About this Policy

Investors

In connection with the formation and ongoing activities of an offering, we may also collect and maintain the following personal information about our investors:

• Identifiers (date of birth, tax identification number/social security number);
• Other information (financial account information, copy of government issued identification);
• Commercial information (products or services purchased);
• Professional and employment information; and
• Inferences drawn from any of the foregoing information.

Tenants

In connection with the leasing or licensing of space in our properties, we may also collect and maintain the following personal information about prospective and current tenants:

• Identifiers (date of birth, tax identification number/social security number);
• Other information (financial account information, copy of government issued identification);
• Commercial information (lease or license information, car details for parking registration);
• Geolocation data (physical location and movements based on access badge usage records);
• Electronic, visual or similar information (including security cameras at the property); and
• Inferences drawn from any of the foregoing information.

Vendors

• In connection with engaging third parties to perform services or provide goods at our properties or for our company, we may also collect and maintain the following personal information about our vendors:Identifiers (tax identification number/social security number);
• Other information (financial account information, copy of government issued identification);
• Commercial information (products or services purchased, car details for parking registration);
• Geolocation data (physical location and movements based on access badge usage records);
• Professional and employment information; and
• Inferences drawn from any of the foregoing information.

Customers/Guests at our Properties

We may also collect and maintain the following personal information about our customers and guests at our properties:

• Other identifiers (copy of photo identification);
• Commercial information (including records of personal property, such as information on your vehicle for onsite parking at our properties);
• Geolocation data (including your physical location or movements, such as those shown by mobile location analytics which capture and analyze signals from mobile devices);
• Electronic, visual, or similar information (including security recordings at our properties); and
• Inferences drawn from any of the foregoing information;

Visitors/Guests Online

We may also collect and maintain the following personal information about visitors and guests on our online Services:

• Age range, gender, and interests if linking social media accounts;
• Your organization/company, title, and website address;
• Aggregated, statistical and summary information of the general behavior and characteristics of users visiting or participating in our online Services;
• Other information as noted in the privacy notice specific to that service; and
• Inferences drawn from any of the foregoing information.

Purpose

We and our affiliates and nonaffiliated third parties collect and process such personal information in connection with the following:

• Providing you with the Services;
• Responding to your inquiries or fulfilling requests for us to contact you;
• Acting in compliance with our legal obligations, rights, and interests;
• Sending marketing or promotional communications relating to our business, products or services to you;
• Preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws, as well as regulatory requirements; and
• Certain other purposes, depending on the specific product or service you have requested from us and/or the nature of your interaction with us, as further detailed below.

Investors

We may also collect and process personal information of our investors in connection with:

• The acceptance of your subscription for shares/interests;
• The issuance of the shares/interests to you;
• The processing and management of the shares/interests, including processing payments and distributions, accounting, auditing, reporting to you, as well as reporting to third party service providers and appropriate government entities, including tax authorities and other governmental and regulatory agencies; and
• Acting in compliance with the terms of the applicable offering circular or private placement memorandum, including with respect to anti-money laundering, sanctions checks and suitability.

Tenants

We may also collect and process personal information of our tenants in connection with:

• Maintaining logs of access badges, parking registration;
• Maintaining safety and security; and
• Documenting waivers in connection with tenant amenities such as gym access, bike rentals and dogs on property.

Vendors

We may also collect and process personal information of our vendors in connection with:

• Maintaining logs of access badges and parking registration; and
• Maintaining safety and security.

Customers/Guests at our Properties

We may also collect and process personal information of customers and guests at our properties in connection with:

• Registering you for events or registering you as a visitor at the property; and
• Maintaining safety and security.

Visitors/Guests Online

We may also collect and process the personal information of visitors and guests on our online Services in connection with:

• Operating and improving our Services, maintaining the integrity of our network, addressing security issues, investigating or taking action regarding complaints, violations or suspected violations of law or our terms of service;
• Communicating with you about upcoming events or other products and services offered by us, our affiliates or others (such as tenants in our properties or providers of services to tenants or visitors in our properties) in which we believe you may have an interest;
• Other purposes as noted in the privacy notice specific to that service; and

Tracking and analyzing your consumer behavior and location within our properties.

Sources of Information

We generally collect and maintain certain personal information from the following sources:

• Information we receive from you on forms, contracts or that you otherwise submit to us;
• Information about your transactions with us, our affiliates, and nonaffiliated third parties;
• Information obtained from meetings and telephone conversations with you;
• Information you provide when requesting us to contact you or respond to an inquiry;
• Information obtained automatically about your activity on our internet sites, property-specific mobile apps, or Wi-Fi networks;
• Information obtained from onsite security videos;
• Information obtained from public databases, such as the OFAC list;
• Information obtained from affiliated and non-affiliated third parties;
• Certain other information, depending on the specific product or service you have requested from us and/or the nature of your interaction with us, as further detailed below.

Investors

We may also collect and maintain personal information of our investors from the following sources:

• Information we receive from you on subscription agreements, investor questionnaires, other forms, or that you otherwise submit to us or contracts that you enter into with us; and
• Information obtained from third parties, including transfer agents, escrow agents, brokerage firms, account managers, portfolio managers, and similar third party providers.

Tenants

We may also collect and maintain personal information of our tenants from the following sources:

• Information we receive from you on lease or license agreements, guarantees, financial statements, waivers, other forms, or that you otherwise submit to us or contracts that you enter into with us;
• Information about your location based on your access card usage within our properties; and
• Information obtained from third parties, including property management, leasing brokers, third party diligence services.

Vendors

We may also collect and maintain personal information of our vendors from the following sources:

• Information we receive from you on invoices, purchase orders, product or services agreements, other forms, or that you otherwise submit to us or contracts that you enter into with us;
• Information you provide in our vendor credentialing system; and
• Information obtained from third parties, including our vendor credentialing system and information in diligence reports provided by third parties.

Customers/Guests at our Properties

We may also collect and maintain personal information of customers and guests at our properties from the following sources:

• Information we receive from you on sign-up forms for newsletters, information or events, Wi-Fi login, other forms, or that you otherwise submit to us; and
• Information obtained from third parties, such as Wi-Fi based location analytics and mobile location analytics.

Visitors/Guests Online

We may also collect and maintain personal information of visitors and guests of our online Services from the following sources:

• Information we receive from you on sign-up forms for newsletters, information or events, Wi-Fi login, other forms, or that you otherwise submit to us;
• Information obtained from third parties, such as Wi-Fi based location analytics, or social media accounts you link during registration for use of our Wi-Fi network;
• Other sources as noted in the privacy notice specific to that service; and
• Information obtained from third parties, such as from digital marketing and public relations service providers.

Information Disclosed/Shared with Third Parties

In order to provide you with the applicable products and services or fulfill our contract with you, we may disclose such personal information to our affiliates and nonaffiliated third parties as permitted by law, including:

• Service providers to our company, such as accounting, legal, and tax preparation services;
• Other third party service providers we may engage to provide services such as analytics and marketing, advertising, communications, customer service, payment processing, infrastructure and information technology services, and others as appropriate;
• A third party in the event of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business;
• For purposes of preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws; and
• Other parties depending on your relationship with us, as detailed below.

If one of the foregoing service providers needs to access Personal Information to perform services on our and your behalf, they are only authorized to collect, use, disclose, and store the Personal Information as described in our contract with them, including requirements to maintain reasonable security procedures.

We do not sell your personal information to third parties, and we do not rent, or share your personal information with third parties for such third parties’ direct marketing.

Please see below for information on additional third parties with which we may disclose your personal information in the context of your relationship with us.

Investors

We may also disclose the personal information of investors to:

• Transfer agents, portfolio companies, brokerage firms, platform providers, escrow agents, account managers, and the like in connection with processing payments and distributions.

Tenants

We may also disclose the personal information of tenants to:

• Property management, security and parking services at the property.

Vendors

We may also disclose the personal information of vendors to:

• Property management, security and parking services at the property.

Customers/Guests at our Properties

We may also disclose personal information of customers and guests at our properties to:

• Property management, security and parking services at the property.

Visitors/Guests Online

We may also disclose personal information of visitors and guests of our online Services to:

• Others as noted in the privacy notice specific to that service.

How to Access and Control your Information

We may send you marketing materials in which we believe you may have interest, and will comply with your request to stop sending any such further communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.

Where appropriate and where applicable by law, we shall provide you with the individual rights with respect to your personal information. See the “Jurisdiction Specific Information” sections for California Residents and EEA Residents below for more information on your rights in these jurisdictions. You can exercise your rights with respect to your personal information by contacting privacy@blackmgroup.com, or calling 1-833-577-7500.

We require certain information to provide our Services to you. For example, we must collect certain personal information from investors, tenants and vendors to comply with legal obligations. We also require certain personal information to provide you with access to certain websites, apps and networks. If you do not wish to share such required personal information, we may not be able to provide you with certain Services.

Security

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law and industry standards. These measures include computer safeguards and secured files and buildings. We restrict access to personal information to those employees, affiliates, agents, and third parties who have a need to know the information to perform a business purpose. We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control.

Data Retention and Disposal

The personal information may be stored in our technology systems or those of our service providers, or in paper files. We will delete your personal information when it is no longer reasonably required for the uses described herein, or when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. Since we maintain our applications and systems to protect against accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or made unusable where deletion is not possible.

Cookies and Other Technologies

Cookies are small pieces of text that are transferred to your browser to enable our Services to recognize your device and to help us improve how our Services work. We use first party cookies, which are served directly by us to your browser as well as third party cookies which are served by a third party on our behalf. We use cookies which allow us to remember your preferences (such as your location or your preferred language) and help our Services to function properly. We also use cookies to authenticate users, prevent fraudulent use of login credentials and protect user data from unauthorized parties. We use other cookies to remember your recent searches and your interactions with certain ads and websites, and use this information to show you customized content tailored to your interests. The cookies we use include both session cookies, which are deleted after you close down your browser, and persistent cookies, which are more permanent and store certain information about your use of the Services.

The “help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to receive notifications from the browser when you receive a new cookie, or how to disable cookies altogether. If you do not wish to have cookies placed on your browser by our Services, we recommend that you adjust your browser settings and delete cookies which have already been placed using your internet browser’s help menu. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.

We use pieces of code or scripts that collect certain information automatically through our website or other services (sometimes referred to as pixel tags, web beacons, web bugs, and similar technologies). This includes information such as pages that you visit, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, preferences you set, and data that you enter into certain forms. This information is used to help us understand how you engage with our Services, to track user behavior and conversions, to engage with customers, and to provide you with the Services.

We use Google Analytics to help us understand how you engage with our Services. This tool collects data, including the URL of the page you’re visiting and your Internet Protocol (IP) address, and sends it to Google. This information is collected in order to provide and protect the security of the Service, and to give us a sense of which country, state, or city in the world you come from. Google Analytics may also set cookies on your browser or read cookies that are already there. For more information on Google Analytics, please see the site “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/ or other URL Google may provide from time to time). If you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on (located at https://tools.google.com/dlpage/gaoptout or other URL Google may provide from time to time).

We also use Google Analytics Advertising Features. We use Google advertising cookies together with the Google Analytics cookies to help show you more relevant ads and to measure interactions with the ads that are shown. You can opt-out of the Google Analytics Advertising Features we use through Google Ads Settings ( http://www.google.com/settings/ads/onweb/, or any other URL Google may provide from time to time) or the Google Analytics browser add-on noted above.

Jurisdiction Specific Information

California Residents

Details of Data Collected, Used and Disclosed

Please see above for the categories of personal information collected, the categories of sources from which information is collected, the business purpose for which the information is collected, and the categories of third parties with whom the information is shared.

Details of sale of data to third parties

BMG does not, and will not, sell your personal information.

Your Privacy Rights

If you are a California resident, you also have certain rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), including:

• The right to request that we disclose to you the specific pieces of personal information that we have about you;
• The right to request that we disclose to you the categories of personal information that