Zeller Realty Group

Investor Portal Privacy Policy

Last Revised: February 19, 2020

Zeller Realty Group (collectively with its affiliates, subsidiaries, related entities and other companies managed by any of the foregoing (“Zeller,” “the Company,” “we,” “us,” and “our”), respects your privacy and is committed to protecting your privacy through our compliance with this Investor Portal Privacy Policy (the “Policy”).

The Investor Portal Privacy Policy and Investor Portal Terms of Use are available online.

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website portal available at:

Zeller Realty – Investor Portal (the “Portal”). 
 

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our Portal.  By using our Portal, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our Portal after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

The information contained in the Portal, including all photographs, documents, and financial reports, should be treated with extreme confidentiality (see below, “Confidentiality of Zeller Information”), and in accordance with the Investor Portal Terms of Use, into which this Policy is incorporated by reference.

What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy. 

Information You Provide to Us

Personal Information is any information that can be used to individually identify you from a larger group, such as data including, but not limited to, your:

• first and last name
• email address
• telephone number
• age
• mailing address
• social security number
• tax identification number
• documents that you upload to the Portal
• comments or messages provided in free text boxes

You may provide us Personal Information when you: 

• request information
• upload documents into the Portal
• share messages with users of the Portal
• subscribe to our emails
• register yourself with the Portal.

 

The information that you provide in each case will vary. In addition, you may submit information that could be considered sensitive, such as information relating taxes and investments.  In some cases, we may ask you to create a username and password that should only be known to you.
 

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Portal.  We collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), when you registered for or last logged onto the Portal, the pages and documents you have viewed, and the actions you have taken while using the Portal.  Some of the tools we use to automatically collect information about you may include:

1. Cookies.  A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use both of them: 
   
   (1) session cookies, which do not stay on your device after you close your browser, and
   
   (2) persistent cookies, which remain on your device until you delete them or they expire. 
   
   Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Portal’s features or lose access to some functionality.

 

2. Analytics.  The Portal may send aggregated, non-Personal Information to third party analytics companies for the purpose of providing us with the ability to conduct technical and statistical analysis on the Portal’s performance.

 

3. Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy. 

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it. 

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen.  We do not target the Portal to minors, and would not expect them to be engaging with our Portal or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Assisting you with items such as personalized experiences, facilitation of product usage, and enforcement of Terms of Use.  
• Preventing malicious activity and providing you with a secure experience. 
• Providing service and support for services you request.
• Providing marketing communications that are effective and optimized for you.
• Keeping you up-to-date with the latest benefits available from us.
• Preventing unwanted messages or content.
• Measuring the performance of our marketing programs.
• Contacting you about services and offers that are relevant to you.

How We Share Your Information

We do not sell or lease your information to any third party.  We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us.  In addition, we employ companies and individuals to perform bookkeeping, financial reporting of investments, and operations of the Portal.  They have access to both Personal Information and non-Personal Information needed to perform their functions, but may not use your information for other purposes.  If you do not wish for these parties to collect your Personal Information from the Portal, you may opt-out by canceling your account.  Please contact (312) 229-8838 if you wish assistance in cancelling your account. 

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances: 

• Responding to duly authorized information requests from law enforcement or other governmental authorities.
• Complying with any law, regulations, subpoena, or court order.
• Investigating and helping prevent security threats, fraud, or other malicious activity.
• Enforcing or protecting the rights and properties of Zeller or its subsidiaries.
• Protecting the rights or personal safety of Zeller’s employees.

There are circumstances where Zeller may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, Zeller will ensure your information is used in accordance with this Policy.

Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our Portal may link to third-party websites and services, but these links are not endorsements of these sites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or site and providing any information. 

Confidentiality of Zeller Information

All information relating to Zeller that you obtain through the Portal (“Zeller Information”), including but not limited to its financial performance, earnings, and losses, is confidential.  You will not disclose any of Zeller Information except to your legal, tax, and investment advisors who are otherwise under an obligation of confidentiality.  You will not use Zeller Information for purposes other than those necessary to further your interests as a Zeller investor.  Zeller Information is not confidential to the extent, but only to the extent, that you can establish that such information is generally known or available to the public without any breach of an obligation to Zeller. Either party may disclose the terms of this Policy or the Investor Portal Terms of Use to any of its advisors, potential successors, or potential purchasers of its business or of its stock not intended for issuance to the public, if the recipient is under an obligation of confidentiality.

For Portal Visitors Outside of the United States

Our Portal is designed for use by individuals in the United States only.  We do not warrant or represent this Policy or the Portal’s use of your Personal Information complies with the laws of any other jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy. 

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  For example, we employ strong password capabilities, Secure Socket Layers, and Terminal Layer Security to help protect your Personal Information. Accordingly, when you upload and download documents containing sensitive information, you will do so using an encrypted connection. We likewise prohibit you from sending sensitive information, such as information relating to taxes and investments, via email outside the Portal.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. We will disable Portal accounts after a pre-determined number of failed log-in attempts, or other suspicious activity. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.   

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at [email protected] or by phone (312) 229-8838 to speak with Maria Lesnicki, Asset Management Associate.