Privacy Policy

WEBSITE PRIVACY POLICY

Date modified: April 11, 2022

Introduction

 

This Privacy Policy explains how TA Realty LLC and its affiliates and subsidiaries (“TA Realty”, “we”, “our”) collects, uses, shares, and protects personal information in connection with our website (the “Site”) and investor portal (collectively, our “Service”).

1. PERSONAL INFORMATION WE COLLECT

From Website Visitors

• Information from cookies and other automated technologies, such as information about the devices you use to engage with our Site, and online activity data. For more details about the technologies we use, the categories of information we collect, and how we use this information, please review our Cookie Policy below; and
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

From Investor Portal Users

• Contact and account information, such as your first name last name, e-mail address, and account credentials;
• Diligence documentation and investor reports, such as company policies and procedures, internal reports, strategy documents, legal documentation, subscription and side letter documents, capital call notices, distribution notices, quarterly investor statements, financial statements, and other reports or documentation concerning your investment(s) or potential investment(s); and
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.

2. WHY AND HOW WE PROCESS PERSONAL INFORMATION

We use the personal information of Website Visitors to:

• Provide support and maintenance for the Site
• Analyze, and improve our Site;
• Ensure compliance with local legal and regulatory requirements;
• Enforce the terms and conditions of our Site; and
• To respond to your requests, questions, and feedback.

We use the personal information of Investor Portal Users to:

• Enable us to carry out our obligations arising from any contracts and to provide you with the information and services that you request from us;
• Comply with our legal obligations;
• Comply with our standards, terms and conditions, policies and procedures;
• Respond to any complaints or inquiries you raise about our Service;
• Communicate with you about our Service, including by sending updates, security alerts and support and administrative messages;
• Protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes; and
• Provide you with the relevant financial information and reports in relation to your account and/or your investment in one of our funds (e.g. annual audited financial statements of the fund, intermediary unaudited financial statements of the fund, other reports, factsheets, etc.).

Research and development. We may aggregate personal information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

3. WHO AND HOW WE SHARE YOUR PERSONAL INFORMATION

In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:

• Affiliates. We may share your personal information with our subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Vendors and Service Providers: To assist us in meeting business operations needs and/or to perform certain services and functions, we may share personal information with service providers, including hosting, cloud services and other information technology services providers and web analytics services. Pursuant to our instructions, these parties may access, process or store personal information in the course of performing their duties to us.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal or regulatory obligations, including to respond to lawful requests from public authorities and to meet national security or law enforcement requirements, applicable anti-money laundering legislation, and under applicable investment fund and company legislation, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability.

4. YOUR RIGHTS

Data subject rights. Depending on your location, you could be entitled to assert the following rights concerning your personal information:

• Access. Request that we provide the individual with information about our processing of the individual’s personal information and give the individual access to their personal information.
• Deletion. Request that we delete the personal information that we maintain about the individual.
• Correction. Request that we update or correct inaccuracies in the individual’s personal information.
• Transfer. Request that we transfer a machine-readable copy of the individual’s personal information to the individual or a third party the individual designates.
• Restriction. Request that we restrict the processing (including sharing) of the individual’s personal information, including the sharing of the information with our customers.
• Objection. Object to our reliance on our legitimate interests as the basis of our processing of the individual’s personal information that impacts their rights.

To exercise these rights, please contact us at compliance@tarealty.com. We reserve the right to confirm the identity of the individual making a request before we respond to the request to assess whether these rights apply to you. Additionally, applicable law can limit these rights, for example, by prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline a request, we will explain why we took that action, subject to legal restrictions.

5. STORING YOUR PERSONAL INFORMATION

We might share and transfer your personal information to other entities in our group, and to third party service providers based in the U.S., the Cayman Islands and Luxembourg.

If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

6. SECURITY OF YOUR PERSONAL INFORMATION

We will take reasonable steps (including appropriate technical and organizational measures) to protect the confidentiality, integrity and availability of your personal information. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.

7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We do not keep your personal information for longer than is necessary for the purposes for which they are processed by us.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, we have legal duties in our capacity as a Registered Investment Advisor that may apply to our keeping of your personal information.

8. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by us. The information that you share with on these sites will be governed by their own specific privacy policies and terms of service and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites.

9. CHILDREN

Our Service is not directed to children who are under the age of 16. We do not knowingly collect personal information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal information through the Service please contact us and we will endeavor to delete that information from our databases.

10. AMENDMENTS TO THIS PRIVACY POLICY

The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

11. NOTICE TO EU, UK AND SWISS RESIDENTS

EU and UK Representatives.

We have appointed a representative in the EU and the UK.

In the EU, please contact our representative at:

DP-Dock GmbH
Ballindamm 39
20095 Hamburg, Germany
E-Mail: tarealty@gdpr-rep.com

In the UK, please contact our representative at:

DP Data Protection Services UK Ltd.
16 Great Queen Street Covent Garden,
London, WC2B 5AH, United Kingdom
E-Mail: tarealty@gdpr-rep.com

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you can contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Controller. TA Realty LLC is the controller of the personal information we collect.

Legal Bases for Processing.

The Why and How We Process Information section above sets out our data processing purposes. We will only use your personal information as described in that section if we have a valid legal ground for the processing, including:

Consent. This is the case where you have consented to the use of your personal information.

Contract. We need your personal information to provide you with our Service in order to perform our end of our contracts with you, such as to create and secure your account, or to respond to your inquiries.

Legitimate Interest. We have a legitimate business interest in processing your personal information to provide our Service to our customers. We only rely on legitimate interest as a legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms and we ensure we comply with any request you make to exercise your rights.

Legal Obligation. We may have a legal obligation to process your personal information and we may process your personal information when necessary to establish, exercise, or defend legal claims. We may also process your personal information when necessary to protect your or another individual’s vital interests.

12. HOW TO CONTACT US

You may contact us at:

E-mail: compliance@tarealty.com

Postal mail:
TA Realty LLC
One Federal Street, 17th Floor
Boston, MA, 02110

13. COOKIE POLICY

This Cookie Policy explains how TA Realty uses cookies and similar technologies in connection with our Services.

What are cookies and similar technologies?

• Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, and enabling functionality.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How do we use cookies and other similar technologies?

We and our service providers automatically log information about individual’s interactions with our services and communications, such as:

• Device information, such as computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.

This Cookie Policy refers to all these technologies collectively as “cookies.”

What types of cookies and similar technologies does TA Realty use?

We use the following categories of cookies:

Purpose	Description
Necessary	Necessary cookies help make the Site usable by enabling basic functions like page navigation and access to secure areas of the Site. The Site cannot function properly without these cookies.
Preferences	Preference cookies enable the Site to remember information that changes the way the Site behaves or looks, like your preferred language or the region that you are in.
Statistics	Statistic cookies help the Site owners to understand how visitors interact with the Site by collecting and reporting information anonymously.

How can you control the use of cookies?

Other than “necessary cookies,” which are required to allow our Service to operate, you can control our use of cookies through our Cookie Settings.

Additionally, we work with Google Analytics, which uses first-party cookies to track user interactions. In our case, we use these cookies to collect information about how users use our Service. We use this information to compile reports, which disclose trends without identifying individual visitors, and help us improve our Service. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of our use of cookies by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

You can also limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser:
  • o Firefox; Chrome; Microsoft Edge; Safari
• Using privacy plug-ins or browsers. You can block our website from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track.

Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.