At GREI Co., the safety and security of your privacy and personal information is paramount and essential to the long-term success of our business. To formalize our conduct governing the collection, use and disclosure of our clients’ personal information, we have adopted this policy. “Personal Information” means any information that can be used to identify you as an individual, including your name, age, address, personal, financial and other details and any other identifying information about you that you provide us when you apply for or when we enter into an agreement to provide you with investment management services.
This policy applies to the operations of GREI Co. and its affiliates (including your asset manager) and to all of the services and products we offer our clients. Reference throughout this policy to “we”, “our”, “us” and “GREI Co.” means GREI Co. – Global Real Estate Investment Company, LLC and its affiliates. We will rely on the following principles with respect to the gathering, use, retention and securing of client information.
Accountability – At GREI Co., we are dedicated to ensuring your confidentiality by protecting the personal, business and financial information entrusted to us. This dedication is fundamental to the way we do business.
All our employees are responsible for maintaining your privacy. The GREI Co. Chief Privacy Officer together with the Privacy Officer of each affiliate are accountable for compliance with this policy and they are available to answer any of your specific or general questions regarding this policy or any of our privacy and data security procedures. We do not sell or distribute our clients’ information to third parties for marketing or soliciting any products or services.
Why We Ask For Your Information – We ask you for information to: (a) establish and maintain responsible commercial relations with clients; (b) to provide ongoing service; and (c) meet our legal and regulatory requirements.
What Information We Collect – At the start of and during the course of our relationship, we collect information about you. Some of the information we collect is from our managed account agreement or investment management agreement with you. Such information includes:
⦁ Information establishing your identity, such as your name, address, phone number, work position, employer, email address, date of birth, social insurance number (for tax purposes) or passport and account numbers;
⦁ For individuals, information about your employment, risk tolerance and the intended nature of your investment;
⦁ For entity clients, information about your business name, address, phone number, email address, industry type, details on the beneficial owners, authorized persons and directors;
⦁ For trusts, information including settlors, trustees and beneficial owners, address, phone number, email address, industry type, details on authorized persons; and
⦁ Additional information to meet our legal and regulatory obligations.
How We Use Your Information – We use your information for a variety of purposes. It is used to help us provide you with investment management services and to satisfy information requests from regulators and other organizations or individuals who are legally entitled to make such requests. We use your information to: (a) verify your identity; (b) manage your investments; (c) communicate with you; (d) understand your financial situation and goals; (e) manage our risks and operations; and (f) meet our regulatory and legal requirements.
Sharing Your Information – GREI Co. combines a number of different investment teams with unique and diverse investment management expertise. GREI Co. provides accounting, marketing, legal, compliance and other back office support functions to its affiliated investment teams. Your personal information may be shared with GREI Co.. This information sharing allows us to more efficiently provide: (a) investment management and client relationship services; (b) investment and tax reporting; and (c) crime and fraud prevention, suppression and detection. It also allows us to meet our legal, financial and reporting obligations.
We may also use outside service providers or agents to perform services on our behalf, including custodial, trustee, legal, marketing, mail distribution or data processing services. These service providers may at times be responsible for processing or handling personal information, and are only provided the information necessary to perform the services they have been engaged to provide.
We are committed to keeping your personal information safe, secure and confidential. We will only share your information with third parties as described in your agreement with us or under the following circumstances:
⦁ To respond to valid and authorized information request;
⦁ As permitted or required by law;
⦁ To help prevent crime, fraud, money laundering and terrorist financing;
⦁ To protect the safety of employees, clients or other third parties; or
⦁ In situations where we have your consent.
When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required.
Keeping Your Information Accurate and Safe – We make reasonable efforts to ensure the information we have about you is accurate, up-to-date and complete. Given that we make decisions based on the information we have, we encourage you to help us keep your information current.
Having accurate information about you enables us to give you better service and minimizes the possibility that out-of-date information may be used to make a decision which impacts you. We have procedures and practices in place to help us maintain the accuracy of your information and we rely on you for such information. You can help by keeping us informed of any changes such as a change of address or phone number. Please let us know if any of your information on file is inaccurate, incomplete or out of date.
We will protect your information with appropriate safeguards and security measures. We retain your information only for the time it is required and for the purposes of providing you with our investment management services. This period of time extends beyond the end of our relationship but only for as long as is necessary for us to meet our legal and regulatory requirements and for as long as it is necessary for us to respond to any outstanding matters. Some non-specific information may be retained for statistical analysis and other internal purposes. When your information is no longer needed we have procedures to destroy, delete or convert it to an anonymous form.
All our employees are familiar with the procedures required to safeguard client information, and they are required to maintain the confidentiality of such information at all times, failing to do so will result in appropriate disciplinary measures. Protecting your information is an essential part of our job. In order to protect your information only authorized employees have access to it and all employees sign a confidentiality agreement when hired. Additionally, all employees annually certify that they have complied with our privacy policy.
Your Right to Access Your Personal Information – In the normal course of business, you receive periodic access to information in the form of transaction activity records, including account statements. This information is available to you through mailings and secure online sites. If you would like to verify the accuracy of your personal information or receive a copy of this policy please submit a request at compliance@GREICo.net. Upon such request, we will give you access to the information we retain about you.
Your Consent and Your Choices – You are always in control of your personal information. Providing us with your information is always your choice. By establishing an account with us, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described in this policy. Your decision to withhold information or withdraw consent with respect to our use of your personal information may prevent us from taking you on as a client, or continuing to work with you as a client. You can withdraw your consent at any time, subject to the requirement of reasonable notice and any legal or contractual restrictions, by writing to us.
Addressing Your Concerns – If you have any questions or concerns about privacy, this policy or your personal information, we encourage you to let us know. If you choose to mail, fax or email us, please include your full name, address, and telephone number.
