The Fifth Wall Companies are providing this notice on their behalf, and on behalf of the funds and clients for which they manage assets, to explain their information collection practices and other important information. These measures reflect our commitment to maintaining the privacy of your confidential information.
Information We Collect
The Fifth Wall Companies collect information about actual and prospective Investors or Clients from the following sources:
a) Information received on applications and other forms including Investment fund subscription documents, questionnaires and online registration forms of websites, whether received in writing or electronically. This information may include name, address, telephone number, e-mail address, tax identification number, income and other financial data, investment experience, and possibly personal bank account information.
b) Information about transactions and account history with Fifth Wall Companies, including initial and follow-on subscriptions, transfers and withdrawals or redemptions.
c) Information received from third parties such as solicitors, brokers, selling agents, advisers, product sponsors, exchanges, clearing firms and/or their respective service providers.
d) Information from online forms completed and data received when individuals visit a Fifth Wall Company website (such as internet protocol address, and browser software).
Disclosure and Use of Information Collected
The Fifth Wall Companies do not disclose personal or financial information collected from individual Investors or Clients, whether prospective, current or former, without authorization or direction of persons from whom the information is collected, except as disclosed below.
The Fifth Wall Companies may share information with affiliated or nonaffiliated service providers or other third parties:
a) for them to assist in providing services to Investors or Clients;
b) as part of marketing arrangements designed to jointly offer a product or service;
c) as may be required by regulatory authorities or law enforcement officials;
d) to the extent reasonably necessary to prevent fraud and unauthorized transactions; or
e) as otherwise permitted by law.
Those receiving information under the circumstances described above are not permitted to use such information for any purpose other than to assist the servicing of account(s) by an of the Fifth Wall Companies, including helping improve the services offered by them, or as permitted by law. Individuals choosing to withhold personal information requested by the Fifth Wall Companies may not be provided the services offered by them and/or may not be able to gain access to certain areas of websites hosted by them.
Confidentiality and Security
The Fifth Wall Companies restrict access to nonpublic personal information about past, present or prospective individual Investors or Clients to those who need to know that information in order to assist them in providing services. The Fifth Wall Companies will maintain physical, electronic and procedural safeguards consistent with applicable U.S. and international standards to protect nonpublic personal information. These safeguards may include, but not be limited to, (i) implementation of network firewalls, dedicated guest-only Wi-Fi access and other network security protocols to prevent internal or external cyber intrusions or tampering, (ii) use of document shredding or third party secured disposal services; and (iii) restricted access to Fifth Wall Company offices (e.g., locks, periodic changes to access codes, electronic access cards, etc.).
The Fifth Wall Companies store and use the information collected in their roles as both “Controllers” (i.e., data users) and “Processors” (i.e., data storage) of that information. They will also utilize third parties as Processors to store and archive information collected (e.g., via cloud-based services offered by Box.com, Global Relay and others), for which service agreements are in place to address confidentiality, security and compliance with applicable privacy directives and laws.
International Privacy Laws
Use of Internet Cookies
Access to Information
Investors or Clients, whether existing, prior or prospective, and others, may contact the Fifth Wall Companies to request access to information they have collected about them. If they do so, the Fifth Wall Companies will first verify their identity before sharing any such information. Once verified, they will send a copy of the information collected electronically, unless a different method is specifically requested. If informed that any information collected is incorrect, the Fifth Wall Companies will take commercially reasonable steps to correct any errors.
Data that is no longer needed by the Fifth Wall Companies to provide services may be deleted (unless required to be retained by applicable books and records retention regulations or other laws).
1410 Abbot Kinney Blvd.
Venice, CA 90291