Prime Finance Advisor, L.P. (“Prime Finance,” “we,” “us,” or “our”) is committed to protecting the privacy of identifiable individuals through our compliance with this Privacy Policy.  We have created this Privacy Policy to inform you of our policies regarding the collection, use and disclosure of personal information as well as the rights and choices you have associated with that information.

This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline in order to provide you access to debt, preferred equity or similar financing or investment opportunities, as applicable (collectively, the “Services”). Such personal information may be collected in the following manners:

• our website located at https://www.primefinance.com and all corresponding webpages that link to this Privacy Policy (the “Site”);
• any mobile applications that link to this Privacy Policy (e.g., Apple iOS Apps, etc);
• when you interact with our advertising and applications on third party websites and services, if the advertising and applications include links to this Privacy Policy;
• via email or phone; and
• in person at our offices.

By accessing, visiting or using our Services, you acknowledge that you understand that your personal information will be processed as described in this Privacy Policy. If you do not feel comfortable with any part of this Privacy Policy, you should not use or access our Site or Services.

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect your personal information when you interact with our Site, mobile applications, with us over email or phone and at physical locations. Personal information is any information that directly or indirectly identifies, relate to, describes, or is reasonably capable of being associated or linked to you.

The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and Services, information from other sources to help us supplement our records, improve the personalization of our service to you, promote safety at our apartment communities, and/or detect fraud.

Information You Voluntarily Provide to Us. The personal information we collect on or through our Site or Services may include:

• Contact Details. You may choose to provide us your contact information, such as your name, address, email, and phone number.
• Financial Information. When you engage us for debt, preferred equity or similar financing or investment opportunities, we may collect your loan information, financial statements and records (and related documents), and required verifications. If applicable, we may also collect investor information, such as your subscription documents and related materials.
• Payment Information. We will process your payment card information, wire instructions, transaction, bank or financial account information, as applicable.
• Forms. We may collect information you provide by filling in forms that we make available.
• Customer Service. When you engage with our support team by email, telephone, in writing, or when you report a problem through our Site or an in-person location, we may collect records and copies of your correspondence (including email addresses), or additional information you choose to share with us.

Information from Third Parties. We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, we may collect credit or identity information, as well as conduct civil and criminal background checks, which we use to help prevent and detect fraud or to ensure safety at our apartment communities.

Information Collected from Other Sources.  We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.

Information Collected Automatically.  As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Usage Data. When you browse our Sites, we automatically collect log data pertaining to your visits to our Site, such as, traffic data, logs and other communication data, your Internet Protocol (“IP”) address, browser type, domain name, the time and length of your visit, the website that referred you to our website, and the subject of the ads you click or scroll over, the resources that you access and use on the Site, and other diagnostic data.
• Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, your device type, and your mobile device’s advertising ID.
• Preference Information. When you interact with our Site, we may collect information about your preferences to make your use of the Site more productive, via the use of Cookies. For more information, please see our Cookies and Other Similar Tracking Technologies section for more information.
• Location Information. When you use our Services, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. We may also collect the precise geo-location of your key fob through GPD, WiFi, IP address, or other wireless network triangulation, in providing access management service to our premises.
• CCTV. We may use closed-circuit television, video recordings, photography, and/or similar technology to monitor our premises for security, fraud, loss prevention, incident reporting, and operational purposes.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar tracking technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (“behavioral tracking”).

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Site or Services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site, to enhance your experience with the Site, to remember information you have already provided; and to provide a secure browsing experience during your use of our Site. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).

The following types of cookies are used on our Site:

• Strictly Necessary Cookies.  These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
• Functional or Preference Cookies.  We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
• Performance or Analytic Cookies. We may work with third-party analytics services to help us understand how the Site is being used, such as tracking the frequency and duration of use of the Site. We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect information about your use of the Site. Google and these analytics services may use cookies to collect information about the content you view, what websites you visit immediately prior to and after visiting the Site, and your system information and geographic information. The information generated by these cookies about your use of the Site will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the Site.
• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

Managing Cookies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you choose to disable cookies in your browser, you can still use our websites, although your ability to use some of the features may be affected.

Managing Analytics. We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics.  Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout. We use these analytics tools in restricted processing mode such that we do not share any personal information about your Site visitors with Google.

Managing Interest-Based Advertising.

Website Browser. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

3. HOW WE USE YOUR INFORMATION

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:

1. To Provide Our Services. We will use your personal information to provide information or perform Services that you request, such as: creating and managing your records and accounts in connection with your use of the Services; managing your access to our premises; facilitating financial transactions related to the Services you use; providing information to lenders or other counterparties in connection with our borrowing or other investments; and responding to your inquiries or providing information on the services you request.
2. To Provide You with Service-Related Communications. We will send you administrative related information to keep you updated about the Services. Such communications may include information about Privacy Policy updates, security updates, tips or other relevant Service-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to the Services.
3. To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, ensure compliance with industry regulator’s standard and policies, to manage risk as required under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.
4. To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our Terms or other legal rights, including those arising from any contracts entered into between you and us, including for billing and collection.
5. To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud and abusive use of our Service, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system security, combat spam, malware, malicious activities or other security risks; and enhance safety and security of our premises and other properties where we provide Service.
6. To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us to respond reviews, comments, or other feedback you provide us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
7. To Provide Marketing Communication. We may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you subscribe to our marketing communications. We will occasionally send you information on products, services and promotions. When you no longer wish to receive these marketing messages from us, you can opt out at any time by using the “Unsubscribe” link that appears at the bottom of such messages and following instructions contained within, or reach out to us as specified in the “Contact Us” section, below.
8. To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Sites are used, how many visitors we receive, when and how visitors return to our Services, and where they click on the Sites. These types of information may help us improve our existing Services and to build new Services. Please see our Cookies and Other Similar Tracking Technologies section for more information.
9. To Personalize Your Experience. We may process your information to personalize your experience on the Site and/or otherwise customize what you see when you visit and use the Site. By personalization, we enable you to interact with our Services more easily across platforms and devices. Such as, saving your user account, registration and profile data or other personal information so you do not have to re-enter it each time you visit or use the Site;
10. To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
11. With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the contact information in the “Contact Us” section below to notify us of your opt-out preference.

4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may share or disclose your personal information in the following circumstances:

• Service Providers. We may employ other companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform service-related activities or assist us in analyzing how our Services are used. The Service Providers may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Within Our Organization.  We may share your personal information with our subsidiaries and affiliates to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.  For example, we may share your information with our subsidiaries and affiliated companies to expand and promote our Services.
• Corporate Transactions. We may share, disclose or transfer your personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Site users is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your personal information, or to financial institutions and other counterparties in connection with making, holding, financing and disposing of our investments.
• As Required by Law.  We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, or safety of Prime Finance or our customers or partners.
• Consent.  We may disclose your personal information for any purpose with your consent.

Please note that we may disclose, without restriction, aggregated or anonymized information about our users, which is information that does not identify any specific individual.

5. COMMUNICATIONS PREFERENCES

To provide Services to you, we may send you communications related to your transactions, security, or the administration of this Site. From time to time, we may also send you other messages or updates about Prime Finance, our website, and promotions or other activities. If you do not wish to receive non-transaction/security-related communications from Prime Finance, you may opt-out by clicking the “unsubscribe” link if available in the communication or contact us where specified in the “Contact Us” section, below.

Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

6. RETENTION

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws and regulations), resolve disputes and enforce our legal agreements and policies.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer data, including personal information, to United States and process it there.  If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

8. NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy.

Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):

• Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, and identification numbers associated with your devices;
• Characteristics protected under state and federal law, such as your age, gender, SSN or TIN, driver’s license, employment, employment history, bank account number, and demographic information.
• Commercial information such as your leasing information, financial information, transaction records, and payment information;
• Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• Geolocation data, to the extent you have configured your device to permit us to collect such information, or use one of the key fobs issued at our properties;
• Audio or Visual information, such as audio recordings of your voice to the extent you call us, as permitted under applicable law, and your video recording through our properties’ CCTV footage; and
• Professional or employment-related information, such as your employment and employment history.
• Inferences drawn from any of the information listed above, such as your preferences, characteristics, and behavior.

We generally do not collect biometric information and education-related information. For more information about the personal information we collect and how we collect it, please refer to Section 1 above.

Purposes for Collecting and Using Categories of Personal Information

We collect and use your personal information for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling your applications and transactions, verifying tenant identity and information, processing payments, providing financing;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Helping to ensure security and integrity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;
• Undertaking internal research for technological development and demonstration; and
• Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance such service.

For more information about the purpose of collecting and using the categories of personal information listed above, please refer to Section 3 above.

Your Rights

California residents have certain rights. Your rights in relation to your personal information are not absolute. Access to your rights may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons. Subject to certain limitations or exceptions, California residents have the following rights:

1. Right to Know/Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
2. Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, including if we need personal information for a reason related to our business, such as: providing goods or services to you; detecting and resolving issues related to security or functionality; complying with legal obligations; conducting research in the public interest; exercising free speech or ensuring another’s exercise of free speech; or using the information for internal purposes that a consumer might reasonably expect.
3. Right to Correct. You have the right to correct inaccurate personal information that you provided to us.
4. Right to Opt-out of Sales. You have the right to opt-out of the sale of your personal information. We do not sell your personal information.
5. Right to Opt-out of Sharing for Cross-Contextual Behavioral Advertising. You may opt-out of the sharing of your personal information for cross-contextual behavioral advertising.  We do not share your personal information for cross-contextual behavioral advertising purposes.
6. Right to Limit Use of Sensitive Information. For California residents, to the extent your sensitive personal information (as that term is defined under the CCPA) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you without your consent.

We do not knowingly sell or share the personal information of any user under the age of 18. We do not process any personal information we collect for the purposes of inferring characteristics about you.

We will not discriminate against you for exercising any of your rights. This means we will not: (a) deny your services; (b) charge you different prices or rates for goods or services, including granting discounts or other benefits or imposing penalties; (c) provide you a different level or quality of services; or (d) suggest that you may receive a different price or rate for services or a different level or quality of services.

Submitting a Rights Request

To exercise the rights described above, please submit a verifiable consumer request to us either by email at ccpainquiry@primefinance.com, and putting “California Rights Request” in the subject line or by contacting us at 888.457.0941.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This means that in making a request you may be required to: provide your email and phone number, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the personal information that is the subject of the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we are unable to verify your identity, we reserve the right to deny the request. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you choose to use an authorized agent to submit a request to delete, a requests to correct, or a request to know, we may require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with us. We will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4121 to 4130. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

How to Submit Opt-Out Requests. To exercise your right to opt-out of sales and targeted advertising, please click on the cookie symbol in the lower left hand corner of our website, and slide the “Targeting Cookies” to off in the Privacy Preference Center pop-up. Please note that you may still receive generalized ads after opting out of targeted advertising.

You may also opt-out of sharing and sales by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Please note that the opt-out choice will only apply to your use of our Sites through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Sites to completely opt-out using this method.

9. DATA SECURITY

We are committed to protecting your personal information from unauthorized access and use. To help protect your personal information, we implement and maintain appropriate technical, physical, and administrative safeguards. We aim to restrict access to your personal information solely to those employees and vendors who need to know that information to provide our Services to you. Our employees receive training to maintain the confidentiality, privacy, and security of your personal information.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

10. CHILDREN

We do not offer Services to minors and do not intend to collect personal information from children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18.  If an individual under the age of 18 has provided us with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.

11. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES

The Site may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including third-party services. The Site may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Site or for the services or the privacy practices of third-party advertising companies. Once you leave this Site or our Services via a link, access a third-party service or click on an advertisement, you should check applicable privacy policies to determine, among other things, how related companies process personal information they may collect about you. This Privacy Policy applies solely to information collected by Prime Finance.

12. CONTACT US

We welcome your questions, comments, and concerns about privacy. If you have any questions or comments regarding this Privacy Policy please email us at ccpainquiry@primefinance.com or you can write to us at 600 Montgomery Street, Suite 1700, San Francisco, CA 94111.