Privacy Policy

I. PRIVACY STATEMENT

Your privacy is our top priority. Our policy is to respect the privacy of all visitors to our Web site, including current and former clients, and to protect personal information entrusted to us. Penn Square Real Estate Group, LLC (“Penn Square”) is also sensitive to privacy issues on the Internet. We believe that it is important you know how we treat the information that we collect through our Web site and other means.

II. IMPORTANT TERMS

When reviewing any privacy statement on the Internet, you should be familiar with the terms “personally identifiable information” and “aggregate information” or “aggregate data.” “Personally identifiable information” is any information that can be used to identify, contact, or locate you as an individual. Common examples are your name, home address and email address. “Aggregate information” or “aggregate data” refers to information or data that we have compiled about the behavior and characteristics of users of this Web site, which information and data could not be used to identify you as an individual. For instance, we may compile data to show that half of those who contact us for information are from the Northeast.

III. COLLECTION OF INFORMATION

What information we gather: In general, you may visit our Web site without telling us who you are or revealing any personally identifiable information about yourself (“Personal Information”). Our servers may, however, collect a variety of technical data, which we store as aggregate information in personally identifiable form (“Technical Data”). This Technical Data includes (but is not limited to) your IP address (a unique number that identifies your access account on the Internet), domain, and Web browser information. We may track the page you visited before coming to our Web site, the page you link to when you leave our Web site, which of our pages you access, and how long you spend on each page. We also gather all Personal Information that you choose to provide to us, including your name, address, phone number, email address, organization, facsimile number, the name of your company, your position, your company address, company phone, and company facsimile.

How we gather information: We gather Personal Information from you when you email us from this Web site or complete a contact form (e.g., to provide comments, request materials or ask questions). As noted above, our servers collect Technical Data about your visit to our Web site. Our Web site also uses “cookies”. Cookies are small text files that our servers can store on your computer and retrieve later. Cookies let our Web site recognize previous visitors, to record users’ progress from page to page, and recall certain information that a user may have entered previously. We may use cookies to store your username and password information. We may also use tracking images and applets to keep track of this information. At times, we may conduct on-line surveys to better understand the needs and profile of our visitors. If we conduct a survey, we will let you know how we will use the information at the time of its collection if our proposed usage differs from the terms of this privacy statement.

IV. USE OF INFORMATION

Personal Information: We may use the Personal Information you provide on this Web site to respond to your inquiries, requests and feedback; send you notices relating to your use of the Web site (for example, if we modify this privacy statement in the future); and fulfill our legal or regulatory requirements. If you have consented to receive information and solicitations regarding products and services available through this Web site or through us our any of our affiliated entities, then we will also use your Personal Information to process and send you such information and materials. If you have indicated you are a certain kind of investor, we may, in addition, use your Personal Information to verify your status and to send you marketing and informational materials regarding our funds. These solicitations and information may take the form of mailings via U.S. mail or other courier service, telephone calls, e-mails, or, in certain situations, via facsimile.

Technical Data: As noted above, we also collect a variety of Technical Data. Technical Data may be stored in both aggregate and, in personally identifiable form. Technical Data may be used, for example, to assess usage of the Web site, to analyze users’ reactions to the design and content of our Web site, to improve the performance and functionality of our Web site, to analyze software compatibility issues, and for internal reporting purposes. We may also use Technical Data for marketing and research purposes.

V. DISCLOSURE TO THIRD PARTIES

You should understand that we may share the Personal Information you provide to us with the following entities: (1) We may share your Personal Information with our affiliated entities, including affiliated service providers. (2) We may share your Personal Information with unaffiliated entities that help us process information or service your requests, such as custodians, broker-dealers and marketing service firms, as well as with other financial institutions with whom we have joint marketing or other agreements. These entities are contractually bound to protect the confidentiality of your Personal Information. For example, Capital Fulfillment, Inc., is an unaffiliated third-party service provider that we use to fulfill requests for information and materials, and if you request that we send you materials, we will share your Personal Information with them or a successor. (3) We will disclose your Personal Information to government agencies, law enforcement officials, and others, in the limited circumstances where we believe, in good faith, that disclosure is required or permitted by law. For example, we will disclose your Personal Information in order to comply with a court order, to cooperate with governmental or industry regulators, or law enforcement authorities. Outside of the types of entities listed above, we will not share your Personal Information with third parties.

VI. UPDATES AND CORRECTIONS

Please contact us promptly if you identify any inaccuracy in your Personal Information or if you need to change your Personal Information for any reason.

VII.OPT-OUTS

At any time, you may request that we cease sending you information about us or other materials. Please contact us at:

Penn Square Real Estate Group, LLC,

442 Lincoln Avenue, Floor 2

P.O. Box 772947

Steamboat Springs, CO 80477-2947

VIII. SECURITY

We use industry-standard physical, electronic and procedural safeguards to guard information you provide to us via telephone, in writing, or through electronic media, such as the Internet. With respect to this Web site, we have implemented security measures designed to protect against the unauthorized access, loss, misuse or alteration of your Personal Information under our control. We always use industry-standard computer security products when transferring and receiving your Personal Information on or through our Web site. Please keep in mind, however, that while we believe these measures to be sufficient, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, we cannot guarantee that no unauthorized access to our servers will occur, and you transmit your Personal Information to us at your own risk. We cannot assume responsibility for uses or disclosures of your Personal Information that result from unauthorized or illegal access to our systems or those of our service providers.

We restrict access to your Personal Information to our employees and agents for business purposes only. All of these people are trained and required to safeguard your Personal Information. We have also instituted security measures in our physical facilities. Companies we hire to provide support services are not permitted to use your Personal Information for their purposes, and they are contractually obligated to maintain its confidentiality. If you are have registered as a Financial Professional, your Personal Information is protected by password. We recommend that you do not divulge your password to anyone else. Each Financial Professional will remain fully responsible for all usage of our Web site by any person using his or her password.

IX. CONTACT INFORMATION

Inquiries and requests relating to this privacy statement should be sent by email to info@pennsquare.com, or at the following mailing address:

Penn Square Real Estate Group, LLC,

442 Lincoln Avenue, Floor 2

P.O. Box 772947

Steamboat Springs, CO 80477-2947

X. POLICY CHANGES

From time to time we may modify our privacy statement. If we change our privacy statement to make a new or different use of your Personal Information, we will post a prominent notice on our Web site, or notify you by email. If you have any concerns about how your Personal Information is used, please contact us using the contact information above. We encourage you to check our Web site periodically to ensure that you are familiar with our current privacy statement.

XI. FEEDBACK

We welcome your feedback regarding this privacy statement or any other part info@pennsquare.com.