THE MILESTONE GROUP
June 8, 2020
Milestone Group, LLC and its affiliates (together, “Milestone,” “our,” “us” or “we”) recognize and respect your right to privacy, and we are committed to managing information responsibly. We are providing this privacy notice (this “Privacy Notice”) to help you better understand the type of information we collect, how and why we collect or share such information as well as inform you of your rights and choices about the use of your information. We will not use, disclose, or share your information except as described in this Privacy Notice. This Privacy Notice explains how we collect, use, and share your Personal Information (as defined herein), including:
This Privacy Notice governs how we collect information through Milestone’s websites or any other programs or materials provided or made available by Milestone (collectively, the “Services”). Please know that you are agreeing to this Privacy Notice when you use the Services, including our website. If you provide Personal Information, you also agree that such Personal Information may be transferred from your current location to Milestone’s office(s) and services and to those of any authorized third parties. If you do not agree with this Privacy Notice, please do not use our Services, including our websites.
This Privacy Notice does not apply to information about businesses or other non-individual users. Milestone reserves the right to use and disclose aggregated and deidentified information for any commercially reasonable purpose.
“Personal Information” is information that reasonably allows us to identify you, your household or your device. Here are examples of the types of information we may collect about you and, if applicable, your beneficiaries:
“Personal Identifiers,” including first and last name, date of birth, social security number, gender, occupation, citizenship and marital status, birthplace, and driver’s license, passport number, or state identification card number;
“Contact Information,” including email address(es), mailing address(es), phone number(s); and
“Financial Information” including income level and/or assets, risk tolerance, transaction history, investment experience and activity, information regarding a potential and/or actual investment in a fund (including ownership percentage, capital investment, income and losses, source of funds used to make an investment in a fund), salary information, sources of income and investment funds, criminal history, details relating to immediate family members or senior political figures to whom you may be connected, investment experience or activity and your status under various laws and regulations, including tax status.
We collect and maintain Personal Information about you obtained through communications with you, including over the telephone, in voicemails, through written materials and via e-mail and other electronic communications. We collect information you voluntarily provide when using our Services, registering to use our investor portal, or contacting us by phone, email, or social media. Such information may include your name, email, and any other information you voluntarily share with us in such interactions. Also, when you interact with us through the website, we may collect usage information and information about your device, as described in greater detail below. We may also collect information about you from other sources, which we may combine with other information we have about you.
If you transact business with us, we may also collect nonpublic Personal Information about you, or information that is not otherwise publicly available.
We may also collect information about you that may not reasonably identify you or your household personally, but instead is linked to your computer or device (“Device Identifiable Information”) in connection with the operation of our website. For example, when you visit our website to browse, read, or download information, we may utilize commonly-used browser storage mechanisms and information-gathering tools.
To help us serve you better, we may collect Device Identifiable Information from you through technologies such as “cookies” and “web beacons” (which are also called clear GIFs, pixel tags, or pixels) or by tracking internet protocol (IP) addresses.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Our website does not currently support Do Not Track requests at this time.
We may disclose the information described above to certain third parties as authorized by you or as permitted or required by law or regulation. More specifically, we may share Personal Information where:
(a) It is necessary to fulfill a contractual relationship with you, to comply with our contractual obligations, or where you have so instructed us to disclose such Personal Information;
(b) We have a public or legal duty to do so (for example, to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order);
(c) We are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
(d) We (or one of our funds) have a legitimate business reason for doing so (for example, to obtain financing, manage risk, verify identity or to enable another business to provide you with services you’ve requested, or assess your suitability for investing in a fund);
(e) Needed to allow us to provide you with necessary or useful services with respect to your investment, for example sharing with affiliates and service providers, including administrators, lenders, banks, auditors, tax preparers, law firms, governmental agencies, self-regulatory organizations, consultants and placement agents;
(f) Needed for the operation of the website or Services to certain external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, or communications agencies);
(g) We are undertaking a merger, change of control, corporate reorganization or other similar transaction; or
(h) We have asked you if we can share it, and you gave consent.
We consider the protection of sensitive information to be a sound business practice, and to that end we employ reasonable physical, electronic and procedural safeguards that seek to protect your nonpublic Personal Information in our possession or under our control, including limiting access to your information to those who need access to such information. However, no method of transmission or storage of data is 100% secure, and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.
Please note that our websites are not designed or intended for children, and we do not knowingly collect data relating to children. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will endeavor to delete that information.
Personal Information will be processed and stored by us for only as long as required by the purpose for which the Personal Information has been collected. For example, Personal Information collected for purposes related to the performance of a contract will be retained until such contract has been fully performed. We may retain Personal Information for a longer period whenever we have a business purpose for doing so or we are required to do so in connection with the performance of a legal obligation or upon order of an authority.
If you are a California resident, then you also have the following rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information. The CCPA exempts information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, and its implementing regulations, or the California Financial Information Privacy Act.
You have the right to know and see what Personal Information we have collected about you over the past 12 months, including:
(a) The categories of Personal Information we have collected about you;
(b) The categories of sources from which the Personal Information is collected;
(c) The business or commercial purpose for collecting your Personal Information;
(d) The categories of third parties with whom we have shared your Personal Information; and
(e) The specific pieces of Personal Information we have collected about you.
You have the right to request that we delete the Personal Information we have collected from you. There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
(a) Complete your transaction;
(b) Provide you a good or service;
(c) Perform a contract between us and you;
(d) Protect your security and prosecute those responsible for breaching it;
(e) Fix our system in the case of a bug;
(f) Protect the free speech rights of you or other users;
(g) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
(h) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
(i) Comply with a legal obligation; or
(j) Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
We do not sell your Personal Information for money or other consideration of value.
We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
To exercise any of your access or deletion request rights, please submit a verifiable consumer request to firstname.lastname@example.org or by calling our toll-free line, (833) 748-0049.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials in order to verify your request. You may also designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
The verifiable consumer request must:
(a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or you are an authorized representative; and
(b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your request or provide you with specific pieces of Personal Information if we cannot verify your identity and authority to make the request.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact us at email@example.com with any questions about this Privacy Notice.
Our websites may contain links to other outside websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. We encourage you to be read the privacy statements of any other website that collects information of visitors.
Milestone may revise this Privacy Notice at any time without notice. By using the Services, including Milestone’s website, you are agreeing to be bound by the then-current version of this Privacy Notice.
You may have additional rights under other foreign or domestic laws that apply to you, in which case the provisions of this Privacy Notice shall be deemed supplemented by any such foreign or domestic laws to the extent applicable to you and binding on us.
Any claim relating to the Services or Milestone’s website shall be governed by the laws of the State of Texas without regard to its conflict of law provisions. All claims, legal proceedings or litigation arising in connection with the Services or Milestone’s website will be brought solely in Dallas County, Texas.
Your privacy and our ability to provide quality Services is important to use. For any questions or concerns about this Privacy Notice, please let us know by calling (214) 442-8150, via email at firstname.lastname@example.org or by writing to us at:
The Milestone Group
8333 Douglas Ave., Suite 1600
Dallas, Texas 75225
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