This Privacy Policy describes how Retail.Properties collects, uses, discloses, and otherwise processes Personal Information in connection with our website (the “Site”) and the services we offer through the Site (the “Services”).

The terms “Retail.Properties,” “we,” “us,” and “our” refer to Retail.Properties and its affiliates and subsidiaries. By using the Services, you acknowledge that your Personal Information will be handled as described in this Privacy Policy. Your use of the Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including their applicable terms regarding limitations of liability and the resolution of disputes.

Personal Information We Collect and How We Use It

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. It does not include information that is de-identified or aggregated such that it can no longer be associated with a specific individual.

The types and amount of Personal Information we collect depend on how you interact with our Services. The more you engage with Retail.Properties, the more information we need to collect to deliver and personalize our Services.

1. Information Collected from All Users. We automatically collect certain information from all users (registered and unregistered), such as:

• IP address, browser type, and access times

• Pages viewed, listings searched, or saved.

• Referring and exit pages/URLs

• Device identifiers (e.g., IDFA, Android ID)

• Geolocation data (if permitted via device settings or consent)

This information is used to:

• Customize your experience based on location or search behavior

• Diagnose technical issues

• Analyze usage trends

• Improve service functionality and performance

• Target relevant ads or marketing content via our Site and third-party platforms

1. Information from Registered Users. To submit sites and interact with Tenant Listings, you must provide certain Personal Information, such as your name and email address. When you register at an event or ask us to create an account on your behalf, you agree to this Privacy Policy and our Terms of Use. When signing in through third-party services (e.g., Facebook, Google), we may receive additional information that helps personalize your experience. We may share this information to tailor content and ads.

• Your password is encrypted and must be kept confidential.

• You may update your information via your account settings. Previous data may be retained as required by law.

1. Communication Data. We collect contact information (email, phone, address) when you communicate with us, request support, sign up for newsletters, or participate in other Retail.Properties interactions.
2. Calls and SMS Messages. With your consent, we may call or text you for service or marketing purposes. Message and data rates may apply. You can opt out at any time.
3. Marketing Communications. We may use your contact information to send emails, texts, calls, or mailers about Retail.Properties products, services, surveys, or promotions. You may also sign up for listing alerts and other notifications.
4. Call Recordings. We may record phone conversations for training and quality assurance.
5. Sharing Tools. If you use tools to share listings or Retail.Properties content with others, we use the email addresses you provide solely to fulfill your request.
6. Interactive Features. Data shared through public forums, chats, or social media pages associated with Retail.Properties is considered public and not covered by this Privacy Policy.
7. Aggregated/De-identified Information. We may use Personal Information to generate de-identified or aggregated data for business purposes such as analytics, research, or reporting.
8. Automatically Collected Technical Data. We may gather technical details such as device type, cookie identifiers, operating system, mobile carrier, referring URLs, and interaction history across our Services.
9. Third-Party Sources. We may supplement the information you provide with data from third-party sources, including public databases or marketing partners.
10. General Business Uses. We use Personal Information to:

• Provide, maintain, and enhance our Services

• Respond to inquiries or support requests

• Ensure compliance with legal and contractual obligations

• Improve usability and effectiveness of the Site

• Prevent fraud and enforce terms

Disclosure of Personal Information

We may share Personal Information as described below:

1. Service Providers. We work with vendors (e.g., cloud hosting, analytics tools) under agreements that limit their use of your data to providing contracted services.
2. Business Partners. We may share information with co-branded partners offering jointly provided services.
3. Cookies and Tracking Technologies. We use cookies, pixels, SDKs, and similar technologies to:

• Remember preferences

• Analyze site traffic

• Deliver relevant ads

1. Advertising Partners. Ad networks may collect data to show you interest-based ads across platforms.
2. APIs and SDKs. We may allow third parties to use SDKs or APIs in our apps, which may collect Personal Information.
3. Legal Requirements and Protection. We may disclose Personal Information if required to do so by law, or to:

• Comply with legal process

• Protect rights, safety, or property

• Investigate fraud or misuse

1. With Your Consent We may disclose your data when you explicitly agree to a specific use or sharing scenario.

Your Choices and Rights

You may:

• Opt out of marketing communications via account settings or unsubscribe links
• Adjust your browser/device settings to limit cookies or location sharing
• Delete or deactivate your account through your account dashboard

Certain legal communications and service-related notices are mandatory and cannot be opted out of.

You can also opt out of third-party advertising or tracking tools using:

• Network Advertising Initiative (www.networkadvertising.org/choices)
• Digital Advertising Alliance (www.aboutads.info/choices)
• Mobile app settings (AppChoices)
• Google Analytics opt-out tools

Monitoring of Services

We may monitor any and all use of our Services, and may capture and retain information and records reflecting your activity on our Services for our business purposes. This may include all of the “Information We Collect Automatically” described in Section 1 above, server logs, cookie information, browser information, your communications with Retail.Properties or otherwise sent or submitted using our Service, and any other information about your activity or actions while on or using the Services (such as, without limitation, the pages you view, links you click or other actions you take with your mouse, videos you watch while on our sites, properties that you view or save, property that you claim, and the URL of the site you came to the Services from).

The Technologies used in connection with our Services (such as cookies, web-beacons, javascripts, software development kits, and others) described above in Section 2 (“Cookies and Similar Technologies”), may also collect the foregoing information reflecting your use of and activity on our Services, or may enable our third-party service providers or partners to collect such information. Similarly, we may disclose any of the information we capture by monitoring the activity on our Services to one or more third parties for our business purposes. Further, if you interact with chat functionalities on our Services, what you enter may be captured and retained by us and our third-party partners for our business purposes. If you type information into forms or other fields on our Services, what you enter may be captured and retained by us and our third-party partners for our business purposes.

By using our Services, you consent to our monitoring of our Services. If you do not consent to the monitoring of our Services described here, you should not use our Services.

Your Privacy Rights

Subject to and in accordance with applicable data protection laws, you may have the following rights with respect to your Personal Information that is collected and processed by Retail.Properties

1. Right to Confirmation – You may request confirmation as to whether Retail.Properties is processing your Personal Information.
2. Right to Access – You may request access to the Personal Information we hold about you, including a copy of such information in a commonly used format.
3. Right to Data Portability – You may request to receive an electronic copy of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format, or request that we transmit such information to another organization where technically feasible.
4. Right to Restrict Processing – You may request that we restrict or limit the way in which we use your Personal Information under certain circumstances, such as when you contest the accuracy of the data or object to its processing.
5. Right to Rectification – You may request that we correct or amend your Personal Information if it is inaccurate, misleading, incomplete, or improperly processed.
6. Right to Erasure – You may request that we delete Personal Information that we hold about you, subject to legal exceptions (such as where the data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims).

To exercise any of the above rights, please contact us using the contact information provided below. We will review and process your request in accordance with applicable laws and regulatory requirements.
To safeguard your privacy and security, Retail.Properties may take reasonable steps to verify your identity before responding to any request relating to your Personal Information. This may include requesting specific information from you to confirm your identity or requiring you to log in to your Retail.Properties account, if applicable.
We are committed to transparency and accountability in our privacy practices. Accordingly, we track and report annual metrics regarding our responses to privacy rights requests. For inquiries or to submit a request, please contact us at: privacy@retail.properties.

Data Retention

Retail.Properties retains the Personal Information we collect as outlined in this Privacy Policy for as long as it is necessary to: (i) provide you with access to and use of our Services; (ii) fulfill the purposes for which the information was originally collected; (iii) comply with our legal and regulatory obligations; (iv) resolve disputes; (v) enforce our agreements; (vi) establish or defend against legal claims; (vii) conduct internal audits; and (viii) support our legitimate business operations. The specific retention period may vary depending on the nature of the information and applicable legal requirements.

Additional Rights for California residents

California Privacy Notice Provisions

This section provides California residents (“consumers” or “you”) with additional disclosures regarding how Retail.Properties collects, uses, shares, and retains Personal Information, in accordance with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). It applies to Personal Information collected both online and offline.

Definition of Personal Information

For purposes of this section, “Personal Information” includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household. This does not include:

• Publicly available information from government records, widely distributed media, or that you have otherwise made available without restricting to a specific audience;
• Deidentified or aggregated data;
• Information exempt from the CCPA, such as:

• Medical or health data governed by HIPAA or CMIA;

• Consumer credit information under the FCRA;

• Financial data under GLBA or California Financial Information Privacy Act;

• Driver’s data governed by the Driver’s Privacy Protection Act.

Categories of Personal Information Collected

To date, we have collected the following categories of Personal Information:

• Identifiers: Name, alias, postal address, unique personal identifier, IP address, email address, account name, or similar identifiers.
• Commercial Information: Records of tenant and/or property interests, or usage data.
• Internet or Electronic Network Activity: Browsing and search history, interaction with websites, apps, or advertisements.
• Geolocation Data: Precise location derived from device settings or usage.
• Audio/Visual/Electronic Data: Recordings of customer service calls, images you provide, or interaction data.
• Inferences: Profiles created from information reflecting preferences, characteristics, and behavior.

Sources of Personal Information

We collect Personal Information from:

• You, directly through your interactions with our Services;
• Our affiliates, business partners, and Partner Agents;
• Advertising and analytics providers;
• Operating systems and platforms;
• Data brokers and third-party information providers;
• Publicly available sources, such as government records.

Retention of Personal Information

We retain Personal Information as long as necessary to provide Services, fulfill disclosed purposes, comply with legal obligations, resolve disputes, and enforce agreements. In lieu of deletion, we may deidentify Personal Information and commit not to reidentify it.

Business and Commercial Use

We may collect, use, or disclose Personal Information for the following purposes:

• Provide, operate, and maintain our Sites and Services;
• Manage user accounts and respond to inquiries;
• Conduct promotions, contests, and surveys;
• Conduct internal research and product development;
• Improve our platforms and user experience;
• Send transactional or marketing communications;
• Detect and respond to security incidents and fraud;
• Verify or maintain quality and safety of Services;
• Conduct audits and ensure regulatory compliance;
• Execute business transitions (e.g., mergers, acquisitions);
• Fulfill any legal obligations or law enforcement requests.

Disclosure of Personal Information

To date, we have disclosed the following categories of Personal Information for a business purpose:

• Identifiers
• Commercial Information
• Internet Activity Data
• Geolocation Data
• Audio/Visual Information
• Inferences
• Sensitive Personal Information

Use of Sensitive Personal Information

Our use of Sensitive Personal Information is limited and proportionate to:

• Delivering services as reasonably expected by you;
• Ensuring safety, fraud protection, or quality assurance;
• Detecting and addressing malicious or unlawful activity;
• Performing short-term or system-critical functions;
• Verifying your identity or providing support;
• Maintaining or enhancing the quality of a Retail.Properties product or service.

Sale and Sharing of Personal Information

The CCPA defines “selling” as providing Personal Information in exchange for value, and “sharing” as disclosing Personal Information for cross-context behavioral advertising. While Retail.Properties does not exchange your information for money, we may be considered to “sell” or “share” Personal Information with analytics providers, ad networks, or social media platforms for marketing purposes.

Categories of Personal Information we may have “sold” or “shared” in the past.

• Identifiers
• Internet Activity
• Geolocation
• Inferences

Third parties involved:

• Advertising networks
• Social networks
• Analytics providers

We do not knowingly sell or share Personal Information of individuals under the age of 16.

Your Rights Under the CCPA

Subject to certain conditions, you have the following rights:

• Right to Know: Request disclosure of categories and specific pieces of Personal Information collected, the sources, business purposes, and third-party disclosures.
• Right to Correct: Request correction of inaccurate or incomplete Personal Information.
• Right to Delete: Request deletion of Personal Information, unless retention is legally necessary.
• Right to Opt-Out of Sale/Sharing: Opt out of the sale or sharing of your Personal Information via the “Do Not Sell or Share My Personal Information” link in your account settings or by transmitting a Global Privacy Control (GPC) signal.
• Right to Limit Use of Sensitive Personal Information: Retail.Properties does not use sensitive data in a way that triggers this right.
• Right to Non-Discrimination: Exercise of your CCPA rights will not result in discriminatory treatment.

How to Exercise Your Rights

California residents may submit requests by:

• Emailing: privacy@retail.properties 
• Completing our online contact form

Authorized Agents

You may designate an authorized agent to make a request on your behalf. Agents must provide:

• A valid authorization document signed by you; and
• Verification of their identity and authority to act on your behalf.

Agents acting as businesses must also provide:

• A certificate of good standing from their state of organization
• Proof of authorization signed by the consumer

Verification Process

We must verify your identity before responding to your request. You may be asked to provide your full name, email address, and other identifiers. If we cannot verify your identity, we will explain the reason for denial.

“Shine the Light” Law

California Civil Code §1798.83 allows California residents to request, once per year, information regarding the disclosure of their Personal Information to third parties for direct marketing purposes. To submit such a request, email privacy@retail.properties with proof of California residency.

Children’s Privacy

Our Sites and Services are not intended for, nor directed to, children under the age of 13, or any other age threshold defined by applicable local law. Retail.Properties does not knowingly collect, solicit, or maintain Personal Information from children without verifiable parental consent as required by law. If you are a parent or guardian and believe that your child has provided us with Personal Information without your authorization, please contact us at privacy@retail.properties with the subject line “COPPA Child Information Request.”

Upon becoming aware that we have inadvertently collected Personal Information from a child in violation of applicable laws, Retail.Properties will take prompt steps to delete the information from our records and systems. We encourage parents and guardians to monitor their children’s online activity and to help enforce this Privacy Policy by instructing children never to provide Personal Information on our Sites or through our Services without permission.

Changes to this Policy

Retail.Properties reserves the right to update or modify this Privacy Policy at any time, in our sole discretion. When we make material changes to this Privacy Policy, we will notify you in accordance with applicable legal requirements. This may include providing notice by updating the “Effective Date” at the top of this Privacy Policy and/or posting a prominent notice on our Sites.

We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use, and protect your Personal Information. Your continued use of the Services after any changes to this Privacy Policy become effective constitutes your acceptance of those changes. If you do not agree to the updated terms, you should discontinue use of the Services.

Contact Us

If you have any questions about this Privacy Policy, contact:

Legal Department
Retail.Properties / Good Fortune Group LLC
18653 Ventura Blvd. #102
Tarzana, CA 91356

or

Email: privacy@retail.properties