Discover lucrative real estate investment & service opportunities designed exclusively for Primior investors.

In the course of serving or otherwise interacting with our current, former, and prospective clients and other individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”), Primior may obtain personal information about such individuals. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use and otherwise process the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the terms “Primior,” “we,” “us,” and “our” refer to Primior Inc. and its affiliates. For purposes of this policy, “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information.

The Sources of Personal Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Primior during the course of your relationship with us. We may also collect information about your transactions and experiences with Primior relating to the services Primior provides. In addition, depending on the services you require, Primior may obtain additional information about you, such as your credit history, from consumer reporting agencies or other third parties, such as service providers, advisors (including, but not limited to, independent financial advisors), vendors, and publicly available sources, such as company websites. We may also collect personal information about individuals who visit our Website or otherwise communicate or engage with us and through the use of cookies on our Website. Additional information on how we use cookies on our Website is provided below, under the section entitled “Cookies.”

Finally, in the provision of financial services to you, and subject to compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., archived email monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Personal Information We Have about You

If you deal with Primior in your individual capacity (e.g., as a private client), as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):

• Your full name, date of birth, phone number, email address, organization, and other contact details;
• Extensive financial information, including the source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
• Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account;
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, Tax Identification Number, driver’s license number, state identification card, passport number, country identification number, etc.;
• Your precise geolocation;
• Details of business advisers you may employ, including, for example, wealth managers and independent financial advisers;
• Records of communications, including, for example, recordings of your attendance (or your representative’s attendance) at certain meetings/phone calls, and electronic communications with our staff and meeting notes (see below for more details);
• The contents of your mail, email, and text messages;
• Your biometric information, such as photos and images of your likeness;
• Details of any complaints made by you with respect to your dealings with the relevant service provider to the fund;
• Data received from due diligence activities (such as anti-money laundering, politically exposed persons, and sanctions checks); and/or
• Fraud inquiries (for example, information from police and other watchlist reports).

Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: (A) social security number, driver’s license number, state identification card, and passport number; (B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; (C) precise geolocation; and (D) your biometric information for the purpose of uniquely identifying you. This policy, and the practices described herein, applies equally to our collection, use, disclosure, and other processing of such “sensitive” personal information.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we endeavor to ensure that all information we hold about our clients is accurate, complete, and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.

We may also collect certain additional personal information through the use of cookies on our Website. Additional information on how we use cookies on our Website is provided below, under the section entitled “Cookies.”

Our Website is not intended for children, and we do not knowingly collect personal information relating to children (including any minors under the age of 16).

Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate, and manage your relationship and/or account with Primior. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, text, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Primior;
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;
• Fulfill our contractual obligations, including, but not limited to, any contractual obligations as the general partner(s) and/or the investment adviser to a fund in which you have subscribed;
• Operate our Website and our other IT systems and safeguard their security;
• Fulfill our contractual obligations to other third parties to whom you have provided your information; and
• Provide information to future purchasers or merger partners of all or a portion of Primior, or to provide information as may be necessary in connection with other corporate transactions, such as financings or restructurings.

If your relationship with Primior ends, Primior will continue to treat your personal information, to the extent we retain it, as described in this policy.

You may opt out of receiving promotional communications at any time by following the “unsubscribe” instructions found within Primior email updates or changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.

We may process some of your personal information, including “sensitive” personal information, for purposes of automated decision-making and profiling. For example, in connection with our entering into, or the performance of, our contracts with you, we may collect your investor preferences and use that information to profile you for specific assets based on your investment objectives, time horizon, risk tolerance, etc.

We do not use or otherwise process your “sensitive” personal information other than as described herein.

Disclosures of Your Personal Information within Primior

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Primior may be given, or given access to, your personal information. For example, one Primior entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management, and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Primior is provided below, under the section entitled “Information Security: How We Protect Your Privacy.”

Disclosures of Your Personal Information to Third Parties

Primior does not disclose your personal information to third parties, except as described in this policy. We may disclose your personal information as follows:

• To investment partners (e.g., deal sponsors), other financial institutions (e.g., lenders requiring such information pursuant to regulatory requirements), and/or nonaffiliated companies that perform support services for your account or facilitate your transactions with Primior, including those that provide professional, legal, or accounting advice to Primior. Each such third party is required to maintain the confidentiality of such information to the extent received and to use your personal information only in the course of providing the services, and only for the purposes, dictated by Primior;
• To fulfill your instructions;
• To protect our rights and interests and those of our business partners or pursuant to your express consent;
• If you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may be provided to such adviser(s);
• To future or potential purchasers or merger partners and on a need-to-know basis with current, future, or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings; and
• As permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

Data Retention

We will keep your personal information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy, information about which you can request by contacting us. When determining the relevant retention periods, we take into account a variety of factors, including, but not limited to, the following:

• our contractual and business relationships with you;
• legal obligations under applicable law to retain personal information for a certain period of time;
• statutes of limitation under applicable law;
• (potential) disputes; and
• guidelines issued by relevant supervisory authorities.

Information Security: How We Protect Your Privacy

Primior is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Primior employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to appropriate standards of privacy. We also maintain physical, electronic, and procedural safeguards designed to protect the information against loss, misuse, damage, or modification and unauthorized access or disclosure.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this Website:

Users of primior.com are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.

Primior.com is built upon an infrastructure designed with multiple layers of protection. For example, Primior uses industry standard encryption technologies designed to protect your personal information from external compromise.

Security is a cooperative effort between Primior and the users of primior.com. Please remember that your login and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.

Additional information on how we use cookies on our Website is provided below, under the section entitled “Cookies.”

Primior may make available on this Website third-party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.

Our Websites are not currently configured to respond to “do not track” signals or similar mechanisms.

Cross-Border Data Transfers

The recipients of your personal information pursuant to this policy may be located in the United States or elsewhere, and certain of such recipients’ respective countries may have different data privacy laws and protections than your home country. We may transfer your personal information outside of your home country, including to our affiliates in other countries, for the purposes set out in this policy. Any transfer of your personal information to recipients in a third country will be made subject to appropriate safeguards or applicable derogations provided for under applicable law. Further information on such safeguards or derogations can be obtained by contacting us using the contact information below.

Information For EEA (EU plus Iceland, Norway and Liechtenstein) and UK Residents

What Rights Do I Have?

Under the EU’s General Data Protection Regulation “GDPR” and the UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), individuals located in the European Economic Area (“EEA”) or the UK, as applicable, have certain additional rights with respect to their personal data. For purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable. For the purposes of applicable data privacy legislation, Primior is a “controller” of such individuals’ personal data.

• Under certain conditions, you may have the right to:
• Access and obtain a copy of your personal data;
• Request correction of your personal data if it is incorrect or incomplete;
• Request restriction of the processing of your personal data;
• Object to the processing of your personal data;
• Request erasure or deletion of your personal data; and
• Request the transfer of your personal data to another party in a machine-readable, commonly used, and structured format.

Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, Primior may process and retain personal data pursuant to a legal obligation or another legitimate interest under the GDPR or UK GDPR, to protect your vital interests, the interests of Primior, or those of another person, or where necessary for the performance of a contract with you for provision of our services. If we have obtained your consent, then you may withdraw it at any time by contacting us.

These rights are not absolute and each is subject to certain exceptions or qualifications.

How May I Exercise My Individual Rights?

Residents of the EEA or UK may contact our Data Protection Officer with questions or requests regarding their personal data using the contact information below. Please note that Primior may request additional information from you to verify your identity before we disclose any personal or account information.

Who Can I Contact at Primior Regarding Data Protection Issues?

Primior has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him/her by emailing support@primior.com and addressing your questions or concerns to the Data Protection Officer. If you are not satisfied with any response that we have provided, or if you otherwise wish to raise a concern or issue about our data processing practices, you may contact your local data protection authority. For example, in the UK, you should contact the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

Information For California Residents

What Rights Do I Have?

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), residents of the state of California have certain rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given to such term under the CCPA. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold, or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022), and/or the California Financial Information Privacy Act. Under the CCPA, you may have the right to:

Request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling, or disclosing such personal information;

• Choose to opt out of the sale of your personal information. As noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising;
• Request that we delete the personal information we have collected about you; and
• Request that we correct any inaccurate personal information we have collected about you.
• We will not discriminate against any California resident who exercises the rights set forth in this section.

These rights are not absolute and each is subject to certain exceptions or qualifications.

How May I Exercise My Individual Rights?

You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, you may contact us using the contact information below. Please note that Primior may request additional information from you to verify your identity before we disclose any personal or account information.

For consumers with disabilities who need to access this policy in an alternative format, please contact us using the contact information below.

Other Privacy Policies or Statements; Changes to Policy; Contact

This policy provides a general statement of the ways in which Primior processes and protects your personal information. You may, however, in connection with specific products or services offered by Primior, be provided with privacy policies or statements that supplement this policy. In the event of a conflict between the terms of this policy and such supplemental privacy policies or statements, such supplemental privacy policies or statements will govern in relation to your use of such products or services. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Website. This version of the policy is effective March 1, 2023. If you require further information regarding our privacy policies and practices, please contact exclusive@primior.com.

Cookies

Statement on Cookies

By using our Website with your browser settings adjusted to accept cookies, you consent to Primior’s use of cookies and other tools to provide the products and services available on our Website. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below. Remember, though, without cookies, you may not be able to take full advantage of all of our Website features.

Cookies at Primior and How We Use Them

Cookies are small text files that may be placed on your Web browser when you visit our Website or when you view advertisements we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. Primior does not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.

Cookies are used primarily for administrative purposes to improve your experience with our Website. Examples of this include the use of cookies:

• To improve our Website security by “authenticating” you (i.e., verify that you are who you say you are) when you sign-in to our Website.
• To keep track of your specified preferences such as language, time zone, and timeouts after periods of inactivity.
• To allow you to navigate our Websites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services.

In addition to administrative uses, Primior may also use cookies in one or more of the following ways:

• To conduct research and analytics to improve our Website and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Website, the pages visited, and the length of each visit.
• To display Primior advertisements when you visit websites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other websites and provide us with de-identified information about you (such as demographic information or the names of websites where you have been shown ads) which we may use to provide you with more relevant and useful advertising.

We may use cookie technology to collect certain aggregate and non-personal information when you visit our Website. “Clickstream” data (e.g., information regarding which of our Website pages you access, the frequency of such access, and your product and service preferences) may be collected by Primior itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Website or when you view an advertisement we have placed on another Website. Clickstream data and similar information may be shared internally within Primior and used for administrative purposes, to assess the usage, value, and performance of our online products and services, to improve your experience with our Website, and as otherwise permitted by applicable law or regulation. If you are a Primior client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.

Managing Cookies

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Website of its manufacturer. Some of our Website pages employ “functionality cookies” that help the Website remember your settings and preferences for use when you visit the Website in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those Website pages using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that if you decline to use cookies, you may experience reduced functionality and, for websites using authentication-related cookies, declining cookies will prevent you from using the website altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit allaboutcookies.org.