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Privacy Policy

This Privacy Policy was Last Updated on June 29, 2020.

This Privacy Policy sets out the privacy practices of the website located at www.aracapital.com (the “Website”), as owned and operated by American Realty Advisors (“ARA”, “we,” “our,” “us”). For purposes of clarity, the Website does not include the Client Portal hosted by Intralinks or any other websites not hosted on www.aracapital.com. This Privacy Policy describes the types of information including “Personally Identifiable Information” (as defined below) we gather about you through the Website and the ways in which we use and share this information. This Privacy Policy does not apply to any information that we may collect offline, through another website (including the Client Portal), or through any other means (for example, at a live event or through the mail, which, for natural persons, is subject to ARA’s privacy policy adopted under the Securities and Exchange Commission’s Regulation S-P). Any terms that are not defined in this Privacy Policy shall have the meaning ascribed to them in our Terms of Use.

For purposes of this Privacy Policy, “Personally Identifiable Information” means any information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with a particular consumer or household including, but not limited to, first and last name, postal address, email address, telephone number, online identifier, internet protocol (“IP”) address, biometric information, geolocation data, and internet or other electronic network activity information such as browsing history and search history. Personally Identifiable Information does not include any aggregate or combined information, such as data that is related to you but studied as a group and does not identify you specifically.   

Please read this Privacy Policy carefully, since it is a part of the Terms of Use that together constitute a binding legal agreement between you and us. By using or attempting to use the Website, you accept, without limitation or qualification, and are agreeing to be bound by and comply with everything contained in our Terms of Use, including this Privacy Policy. If you do not agree to any of these provisions, do not use or attempt to use the Website.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below. If you are a California resident, please also see the “Additional Disclosures for California Residents” section below.

Information Collection

  1.  Information You Provide

We collect information that you provide directly via the Website, such as when you access our content or complete the “Contact Us” form on the Website. We may use Service Providers (defined below) to collect this information.

The information we collect includes information that identifies you personally (whether alone or in combination). The categories of information we collect and have collected include:

  • Contact Data. We collect your name, e-mail address, country of residence and at your election the company you represent, job title and phone number.
  • Content. We collect the content of messages you send to us, such as your feedback or questions and information you provide to us.

You may choose to voluntarily submit information to us through the Website that we do not request, and, in such instances, you are solely responsible for such information.

When you complete the Website forms or otherwise provide us your information in connection with your use of the Website, you agree to provide accurate, complete and true information. You agree not to use or submit any false or misleading names or any other inaccurate or misleading information. If we, in our sole determination, believe that any information you provide to us is intentionally untrue, inaccurate or incomplete, we may prohibit your use of the Website.

  1. Information we Collect Automatically

When you visit the Website, we and our Service Providers may collect and store certain technical information automatically. The categories of information we automatically collect and have collected include:

  • Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the time of day you browse, your referring and exiting pages, and other similar information.
  • Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, and other device identifiers.
  •  Location Data. We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).

We use various technologies to collect this information (“Tracking Technologies”) including the following:

  • Log Files. A log file is a file that records events that occur in connection with your use of a website or service, such as your service use data.
  • Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate a website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. You may elect to disable cookies by clicking on “Deny” on the pop-up when you first access the Website or anytime thereafter using “Cookie Preference” at the bottom of each page on the Website.
  • Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from other parties that allow us to track our conversions, bring you advertising, and provide you with additional functionality. You may elect to disable any pixels by clicking on “Deny” on the pop-up when you first access the Website or anytime thereafter using “Cookie Preference” at the bottom of each page on the Website.
  • Location-Identifying Technologies. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on Tracking Technologies and your rights and choices regarding them, see the “Your Rights and Choices” section.

Use of Information We Collect

We do not sell or rent information you provide to us through the Website to unrelated third parties without your consent. We do use that information for our business purposes in accordance with the practices described in this Privacy Policy. Our business purpose for collecting and using information, includes, the following:

  • Operate and manage our Website.
  • Perform services requested by you, such as to respond to your comments, questions, and requests.
  • Prevent and address fraud, breach of policies or terms, and threats or harm.
  • Monitor and analyze trends, usage, and activities.
  • Conduct research, including focus groups and surveys.
  • Improve the Website or other services we provide including, apps, marketing efforts, products and services.
  • Develop and send you direct marketing, including advertisements and communications about our and other party’s products, offers, promotions, rewards, events, and services.
  • Fulfill any other business or commercial purposes disclosed to you and with your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the “Your Rights and Choices” section below.

Sharing of Information

We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information include:

  • Service Providers. We may share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as data analytics, marketing, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
  • Affiliates. We may share your information with our related entities. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
  • Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our business to another business.
  • Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Website or any other party.
  • Consent. We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the “Your Rights and Choices” section below.

Your Rights and Choices

  1. Tracking Technology Choices.

  • Cookies and Pixels. Most browsers accept cookies by default. You may elect to disable any cookies and pixels by clicking on “Deny” on the pop-up when you first access the Website or anytime thereafter using “Cookie Preference” at the bottom of each page on the Website. You can also instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies through your browser is subject to your browser settings and limitations.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Website may not function correctly.

  1. Analytics.

You can opt out of your data being used by Google Analytics by clicking on “Deny” on the pop-up when you first access the Website or anytime thereafter using “Cookie Preference” at the bottom of each page on the Website.  You can also opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Retention of Information

Any information we collect may be retained for an indeterminate period of time.

Confidentiality and Security

We urge you to take every precaution to protect your Personally Identifiable Information when you are on the Internet. We are committed to protecting the security of the information collected from users of our Website and we have implemented generally accepted standards of technology security in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, it is not possible to guarantee the security or integrity of information disclosed online because no data transmission over the Internet or method of electronic storage is completely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Linked to Other Sites

The Website may contain links to third party websites. Please be aware that, when you click on (i.e., select) a link applicable to another website, your browser will re-direct and leave our Website and your activities and the collection of information about you will no longer be subject to the provisions of this Privacy Policy. We are not responsible for the privacy practices of other websites. You should review the terms and conditions and privacy policies of those websites.

Children's Privacy Statement

The Website is not directed to children under the age of 13 and we do NOT knowingly collect Personally Identifiable Information from children under the age of 13 as part of the Website. If we become aware that we have inadvertently received Personally Identifiable Information from a user under the age of 13, we will take the appropriate steps to delete such information from our records. We do not knowingly “sell,” as that term is defined under the California Consumer Protection Act, the personal information of minors under 16 years old who are California residents.

International Transfer

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Website from outside of the U.S., please be aware that information collected through the Website may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Website or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy.

Additional Disclosures for California Residents

California Civil Code Section 1798.83, also known as the ”Shine The Light” law, permits users who are clients of ours and who are California residents to request and obtain from us once a year, free of charge, information about the Personally Identifiable Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to American Realty Advisors, Attn: Legal/Compliance, 515 S Flower St 49th Floor, Los Angeles, CA 90071.

Changes to our Privacy Policy

You understand that we have the right to change this Privacy Policy from time to time, subject always to applicable law and regulation. If we make changes, we will post the revised Privacy Policy on the Website and update the “Last Updated” date to reflect the date of the changes. We will notify you of any material changes to this Privacy Policy by prominently posting it on the Privacy Page of the Website.

Contact Us

If you have any questions about this Privacy Policy, please contact us by e-mail at tmathiews@aracapital.com or by telephone at (213) 233-5768 or using the “Contact Us” form on the Website.

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