FOCUSED ON
PERFORMANCE

PRIVACY NOTICE
EFFECTIVE MARCH 31, 2017

Our Privacy Practices

AR Global Investments, LLC and its affiliates and subsidiaries (“AR Global” or “we” or similar pronouns) are proud of the strong relationships we have built over the years – relationships based on common goals and mutual trust. In serving you, we endeavor to provide you with the investment products and services you need now and in the years ahead, and to protect your personal information along the way.

We do not disclose any Client Information (as defined below) except as described in this privacy notice or otherwise 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 help protect your non-public personal information.

Information We Collect From and About You

We collect non-public personal information from and about you, which may include the following information (collectively, “Client Information”):

  • 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, including, for example, financial account information and credit report information.

In addition to Client Information, we and our service providers may collect information about you and your online activities through our website and the various social networking platforms that we use, such as your IP address, clickstream data pertaining to your online activities and the device and browser you are using. We and our service providers may deploy various tracking technologies, such as cookies, on our website to collect additional information about your visits.  To learn more about the use of cookies, including how to manage or delete them, visit http://allaboutcookies.org.

WE COMPLY WITH U.S. FEDERAL SECURITIES LAWS WITH REGARD TO THOSE PAGES OF OUR WEBSITE USED TO FURNISH ELECTRONIC PROXY MATERIALS.  WE DO NOT USE TRACKING TECHNOLOGIES ON THESE PAGES.

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not change our tracking practices in response to DNT settings in your web browser, and we do not obligate our third party partners to change their tracking practices in response to DNT settings in your web browser.

How We Use and Disclose Your Information

We use and share any of the information we collect, including Client Information, to provide quality investment products and services to our customers. For example, this information enables us to serve and administer your accounts and our website with efficiency and accuracy, to respond to your requests, questions and concerns, and to develop and improve our products and services.

We do not disclose any Client Information except as described in this privacy notice or as otherwise permitted by law. We use and disclose any of the information we collect, including Client Information, under the following circumstances:

  • When requested or authorized by you;
  • To verify, process or complete transactions initiated or authorized by you;
  • When complying with law, regulation, legal process, court or government order or request or investigation or when we believe it is reasonably necessary to enforce or protect our rights or property; 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.

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 AR Global programs, 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.
  • Companies with whom we have teamed through a joint marketing agreement to provide you with a particular benefit or service.
  • Others, such as join account holders and those with whom you have consented in writing to our sharing your Client Information.

Any of the information we collect, including Client Information, may be shared within AR Global Investments, LLC and its affiliates, including, but not limited to: American Realty Capital New York City REIT, Inc., New York City Advisors, LLC, American Finance Trust, Inc., American Finance Advisors, LLC, Healthcare Trust, Inc., Healthcare Trust Advisors, LLC, Global Net Lease, Inc., Global Net Lease Advisors, LLC, American Realty Capital Healthcare Trust III, Inc., American Realty Capital Healthcare III Advisors, LLC, and other Products sponsored or distributed by AR Global.

We may also share any of the information we collect, including Client Information, with certain non-affiliated third parties that are bound by written agreements of confidentiality with respect to the use and disclosure of Client Information.

In addition, we may share non-personally identifiable site usage information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Client Information About Former Customers

If you terminate your relationship with us, this privacy notice (as it may be modified in the future) will continue to apply to your Client Information after that time, and we will retain Client Information in accordance with federal law and our records retention policies.

Security

We have physical, electronic and procedural safeguards in place that are designed to protect the confidentiality, security and integrity of your Client Information.

We restrict internal access to Client Information to those who need that information in order for us to provide our products and services to you.

However, while we endeavor to protect the security and integrity of sensitive Client Information, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.  If you correspond with us by email or using web forms, you should be aware that your transmission might not be secure.  A third party could view the information you send in transit by such means.  We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If you create an account on our website, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity.  Please notify us of any unauthorized use of your password or account or any other breach of security.

If at any time during or after our relationship we believe that the security of your Client Information in our care may have been compromised, we may seek to notify you of that development.  If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances.  If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile.  Please keep your email address in your account up to date.  You can change that email address anytime in your account profile.  If you receive a notice from us, you can print it to retain a copy of it.  To receive these notices, you must check your email account using your computer or mobile device and email application software.  You consent to our use of email as a means of such notification.  If you prefer for us to use the U.S. Postal Service to notify you in this situation, please contact us using our contact information below. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request.  You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Client Information.

Additional Policies and Practices

We value the trust of our customers and will continue to recognize the importance of holding your Client Information as confidential.

We will endeavor to respond promptly to your requests to review and correct your Client Information when you contact us using the contact information below.  Your right to review and correct your non-public personal information is subject to our records retention policies.

We will require companies with whom we do business and to whom we disclose Client Information to use and safeguard the confidentiality of such information in accordance with our requirements.

We appreciate the opportunity to serve your investment needs, and your relationship is very important to us. We will take great care to follow the policies, safeguards and guidelines as described in this notice and endeavor to protect the confidentiality of your information. Thank you for choosing an AR Global product.

This notice applies to individuals and covers information in connection with consumer transactions.

Our website may contain links, banners, widgets or advertisements that lead to other websites.  We are not responsible for these other sites, and so their posted privacy policies (not this privacy notice) will govern the collection and use of your information on them.  We encourage you to read the privacy statements of each website visited after leaving our website to learn about how your information is treated by others.

We may change this privacy notice from time to time.  If we change our policies or practices, we will let you know by posting the modified privacy notice on this page with a new effective date.

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
14th Floor
New York, NY 10022
(212) 415-6500