Privacy Policy

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Your privacy is important to us. This Privacy Policy (the “Privacy Policy”) applies to the personal information that Guardian Realty Investors, LLC, Guardian Realty Management, Inc., and any other affiliates (“Guardian,” “Guardian Realty” “we” or “us”) collects and explains our information practices.

1. Privacy Policy

This Privacy Policy applies to the personal information we collect related to our:

• websites, including www.guardianrealty.com, www.guardian-realty.com, and our other websites that display this Privacy Policy, and the services available through our websites (together, our “Sites”).

• mobile apps (“Apps”) and social media properties

• events, marketing and business development activities

• business communications and other online and offline business interactions

• any and all professional services

Collectively, we refer to the above as our “Services.” Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, this will be clearly disclosed to you. This Privacy Policy does not apply to the personal information that we collect about employees and other personnel, contractors, or applicants and candidates.

2. Information we collect

We may collect information directly, as well as from third parties or automatically related to the use of our Sites and Services.

• Information collected directly

We may collect personal information about you—such as your name, address, telephone number, fax number, e-mail address, etc.—directly from you. For example, personal information may be collected when you fill out a ‘Contact Us’ form, sign up for our mailing lists, register for events we host or sponsor, submit information as part of certain online services, post comments on our blogs, or otherwise provide us personal information through the Sites and Services. Generally, the information we collect includes your:

• Name, company name and title/position.

• Email address, phone number, mailing address and contact details.

• Contact preferences and interests.

• Business affiliations.

• Other information related to your request or inquiry, or that you provide when you communicate, engage or otherwise interact with us or the Services.

• Automatically-collected information

We use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information when users access or use the services or visit our Site, such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information

• Information received from third parties

We may collect or receive information about individuals from service providers, and other third parties, such as our clients, representatives and professional advisers, content providers, government authorities and public sources and records.

3. Use of personal information

We use the personal information we collect in order to respond to your request or inquiry and in the ordinary course of conducting our business. Generally, we use the personal information that we collect as follows:

• Providing support and services

To operate our Sites, provide our Services, communicate with you about your use of the Sites or Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.

• Responding to your requests

To respond to your inquiries, fulfill your orders and requests, and otherwise consider or process your request.

• Personalization

To tailor content we may send or display to you, including to offer location customization and personalized help and instructions on our Sites and Apps, and to otherwise personalize your experiences.

• Newsletters, mailing lists and direct marketing

For direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you.

• Analytics and improvement

To better understand how users access and use our Sites and other Services, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations and to develop services and features.

• Protect legal rights and prevent misuse

To protect the Sites, Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of us or any person or third party, or violations of our Terms of Use or other agreements; and to respond to actual or potential legal claims against us.

• Comply with legal and ethical obligations

In order to respond to legal process (eg, court orders, subpoenas or warrants) or regulator investigations and inquiries, or where otherwise required by law or our legal, regulatory or ethical obligations.

• General business operations

Where necessary, for the administration of our general business, accounting, recordkeeping, audit, compliance and legal functions.

• Anonymous and de-identified information

We create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.

4. Disclosure of personal information

We may share personal information with the following categories of third parties:

• Third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.

• Content providers that we partner with to make available CLEs, training and other content or resources. We do not share your information with them for their own independent use; however, if you register for an account with one of these third parties they will use the information you provide to them subject to their own privacy policy and terms.

• Our professional advisers, such as lawyers and accountants.

• Government and/or regulatory authorities.

• Professional indemnity insurers.

• Regulators, tax authorities and/or corporate registries.

In addition, we may disclose personal information to other third parties, including but not limited to, investors, lenders, partners etc., under the following circumstances:

• Business transfers

As part of any actual or potential merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.

• Comply with law, legal process and ethical obligations

To comply with the law and our ethical obligations or respond to legal process or regulator investigations and inquiries, or where otherwise required by law or our ethical obligations. For example, we may disclose information in response to subpoenas, court orders and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.

• Protect and defend rights

Where we believe it necessary to respond to claims asserted against us, enforce or administer our agreements and terms, or for fraud prevention, risk assessment and investigation, and to protect and defend the rights, property or safety of Guardian, our clients and customers, or others.

We may also share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

5. Cookies and similar devices

We and our service providers use cookies, pixels, log files and other mechanisms to gather information about your use of our Sites and Apps.

• Cookies

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

• Clear GIFs, pixel tags and other technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.

• Log files

Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

• Third-party analytics

We also use automated devices and applications, such as Google Analytics to evaluate the use of our Sites and Services. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

6. Third-party websites and links

Our Sites may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

7. Revisions to our Privacy Policy

We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes.