Privacy Policy

GLOBAL PRIVACY NOTICE

As the leading provider of information, analytics, and online marketplaces to the commercial real estate industry, PAXIV, LLC and our affiliates (collectively, “PAXIV,” “we,” or “us”) respect your privacy and are committed to protecting your Personal Information. This Global Privacy Notice describes the types of Personal Information we collect and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, and specific privacy practices may apply to some of our products and services.

This Global Privacy Notice applies to the following websites and any associated PAXIV websites, products, services, and mobile applications (the “Services”):PAXIV.com. It does not apply to the collection and use of certain employment-related information. If you are a current or former PAXIV job applicant, employee, owner, director, officer, or contractor, please Contact Us for the appropriate policy.

When using our websites, you may choose to interact with features from third parties that operate independently from PAXIV, such as social media widgets and links to third-party websites. PAXIV has no control over and is not responsible for the privacy practices of such third parties. This Global Privacy Notice does not apply to the extent PAXIV does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of these third parties.

Table of Contents

1. Types of Personal Information

2. Collection of Personal Information

3. Use of Personal Information

4. Disclosure of Personal Information

5. International Transfer of Personal Information

6. Security of Personal Information

7. Retention of Personal Information

8. Manage Your Personal Information

9. Global Policy Notice Changes

10. Contact Us

1. Types of Personal Information

“Personal Information” means any information directly or indirectly relating to an identified or identifiable individual. Examples of Personal Information PAXIV may collect include:
Payment information (credit card and other payment card information)
● Personal contact information (name, nickname, gender, mailing address, email address, phone number)
● Business information (office location, business contact information, department, job title/description, professional bio)
● Log-in credentials (username, password)
● Photographs and biometric data (facial geometry)
● Usage details (log-on activity, search terms, views, clicks, downloads, PAXIV-related preferences, leadsubmission information, cursor movement, scrolling activity and other related attributes)
● Technical details (IP address, geolocation information, cookie/session IDs, authentication information, browser type/version, operating system/platform)
● Any other information you or other PAXIV customers may upload or enter into to the Services

Service-Specific

PAXIV Information and Analytics Through our PAXIV information services and analytics services, we may additionally collect:
● Country code, location name, and contact ID
● Business history, investor type, prior companies, credentials, and phone call recordings
● Phone call and video conference recordings

California Residents

We collect Personal Information as defined by the California Consumer Privacy Act, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer orhousehold. Personal Information does not include de-identified or aggregate information, publicly-available information that is lawfully made available from federal, state, or local government records, and information covered by certain sector-specific privacy laws. PAXIV has collected the following categories of Personal Information about consumers in the 12 months preceding the date this Global Privacy Notice was last modified:
● Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers)
● Categories of personal information described in California Civil Code §1798.80(e) (e.g., signature, telephone number, bank account number, credit card number, debit card number, or other financial information)
● Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
● Internet or other electronic network activity information
● Geolocation data
● Professional or employment-related information
● Inferences drawn from other Personal Information (e.g., profile reflecting your preferences, characteristics, and behavior)
● Sensitive personal information, including: biometric information, precise geolocation, login credentials (username and password), and the content of messages sent through the Services

2. Collection of Personal Information

PAXIV may collect Personal Information using the following methods:
● Directly from you when you provide it to us (information you enter into web forms, participation in phone calls or video conferences, subscription agreements, and contracts or submit to the Services)
● Through your participation in surveys, promotions, and contests
● PAXIV’s internal customer relationship management system and databases
● From third parties, such as analytics and email marketing service providers
● Researching public websites where permitted by the Terms of Use (company websites, search engines, social media)
● Automatically through tracking technologies (cookies, web beacons, log files), including over time and across third-party websites or other online services For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see Use of Personal Information, our Cookie Policy, andManage Your Personal Information.

Service-Specific

PAXIV Email Advertising Products
● Marketing, Investment Development and Third Party Advertising: We collect Personal Information from individuals whose details are on our database and who are most likely to be either a commercial or private investor.
● Secondary Corporate Marketing: We collect Personal Information from individuals whose details are on our databases.
● Weekly Property Marketing: We collect Personal Information from individuals whose details are on our database and who are most likely to be either a commercial or private investor.
● Retail: We collect Personal Information from individuals whose details are on our database and who will be either commercial or private individuals. Privacy practices related to our marketplace are detailed in theMarketplace Global Privacy Notice. PAXIV Information and Analytics We may additionally collect Personal Information in the following ways specific to PAXIV Information and Analytics:
● Extracting information from past registrations
● For Personal Information about a user through agents, owners, property managers, developers, asset managers and architects; from clients or other contacts (including, among others, admins, colleagues, joint agents brochures) with updated contact information; search engine searches; or from a listing Broker’s website
● For Personal Information about corporate tenants and landlords, from corporate tenants, landlords, building managers, front desk/concierge, and neighboring tenants; LinkedIn or other social media (business Facebook page, Twitter); paid third-party providers; public and freely accessible databases such as statewebsites; published agent investment brochures and tenancy schedules; search engine searches; or from a corporate tenant’s or landlord’s website.

Biometric and Geolocation Information

Some areas of PAXIV Services may require you to opt-in to PAXIV collecting photos, facial geometry, and geolocation information from you when you log in to certain PAXIV Services. This information is used to authenticate you as the user of such Services, maintain a secure session, and detect potential abuse and fraudulent use of the Services. For example, PAXIV may scan and analyze a photo you submit to the Services to confirm your identity for security purposes each time you access the Services by using facial recognition technology to compare your photo to the most recent photo uploaded to your account. PAXIV will securely store this information on servers located in the United States, and this information will only be accessed by authorized PAXIV employees. We will retain biometric information until the initial purpose forcollecting or obtaining such information has been satisfied or within three years, whichever occurs first. If you have questions regarding PAXIV’s use of biometric or geolocation information, please Contact Us.

Children Under 16

PAXIV websites are not intended for children under 16 years of age, and we do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this website or through any of its features, register, or make any purchases. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete it. If you believe we might have any Personal Information from or about a child under 16, please Contact Us.

California Residents

PAXIV collects Personal Information from the following categories of sources:
● Directly and indirectly from you
● Other PAXIV customers
● Service providers, including data analytics providers
● Third parties, including advertising services and social media networks
● Consumer reporting agencies
● Companies with public websites
● Government entities

European Economic Area (EEA) and United Kingdom Residents

Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but will notify you first.

3. Use of Personal Information

We may use your Personal Information for the following purposes:
● Communicating with you
● Providing you with the Services
● Authenticating use, detecting potential fraudulent use, and otherwise maintaining the security of the Services
● Developing, testing, improving, and demonstrating the Services
● Creating and maintaining a customer relationship management system, member directories, and invitation lists for PAXIV events
● Carrying out our legal and contractual obligations and enforcing our rights, including billing and payment processing
● Anonymizing and aggregating information for analytics and reporting
● Advertising, marketing, and selling the Services, including linking together or merging Personal Information with other Personal Information so that we may better understand your needs and inform you about our Services and those of our partners
● Short-term transient use, as defined in the California Consumer Privacy Act of 2018
● Any other purpose with your consent

Service-Specific

PAXIV Information and Analytics We may use Personal Information for the following additional purposes in connection with PAXIV Information and Analytics products:
● Populating and updating email lists
● Advising clients of PAXIV product enhancements and improvements
● Contacting users to collect listing, deal and other industry data on a monthly basis
● Entering details into PAXIV® where those details can be viewed by our subscriber base and used for marketing purposes
● Identifying trends, aggregating statistics, optimizing your use of the Services and providing a safer environment for purchasing in connection with your use of PAXIV.com and its related services
● Training and quality assurance PAXIV Applications Through PAXIV Applications, PAXIV stores information uploaded and entered into the applications by PAXIV customers for their own purposes (property records, tax documents, property and prospect contacts, listings, deal/lease information, free form notes, etc.) on behalf of PAXIV’s customers as a data processor.PAXIV uses this information for the purpose of interacting with current and prospective clients, tracking engagement, and for customer support activities.

Online Advertising

When you use the Services, we and third parties may use cookies and other tracking technologies to collect information, including Personal Information, to help us target content to you on the Services or elsewhere. This information may be associated with other information or combined with information from other sources, including information these third parties might track about your online activities over time and across the Internet. Third parties use this information to provide interest-based display advertising and retargeting on our behalf, which may include placing our advertisements on other websites you visit, including your social media accounts, or matching a cookie or device ID to your email address so we can send you promotional emails that may be of interest to you.
To make informed choices about targeted advertising, see our Cookie Policy and Manage Your PErsonal Information.

European Economic Area (EEA) and United Kingdom Residents

We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:

Consent

We may obtain your consent to process your Personal Information in certain circumstances, which may include when we send you relevant marketing, you elect to receive information from us, or you contact us to register an interest in our Services or company. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about our Services (see below).

Performance of a Contract

We rely on this lawful processing ground when we process your Personal Information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with the provision of our Services to you and the management of our relationships with third parties.

Compliance with a Legal Obligation

We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.

Legitimate Interests

We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when weprovide you with marketing information or other information in relation to our Services which we believe may interest you. If you wish to have more information regarding the legitimate interests assessments we have conducted in order to reach these conclusions, please Contact Us.

4. Disclosure of Personal Information

We may disclose Personal Information:
● To affiliates and other entities within PAXIV’s group of companies, distribution partners, other PAXIV customers, and service providers
● To third parties when you use a third party feature in our Services
● To enforce or apply our Terms of Use and other agreements or comply with any court order, law, or legal process, including government or regulatory requests
● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PAXIV’s assets
● To advisors, consultants, auditors, or similar professionals to assess our business, financial, and legal obligations or operations
● If we believe it is necessary to protect the rights, property, or safety of PAXIV or others
● For any other purpose disclosed by us when you provide Personal Information
● With your consent, such as when you choose to provide your information to third parties We may also disclose de-identified information without restriction. Note that if you make any Personal Information publicly available on the Services, anyone may see and use such information.

Service Providers

PAXIV retains third party service providers to assist us in our business. For example, we use service providers to assist with analytics, email marketing, payment processing, customer relationship management, and IT infrastructure and support. PAXIV may permit these affiliates and service providers to access your Personal Information in order to assist us in providing services; however, we contractually require these vendors to keepPersonal Information confidential and use it only for the purposes for which we disclose it to them.

California and Quebec, Canada Residents

PAXIV shares Personal Information with the following categories of third parties and has disclosed the following categories of Personal Information for a business or commercial purpose in the 12 months preceding the date this Global Privacy notice was last modified:

Personal Information

Third Parties

Identifiers

Service providers, including data analytics and advertising providers, operating systems and platforms, social networks, other PAXIV customers

Categories of personal information described in California Civil Code §1798.80(e)

Service providers, other PAXIV customers

Commercial information

Affiliates, distribution partners, other PAXIV customers

Internet or other electronic network activity information

Service providers, including data analytics and advertising providers

Geolocation data (e.g., IP addresses)

Service providers

Professional or employment-related information

Service providers, other PAXIV customers

Inferences

Service providers, including data analytics and advertising providers

Sensitive personal information, including biometric information, precise geolocation, login credentials, and the contents of messages sent through the Services

Service providers

PAXIV may also sell/share certain Personal Information. In the 12 months preceding the date this Global Privacy Notice was last modified, PAXIV sold:

● Identifiers (e.g., IP address and other online identifiers), Internet or other electronic network activity information, and commercial information (e.g., purchasing tendencies or records of products or services purchased or considered) to advertising providers for the purpose of advertising its Services
● Identifiers (e.g., name, email address), categories of personal information described in California Civil Code §1798.80(e) (phone number), and professional information (e.g., name, title, email address, business address) to other PAXIV customers for the purpose of making business contact information available through the Professional Directory feature

5. International Transfer of Personal Information

PAXIV is a global business. We may transfer your Personal Information to the United States, where we are headquartered, and to other countries which may not have the same privacy laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Global Privacy Notice, or as otherwise disclosed to you.

European Economic Area (EEA) and United Kingdom Residents

If you live in the EEA or the United Kingdom, we may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as an intra-company agreement or the European Commission’s Standard Contractual Clauses or their equivalent under applicable law.

You may Contact Us to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA or the United Kingdom.

Canadian Residents

We may use service providers located outside of Canada, including, without limitation, in the United States of America, to process Personal Information, and may transfer your Personal Information to such service providers for this purpose. When your Personal Information is processed outside of Canada, it will be subject to the laws of the countries where the information is processed and may be accessible to law enforcement and national security authorities of those countries in accordance with their laws.

You mayContact Us to obtain information about our policies and practices regarding the use of service providers located outside of Canada.

6. Security of Personal Information

PAXIV implements security safeguards to protect your Personal Information.

We take steps to secure Personal Information through administrative, technical, and physical safeguardsdesigned to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. For example, we encrypt payment card information in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and store sensitive information such as biometric and geolocation data on PAXIV servers located in the United States with access limited to authorized PAXIV employees.

Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

PAXIV has designated a Cybersecurity Team to investigate and respond to all security issues and vulnerabilities regarding its offerings. You can contact this team at: PAXIVSecurity1@PAXIV.com.

7. Retention of Personal Information

PAXIV will retain your information only for as long as is reasonably necessary for the purposes set out on this Global Privacy Notice, for as long as your account isactive (i.e., for the lifetime of your PAXIV customer account), or as needed to provide the Services to you. If you no longer want PAXIV to use your information to provide the Services to you, you may close your account. PAXIV will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this Global Privacy Notice. Please note that closing an account may not make your email address, username, or property name (if any) available for reuse on a new account. We also retain log files for internal analysis purposes. These log files are retained for a brief period of time, except in cases where they are used to protect the safety and security of the Services, to maintain and improve functionality of the Services, or to comply with legal obligations.

8. Manage Your Personal Information

You may manage your Personal Information by making certain choices. If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information ifit is within your online account by logging in at any time or Contact Us. You may also have additional rights detailed below depending on where you live. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.

Direct Marketing Opt-Out

If you no longer wish to receive direct marketing emails from PAXIV, you may click the “Unsubscribe” link in an email at any time. Depending on the Services, you may also be able to manage notification preferences in your account. Note that PAXIV may still contact you about the Terms of Use, Global Privacy Notice, or other legal notices, or in connection with providing you Services you have requested from us.

Tracking/Online Advertising Opt-Out

You may disable or delete browser cookies through your browser settings. Cookies are generally easy to disable or delete, but the method varies between browsers. To learnhow you can manage Flash cookies, visit Adobe’s Flash player settings page  . Flash player settings page. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our websites may not work properly. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States or Canada by visiting the National Advertising Initiative’s (NAI)  opt-out page and the Digital Advertising Alliance’s (DAA)  opt-out page and in the EEA and United Kingdom by visiting The Programme’s  opt-out page. Our Services do not recognize  Do Not Track  signals.

California Residents

If you live in California, you have the right to:

(1) request that PAXIV disclose what Personal Information we collect, use, disclose, and sell;
(2) request deletion of Personal Information, subject to certain exceptions;
(3) request that PAXIV correct inaccurate or incomplete Personal Information;
(4) opt-out of the sale of Personal Information;
(5) opt-out of the “sharing” or disclosing Personal Information for the purposes of cross-context behavioral advertising, and
(6) not receive discriminatory treatment by PAXIV for exercising these rights.

Requests to Know You have the right to request that we disclose the following information:

● Specific pieces of Personal Information PAXIV has collected about you;
● Categories of Personal Information PAXIV has collected about you, disclosed about you for a business purpose, or sold;
● Categories of sources from which the Personal Information is collected;
● Categories of third parties with whom PAXIV shares or to whom PAXIV sells Personal Information; and
● The business or commercial purpose for collecting and selling and sharing Personal Information.

Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale of your Personal Information. To make such a request, please Contact Usby email or visit Do Not Sell my Personal Information [hyperlink]. To opt-out of PAXIV sharing your Personal Information with third parties to advertise our Services, please additionally manage Tracking/Online Advertising Opt-Out [hyperlink] privacy controls.

Please click here [hyperlink]for statistics relating to California Consumer Privacy Act requests received by PAXIV brands under this Global Privacy Notice in the prior calendar year.

We do not have actual knowledge that we sell or share the Personal Information of consumers under the age of 16. We do not use or disclose sensitive personal information for purposes other than those specified in Cal. Civ Code § 1798.121.

Exercising Your Rights

To make a request, please Contact Us by email, call us toll-free at (407) 242-4321, or submit the request through your PAXIV account or our rights request web form [hyperlink]. In order to verify your request, PAXIV mayrequire you to provide additional information to confirm the identity of the consumer.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may Contact Us by email with proof of your written and signed permission to do so. Note that PAXIV may also require you to verify your identity and confirm that you gave permission.

Shine the Light Request

California residents may also have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please Contact Us.

Nevada Residents

Nevada residents may have the right to opt-out of the sale of Personal Information we have collected or will collect. To make such a request, please Contact Us.

Virginia Residents

If you live in Virginia, you have the right to:
(1) request that PAXIV disclose and provide a copy of what Personal Information we collect, use, disclose, and sell;
(2) request deletion of Personal Information, subject to certain exceptions;
(3) request that PAXIV correct inaccurate or incomplete Personal Information;
(4) opt-out of the sale of Personal Information;
(5) opt-out of targeted advertising;
(6) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects about you, and
(7) not receive discriminatory treatment by PAXIV for exercising these rights. To make a request, or to appeal our decision regarding a previous request, please Contact Us by email, call us toll-free at (407) 242-4321, or submit the request through your PAXIV account or our rights request web form [hyperlink]. If you are appealing our decision, please submit your appeal by email referencing and/or attaching information to identify your original request. In order to verify your request, PAXIV may require you to provideadditional information to confirm the identity of the consumer.

European Economic Area (EEA) and United Kingdom Residents

If you live in the EEA or the United Kingdom, you may have the right to
(1) request access to, rectification, or erasure of your Personal Information or restrict the processing of your Personal Information;
(2) object to processing;
(3) data portability
(receive and transfer your Personal Information);
(4) lodge a complaint with a supervisory authority; and,
(5) where processing of your Personal Information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of Personal Information that occurred before you withdraw consent. To make such a request, please Contact Us.

Canadian Residents

If you live in Canada, in addition to the other rights you may have hereunder, you may have the right to
(1)request access to, review and to correct inaccuracies or omissions in your Personal Information;
(2) to withdraw consent for collection, use or disclosure of, or to request deletion of, your Personal Information
(provided that, if you do so, we may no longer be able to provide services to you that rely on such Personal Information);
(3) to ask questions about our policies and practices, and to lodge complaints about our compliance with them with us or with regulatory authorities; and
(4) for Quebec residents, to request an electronic copy of the Personal Information you have provided to us in a structured and commonly used technological format.To make such a request, please Contact Us. We may require you to provide additional information to confirm your identity prior to carrying out any such request.

9. Global Policy Changes

This Global Privacy Notice may be updated periodically to reflect changes in our privacy practices.

We will post changes on this page and identify the date the privacy notice was last revised at the top of the page.If we make material changes to our privacy practices, we will notify you through a notice on the home page of the websites covered by this Global Privacy Notice. If a material change will apply to Personal Information we have already collected, including any new purposes for which the Personal Information will be used or disclosed to which you have not previously consented, we will additionally seek your affirmative consent.

10. Contact Us

We have appointed a Privacy Officer and Data Protection Officer to investigate and respond to privacy issues and to be accountable for our compliance with this Global Privacy Notice.

Please submit questions, concerns, or requests to exercise your applicable rights to PAXIV by email to PAXIVPrivacy1@PAXIV.com.

You may also write to:

PAXIV, LLC. 1840 N Technology Drive, Springville, Utah 84663-4965 Attn: Legal Department

If you live in the EEA or the United Kingdom, PAXIV UK Limited is the entity responsible for the processing of your Personal Information. Please submit questions, concerns, or requests to exercise your applicable rights by email to PAXIVPrivacy1@PAXIV.com.

or write to:

PAXIV, LLC. 1840 N Technology Drive, Springville, Utah 84663-4965 Attn: Legal Department

You may also make a complaint to your local data protection authority