EFFECTIVE FEBRUARY 2014
Committed To Protecting Your Privacy
AR Capital, LLC and its affiliates and subsidiaries (“AR Capital” or “we”) are proud of the strong relationships we have built over the years – relationships based on common goals and mutual trust. In serving you, we are committed to providing you with the investment products and services you need now and in the years ahead, and to protecting your personal information along the way. This privacy notice contains information about how we fulfill this commitment to you.
We do not disclose any Client Information (as defined below) except as permitted by law. We do not sell or disclose any Client Information to any third parties for their independent use. The sections that follow will describe our information collection and sharing practices and the safeguards we use to protect your non-public personal information.
We Collect Information That May Include:
- Information that we receive from you personally on applications, forms, or other correspondence, or our website, such as your name, address, phone number, social security number and email address.
- Information about your transactions with us, such as your account holdings and transaction history.
- Information we receive about you from third parties, such as transfer agents, custodians, financial institutions and credit or service bureaus.
In selected situations, as permitted or required by law, we have to disclose all of the information we collect described above (the “Client Information”) to comply with the law, an investigation or a legal process, such as a court order or subpoena. We may disclose information when we believe that such a release is reasonably necessary to enforce or protect our rights.
We Carefully Limit Client Information Sharing, Use and Disclosure
We use and share Client Information solely to provide quality investment products and service to our customers. For example, this information enables us to serve and administer your accounts with efficiency and accuracy.
We do not disclose any Client Information except as permitted by law. We disclose Client Information under the following circumstances;
- When requested by you;
- When necessary, in our opinion, to verify or complete a transaction initiated by you;
- When complying with law, regulation or a court of government order or request; and
- In connection with any merger or consolidation of our sponsored REITs, business development corporations, funds or other investment products (our “Products”) with, or sale of, all or substantially all of the assets of our Products to a third party in each case, as approved by the board of directors and shareholders, as applicable, of such Product.
The Client Information described above may be shared within RCS Capital Corporation and its affiliates and AR Capital, LLC and its affiliates, including, but not limited to: American Realty Capital Advisors IV, LLC American Realty Capital New York Recovery REIT, Inc., New York Recovery Advisors, LLC, American Realty Capital New York Recovery REIT, Inc., New York Recovery Advisors, LLC, American Realty Capital Daily Net Asset Value Trust, Inc., American Realty Capital Advisors, II, LLC, American Realty Capital Trust V, Inc., American Realty Capital Advisors V, LLC, American Realty Capital Healthcare Trust, Inc., American Realty Capital Healthcare Advisors, LLC, American Realty Capital – Retail Centers of America, Inc., American Realty Capital Retail Advisor, LLC, Phillips Edison – ARC Shopping Center REIT, Inc., American Realty Capital II Advisors, LLC, American Realty Capital Global Trust, Inc., American Realty Capital Healthcare II Advisors, LLC, Business Development Corporation of America, BDCA Adviser, LLC, American Realty Capital Properties, Inc., ARC Properties Advisor, LLC, ARC Realty Finance Trust, Inc., ARC Realty Finance Advisors, LLC, Phillips Edison – ARC Grocery Center REIT II, Inc., American Realty Capital Hospitality Trust, Inc., and other Products sponsored or distributed by AR Capital.
We may also share Client Information with selected non-affiliated third parties, each of which is bound by written agreements of confidentiality with respect to the use and disclosure of Client Information. The sharing of Client Information with non-affiliated third parties is carefully limited to individuals who have been informed of the confidential nature of such information and who agree to keep such information confidential, as described in this section.
In connection with the ordinary course execution of our business strategy, we may disclose Client Information to the following types of third parties:
- Financial service providers that assist us in servicing your accounts, such as the distributor of the American Realty Capital programs, Realty Capital Securities, LLC, a FINRA-registered wholesale broker-dealer, its affiliates and third party providers of transfer agency services.
- Non-financial companies, such as service providers that fulfill product information requests or maintain our website.
- Others, such as join account holders and those with whom you have consented in writing to our sharing your Client Information.
In addition, we may share the Client Information with other companies with whom we have teamed through a joint marketing agreement to provide you with a particular benefit or service.
We Protect Client Information About Former Customers
If you terminate your relationship with us, we will continue to adhere to the privacy policies and practices provided in this notice and shall retain all collected Client Information in accordance with federal law.
We Have Safeguards In Place
We have physical, electronic and procedural safeguards in place to protect the confidentiality, security and integrity of your Client Information.
We restrict access to Client Information to those who need that information in order for us to provide our products and services to you.
Our Commitment To You
We value the trust of our customers and will continue to recognize the importance of holding your Client Information as confidential.
We will maintain accurate Client Information and respond promptly to customer requests to correct information.
We will require companies with whom we do business to use Client Information appropriately and to safeguard the confidentiality of such information.
We appreciate the opportunity to serve your investment needs. We pledge to follow the policies, safeguards and guidelines as described in this notice, to protect the confidentiality of your information. Your relationship is very important to us and we will take great care to honor these commitments to you. Thank you for choosing an American Realty Capital product. This notice applies to individuals and covers information in connection with consumer transactions. In compliance with government regulations, we provide this notice at the time the customer relationship commences, and to the extent required by law, annually and during the year in which the relationship exits. If we change our policies or practices, we will update this Privacy Notice.
If you would like to contact us about this Privacy Notice or any data privacy or confidentiality issues, below is our contact information:
405 Park Avenue
New York, NY 10022