PCCP

Last Updated: July 16, 2023

PCCP, LLC (“PCCP”, “we”, “us”, or “our”) is an investment manager, providing commercial real estate debt and equity solutions to investors. This Privacy Policy describes how PCCP collects, uses, discloses and otherwise processes personal information from individuals who visit our website (the “Website”), or who obtain information about us or otherwise interact with us, both online and offline.

This Privacy Policy does not address the information we collect from investors in PCCP funds, borrowers or other individuals who receive financial products or services from us, either in their individual capacity or on behalf of a business (“Investors”). For more information about how we handle information about Investors, please visit our Investor Privacy Notice.

Personal information we collect

Personal information you provide:

• Contact information, such as your name, email address, mailing address, and phone number.
• Account information, such as your age, occupation, login information, and Social Security number where required by law.
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us, including your full name, email address, telephone number and the content of your communications.

Information we obtain from other sources: We may maintain pages on social media platforms, such as LinkedIn or Twitter. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Automatic data collection. We and our service providers (such as our investor portal operator) may automatically log information about you, your computer or mobile device, and your interaction over time with our Website, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area.
• Online activity and usage data: When you access and use the Website, we receive and store information about such interactions such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

How we use your personal information

We use the personal information collected above for the following purposes:

• Operating the Website, to perform any contract we have with you in accordance with our Terms of Use, including allowing you to create and use an account on the investor portal.
• To support our online services, and to improve, monitor usage of and protect the Website, in accordance with our legitimate interests, including:
  • responding to your requests, providing customer support, contacting you in case of any issue with your account, and sending you announcements, updates, security alerts, and support and administrative messages;
  • protecting, investigating and deterring fraudulent, harmful, unauthorized or illegal activity in order to keep our Website safe and secure for our users, including conducting authenticating your identity, troubleshooting, testing and research; and
  • improving, monitoring and analyzing trends and use of our Website, including anonymizing or aggregating personal information in a form that does not allows users to be identified.
• To comply with a legal obligation, for example to keep records of transactions, to verify your identity, or as requested by any judicial process or governmental agency.
• To send you direct marketing communications, including notifying you of investment opportunities, subject to consent where required. You may opt out of our marketing communications as described in the “Unsubscribe from direct marketing communications” section below.

How we share your personal information

We do not sell personal information. We share personal information with the following categories of recipients:

Affiliates. We share personal information within PCCP and with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy. Our affiliates include funds with a PCCP name and any company that is a member of the PCCP, LLC group.

Service providers. We share personal information with third party companies and individuals that provide services on our behalf or help us operate our Website (such as customer support, portal hosting, email delivery, marketing, identity verification, fraud detection, and database management).

Professional advisors. We disclose personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We share personal information for compliance, fraud prevention and safety purposes described above.

Legal. We share personal information with law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of PCCP, users, a third party, or the public.

Business transfers. We may share personal information in connection with a corporate transaction (or potential transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your rights and choices

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the “Contact Us” section below.

Personal information requests. Depending on your location and the personal information processed, we also offer you choices that affect how we handle the personal information that we control. You may request the following in relation to your personal information:

• Information about how we have collected and used your personal information.
• Access to a copy of the personal information that we have retained about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide our online services or for other lawful purposes.
• Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.

To make a request, please email us using the contact information provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. Your choices and rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us using the contact information provided in the “Contact Us” section below.

Complaints. If you are based in certain jurisdictions, you may lodge a complaint about how we handle your personal information with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

International data transfers

We may transfer your personal information to countries that may not provide the same protections as the data protection laws where you are based. We endeavor to safeguard personal information that we transfer, including by binding service providers that receive personal information from us to contractual protections. For more information, please contact us using the contact information set out in the “Contact Us” section below.

Children’s privacy

Our Website is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Website from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us using the contact information set out in the “Contact Us” section below.

Retention of personal information

We endeavor to retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our policies and with applicable laws, based on factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and the purposes for which we use personal information.

Security practices

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Notice at any time and we will notify you of any changes when required by applicable law. Please review this Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions, comments or complaints about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by phone at 866-PCCP LLC, by email at compliance@pccpllc.com or write to us at:

PCCP, LLC

10100 Santa Monica Blvd Suite 1000

Los Angeles, CA 90067

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COOKIE POLICY

Last Updated: July 16, 2023

This Cookie Policy explains how we use cookies and similar technologies in connection with our Website.

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, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• 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.

We refer to all these technologies collectively as “cookies.”

What types of cookies and similar technologies do we use?

We use the following categories of cookies:

• Necessary. These cookies are necessary to allow the technical operation of our Website (e.g., they enable you to move around on the website and to use its features).

How can you control the use of cookies?

Other than “necessary cookies,” which are required to allow our Website to operate, you can control our use of cookies through the cookie banner located on our Website.

You may also limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject third-party 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 allaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our websites from setting third-party 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. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

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.

Please note that some Internet browsers may 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 www.allaboutdnt.com.