We consider privacy to be fundamental to our relationship with our Investors. We are committed to maintaining the confidentiality, integrity and security of our current and former Investors’ non-public information. Accordingly, we have developed internal policies to protect confidentiality while allowing Investors' needs to be met.

We respect your right to privacy. We also know, however, that you expect us to conduct our investment program in an accurate and efficient manner. To do so, we must collect and maintain certain non-public information about you and our other investors. We collect this information from sources such as subscription agreements and other documents.

We will not disclose any non-public personal information about Investors who are individuals, except to our affiliates and service providers as allowed by applicable law or regulation. In the normal course of serving our Investors, information we collect may be shared with companies that are (or may) perform various services such as accountants, auditors, attorneys, broker-dealers, franchises, and/or fund administrators. We are also sometimes asked to provide ownership and other information to certain lenders about loans on our investment properties. Specifically, we may disclose to these service providers and lenders non-public personal information including:

• Information we receive on subscription agreements or other documents, such as name, address, account or tax identification number and the types and amounts of investments; and

• Information about transactions with us, our affiliates or others, such as participation in other investment programs, ownership of certain types of accounts or other account data.

Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose. To protect the personal information of individuals, we permit access only by authorized employees who need access to that information to provide services to us and our investors. To guard Investors' non-public personal information, we maintain physical, electronic and procedural safeguards that comply with U.S. federal standards. An individual Investor's right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the internet.  

We note, however, that notwithstanding the foregoing, we reserve the right to disclose non-public personal information about Investors to any person or entity, including without limitation any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is  necessary  or advisable  pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the USA PATRIOT Act of 2001 and (ii) such disclosure is not otherwise  prohibited  by  law,  rule, regulation, executive order or policy.