Trammell Crow Residential (collectively “we,” “us,” or “our”) is committed to keeping the personal data collected from individuals confidential and secure. The proper handling of such personal data is a high priority. Please read this policy carefully to understand how we collect, use, share, and protect your personal data. In this policy, “you” and “your” refers to the individual to whom such personal data relates.

Data We Collect

We collect personal data about you (such as your name, address, email address, phone number, tax identification number, bank account information) that you voluntarily provide us in our discussions with you and from other documents and information you may deliver to us. Your submission of personal data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide the necessary personal data.

If you visit our website, we may also collect other technical data, including information about your device and usage such as your operating system, browser, geographical location, IP address, and page views and clicks. Our website may use cookies to obtain certain types of data when you visit our website. Cookies are files that we transfer to your computer’s hard drive through your web browser to enable our system to recognize your browser, to provide various types of functionality, to better understand how you interact with our website, to monitor aggregate usage, and to optimize web traffic routing on our website. You can typically adjust browser settings to accept or reject cookies automatically or ask you for permission before cookies are placed. Certain areas or features of the website may not be available or fully-functional if you choose to disable cookies. We use Google Analytics to provide insight on our website visitors. To learn about Google Analytics, click here. You can opt out of Google Analytics by installing Google’s browser opt out add-on available here. Our website does not respond to browser “do not track” settings at this time.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate entity (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Use of Personal Data

The legal basis for our processing of your personal data generally includes one of the following: (a) you have consented to our processing of your personal data; (b) processing is needed to fulfill a request made by you; (c) processing is required to comply with a legal or regulatory obligation; or (d) processing is necessary for reasons that are in our legitimate interest as a company, such as to protect our business. For example, we may use personal data:

• for the purposes for which you provided it to us;
• to improve, maintain, and operate our offerings;
• to respond to your inquiries and communications to us;
• to fulfill our obligations and enforce our rights arising under our customer contracts;
• to market to you about products and services in which you may be interested, unless you have opted out of our marketing messages;
• in any other way that we may describe when you provide the information; and
• for any other purpose with your consent.

Sharing of Personal Data

We do not sell your personal data to any third parties for monetary consideration. We may share your personal data as needed to fulfill the purposes described in the “Use of Personal Data” section above, including:

• to our subsidiaries and affiliates, including for their marketing purposes unless you have opted out of such sharing;
• with nonaffiliated persons and entities that perform services for us, such as attorneys, brokers, administrators, accountants, auditors and custodians;

• to third party companies or individuals that contract with us to perform servicing functions such as record-keeping, accounting, management, administrative services and computer-related services;
• as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements;
• for any other purpose disclosed by us when you provide the information; and
• as requested or approved by you (including to your advisors, which can include, among others, accountants, investment advisors, and/or attorneys).

Companies we hire to provide services are not authorized to use your personal data for their own purposes and are obligated to maintain confidentiality of such data. We do not provide your personal data to mailing list vendors or solicitors for any purpose.

In the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets which would generally be transferred is the data we have collected. We will advise a successor or successors in interest of the terms of this policy and our expectation that the successor(s) in interest will comply with the terms hereof.

We may also disclose your personal data to comply with any court order, law, or legal, process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements (including any agreement for the your investment into any of our funds); and if we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers, or others.

Opt Out Options

Natural persons may opt out of our disclosure of your personal data for the following purposes:

• internal marketing efforts (regarding our offerings); or
• external marketing efforts (regarding our affiliates’ offerings);

To opt out, please contact us in writing or by email as set out at the end of this policy. Please be specific about which of the above purposes you wish to opt out from, so we can efficiently process your request.

Employee Access to Data

We have implemented policies and procedures designed to restrict access to nonpublic personal data to those employees with a legitimate business reason to have access to such personal data. These employees are educated on the importance of maintaining the confidentiality and security of this data and are required to abide by our data handling practices.

Protection of Data

We maintain commercially reasonable administrative, physical, and technical security standards designed to protect your personal data, whether written, spoken or electronic. The safety and security of your information also depends on you. Where you have been provided a password for access to our website or your account, you are responsible for keeping this password confidential. We ask you not to share your password with anybody. We urge you to be careful about giving out sensitive or confidential information through email, as email may not provide a means for complete security and private communications between us and yourself. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us, including to our website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any private settings or security measures we deploy.

Data Retention

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

Children

Our website and services are not directed toward children under 16, and no one under the age of 16 may provide any information to us, including on the website. We do not knowingly collect personal data directly from children under 16. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us as set forth at the end of this policy and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable legally required or permitted retention standards.

Your California Privacy Rights

California law entitles California residents to certain additional protections regarding personal information. For purposes of this section alone, “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:

• information regarding your personal information we have collected in the past 12 months (including the categories of personal information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
• notice of whether we have disclosed your personal information to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
• a copy of your personal information collected by us in the past 12 months; and
• that your personal information be deleted.

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

Revisions to this Policy

We recognize and respect the privacy concerns of individuals. We are committed to safeguarding this data. As a member of the financial services industry, we are providing you this policy for informational purposes and will update and distribute it as required by law. It is also available to you upon request. We may revise this policy from time to time. If we make a material change to this policy, we will post the updated version (with the date of change(s) noted in the policy) on our website and other places we may deem appropriate, and/or notify you by mail or email, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.

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If you have any questions about our privacy policy, please contact us as set forth below, because your privacy and the confidentiality of your data are very important to us.

Email:   privacy@tcr.com

Mail:    Attn: TCR Privacy Team, 3819 Maple Avenue, Dallas, TX 75219

Phone: 214-661-8119 (toll-free)

Last Updated: September 1, 2020