Neighborhood Property Group, LLC Privacy Policy

This Privacy Policy sets forth how Neighborhood Property Group, LLC, and its subsidiaries (referred to herein collectively as “NPG” or “we”) collect and process personal information about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which NPG conducts business. These regulations require that NPG (as a data controller) ensure that you understand how we collect, use, process and share your personal information. Please note that certain of these disclosures may not apply to you.

This Privacy Policy applies to visitors to this website (the “Site”), including job applicants, as well as visitors to our offices, individuals who call NPG personnel in certain of our offices, third-party service providers, vendors and suppliers, business contacts and prospective clients and investors. If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used. You may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

If you visit this website, you should review this Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site, which detail other important information surrounding your use of the Site.

Collection of Personal Information
We collect, and have collected over the last twelve (12) months, the following information from the following categories of individuals.

Website Visitors
Depending on how you choose to use the Site, we may need you to provide the following information:
to contact us – name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide; and
to subscribe to certain communications – email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).
For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.

Office Visitors and Callers
When you visit NPG offices or telephone certain NPG employees, we may collect certain personal information such as:

• name, organization and other contact details;
• video images of you in certain areas of the buildings in which our offices are located from CCTV footage;
• date and time of your visit to NPG offices; and
• voiceprints and telephone numbers during the recording of telephone calls.

Third-Party Service Providers, Vendors and Suppliers
In the process of engaging third-party service providers, vendors and suppliers, NPG may collect certain personal information about them and/or about their individual representatives and associates including:

• name, job title, telephone number, email address and other contact details;
• the name of the third-party service provider, vendor or supplier with whom you are associated and its address; and
• information required to process payments, such as a tax I.D. number and wire instruction details.

We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

Recruitment (if applicable)
When you submit a job application through our website or a third-party website for an open job position, we will process your personal information for purposes of recruitment.

Business Contacts and Prospective Clients and Investors (if applicable)
NPG may collect personal information about individuals or representatives of organizations with whom NPG has a business relationship (or with whom NPG seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

• name, address, telephone number, email address and other contact details;
• organization name and address, job title; and
• investor type, strategy, product and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication).

Use of Personal Information
Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; and/or (iv) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

• to respond to your questions and handle and resolve complaints;
• to perform research with respect to the usage of the Site (applicable to website visitors);
• to personalize and enhance your website experience (applicable to website visitors);
• to fill open job positions as part of a recruiting process (if applicable);
• to maintain the security of our premises, personnel, assets, systems and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
• to pay you for your services (applicable to third-party service providers, vendors and suppliers);
• in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which NPG conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
• to maintain and provide appropriate management of our relationship with you;
• to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
• to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);
• to contact you to set up meetings and/or phone calls between you and your NPG business contact(s); and
• to process your subscription requests and to send marketing communications about NPG to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors).

Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications.

For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.

Where NPG is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.

Sharing and Transfer of Personal Information
We may share, and have shared over the last twelve (12) months, the personal information we receive about you with the following categories of recipients:

• NPG affiliated entities;
• third-party service providers, vendors, contractors, and agents of NPG as part of normal business operations, including providers:
• engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors and suppliers);
• of accounting, banking and other data processing services;
• of information technology services and platforms/applications;
• of courier services or other package delivery services;
• of call recording and storage services (applicable to office callers);
• third party outsourcing providers;
• building security personnel (applicable to office visitors);
• third parties acting on your behalf such as consultants and other agents;
• governmental authorities and/or law enforcement officials where required;
• financial institutions to wire payments to you (applicable to third-party service providers, vendors and suppliers);
• advisors who provide audit, financial and legal advice to NPG;
• group companies for marketing purposes, including sending marketing communications on our behalf, sending their own marketing communications and facilitating joint marketing activities; and
• other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving NPG, or steps in contemplation of such activities

NPG may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfill other applicable requirements.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for NPG but are prohibited from using such information for other purposes.

Your personal information may be transferred to or shared with entities in countries where data protection laws might not exist or be of a lower standard than in Europe or the Cayman Islands. This includes the transfer of personal information among NPG affiliated entities and the jurisdictions in which they operate. In addition, we may transfer or share your personal information with non-affiliated parties located in the same jurisdictions as NPG entities as well as other jurisdictions and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this Privacy Policy.

When transferring personal information from outside the EEA, the UK or the Cayman Islands, we seek to comply with European Union and the UK law by using Standard Contractual Clauses or by adopting other means to ensure that adequate safeguards are applied (including, where relevant, transfers to a recipient with an appropriate Privacy Shield certification or appropriate arrangements in compliance with obligations in the Cayman Islands).

We do not, and will not, sell personal information collected about you.

Safeguarding of Personal Information
NPG maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use or disclosure. We endeavor to limit access to personal information about you to those employees, agents and other authorized parties who need to know the information to enable NPG to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under NPG’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

Retention of Personal Information
We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period, as described further in our document retention policies. In addition, we may retain your personal information for the duration of any period necessary to establish, exercise, or defend any legal rights.

Your Rights
The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask NPG for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. In particular, you have rights to object to direct marketing at any time.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, NPG may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request you make because your rights are limited, we will inform you of the reasons as to why when responding.

Depending on the type of personal information processing described in this Privacy Policy, we may be operating as a sole or joint controller. If operating as joint controllers, the entities jointly determine the means and purposes of the processing of your personal information. However this has no impact on your rights and how you can exercise them against either of the joint controllers by contacting us as set out below.

If you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

Where applicable, if you are a California resident you may have the following rights under the California Consumer Privacy Act of 2018 (the “CCPA”) in relation to “personal information” we have collected about you as defined in the CCPA; these rights are, to the extent required by the CCPA and subject to verification and any applicable exceptions:
Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:

• the specific pieces of personal information collected;
• the categories of personal information collected;
• the categories of sources from whom the personal information is collected;
• the purpose for collecting the personal information; and
• the categories of third parties with whom we have shared the personal information.

Right to Delete: You have the right to request that we delete the personal information.

Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of the rights above.

We will need to verify your identity prior to addressing your request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Use of Technology and Cookies

Technology
When you visit our Site or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we may collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email. We, or our appointed service providers, may also collect certain personal information through your interaction with marketing communication, text messages or emails we (or others on our behalf) send.

We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.

The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

Cookies
The Company may collect certain information about you through the use of cookies. Cookies are pieces of information, or files, placed on your device’s disk that provide information including how and when pages on the Site are accessed by users. To find out more about cookies please visit www.allaboutcookies.org, or see www.youronlinechoices.eu which contains further information about behavioral advertising and online privacy.

We use the following types of cookies on our Site (note that some cookies may fall into multiple categories):

Test Cookies – These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.

Tracking Cookies – These cookies are used to track anonymous user movement throughout the site for statistical purposes. For example, it may track the duration of a user’s visit to a certain page or for example, to allow the Company to determine the number of users that visited a given page of the Site, or that read a certain press release.

Required Cookies – These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.

Analytics Cookies – These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. The Company uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.

When visiting the Site, you may receive a pop-up banner informing you of our use of cookies.

You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by the Company to help maintain and improve the information provided on this Site for users. The Company may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. The Company may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, the Company may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. The Company may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

Managing Cookies – It is always your choice to decide what cookies are stored on your device and whether you choose to delete them. By accepting cookies that are stored on your computer when you visit our Site, we infer that you have accepted the use of cookies as explained in this Privacy Policy. Please note that while you are free to decline cookies, certain features of this site may be difficult or impossible to use and offerings will not be personalized.

You can manage cookies using various means:
Browser Setting. Your browser likely supports a variety of settings to control the cookies that are set on your computer or device and to delete cookies. These settings are typically found under the “Tools”, “Settings”, or “Options” menus. You can also check the “Help” menu of your browser to learn how to change the cookie preferences through your browser settings. Note that you will need to manage the settings for each browser and device you use. Further information from several popular browsers can be found at the following sites:

• Apple Safari
• Google Chrome
• Microsoft Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Online Tools. Some third parties allow you to manage cookies through online tools such as: Network Advertising Initiative, Digital Advertising Alliance, Your Online Choices, Adobe Flash, and the Interactive Advertising Bureau (IAB) Europe.
• In order to opt out of Adobe and Google Analytics Cookies across our websites, visit:
• Adobe Analytics
• Google Analytics

You can opt out of cookies to tailor content or advertising to you by visiting the above links. Note that if you choose to opt out, you won’t necessarily see fewer ads. However, the ads you see may be less relevant to your interests.
Browser Extensions. Some third parties have created software that can be added to your web browser to manage their or third-party cookies such as: Google Analytics and Evidon, Inc.
Our reference to any third party or their software or services is not an endorsement by us of such third party or their products and services and we disclaim any liability for the use or operation of any third-party software or services.

Do Not Track
We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

Links to Third-Party Websites
The Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. NPG encourages you to read the privacy policies of other websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

Children’s Online Privacy Protection Rule (“COPPA”)
The Site is not intended for or targeted towards, and we do not knowingly collect personal information via the Site from, children under 13 years of age. If we learn we have collected or received personal information via the Site about a child under 13, we will delete that information.

Updates to this Privacy Policy
NPG reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.

Contact Us
Please direct any questions regarding NPG’s Privacy Policy to.
Neighborhood Property Group, LLC
1301 Avenue of the Americas, 33rd Floor
New York, NY 10019
p +1 917 623-6112
This Privacy Policy was last updated on September 24, 2021.