GDPR PRIVACY POLICY

Ranger Global Real Estate Advisors, LLC’s (“RGREA”) primary client goal is to protect your privacy and to maintain the confidentiality and security of your personal information. Any personal information processed by RGREA is controlled by RGREA, and thus is the data controller of your personal information. Where certain nonpublic personal identifying information about you is provided to RGREA as a consequence of your investment (or potential investment) in a mutual fund, private investment fund (collectively, the “Funds”) or a separate account (an “Account”) for which RGREA serves as investment adviser, then RGREA, acting as a data controller, may itself (or through a third party) process your personal information (collectively, “Personal Information”). If you are an entity, then RGREA may process the Personal Information of your (i) beneficial owners; (ii) employees; and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity. When processing your Personal Information, there may also be times when the administrator of the Funds and Accounts will act as a data controller.

This policy (the “GDPR Privacy Policy”) explains the manner in which RGREA collects, utilizes and maintains nonpublic personal identifying information about investors and clients (and potential investors and clients) (collectively, “Investors”) based in the European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This GDPR Privacy Policy applies to your investment or potential investment in the Funds or Accounts.

COLLECTION OF YOUR PERSONAL INFORMATION

RGREA collects your Personal Information from the following sources, as applicable:

  • Information reported by you in investment management agreements, subscription documents, purchase applications and any other related documents or forms;
  • Information about your transactions with us, our affiliates or others (such as purchases, sales, account balances and average costs);
  • Information used to verify you or your firm’s identity;
  • Information about any bank accounts you or your firm uses for transfers between you or your firm’s bank account and the Funds and/or Accounts; and
  • Information RGREA receives about you, your firm, or investment in the Funds or Accounts as a result of your inquiries by mail, e-mail or telephone.

WHY RGREA USES YOUR PERSONAL INFORMATION

Your Personal Information may be processed by RGREA (or any of its affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

  • To facilitate your investment in the Funds or Accounts and the management and administration of your investment in the Fund or Accounts on an ongoing basis, which are necessary to fulfill all contractual and regulatory obligations related to your investment in the Funds or Accounts, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests;
  • In order to carry out anti-money laundering checks and related actions which RGREA considers appropriate or necessary to fulfill any of their legal obligations on an ongoing basis, in accordance with RGREA’s anti-money laundering policies and procedures;
  • To comply with RGREA’s legal obligations and, in particular, to report tax-related information to tax authorities;
  • To disclose information to other third parties such as service providers of the Funds, Accounts and/or RGREA (such as broker-dealers, custodians, independent managers or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on the Funds, Accounts and/or RGREA or in order to pursue the legitimate interests of the Funds, Accounts and/or RGREA;
  • To monitor and record electronic communications and, if applicable, calls, for any of the purposes specified herein; and/or
  • To otherwise pursue the legitimate interests of RGREA relating to your investment or your potential investment in the Funds or Accounts, where the processing of your Personal Information would be in the public interest; and/or as otherwise provided by law.

COUNTRIES HAVING ACCESS TO YOUR PERSONAL INFORMATION

RGREA’s servers, which store and keep your Personal Information, are located in the United States of America.

RGREA also engages with service providers (such as broker-dealers, custodians, independent managers or other professionals) whose personnel will have access to your Personal Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the performance of the contract between the Funds and/or Accounts and the Investors. These jurisdictions either: (i) afford an adequate level of protection for your Personal Information (as declared by the European Commission) or, (ii) if they do not, then RGREA, the Funds and/or Accounts, as applicable, have entered into an agreement with these service providers incorporating clauses the same or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and obligations no less onerous than those contained in this GDPR Privacy Policy.

COLLECTING INVESTOR INFORMATION LEGALLY

RGREA is able to legally collect and use our Personal Information either because:

  • You have consented to their doing so;
  • It is necessary for the performance of a contract to which the Investor is a party or to take steps at the request of the Investor prior to entering into a contract;
  • Collecting and using your Personal Information is necessary for RGREA to fulfill its legitimate business interests, which may include, without limitation, investigating, defending against, or prosecuting any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect their legal rights; and/or
  • It is necessary to comply with any applicable regulatory, judicial or other legal obligations.

RETENTION OF INVESTOR INFORMATION

RGREA will retain your Personal Information for the purposes described in the immediately preceding paragraph so long as required for the purposes described above. To determine the appropriate retention period for your Personal Information, RGREA considers the statutory obligations, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which RGREA processes your Personal Information and whether RGREA can achieve those purposes through other means.

In particular, and without limitation to the foregoing, RGREA has legal obligations imposed on it under applicable legal systems, which requires it to retain your Personal Information for certain minimum time periods.

YOUR RIGHTS

You have the right to:

  • Be informed about your Personal Information that RGREA collects from you, uses and retains, which this GDPR Privacy Policy seeks to do;
  • Obtain confirmation from RGREA that your Personal Information is being collected, used and retained as described above, and to access your Personal Information held by RGREA;
  • Have your Personal Information corrected if it is inaccurate or incomplete at any time;
  • Erasure, or the right to be forgotten, which means you can request deletion or removal of any of your Personal Information RGREA holds about you at any time, subject to RGREA’s rights to retain your Personal Information as provided for under the GDPR;
  • Block or suppress RGREA from collecting and using your Personal Information, which means RGERA can continue to store your Personal Information but cannot further collect or use it in any way;
  • Obtain and reuse any of your Personal Information that RGERA holds about you for your own purposes across different services, which allows you to move, copy or transfer your Personal Information easily from RGREA to another place identified by you to RGREA in a safe and secure way without hindrance to the usability of your Personal Information;
  • Object to RGREA collecting, using or retaining your Personal Information where this is based on: (i) your legitimate interest or the performance of a task in the public interest; or (ii) direct marketing even if otherwise legally permitted; and
  • Withdraw your consent to the use of your Personal Information at any time, as described below.

To make any requests as listed above, please contact RGREA at 720-477-0644 or rlewis@RangerGlobalRE.com.

RGREA will respond to requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where the request is more complex.

WITHDRAWAL OF YOUR CONSENT

You can direct RGREA to stop collecting, using and retaining your Personal Information at any time by contacting RGREA at 720-477-0644 or rlewis@RangerGlobalRE.com. You should note that notwithstanding your withdrawal of consent, RGREA may be legally required to retain some or all of your Personal Information.

Where RGREA requires your Personal Information to comply with anti-money laundering or other legal requirements, failure to provide this information will mean that you will be unable to be accepted as an investor in the Funds or Accounts and/or may be mandatorily redeemed from the Funds or Accounts if you are already an Investor.

PROTECTION OF INVESTOR INFORMATION

RGREA maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:

  • The pseudonymization and encryption of your Personal Information where appropriate;
  • Ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services are in place;
  • Ensuring RGREA can restore access to your Personal Information in a timely manner if a physical or technical incident occurs; and
  • Regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure your Personal Information is secure.

RGREA restricts access to the nonpublic personal and account information of Investors to those employees and third-parties who need to know such information in the course of their job responsibilities. RGREA will destroy, erase or make unreadable data, computer files and/or documents containing your Personal Information that is nonpublic prior to disposal.

MAKING A COMPLAINT

If you would like to make a complaint about the way RGREA has collected, used or retained your Personal Information, please contact RGREA at 720-477-0644 or rlewis@RangerGlobalRE.com.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work, or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by RGREA or its service providers infringes the GDPR.

FORMER CLIENTS AND INVESTORS

This EU Privacy Policy also applies to former investors and clients in the EU and the EEA.

FURTHER INFORMATION

This GDPR Privacy Policy is in addition to RGREA’s existing Privacy Policy adopted under United States law, a copy of which is available from RGREA on request. RGREA reserves the right to change this GDPR Privacy Policy at any time and without prior notification.

The examples contained within this GDPR Privacy Policy are illustrations and are not intended to be exclusive. This GDPR Privacy Policy complies with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this GDPR Privacy Policy, please call Randy Lewis at 720-477-0644 or email at rlewis@RangerGlobalRE.com.