PRIVACY POLICY

Date Last Updated: January 15, 2026

Please click here for a printable version of this Privacy Policy.

GID Investment Advisers LLC, GID Credit Advisers LLC, GID Industrial Advisers LLC, GID Multifamily Investment Management LLC, GID Industrial Investment Management LLC, GID Credit Investment Management LLC, GID PCS Investment Management LLC, and their affiliates (collectively, “Company” or “we”) respect your privacy. This Privacy Policy (“Policy”) describes how we collect, use, and share your Personal Information, as defined below, when you visit our websites where this Policy is posted (including www.gid.com), when you visit any social media page we maintain that contains a link to this Policy, or when you download or use our mobile applications (collectively, the “Sites”), through our commercial and retail leasing activities, our investment related interactions, and when you contact us, by email, telephone, or otherwise interact with us (collectively, “Interactions”).  Please read this Policy carefully. By using the Sites or visiting one of our properties, you agree to our collection, use, and sharing of your Personal Information as described in this Policy.

Our Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and delete information.

Depending on how you interact with us, GID Multifamily Investment Management LLC; GID Industrial Investment Management LLC; GID Credit Investment Management LLC; and GID PCS Investment Management LLC are the data controllers of Personal Information (defined below) collected in relation to this Policy.

Residents in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia  should refer to the body of this Policy as well as the “Privacy Rights” and “Jurisdiction-Specific Notices” sections below for additional information that may be applicable to them.

COLLECTION OF PERSONAL INFORMATION

Through your use of the Sites or Interactions, we may collect “Personal Information,” which is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. “Sensitive Personal Information” refers to a smaller subset of Personal Information which is considered more sensitive to the individual, such as a Social Security, driver’s license, or passport number, race and ethnic origin, or physical or mental health information. We also collect information from other parties, such as identity verification services or credit reporting agencies, including the results of identity verification and credit report searches.

We may collect the following categories of Personal Information, including Sensitive Personal Information:

Information Provided by You - General

Contact information.  If you choose to contact us to learn more about our properties, request customer support, use our “Contact” or similar features on our Sites, or through Interactions we may receive your personal identifiers and contact information, such as your name, address, phone number, or email address. We will also collect any other information that you provide to us, such as your questions, comments, or feedback.

Business Contact Information. We may receive your contact information, such as your personal identifiers (including your name, telephone number, and email address) and/or professional or business-related information (including your business address), through our online or offline interactions with you, such as when we work together on a project, when you or your company provides services to us, or when we discuss opportunities to work together. We may send you emails or call you with information about our business dealings, news, or marketing information to communicate with you for business purposes.

Social Media Information. If you post information on a webpage we establish on a social media platform, we may use the information to respond, to promote our business and services, and in the normal course of our business operations. We may collect personal identifiers, such as your social media username, and other personal characteristics that you have made publicly available on the social media website. Note that the third-party operators of social media websites also receive such information, and their use of your Personal Information is governed by their own privacy policies.

Information Collected Based on How You Interact With Us

Job Applicants.

If you apply for employment with us, we collect information associated with your application and information that you provide to us, such as your name, email address, phone number, address, the content of any comments, resume, education information, employment information, and any cover letter you provide. We may also collect certain information that is considered Sensitive Personal Information under certain laws. If you are a California resident, please see the “California Residents that are Job Applicants” section below.

 

Current or Prospective Commercial or Retail Tenants. 

If you are a current or prospective commercial or retail tenant, we may collect personal identifiers, such as your full name, telephone number, and email address. We may also collect your professional information, such as your place of employment and job title.

Prospective Borrowers.

If you apply for a line of credit with us, GID Credit Investment Management LLC may collect the following information:

  • Identifiers, such as name, phone number, home address, date of birth, and email address.
  • Financial information, such as financial account numbers.
  • Government identifiers, such as Social Security number, tax ID, passport numbers, and driver’s license numbers, which may be considered sensitive Personal Information under certain privacy laws.
  • Commercial information, such as products or services purchased.
  • Professional and employment related information, including business address.
  • Inferences drawn from any of the foregoing information, with the exception of sensitive Personal Information.

Potential Investors.

 If you are a current or potential investor in one of our ventures, we may collect the following information:

  • Identifiers, such as name, phone number, address, and date of birth.
  • Financial information, such as financial account numbers.
  • Government identifiers, such as Social Security number, tax ID, passport numbers, and driver’s license numbers, which may be considered sensitive Personal Information under certain privacy laws.
  • Commercial information, such as products or services purchased or the issuance of shares/interests.
  • Professional and employment related information.

In addition, we may also collect the Personal Information of our investors in connection with:

  • The acceptance of your subscription for shares/interests;
  • The issuance of shares/interests to you;
  • The management of the shares/interest, such as processing payments/distributions, accounting, auditing, as well as reporting to you, third party service providers, appropriate government entities; or
  • 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.

Information Automatically Collected

We may directly or through our third-party service providers and partners collect information through “cookies” or similar technologies. Cookies are small strings of text sent by our Sites to your browser and then stored by your browser on your device’s hard drive. Cookies help us understand how you use our Sites and other linked sites so that we can personalize and improve your experience on our Sites and the overall quality of our services. Most web browsers automatically accept cookies, but you may change your browser settings to reject cookies.

We may automatically collect the following types of information when you use the Sites:

  • Usage Information: We collect certain information automatically through your use of the Sites, such as which pages of the Sites that you access, the frequency of access, and what you click on while on the Sites.
  • Location Information: We may collect information about your location which may be determined from your IP address.
  • Device Information: We may collect information about the device you are using to access the Sites, such as hardware model, operating system, application version number, browser, and other device attributes (“Device Information”).
  • Mobile Device Information: In addition to the Device Information listed above, when you access the Sites via a browser on your mobile device, we may also collect mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.

You may manage the use of cookies by selecting the appropriate settings in the cookie banner associated with each Site, however, please note that if you do this you may not be able to use the full functionality of the Sites.

Please see our Cookie Policy for more information.

We may use your Personal Information to see which webpages you visit at our Sites, how you navigate through and interact with our Sites, which website you visited before coming to our Sites, and where you go after you leave our Sites. We can then develop statistics that help us understand how our visitors use our Sites and how to improve them. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Sources of Personal Information

We collect the Personal Information described above from the following categories of sources:

  • Other parts of our business, including our parent company, subsidiaries, and affiliates, some of which do not share our name or branding;
  • Our service providers, such as credit and background check providers or website hosting providers; and
  • Credit and government institutions, including in relation to anti-money laundering requirements.

USE OF PERSONAL INFORMATION

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

  • In connection with the employment application process,such as determining your eligibility or suitability for employment, or requesting credit and background check reports in connection with job applications;
  • In connection with a commercial or retail lease, such as completing the leasing process;
  • In connection with reviewing loan applications and processing loans;
  • In connection with analyzing prospective investors and providing investment opportunities;
  • To verify information provided, as an additional step to ensure the accuracy of information provided to us;
  • To provide services that you request or fulfill our contractual obligations to you, such as processing transactions;
  • To communicate with you, such as notifying you about updates to the Sites, your employment application, or any Interactions you have previously had with us.
  • For marketing or promotional purposes, such as informing you of special promotions or offering you additional products or services that may be of interest to you;
  • To provide customer service or technical support, such as contacting you in response to your inquiries, comments and suggestions or when otherwise necessary;
  • To debug, maintain, enhance, further, develop, and improve our Sites and services, such as tracking use of the Sites for internal market research or improvement of the Sites;
  • To present, operate, maintain, secure, authorize access to, or personalize our Sites and services;
  • To comply with all applicable legal requirements;
  • For commercial purposes, such as processing your data for analytics purposes in relation to the Sites;
  • To protect the Company, its employees, or others,such as to detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activities; and
  • To otherwise fulfill the purpose for which the information was provided.

DISCLOSURE OF PERSONAL INFORMATION

  • Our service providers or independent contractors, including background check providers: We may disclose all of the categories of Personal Information listed above with our service providers, including to help us perform functions, provide our services, and operate our business.
  • Third parties: We may disclose certain Personal Information to third parties, such as third-party lenders.
  • Analytics companies and other partners. We may disclose certain Personal Information that we automatically collect through the Sites for our commercial purposes.
  • Within our corporate family: We may share information with our affiliates, joint ventures, or other companies under common control with us, to the extent permitted by law.
  • If there is a change in corporate structure: We may share information in connection with a proposed or actual merger, acquisition, consolidation, change of control, or sale of all or a portion of our business or property or if we undergo bankruptcy or liquidation.

We may also share Personal information:

  • To prevent harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, ortake actionagainst illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
  • For legal purposes: We will share information where we are legally required to do so, such as in response to court orders or legal process; to establish, protect, or exercise our legal rights; to defend against legal claims or demands; or to comply with applicable legal requirements.
  • For legitimate business purposes: We reserve the right to share information with other parties for our legitimate business purposes, to the extent permitted by law.
  • With your consent: We may request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide certain Personal Information or before the Personal Information you have already provided is shared for such purpose.
  • Without identifying you: We may share information in a manner that does not identify you. For example, we may share anonymous, aggregate information about your use of our Sites and products with our service providers, affiliates, and partners.

PROTECTION OF PERSONAL INFORMATION

The security of your Personal Information is important to us. We maintain reasonable physical, technical and administrative security measures to protect and limit access to your Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially-acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

INTERNATIONAL DATA TRANSFERS

The Sites are controlled, operated, and administered by Company from its offices within the United States and are intended to serve individuals interested in properties or employment with the Company in the United States. If you are accessing the Sites or having Interactions with us from a location outside the United States, you acknowledge the collection, storage, processing, and transfer of your Personal Information to our facilities in the United States and to any other parties with whom we share it as described in this Policy. Please note that privacy laws in the United States may not offer the same protections as the laws of other countries.

NO USE BY CHILDREN

The Sites are not directed to, nor do we intentionally collect information from, children under 16 years of age. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at privacy@gid.com. If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

DATA RETENTION

As a general rule, we keep your Personal Information for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your Personal Information for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations.

We determine the appropriate retention period for Personal Information based on certain criteria, including:

  • The duration of our relationship with you;
  • The length of time necessary to complete a transaction;
  • Whether your Personal Information is a sensitive type;
  • Whether you specifically consented to retain the data; and
  • Our legal, contractual or similar obligations to retain or delete the data.

PRIVACY RIGHTS

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. If you are a California resident, see the Jurisdiction-Specific Notices section below for additional information as to your rights and to how to exercise those rights.

Nevada residents have the right to opt out of the sale of certain pieces of their information to third parties who will license or sell their information to others. However, Company does not sell Personal Information as contemplated by Nevada law.

If you are a resident of one of the U.S. states listed below, you have one or more of the following rights: (1) to request additional information about our data collection, use, disclosure, and sales practices in connection with your Personal Information; (2) to request the specific Personal Information collected about you; (3) to request the deletion of the Personal Information we have about you, with exceptions; (4) to request a restriction on certain processing of Personal Information; (5) to request correction of inaccurate information; (6) to opt-out of the processing of Personal Information for the purpose of “profiling” in furtherance of decisions that produce legal or similarly significant effects; and (7) to opt-out of the “selling” and “sharing”/“targeted advertising” of Personal Information as such terms are defined under U.S. state privacy laws. Please note, Company Personal Information/engages in “targeted advertising ”. For a description of the categories of Personal Information that are sold or shared/used for targeted advertising and for a description of the categories of third parties that such Personal Information is disclosed to, see the chart in the “California Residents” section below. Company does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. You may also have the right to not be discriminated against for exercising your privacy rights. If you are a resident of one of the following U.S. states, you have one or more of these rights:

Colorado Connecticut Delaware Indiana
Iowa Kentucky Maryland Minnesota
Montana Nebraska New Hampshire New Jersey
Oregon Rhode Island Tennessee Texas
Utah Virginia

 

If you are located outside of these jurisdictions and seek to exercise your rights under the law of another jurisdiction, please contact us by emailing privacy@gid.com.

You or, depending on your state or residence your authorized agent may submit a request regarding your Personal Information by:

To opt out of the selling or sharing of Personal Information via cookies, please use the “Do Not Sell or Share My Personal Information” link in the footer of the Sites.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. When you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

JURISDICTION-SPECIFIC NOTICES

California Residents

During the last twelve (12) months, we have collected the following categories of Personal Information from consumers depending on how a consumer uses our Sites.

Please see our Cookie Policy for information about the collection and use of Personal Information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Sites. Except as indicated in the “California Job Applicants” section, we do not seek to collect any additional “sensitive personal information” (as defined in the CCPA).

Category  Type of Identifiers We Collect Sold or Shared Disclosed To
Identifiers First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, social media username, email address Not s, except that we may sell or share certain Personal Information in relation to the use of certain cookies and similar technologies on the Sites Service providers, affiliates, management companies, and select analytics providers
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80€)* Name, address, telephone number Not sold or shared Service providers, management companies, and affiliates
Employment or professional information Business/Institution address or name Not sold or shared Service providers and affiliates
Internet or another similar network activity Information on a consumer’s interaction with a website, application, or advertisement Sold and shared Service providers, affiliates, management companies, and certain analytics providers

California Residents that are Job Applicants

When you apply for a job with Company, information may be collected about you in multiple ways: you may provide it to us in connection with your application; we may make observations in the application process or collect information from public information sources; or you may authorize us to collect information from other sources, such as a former employer or reference.

The following table describes our practices with regard to information submitted in the job application process. If you use our Sites in the job application process, additional information may be automatically collected, as described above.

Category (* may constitute “sensitive personal
information” under the CCPA)
Types of information we collect Sold or shared Disclosed to
Identifiers* name, email address, phone number, and contact address, username, social
media handle
Not sold or shared Service providers, affiliates
Protected Classifications* gender, race and ethnicity, date of birth Not sold or shared Service providers, affiliates
Geolocation Information* location information (e.g., ZIP code, IP address) Not sold or shared Service providers, affiliates
Professional or employment-related information. employer’s name, employer’s address Not sold or shared Service providers, affiliates
Education Information institutions attended, degrees and certifications attained Not sold or shared. Service providers, affiliates

 

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Rights Specific to California Residents

Under the CCPA, a California resident has the following rights:

  • to request additional information about our data collection, use, disclosure, and sales practices in connection with your Personal Information,;
  • to request the specific Personal Information collected about you during the previous 12 months;
  • to request the deletion of the Personal Information we have about you;
  • to request a restriction on certain processing of Personal Information,;
  • to request correction of inaccurate information; and
  • to restrict the usage and disclosure of Sensitive Personal Information. We do not use Sensitive Personal Information for any purpose other than permissible business purpose. uses under the law.

You may not be discriminated against for exercising your California privacy rights. You may submit a request to exercise your rights under the CCPA through one of two means:

To opt out of the selling or sharing of Personal Information via cookies, please use the “Do Not Sell or Share My Personal Information” link in the footer of the Sites.

Upon receiving your request, we will confirm receipt of your request by email or if you are registered in our customer portal, we may do so by a message directed to you in the portal. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.

We aim to respond to your request as soon as reasonably practicable and consistent with any applicable laws. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

California residents are also entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to privacy@gid.com with the subject heading “California Privacy Rights,” or (b) a letter to us at the address listed in the “How to Contact Us” section. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.

We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

OPT OUT OF EMAIL MARKETING

You may opt out of any future commercial/marketing email messages from us by choosing the link described as such within the email, with instructions on how to remove yourself from our email list.

CHANGES TO THIS POLICY

We reserve the right, at any time, to make changes to this Policy. We will post Policy changes on this page and, if the changes are material, we may provide a more prominent notice (including, for certain services or programs, email notification of privacy notice changes) for a reasonable period of time. Nevertheless, please check this page periodically for the most recent version of this Policy. Unless otherwise stated, any changes will be effective immediately upon posting to the Sites. Your continued use of the Sites after any changes have been made will constitute acceptance of the revised Policy.

CONTACT US

Should you have other questions or concerns about this Policy, please send us an email at privacy@gid.com.

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