG Real Estate Asset Management, LLC uses the following third-party Cookies on the Website:
      
      1. Google Analytics. Google Analytics tracks unique visitors to the Website, and provides analytics reports showing website usage and referral sources. It also helps determine whether visitors have arrived at the Website via Google marketing campaigns. See https://policies.google.com/privacy for details.
      2. Facebook. Facebook’s tracking determines whether visitors have arrived at the Website via Facebook marketing campaigns. See https://www.facebook.com/about/privacy for details.
      3. Marketo (Munchkin). – Marketo links visitor behavior on the Website to the recipient of an email marketing campaign to measure campaign effectiveness. See https://documents.marketo.com/legal/privacy/ for details.
      4. RollWorks, a division of NextRoll – RollWorks collects information about your visits to and actions on certain pages of our Website so that they can deliver ads for relevant GFG Real Estate Asset Management, LLC products and services to you later. See https://www.nextroll.com/privacy for details.
      5. Bing. Bing’s tracking determines whether visitors have arrived at the Website via Bin marketing campaigns. See https://privacy.microsoft.com/en-us/privacystatement for details.
      6. Wistia. Wistia hosts the video content embedded in the Website. It tracks how many visitors play embedded videos and how much of each video they play. See https://wistia.com/privacy for details.
      7. Greenhouse. Greenhouse operates the careers page on the Website, and uses Cookies to track job application submissions. See http://www.greenhouse.io/privacy-policy for details.
      8. MailChimp. If you subscribe to our newsletter, GFG Real Estate Asset Management, LLC uses Constant Contact for correspondence with you. Constant Contact may utilize web beacons or other cookies in their internal operations. See https://mailchimp.com/legal/privacy/ for more details.
      9. Capterra. Capterra’s tracking determines whether visitors have arrived at the Website via Capterra marketing campaigns. See https://www.capterra.com/legal/privacy-policy for details.
      10. Intercom. Intercom is a medium for communications, both through messaging on our website and via email. If you engage with the chat function on the Website, Intercom collects publicly available contact and social information related to you to enhance your user experience. See https://www.intercom.com/terms-and-policies#privacy for details.
      11. LinkedIn Insight Tag. LinkedIn’s tracking allows us to target users with advertising if they have visited the Website and subsequently visit LinkedIn. See https://www.linkedin.com/legal/privacy-policy for details.
      12. Google Tag Manager. Google Tag Manager is a solution that allows website tags to be managed using an interface. The Tag Manager tool itself is a cookie-less domain and does not register personal data, but rather activates other tags. Google Tag Manager does not access the information captured by other tags. See https://www.google.com/analytics/tag-manager/use-policy/ and https://policies.google.com/privacy for details.
   4. Opting Out. You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by GFG Real Estate Asset Management, LLC.
6. Notice to European Residents: General Data Protection Regulation
   If you are a resident of the European Economic Area or the United Kingdom, GFG Real Estate Asset Management, LLC will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”).
   For information submitted using the Website, GFG Real Estate Asset Management, LLC, Inc. is the data controller, as defined under GDPR. In accordance with GDPR, where GFG Real Estate Asset Management, LLC processes your Personal Information as a data controller, in certain circumstances you will have certain rights, which may include the following:
   
   1. right of confirmation;
   2. right of access;
   3. right to rectification;
   4. right to erasure;
   5. right of restriction of processing;
   6. right to data portability;
   7. right to object;
   8. right to withdraw data protection consent; and
   9. right to lodge a complaint with a supervisory authority.***As described above, where a customer uses our cloud products and services, we may store your personal information on behalf and under the instructions of our customers, which we process as a data processor on that customer’s behalf. We are not responsible for and have no control over the privacy and data security practices of such customers, which may differ from those explained in this Policy. The data protection rights listed above do not apply to GFG Real Estate Asset Management, LLC where we process your data as a data processor on behalf of a customer. If your data has been submitted to us by or on behalf of a GFG Real Estate Asset Management, LLC customer and you wish to exercise any rights you may have under the GDPR or other applicable data protection laws, please inquire with them directly.***
7. Notice to California Residents: California Consumer Privacy Act
   As of January 1, 2020, verified California residents have the right to:
   • ***request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
   • request and receive a copy of the personal information we have collected about them during the prior 12 months;
   • request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose;
   • request that we not sell personal information about them; and
   • request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.***
   For the purposes of this Section 7, “personal information” has the meaning given in the California Consumer Privacy Act (“CCPA”), but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.
   In order to make a request for disclosure California residents may contact us at info@gfgam.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information, we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
   You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
   For requests for a copy of the personal information we have collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
   For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
   We will not discriminate against you as a result of your exercise of any of these rights.
   Selling Information. We do not sell your information for monetary consideration and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this privacy policy and our compliance with the CCPA.
   Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
   During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The business purposes for which we collect the Personal Information are described in Section 3 above. The categories include information we collect from visitors to our Website, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.
   As described above, we may also act as a service provider to customers by providing technology that they can use to process personal information submitted by or for a customer to our cloud products and services. We are not responsible for and have no control over the privacy and data security practices of such customers, which may differ from those explained in this Policy. If your data has been submitted to us by or on behalf of a GFG Real Estate Asset Management, LLC customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly.
8. Third-Party Websites. The Website and communications from GFG Real Estate Asset Management, LLC may contain links to websites operated by third parties. You acknowledge and agree that GFG Real Estate Asset Management, LLC is not responsible for the collection and use of your information by such websites that are not under GFG Real Estate Asset Management, LLC’s control. GFG Real Estate Asset Management, LLC encourages you to review the privacy policies of each website you visit.
9. Children’s Information. The Website is not directed to, nor does GFG Real Estate Asset Management, LLC knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact GFG Real Estate Asset Management, LLC immediately using the contact information provided below.
10. Other Agreements. You may from time to time enter into binding legal agreements relating to certain Services available through the Website, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.
11. Contact Information. If you have any questions about this Policy or the collection or use of information about you, please write to GFG Real Estate Asset Management, LLC at info@gfgam.com or 701 Brickell Avenue Suite 1400 Miami, FL 33131.