Pilot Ventures LLC DBA Pilot Capital and its affiliates (referred to herein as “Pilot”, “we”, “us”, or “our”) values its users privacy. We recognize the importance of protecting the privacy of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“Personal Information”), particularly our consumers or users (referred to as “you” or “your” in this material).

This Privacy Policy (“Policy”) will help you understand how we collect and use personal information from those who visit our website or make use of our online facilities and services, and what we will and will not do with the information we collect. Our Policy has been designed and created to ensure those affiliated with Pilot of our commitment and realization of our obligation not only to meet, but to exceed, most existing privacy standards.

We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time Pilot decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be promptly notified by email. Users at that time shall have the option as to whether to permit the use of their information in this separate manner.

This Policy applies to Pilot and it governs any and all data collection and usage by us. By using www.pilotcre.com you are therefore consenting to the data collection procedures expressed in this Policy. Please note that this Policy does not govern the collection and use of information by companies that Pilot does not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand the way in which websites garner, make use of and share the information collected.

This Privacy Policy applies to information we collect:

• through the Pilot website;
• through other websites and online services that we own, operate, or make available and that link to this Privacy Statement;
• when you apply or rent at one of our properties, or through other offline interactions (on-site property visits);
• when you apply for a job with Pilot;
• when you engage with us as a third-party vendor or contractor;
• through other general inquiries we receive (including postal mail, e-mail, telephone, SMS, and in-person).

Collectively, we refer to the websites, online services, property visits and in-person interactions as “services.” This Privacy Statement describes what Personal Information we gather, how we use it, how it is shared and how you can access, delete, correct, change, and limit our use of it. If you are asked to submit registration details via this site, you may be requested to agree to additional terms regarding our use of your Personal Information, and those additional terms will apply in that context. Any additional terms will be provided for your review at the time of registration.

INFORMATION WE COLLECT

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. In addition, Pilot may have the occasion to collect non-personal anonymous demographic information, such as age, gender, household income, political affiliation, race and religion, as well as the type of browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining superior quality service.

Depending upon the type of relationship you have with Pilot, we may collect the Personal Information described in general terms below.

• Contact Information such as name, physical and/or mailing address, email address, date of birth, picture, and emergency contact details.
• Other Personal Identifiers such as user/account name, social security number, taxpayer identification number, driver’s license number, passport number, identity card or student card, and resident identification number.
• Financial and Insurance Information such as bank account/credit card number, rent payment details, insurance policy number, credit history, sanctions and Politically Exposed Persons (“PEP”) screening results, and other financial or tax documentation.
• Demographic Information such as age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status, in each case subject to applicable laws. In certain jurisdictions, you may also choose to share with us any disabilities or other health-related restrictions so that we can provide you with adequate accommodations.
• Commercial Information such as records of products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, and rent amount.
• Internet or other electronic network activity information through the use of our websites such as browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, and internet postings.
• Sensory data such as pictures, videos, and sounds.
• Employment, Investment or other professional information such as education, employment history, job title, university or school attended, diploma, pay history, income, net worth, source of your subscription funds, and wire transfer instructions.

HOW AND WHERE WE COLLECT YOUR PERSONAL INFORMATION

We may collect Personal Information through the following:

• Online Services. We collect information when you interact with our Online services which may include, but are not limited to, searching for an apartment, communicating with us, applying for a job, posting to social media pages, or participating in a survey.
• Property Owners. Our properties may be owned by other parties who share personal information with us for the purposes of managing the property and providing services.
• Property Visits and In-Person Interactions. We collect your Personal Information when you visit our properties and/or inquire about housing directly with our properties.
• Other Sites and Third Parties. We may use separate sites for the processing of applications and agreements and to assist our residents and service providers with other tasks which are required or helpful to them, such as paying rent online. We may also receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward us your email address and other information about you so that we may contact you as requested and in accordance with applicable law.
• Investor and Third-Party Due Diligence. When you invest in a private fund advised by us or when you provide services to Pilot as a third-party vendor/contractor, we will collect certain information through our discussions with you, from documents that you may deliver to us, and in the ordinary course of our business relationship.
• Other Sources. We collect Personal Information from other sources, such as public databases or credit agencies. Where legally required, we will obtain your consent before undertaking these checks.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may also collect “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data includes:

• Your browser or device. We collect certain data through your browser or automatically through your device, such as your operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the online services (such as the apps) you are using. We use this data to ensure that the online services function properly.
• IP Address. We collect your Internet Protocol (IP) address which is a number that is automatically assigned to your computer whenever you are using the Internet. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Pilot collects IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our sites. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We may seek to link your IP address to your identity when we feel it is necessary to protect our sites and other users from harm and to prevent criminal misconduct.
• Aggregated Data. We may aggregate data that we collect and this aggregated data will not personally identify you or any other user.
• Cookies, Pixels, and other similar technologies. We collect certain data from cookies, pixel tags, web beacons, and other technologies (“Cookies”) which are pieces of data stored directly on your device or browser and may, in certain jurisdictions, be considered Personal Information. Cookies may be set by us and called first-party Cookies. We also use third-party Cookies for our advertising and marketing efforts, to measure the success of our marketing campaigns, and to compile statistics about usage of the online services.
• Strictly Necessary Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these Cookies, but some parts of the site will not work.
• Performance Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
• Functional Cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these Cookies, then some or all of these services may not function properly.
• Targeting Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. These work by uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.
• Social Media Cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these Cookies you may not be able to use or see these sharing tools.

Most browsers are set up to accept Cookies. If you want to change your cookie preferences, you can do so through your browser settings or by updating your Cookie preferences, where applicable, when you enter any of our websites.

WHY WE COLLECT INFORMATION

We are collecting your data for several reasons:

• To better understand your needs and provide you with the services you have requested;
• To fulfill our legitimate interest in improving our services and products;
• To send promotional emails containing information we think you may like when we have your consent to do so;
• To contact you to fill out surveys or participate in other types of market research, when we have your consent;
• To customize our website according to your online behavior and personal preferences.

HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.

• Affiliates. We disclose your Personal Information and Other Data with our affiliated companies as necessary to communicate with you, provide you services, fulfill our contract with you and to accomplish our business purposes.
• Service Providers. We disclose Personal Information and Other Data to third parties who perform services such as hosting our websites, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice.
• Property Owners. We disclose Personal Information to the Owners of the properties we manage. Owners may use your Personal Information for their own purposes and legal obligations and are therefore considered separate data controllers for multiple processes during your tenancy journey.
• Partners. We disclose Personal Information and Other Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.

We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of Pilot employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.

CHANGES IN BUSINESS

If Pilot goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Privacy Statement in place at the time of the transfer.

YOUR PRIVACY PREFERENCES AND RIGHTS

We provide you with options, information, and choices below to express your preferences.

Email Consent and Opt-out
All users and visitors to our website have the option to discontinue receiving communications from us by way of email or newsletters. To discontinue or unsubscribe from our website, please click unsubscribe in a recent email, or send an email to connect@pilotcre.com stating that you wish to unsubscribe. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe or opt-out. Pilot will continue to adhere to this Policy with respect to any personal information previously collected.

Cookies and Other Data
For information on your choices related to Cookies and Other Data, please see the Section on Cookies and Other Tracking Technologies, above.

Access, Change, Delete, Restrict the Use, or Object to the Processing of Your Personal Information
You may have the right under applicable privacy laws to request that Pilot inform you as to whether Personal Information relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, change, delete, restrict the use of, or object to the processing of your Personal Information that was previously provided to us. If you wish to exercise your rights, please contact us (contact information below). For your protection, we will verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

SECURING INFORMATION

Pilot takes precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (e.g. credit card information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure, or modification of the user’s personal information under our control.

RETENTION

The data we collect from you will be stored for no longer than necessary. The length of time we retain said information will be determined based upon the following criteria: the length of time your personal information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in this Policy.

The criteria used to determine the retention period includes:

• The length of time we have an ongoing relationship with you and provide the services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

CHILDREN’S PRIVACY

Pilot’s website is not directed to, and does not knowingly collect personal identifiable information from children under the age of thirteen (13). If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database, or in the alternative, that verifiable parental consent is obtained for the use and storage of such information. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use this website. If you are a parent or guardian and you believe that your child may have provided personally identifiable information through any of our websites, please contact us (contact information below).

NOTICE TO EUROPEAN UNION USERS

Pilot’s operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) and sent to the United States. (The adequacy decision on the EU-US Privacy became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.) By providing personal information to us, you are consenting to its storage and use as described in this Policy.

NOTICE TO RESIDENTS OF CERTAIN STATES

Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.

UPDATES TO THIS PRIVACY POLICY

Any changes we make to this Privacy Policy will become effective upon posting. If we change our Privacy Policy, we will advise users of those changes through a general description at the top of this page and may also post these details to other places we deem appropriate. If we are legally permitted to do so, we may also email you.

CONTACT INFORMATION

If you have any questions about this Policy, please contact us. Current contact information can be found at the bottom of this page.