Privacy Policy

General

Merlone Geier Management, LLC and its affiliates (“MGP”, “us,” “our” or “we”) are committed to respecting privacy.  This MGP Privacy Policy (“Privacy Policy”) governs our data collection, usage and services. When referring to our websites, we are including the MGP websites, our properties’ websites and any other development websites that link to this policy (the “Websites”). This Privacy Policy discloses how we collect, protect, use and share information gathered about you. If you use the Websites or provide us with information, you explicitly agree to the terms and conditions of the Privacy Policy in effect at that time. Please read our Privacy Policy to understand our practices.

1. Information We Collect from the Websites

To receive certain benefits of using the Websites, you may be required to voluntarily provide your personally identifiable information (“Personal Information”). If you do not agree with the collection of this Personal Information, please do not provide it. The following describes the types of personal and other information we may collect about you, and how we use and maintain that information:

Site Use Information

Our web servers may collect the IP address of visitors to our Websites. This information may be aggregated to measure the number of visits, average time spent on the Websites, pages viewed, etc. Such information is not considered Personal Information under this Privacy Policy. We may use this information to measure the use of our Websites and to improve the content we offer. We may share with third parties this experiential information or other data on an aggregated basis without the use of any information that personally identifies you.

Use of Cookies

Like most websites, we employ “cookies” or similar technologies on certain pages of our Websites. Cookies make the use of the Websites easier by, among other things, saving your preferences. We may also use cookies to improve your experience on our website or to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Websites to Personal Information that you previously submitted. The information that we collect with cookies allows us to statistically analyze usage of our Websites, and to improve and customize our content and other offerings.

If we disclose information collected from cookies, we will only do so on an aggregated basis without the use of Personal Information. Cookies are not considered Personal Information under this Privacy Policy.  The cookies we use on our Websites may include session (temporary) cookies or persistent (extending into the future) cookies.

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. Our websites do not alter their behavior when we receive a “Do Not Track” signal from browser software. Currently, we do not monitor or take any action with respect to these signals or other similar mechanisms.

2. Information You Provide to Us

By providing Personal Information you explicitly agree to our collection and use of that information as described in this Privacy Policy.

You also agree that we may use any information that you provide for our general purposes, and may share it with our affiliates and third parties, only as described in this Privacy Policy.

Personal information may be used, for example, for identification purposes, to communicate with you regarding career opportunities or to facilitate the functioning of our Websites. If you provide us with a telephone number and/or email address, you expressly agree that we, or our authorized agents, can use that number and/or email address to contact you about business or career opportunities.

We may keep any information that you provide to us indefinitely.

3. Disclosing Information to Third Parties

We will not share, rent, sell or otherwise disclose any Personal Information that we collect about you through our Websites, except in any of the following situations:

  • You request or authorize the release of your Personal Information.
  • We may use the Personal Information we collect from you to fulfill your requests, manage the Websites, and communicate with you about career opportunities.
  • We may provide your Personal Information to our affiliates, so as to provide access to benefits and communicate important information about them.
  • We may also provide such Personal Information to other select third parties approved by MGP as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by MGP.
  • We may disclose Personal Information about you as part of a merger, acquisition or other sale or transfer of the assets or business of MGP. We do not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this Privacy Policy.
  • We may disclose Personal Information about you to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
  • We may share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose the number of visitors to our Websites or the number of people who have downloaded a particular document.

4. Links to Other Websites

Our Websites may contain links to other websites, however this Privacy Policy only addresses MGP’s use and disclosure of your information collected on our Websites, if any. Please read the applicable privacy policies and terms and conditions of such parties or websites.

5. Child Privacy

If you are under the age of 18, please do not use or access the Websites in any way. We will not knowingly collect or use any Personal Information from any child under the age of 18. It is not our intention to collect Personal Information from anyone under 18 years of age. If we become aware that we have collected any personal information from children under the age of 18, we will promptly delete such information from our databases.

6. European Union

By using the Websites, you are representing that you are located outside of the European Union (“EU”). You may not use the Websites from the EU.

7. Notice to California Residents

Your Rights under the California Consumer Privacy Act (“CCPA”)

This section describes your rights under the CCPA and how to exercise your rights. These rights are in addition to the other rights outlined in this Privacy Policy. Under California law, California residents with whom we have an established relationship have the right to request certain information with respect to the types of Personal Information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. California residents who have an established relationship with MGP may tell us not to share their Personal Information with third parties for marketing purposes. To opt out, you may contact us at any time as described below under MGP Privacy Contact.

Collection and Use of Personal Information

We may collect personal information for a variety of purposes. Not all information collected is from individuals. We also collect information from our tenants and suppliers. In the last 12 months, we have collected the following categories of personal information, from the sources and for the purposes stated below:

Category of Personal Information Categories of Sources Purpose of Collecting and Sharing Personal Information
Identifiers (name, address, email address, phone number, Social Security number, driver’s license number, passport number, unique personal identifier, IP address and other similar identifiers) · Directly from you
· Affiliates and business partners
· Third parties that you direct to share with us
· Government regulators
· Providing services
· Enhancing services
· Vendor and employment related
Commercial Information (your use of our services) · Directly from you · Providing services
· Enhancing services
Protected Classification Information (age, sex, gender, religion, national origin, marital status, disability status) · Directly from you · Regulatory filings
· Governmental requests
· Vendor and employment related
Sensitive Information (financial account, medical, health, and health insurance information, user name and password) · Directly from you · Providing services
· Enhancing services
· Regulatory or government requests
· Vendor and employment related
Professional, Educational or Employment Related Information · Directly from you
· Third parties that you direct to share with us
· Providing services
· Enhancing services
· Vendor and employment related
· Regulatory or government requests
Internet/Network Information (IP address, browsing information) · Automatically collected from Websites and mobile devices · Providing services
· Enhancing services
· Vendor and employment related
Biometric Information (fingerprint, voiceprint, etc.) · Directly from you
· Third parties that you direct to share with us
· Providing services
· Enhancing services
· Vendor and employment related
Geolocation Data (physical locations or movements) · Your browser or device · Providing services
· Enhancing services
Sensory Information (pictures of you) · Directly from you
· Third parties that you direct to share with us
· Providing services
· Enhancing services
· Employment related
Inferences from other Personal Information (preferences, characteristics) · Your browser or devise
· Directly or indirectly from you
· Providing services
· Enhancing services
· Vendor and employment related

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights:

  • The Right to Know
  • The Right to Request Deletion
  • The Right to Opt Out of Personal Information Sales
  • The Right to Non-Discrimination
  • “Shine the Light”- The right to know how your information is shared with third parties

Your CCPA rights are subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.

How to Exercise your California Consumer Rights

As of January 1, 2020 verified California residents have the right to:

Upon verification of your identity, you have the right to request any or all of the following information that we have collected and disclosed in the last 12 months:

  • The personal information we have collected;
  • The categories of personal information we have collected;
  • The categories of sources of personal information we have collected;
  • The categories of personal information that we have disclosed to third parties for a business purpose and the categories of recipients of the information;
  • The categories of personal information we have sold about you (if any) and the categories of third parties to which any information was sold; and
  • The business or commercial purpose of for collecting and/or selling the information.

In addition, you may request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions. You also have the right to direct us not to sell your information. Please note that we do not sell your Personal Information. If we begin to sell your Personal Information in the future, we will update this Privacy Policy to enable you to submit a request to opt-out.

In order to make a request for disclosure California residents may contact us by emailing us at privacy@merlonegeier.com or calling us toll-free at 1-844-325-0303. We will ask you for information that allows us to reasonably verify your identity. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. We will not discriminate against you as a result of your exercise of any of these rights.

Governing Law

By choosing to visit our Websites or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California. You also agree to abide by any limitation on damages contained in other agreement that we have with you.

Changes to this Privacy Policy

We may occasionally amend this Privacy Policy to reflect MGP and user feedback and we reserve the right to make changes to this Privacy Policy at any time. The use of your information is subject to the Privacy Policy in effect at the time of use.

Contact

If you have any questions or comments regarding our Privacy Policy or our Websites, please contact us at privacy@merlonegeier.com or by calling us toll-free at 1-844-325-0303.

 

Effective Date – January 1, 2020