We at Cottonwood Management, LLC and its affiliates (collectively, “Cottonwood”), respect your concerns about privacy. Cottonwood is committed to safeguarding and processing Personal Information in line with applicable privacy and data protection laws. “Personal Information” means information that relates to, describes, identifies or can be used, directly or indirectly, to identify you, such as name, postal address, email, and telephone number. Personal Information does not include (a) publicly available information as defined under applicable laws or (b) de-identified or aggregated information.

This Privacy Notice describes how we process the Personal Information that we collect on the cottonwoodmgmt.com website (the “Website”). We provide information on the types of Personal Information we collect, how we use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

If you are a California consumer, please see the section of this Privacy Notice called “California Consumer Privacy Statement”.

PERSONAL INFORMATION AND HOW WE COLLECT IT
We collect Personal Information directly from you when you provide it to us.

If you choose to contact us by filling in the forms in the Contact Us tab on the Website or by emailing us, we’ll collect your contact information and other information you choose to provide in connection with your inquiries. If you email us a message, we will store the message and copies of your correspondence so we can reference it to tailor our responses to you.

We will never sell your Personal Information to any third party or our affiliates.

HOW WE USE THE INFORMATION WE OBTAIN
We may use, disclose or otherwise handle Personal Information for the following purposes to:

• To respond to your inquiries or provide you with information, products, or services that you request from us;
• Operate, evaluate, develop, promote, and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; and managing our communications);
• Comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms of Use and Disclaimers;
• Protect against, identify and prevent fraud, money-laundering, breach of confidence, cyberattack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
• In some cases, in order to operate, administer and improve the user’s experience of the Website; and
• For any other purpose with your consent.

We may also use the information in other ways for which we provide specific notice at the time of collection.

We will only process Personal Information as necessary so that we can pursue the purposes described above. When we collect Personal Information, unless indicated otherwise, we need it for our business or compliance purposes. Where we process Personal Information for our legitimate interests as a business, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.

In limited circumstances, we are required to collect Personal Information to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.

INFORMATION WE DISCLOSE TO OTHERS
We do not knowingly share your Personal Information we obtain through the Website without your consent, except as described in this Privacy Notice.

We may share Personal Information with our affiliates and subsidiaries. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.

We also may disclose Personal Information (a) if we are required to do so by law or legal process, (b) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (c) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We reserve the right to transfer Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

In addition, we may share anonymous/aggregated information with third parties, such as service providers, in order to facilitate our business operations.

RETENTION AND DELETION OF YOUR INFORMATION
We retain Personal Information for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, in anticipation of litigation or a legal matter, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.

We will retain Personal Information in line with our data retention policies.

Note that we may retain some limited information about you so that we can maintain a continuous relationship with you if and when we are in contact with you again.

YOUR RIGHT AND CHOICES
We offer you certain choices in connection with the Personal Information we collect from you.

To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Information, and we will apply your preferences going forward.

These rights, subject to certain limitations, may include:

• Rights of Access, Correction, and Deletion. You may have a right of access to the Personal Information that we hold about you, and to some related information, including the purpose for processing the Personal Information, the categories of recipients of that Personal Information to the extent it has been transferred internationally, and, where the Personal Information has not been collected directly from you, the source. You may also have the right to require any inaccurate Personal Information to be corrected or deleted.
• Right to Object and Portability. You can object to our use of your Personal Information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Information (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your Personal Information to you or a third party, in a data portable format.

We review and verify requests to protect your Personal Information and will act on your data protection requests fairly and in accordance with applicable data protection laws and principles.

If you wish to exercise any of these rights, update your preferences, or submit a request, please contact us as indicated in the Contact Us tab on the Website.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called “California Consumer Privacy Statement”.

HOW WE PROTECT PERSONAL INFORMATION
We take reasonable measures to protect Personal Information we obtain through the Website against accidental, unlawful or unauthorized access, disclosure, or use. Please be aware that, despite our best efforts, security measures are not impenetrable, and we can’t guarantee against misuse.

LINKS TO OTHER WEBSITES
The Website may contain links to third-party websites and services, which are provided solely for your convenience and information. If you use these links, you leave the Website and will be directed to a third-party platform, and any information you share on those websites will be governed by the privacy notices or policies of those third parties, not this Privacy Notice. This Privacy Notice applies only to the information we collect on the Website. We are not responsible for the information practices of such third-party websites and those third parties are under no obligation to comply with this Privacy Notice if you provide information directly to those third parties. We advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Information practices. We will post the updated version on the Website and indicate at the top of the Privacy Notice when it was most recently updated. Please check for any updates regularly.

CALIFORNIA CONSUMER PRIVACY STATEMENT
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”). California residents have the right to receive certain disclosures regarding our information practices related to Personal Information Solely with respect to this “California Consumer Privacy Statement” section, “Personal Information” shall have the meaning as defined under the CCPA.

This section does not apply to information that is exempt from CCPA, such as information protected under the federal financial privacy laws.

To the extent you are a resident of California and we collect Personal Information subject to CCPA, the following applies.

CCPA RIGHT TO KNOW DISCLOSURE OF PERSONAL INFORMATION
While our information practices may vary based upon our relationship and interactions with you, the chart below describes the categories of Personal Information (as enumerated in the CCPA) that we collect and the categories of third parties for each category of Personal Information to whom Personal Information may have been disclosed. For more information about how we collect, use, and disclose Personal Information, please refer to the sections above.

CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you may have the following rights to your Personal Information:

• Right to Access. With respect to the Personal Information we have collected about you in the prior 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions): (a) categories of Personal Information about you we have collected; (b) the sources from which we have collected that Personal Information; (c) our business or commercial purposes for collecting, selling, or disclosing that Personal Information; (d) the categories of third parties to whom we have disclosed that Personal Information; and (e) a copy of the specific pieces of your Personal Information we have collected.
• Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.
• Right to Delete. Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected from you.
• Right to Opt-Out of Sale/Sharing. You may have the right to opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising purposes. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age. We do not, and will not, sell your Personal Information. If, in the future, we decide to sell Personal Information, we will provide you with notice and the right to opt-out of (or for minors, opt-in to) the sale of your Personal Information.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

HOW TO SUBMIT A REQUEST
To request access, correct, or delete your Personal Information; opt out of the sale or sharing of your Personal Information; or submit questions or concerns about our privacy policies and practices, contact us as indicated in the Contact Us tab on the Website.

To be considered a proper verified request, your request must: (a) indicate you are making a request pursuant to your “California Privacy Rights”, (b) provide us with sufficient information allowing us to reasonably verify that you are the same person about whom we collected the Personal Information or the authorized representative, and (c) describe your request in reasonable detail so we can correctly understand, evaluate, and respond to the request.

VERIFYING REQUESTS
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request.

If you request access to, correction of or deletion of your Personal Information, we may require you to verify your email address or certain of your information in our records, such as your name, email address, mailing address, phone number, company name and job-details, or other information about your interactions with us.

If you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.