This Privacy Policy (this “Privacy Policy”) describes the ways in which Center Street Investors.com, LLC (“CSI”) collects, uses and discloses information about you, including personally identifiable information, in connection with your use of this website (including any subdomains thereof, this “Site”). Throughout this Privacy Policy, “you” refers to the individual or entity that is visiting this Site.
Please read this Privacy Policy carefully before accessing or using this Site. By accessing this Site, registering as a user, using any of the publicly available content, services and or products provided through this Site (collectively, the “Services”) or by otherwise submitting your personal information to CSI, you acknowledge and consent, as described in this Privacy Policy,to the collection, use, sharing and disclosure of your personal information and data on and in connection with this Site and the Services.
If you have any questions about this Privacy Policy, please contact CSI at info@centerstreetinvestors.com.
a. Scope. CSI utilizes this Site to provide you with certain Services In the course of providing the Services, CSI will collect “Personal Information,” which means information that personally relates to or identifies you, including without limitation your name, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, and other types of information from you.
b. Changes to this Privacy Policy. CSI reserves the right to update this Privacy Policy from time to time by posting a new Privacy Policy on this page. In some cases, where the changes to this Privacy Policy are material, CSI 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 Privacy Policy regularly for any changes. Your continued use of this Site after such changes have been made constitutes acceptance of those changes.
a. Information that You Provide. When you register for an account on this Site, CSI collects certain Personal Information from you that you voluntarily provide to open an account, transact business, communicate with CSI, verify your identity and fulfill legal and regulatory requirements. From time to time, CSI may request additional information to help it further assess your needs and preferences. CSI may also collect information that you provide by electronic mail, telephone or other means.
b. Automatically Collected Information. CSI may automatically collect certain technical information from your computer or mobile device when you use this Site, 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 this Site, the pages you view immediately before and after you access this Site, and the search terms you enter on this Site. This information allows CSI to recognize you and personalize your experience if you return to this Site using the same computer or mobile device, and to improve this Site and the Services.
c. Information about Legal and Other Materials. In addition, CSI 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 this Site, including this Site’s Terms of Use(“Terms”) and this Privacy Policy.
d. Cookies. CSI may collect this information using “cookies,” which are small text files that this Site 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 this Site. CSI may also collect information 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 CSI compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy in Section 5 below.
e. Cross-Site Tracking. CSI does not utilize technical measures on this Site to track your activities across different websites or online services, whether you configure your browser’s Do Not Track feature or otherwise. This Site does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
f. Reviewing, Correcting and Deleting Information. You may update or correct contact information and other Personal Information stored about you on this Site, or delete your account in its entirety, by accessing your account/profile page, or by sending a written request to the CSI at ir@centerstreetinvestors.com.
3. Use and Disclosure of Information. CSI may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:
a. Accessing this Site and Providing the Services. CSI uses your Personal Information to provide you with the Services, or products, services or information related to this Site or the Services, including:
• providing you with information about this Site, Services or required notices;
• customizing your experience when using this Site, such as by providing interactive or personalized elements on this Site;
• more effectively marketing and advertising CSI, the funds of its affiliates and third-party funds;
• better determining which Services may be of most interest to you; and
• providing you with content based on your interests.
b. Analysis. CSI uses your Personal Information for improving this Site and/or the Services, including by (i) combining or aggregating any of the information collected through this Site or elsewhere for generating and analyzing statistics about your use of this Site 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 offerings.
c. Security. CSI may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue CSI’s legitimate interests in ensuring the security of this Site and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the Terms, violations of law or other misuse of this Site; and when CSI believes in good faith that disclosure is necessary (i) to protect CSI’s rights, the rights of other users of this Site, the integrity of this Site, or your safety or the safety of others, or (ii) to detect, prevent or respond to fraud, intellectual property infringement, violations of the Terms, violations of law or other misuse of this Site.
d. Service Providers. CSI engages third-party service providers (such as payment processors, hosting providers and analytics and security providers) to assist in operating and marketing this Site. CSI’s engagement of third-party service providers is sometimes necessary for CSI to provide the Services to you, particularly where such third-party service providers ensure that this Site and Services are operating and secure. In other instances, although not necessary as described in the previous sentence, the engagement of such third-party service providers allows CSI to more effectively serve its customers and improve this Site and the Services.
e. Other Disclosure. CSI may disclose Personal Information about you to others: (i) with your valid consent to do so; (ii) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (iii) to enforce any of the terms and conditions or policies; (iv) as necessary to pursue available legal remedies or defend legal claims; or (iv) as is otherwise legally permissible and not in violation of the Terms, this Privacy Policy or any other applicable agreement.
f. Marketing. If you submit your information to CSI, CSI may provide you with information about this Site, Services or required notices. In addition, CSI may use collected information for delivering marketing communications that may be of interest to you.
4. Storage.
a. Jurisdiction. Information collected through this Site will be stored in, processed in and subject to the various local, state and federal 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 this Site, you consent to such transfer to, storage in and processing within the United States.
b. Security. CSI is committed to protecting your information from unauthorized access, use or disclosure. Reasonable administrative, technical and physical safeguards designed to protect the information collected through this Site are maintained. However, no information or communication system can be 100% secure, so CSI cannot guarantee the absolute security of your information. In addition, CSI is not responsible for the security of information that you transmit to this Site over networks that CSI does not control, including the Internet and wireless networks.
c. Retention. CSI will not retain data longer than is prohibited by applicable laws or regulations, if any. If you wish to access or correct any information CSI holds about you, you may have your data deleted, blocked or corrected, in each case in accordance with any applicable laws or regulations, if any. CSI also collects and retains information through this Site in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page.
5. Cookie Policy. This section provides CSI’s cookie policy and describes how CSI uses Cookies and similar technologies.
a. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. CSI may use cookies, web beacons and similar technologies (“Cookies”) to enhance your user experience, understand your usage of this Site 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 CSI places on your device because it is necessary for the performance of this Site or Services. CSI may use “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave this Site or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.
b. Use. Cookies can contain the following information about you and your use of this Site: browser type, search preferences, data relating to which pages of this Site that you have visited and the date and time of your use. CSI may use Cookies for the following purposes:
• to enable and support security features, prevent fraud, and protect your data from unauthorized access;
• to enable features and help CSI provide you with personalized content; and
• to analyze how you use this Site and to monitor site performance, as these Cookies help CSI to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached this Site.
c. Third–Party Cookies. CSI may use certain third–party Cookies on this Site, including without limitation the following:
• Google Maps and Google Charts. This Site utilizes mapping and charting services from Google. These services use cookies in their internal operations. See https://policies.google.com/privacy for details.
• DocuSign (if applicable). This Site provides the option to execute agreements via DocuSign. If you interact with DocuSign via this Site, you may encounter cookies used by DocuSign in their internal operations. See https://www.docusign.com/company/privacy-policy for details.
• Wistia, YouTube, and Vimeo. This Site offers the capability to embed video from Wistia, YouTube, or Vimeo as part of offering marketing materials. If you view marketing materials containing embedded video, the video player may use cookies in its internal operations, including functions such as tracking how many visitors play the video, and how much of the video they play. In addition, Wistia hosts the video content embedded in this Site’s help center. See https://wistia.com/privacy, https://policies.google.com/privacy, and https://vimeo.com/privacy for details.
d. Opting Out. You can control and/or delete cookies as you wish. For details on how to do this, you can visit online https://www.aboutcookies.org/ and numerous other websites. 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 CSI.
6. Third-Party Websites. The System and communications from CSI may contain links to websites operated by third parties. CSI does not control how these third parties collect information or by what means such third parties may use their own cookies to collect information about you. You acknowledge and agree that CSI is not responsible for the collection and use of your information by such websites that are not under CSI’s control. CSI encourages you to review the privacy policies of each website you visit.
7. Children’s Information. The System is not directed to, nor does CSI knowingly collect information from, children under the age of 18. The Terms expressly prohibit the use of this Site by anyone under the age of 18. If you become aware that your child or any child under your care has provided information without your consent, please contact CSI immediately using the contact information provided below.
8. International Visitors. This Site and the Services may be accessed and/or used by users located outside the United States in accordance with the Terms and other policies and procedures posted on this Site, if any. If you use the Services from the European Union (EU) or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.
9. Other Agreements. You may from time to time enter into binding legal agreements relating to certain Services available through this Site, which may have terms that are different from those of this Privacy Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.
10. Role of Juniper Square.
a.Host and Operator. Juniper Square, Inc., a Delaware corporation (“Juniper Square”), hosts and operates on behalf of CSI the internet-based technology platform, accessible through this Site at https://login.centerstreetinvestors.com/login that allows investors to independently review and invest in certain offerings of securities related to real estate (the “Platform”). As operator of the Platform, Juniper Square has access to, stores and processes all Personal Information received and collected about you by means of the Platform, as well as information that CSI furnishes to Juniper Square about you, for the purpose of hosting and operating the Platform and facilitating provision of products and services by CSI to you. Juniper Square does not direct or control CSI’s use or storage of Personal Information about you. Juniper Square’s collection, use and disclosure of your Personal Information is described in the Juniper Square privacy policy, which is available at http://www.junipersquare.com/legal/privacy_policy.html.
b.Business Transfer. If Juniper Square, or substantially all of Juniper Square’s assets, are acquired, or in the unlikely event that Juniper Square were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Juniper Square may continue to use your Personal Information as set forth in the privacy policies for CSI and Juniper Square in respect of the Platform (as it may be amended from time to time).]
10.Contact Information. If you have any questions about this Privacy Policy or the collection or use of information about you, please write to CSI at info@centerstreetinvestors.com.