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Thank you for visiting the site of Banner Real Estate Group and/or its affiliate(s) (“Banner,” “we,” “us” or “our”), an industry leading, fully integrated real estate operating company. We value our clients and investors and protecting the privacy of your information is important to us. This Privacy Policy (the “Policy”) details how we handle personal and other information gathered, submitted or maintained by Banner as a result of visits to our site, via any promotions that Banner may conduct, through our relationships with clients and investors generally, and from any of our third-party partners. It also describes our disclosure policies, as well as the choices that you have regarding use, access and correction of your information. If you do not agree with the practices described in this Policy, you should not use our site or otherwise interact with Banner Real Estate Group.


We may periodically update this Policy, and any changes will be reflected here. If the changes are significant we may provide a more prominent notice, and at our discretion may email you directly with information on the same.


How We Collect Information


If you are an investor we collect personally identifiable information which you choose to directly submit to us via our subscription agreement(s) or through the investor portal. The personally identifiable information that we collect about you may include, but is not limited to, your name, postal address, e-mail address, phone number, taxpayer identification number, and similar. From time to time we also collect certain information that may be considered personally identifiable information, such as the IP address of your computer or network connection.


We also automatically collect non-personally identifiable information such as the time and date of your visit, your location, the pages and other content that you access, and the number of times you return to the website. Collecting usage information such as that described above is done via tracking technologies, including:


Cookies and Log Files: Banner uses cookies and web log files to track usage of our website. A cookie is a small data file which resides on your computer, and which allows us to recognize you as a user when you return using the same computer or web browser. Cookie data is used to customize your experience when you use our website and purchase our products. You can configure your internet browser to warn you each time a cookie is being sent or to refuse cookies completely. However, if you opt not to accept cookies from our site, you will not be able to take full advantage of all the features on our website.


In addition, we may integrate into the website technology provided by third parties (e.g., Google Analytics) to accomplish similar information collection. We may also use a variety of other technologies that collect similar information for security and fraud detection purposes.  


How We Use Information


We use the collected information to provide pertinent information to our investors. Your information is used to respond to inquiries, provide customer service, send administrative information, and to personalize your experiences. We may use your information to contact you in the future to tell you about new products, promotions, opportunities, or other general information about Banner or our offerings that we believe will be of interest to you.


In addition, we use the information that we collect to improve our site and to learn about how it is used and accessed and to analyze user behavior as a measure of interest in and use of the website. We may disclose such analyses to advertisers or other third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user. We may also use the information to investigate and prosecute potential breaches of the Banner security agreements. 


Information collected from site submissions will be used for Banner’s internal business purposes. We may share pertinent personal information with select affiliates and partners for the purposes of processing data to provide certain financial services, as well as for research, analytics, customer support and account management. We may also disclose information about you to third parties to protect the rights, property or safety of Banner or our employees, or the rights, property or safety of others.


To the extent, if any, that you share payment processing information with Banner, we will only use that information in accordance with your instructions and with your explicit consent. If you contact us by email, you should be aware that email transmissions might not be secure. Information you send by email could be viewed in transit by a third party. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.


Other Disclosures of Information


We do not sell, trade, share or rent any of your information to unaffiliated third parties.


We will not disclose your information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant and in response to a valid, compulsory legal process, or as otherwise required by law.


In the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion of our assets, we may disclose information about you to the acquiring party(s). The successor organization’s use and disclosure of your personally identifiable information will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personally identifiable information will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use the website). If you submit personally identifiable information after such a transfer, that information may be subject to the successor entity’s policy.


Information Security


Banner takes commercially reasonable security and backup measures to protect the information submitted to us. However, no method of transmission over the Internet or method of electronic storage and security is 100% secure. Therefore, while we strive to protect your information we cannot guarantee its absolute security. We encourage all our customers and partners to retain copies of all uploaded information on their own systems.


Children’s Privacy


The website is not directed to children under the age of 13 and we do not knowingly collect any personal information from children under the age of 13 without parental consent. If we learn that a child under the age of 13 has provided us with personal information, or that such personal information has otherwise been inadvertently collected, we will delete it in accordance with applicable law.  


California Privacy


California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. Banner does not share your personal information with third parties for their own direct marketing purposes.


Updating or Amending Your Information


You may update, amend or otherwise change certain information that Banner retains about you at any time by logging into your account on the Banner investor portal or by contacting the Banner support team.


Consent to Transfer


Banner is operated in the United States. If you are located outside of the United States then please be aware that information we collect will be transferred to and processed in the United States. By using our website, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.


Changes to this Privacy Policy


Banner may update this Policy at any time and any changes will be effective on posting. In the event that there are material changes to the way that we treat personal information, we will display a notice on the website. Continued use of our website or services after any update shall constitute your agreement to the new policy.


Questions or Comments


If you have any questions or comments about this Privacy Policy, the practices, or use of the site, please feel free to contact us by email at slevine@bannerreg.com, or by mail at the following address: 500 Skokie Boulevard, Suite 600, Northbrook, IL, 60062 Attn: Data Privacy.


Last Update


This Policy was last updated August 5, 2019.