LJJ Funds Privacy Policy

Dated: May 23, 2018

Introduction

This policy applies to LJJ NYC Multi-Family Real Estate Fund, L.P.and LJJ NYC Multi-Family Real Estate Fund II (PF), L.P., each a Delaware limited Partnership, collectively also referred to in this policy as “we”, “us”, “our” or the “Partnerships”.

Information, confidential and proprietary, plays an important role in the success of our business. We recognize that as a visitor of our website www.ljjrealestate.nyc ( https://ljjrealestate.nyc) and/or as a customer you entrust us with personal information and financial data and we recognize our obligation to keep this information secure. Maintaining your privacy is important to us and we hold ourselves to the highest standards in its safekeeping and use. This privacy policy applies where we are acting as a data controller or processor with respect to the personal data and information we collect when you use our Website or purchase our services or products, in particular when you become an investor in the LJJ NYC Multi-Family Real Estate Fund, L.P and LJJ NYC Multi-Family Real Estate Fund II (PF), L.P.  This privacy policy sets out

1. how we collect personal information;
2. what personal information we collect;
3. how and on what legal basis we process and use your personal information;
4. with whom we may share your personal data;
5. how we control and protect personal information;
6. how long we store your personal information;
7. your rights to access, correction and deletion of personal information collected by us;
8. our use of cookies;
9. our use of third party links; and
10. how we notify you of changes to this privacy policy.

 

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

1. How is your personal data collected?
   We may collect data from and about you through different methods including through direct interactions with us in person or when you give us your personal information by corresponding with us  by mail, email, phone, through our Website or otherwise when you:

• log into our Website;
• apply for our products or services;
• create an account or fill out a form in paper or on our Website;
• subscribe to our products, services or publications;
• request marketing to be sent to you; or
• give us some feedback.

 

2. What information do we collect?

We may collect information including your:

• Identity Information: Names, titles, social security number, date of birth, marital status, gender
• Contact Information: Postal address, billing address, email address, phone and fax numbers, other contact information
• Investment and Financial Data: Data related to your financials (e.g. banking information; credit history) and your investment with us such as the amount of your ownership interest percentage and your capital contribution.
• Platform Information: Your password and other related log-in details for platforms maintained by us, where you have access to any.
• Information on your company: If you have invested through an entity we will collect all information provided to us regarding this entity in the subscription document.

 

3. How do we use or process your information and on what legal basis?

Any of the information we collect from you may be used in one of the following ways:

• Services based on a Contract with you: We will primarily use your personal data to perform services based on a contract with you pertaining to your investment with us. For example, we will use your information for the administration and operations of our Partnerships and investment funds, to send you statements or process your transactions with us. We may also use your personal data to prepare, negotiate and enter into such a contract with you.
• Marketing based on your Consent: With your express consent, we will send you marketing information about new funds which we are setting up and may be of interest to you as well as other news and updates about us. If you have consented to receive marketing, you may opt out at any point as set out below.
• Legitimate Interests: We may use your personal information if it is necessary for our legitimate interests (or those of a third party) and if your interests and fundamental rights do not override those legitimate interests.

 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications and news about us to you via email or mail.

You have the right to withdraw consent and stop us from contacting you for marketing purposes at any time by contacting us. To opt out, please email our Data Protection Officer, Robert Silverman at info@ljjrealestate.nyc.

4. Who may we share your personal data with?

In servicing your account, we may provide your personal information to:

• our affiliates such as our parent companies, our subsidiaries and any subsidiaries of our parent companies (including those who are involved in the operation, administration or management of, or the sale of interests in, us);
• non-affiliated service providers, only as permitted by law. For example, we may share such information in connection with the administration and operations of our Partnerships and investment funds, including disclosure to attorneys, accountants, auditors, administrators, or companies that may provide us with professional advice or assist us with mailing statements or processing your transactions; and
• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

We limit disclosure of your personal data to the parties listed above who have a business need to know and require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not provide investor or former investor information including names, addresses, or investor lists to outside companies except in furtherance of our business relationship and in accordance with our contractual agreement with you, or as otherwise permitted by law.

Within the Partnerships and its affiliates, access to the nonpublic personal information of our investors is restricted to employees who need to access that information to provide services to our investors.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

5. How do we protect your data?

We are committed to ensuring that your information is secure. To guard your nonpublic personal information, physical, electronic, and procedural safeguards are in place that comply with federal standards. Your right to privacy extends to all forms of contact with us, including telephone, written correspondence, and electronic media. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

6. How long will we store your personal data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data, please see below for further information.

7. Your rights concerning access, correction, deletion and processing of personal information

As the subject of data processing you have the right to:

• request access to the information we hold about you;
• request and receive a copy of your personal data stored by us in a structured, commonly used and machine readable format;
• request complete deletion of all information we hold about you;
• request correction of your personal information;
• object to processing of your personal information;
• request restriction of processing your personal information;
• request transfer of your personal information; and
• withdraw consent (e.g. to marketing communications).

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will try to respond to your request within one month of the receipt of the request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To make a request please email or write us at the following address: info@ljjrealestate.nyc

8. Do we use cookies?

No, we don’t use any cookies.

9. Third party links

Our Website does not include any links to third party websites.

10. Changes to our Privacy Policy

This Privacy Policy was last updated on May 23, 2018 and is compliant with the European General Data Protection Regulation 2016 guidelines. We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this Website. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.

Contact us

Please contact our Data Protection Officer, Robert Silverman, if you have any questions about this Privacy Policy or personal information we hold about you:

Email: info@ljjrealestate.nyc

Address: 1024 Broadway, Woodmere, NY 11598

Phone: (516) 268-5900