Privacy Policy

Rev. February 10, 2022

This Privacy Policy describes the types of information Net Lease Capital Advisors LLC, NLC Online Services LLC, and/or their affiliates, subsidiaries and agents (collectively, “Net Lease,” “We,” or “our”) collect from and about you when you visit this site, services.netleasecapital.com (“Site”), and in connection with our provision of services to you. The Site and the connected services are collectively referred to as the “Service” or “Services.” This Privacy Policy also explains how Net Lease may use and disclose such information, as well as your ability to control certain uses of it.

By using the Site, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy, and agree to the Net Lease Terms of Use which are incorporated by reference. If you do not agree, please do not access or use the Site.

1. WHO WE ARE & GLBA PRIVACY INFORMATION

Net Lease provides this Privacy Notice pursuant to the Gramm-Leach-Bliley Act, Public Law No. 106-102, and Regulation P, 12 C.F.R. Part 1016 to inform you of our policies with respect to your personal information. Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

In order to provide services to you, we must collect and maintain certain non-public information about you. This information includes:

Personal information that you provide in connection with opening your account, the Investor Questionnaire, and related to your accounts (such as name, address, tax identification number);
Information about your transactions and investments with us;
Information collected on this Site.

We may disclose this information to any regulatory authority having jurisdiction over us or any of our funds, in connection with any litigation or other dispute, or otherwise as necessary or appropriate to provide services to you or enforce the terms of our agreements with you. Additionally, we collect and may disclose this information to our affiliates and service providers on a “need to know” basis, including information related to your participation in certain investments and related balance and transaction information.

We do not disclose information to affiliates or nonaffiliated third parties for marketing purposes.

We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to us.

If you have any questions about this notice or our privacy policies, please contact us at services@netleasecapital.com

2. INFORMATION WE COLLECT

There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly (i.e. your name) or indirectly (i.e. information about your online use).

· Information You Provide

Net Lease collects information from you when you choose to share it with us. This may include when you use our Site, register or create an online account with or through the Site, use the Services, request information from us, sign up for an email list, request customer support, or otherwise communicate with or contact us. The information we collect may include your name, address, email address, tax identification number.

You may also provide us with certain information in connection with specific transactions:

Information You Provide When You Make an Investment. If you make an investment or enter into a transaction with us, we collect bank account information along with your address, and any other information that is necessary to provide you with the Services.

· Information Automatically Collected

Whenever you visit or interact with the Services, we may use cookies, web beacons, pixel tags, log files, or other technologies to automatically or passively collect information about your online activity.
Please note that we automatically collect the following information about you:
Computer or Device: We may automatically collect your IP address or other unique identifier or information from the computer, mobile device, tablet, or other device you use to access the Services, including the browser type, device type, operating system, software version, hardware model, mobile network information, and the domain name from which you accessed the Services.
Usage of Service: We also may collect information about your use of the Service, including the date and time you visit the Service, the areas or pages of the Service that you visit, the amount of time you spend viewing or using the Service, the number of times you return to the Service, other click-stream or site usage data, emails that you open, forward or click-through to our Service, and other sites that you may visit. The data may be used to help diagnose problems with our servers, analyze trends, track users’ web page, email and mobile application movements/activities, and help identify or gather broad demographic information for aggregate use.
Third Party Service Providers: We may use third party service providers to support our Service. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information.
Third Party Analytic Technologies: We may use third parties’ analytics and tracking tools to better understand who is using the Service, how people are using the Service, and how to improve the effectiveness of the Services and related content. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, HTML5 cookies, or other technologies to automatically collect and store certain information. They may also combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

3. INFORMATION USE

We may use the information we collect from and about you for a variety of business purposes; in general, to provide the Services, improve customer experience and engagement, and develop the Services. We are committed to protecting and maintaining the privacy of your information. Therefore, we will process your data only in accordance with applicable data protection law and this Privacy Policy.

We may use the information we collect from and about you for any of the following purposes:
To respond to your inquiries, fulfill Services, and contact and communicate with you when necessary;
To enhance your online experience, including as a way to recognize you and welcome you to the Service;
To review the usage and operations of our Service, develop new products or services, and conduct analysis to enhance or improve our content, products, and services;
To contact you with information, newsletters and promotional materials from Net Lease or on behalf of our partners and affiliates;
To use your data in an aggregated non-specific format for analytical and demographic purposes;
To address problems with the Service or our business, and to protect the security or integrity of the Service and our business;
To use and disclose your bank information only to use the Services and prevent fraud; and
For other purposes disclosed at the time you provide your information or otherwise with your consent.

Additionally, if you use the Service to connect with third party services, you authorize us to use information from and about you, on your behalf, to interact with these third-party services based on your requests.

4. INFORMATION WE SHARE

We may share the information we collect from and about you as described below.

We may share your personal information with:

Our Affiliates: We may share your information with Net Lease affiliates and subsidiaries for business and operational purposes.
Third Party Service Providers: We may share your information with third party service providers that provide business, professional or technical support functions for us, help us operate our business and the Service, or administer activities on our behalf.
Co-Branded Relationships: Certain areas of our Service may be provided to you in association with third parties. We may share information with these third parties if you participate in a co-branded, co-sponsored, or jointly presented promotion, contest, survey, voting feature, or service.
Legal Obligations; Safety: We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Service, servers, network systems, and databases. We also may disclose your information as necessary, if we believe that there has been a violation of our Terms of Use, any other legal document or contract related to our Services, or the rights of any third party.
Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through this Service in a manner that is consistent with this Privacy Policy.
Other: We also may share your information as disclosed to you at the time of collection.

5. HOW LONG YOUR INFORMATION IS RETAINED

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6. YOUR RIGHTS

We respect your privacy rights and provide you with reasonable access and rights to the Personal Data that you may have provided through your use of the Services.

You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

Cookies, Tracking Options and California Do Not Track Disclosures

For California Residents: Certain parts of our Services require cookies. You are free to adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Service or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

Our system may not respond to Do Not Track requests or headers from some or all Internet browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

7. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS

The Service may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

8. CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not direct the Service to, nor do we knowingly collect any personal information from, children under the age of sixteen. If we learn that a minor has provided personal information through the Services, we will use reasonable efforts to remove such information from our files.

9. DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Service visitors. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

10. REVISIONS TO THIS PRIVACY POLICY

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) on the Service. Your continued use of the Service following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.

11. HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at services@netleasecapital.com or by mail to:

NLC Online Services LLC
c/o Net Lease Capital Advisors LLC
10 Tara Boulevard, Suite 501
Nashua, NH 03062
Attention: Investor Services