Privacy Policy

Last updated: May 7, 2024

PRIVACY POLICY

About this Policy

Jamestown, L.P. and its affiliates, subsidiaries, and related companies (“us” or “we”) are dedicated to protecting the privacy of your personal information, which is information that identifies, relates to, describes, or is reasonably capable of being associated with you or that could reasonably be linked to you. This Privacy Policy describes how we collect, use, store and share information we collect from or about you in connection with the product or service you have requested from us and/or the nature of your interaction with us, including but not limited to your use of the Jamestown Invest platform located at jamestowninvest.com (the “Services”). Your use of certain Services offered by us may be subject to other terms and conditions or additional privacy notices (for example, if you are an investor in one of our funds or you register for a property-specific mobile app). This policy also explains your choices about how we use information about you.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to people who we do not employ or manage. We cannot guarantee the confidentiality of electronic communication, and as such, you should carefully consider whether to submit sensitive information that you would not want made public, and should recognize that your use of the Services is solely at your own risk. Accordingly, please read this policy carefully to understand our practices with respect to your personal information. By using any of the Services, you are permitting us to collect, use, store and disclose your personal information in accordance with this Privacy Policy.

Information Collected

In connection with your use of the Services and your interactions with us, we generally collect the following information:

Identifiers (such as your name, address, email address);
Other information (such as your phone number);
Internet or other electronic network activity information when you use our websites, property-specific mobile apps or Wi-Fi network (such as your Internet protocol address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, advertiser ID, and other device identifiers, browser type, hardware type, operating system, Internet service provider, user preferences, and information about the pages you visit, the date and time, the amount of time you spend on each page, and the links you click within the Services);
Any information you provide to us (such as in any forms, surveys, questionnaires, phone conversations, written correspondence or otherwise); and
Certain other information, depending on the specific product or service you have requested from us and/or the nature of your interaction with us, as further detailed below.

Investors

In connection with the formation and ongoing activities of an offering, we may also collect and maintain the following personal information about our investors:

Identifiers (date of birth, tax identification number/social security number);
Other information (financial account information, copy of government issued identification);
Commercial information (products or services purchased);
Professional and employment information; and
Inferences drawn from any of the foregoing information with the exception of sensitive personal information.

Visitors/Guests Online

We may also collect and maintain the following personal information about visitors and guests on our online Services:

Age range, gender, and interests if linking social media accounts;
Your organization/company, title, and website address;
Aggregated, statistical and summary information of the general behavior and characteristics of users visiting or participating in our online Services;
Other information as noted in the privacy notice specific to that service; and
Inferences drawn from any of the foregoing information with the exception of sensitive personal information.

Purpose

We and our affiliates and nonaffiliated third parties collect and process such personal information in connection with the following:

Providing you with the Services;
Responding to your inquiries or fulfilling requests for us to contact you;
Acting in compliance with our legal obligations, rights, and interests;
Sending marketing or promotional communications relating to our business, products or services to you;
Preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws, as well as regulatory requirements; and
Certain other purposes, depending on the specific product or service you have requested from us and/or the nature of your interaction with us, as further detailed below.

Investors

We may also collect and process personal information of our investors in connection with:

The acceptance of your subscription for shares/interests;
The issuance of the shares/interests to you;
The processing and management of the shares/interests, including processing payments and distributions, accounting, auditing, reporting to you, as well as reporting to third party service providers and appropriate government entities, including tax authorities and other governmental and regulatory agencies; and
Acting in compliance with the terms of the applicable offering circular or private placement memorandum, including with respect to anti-money laundering, sanctions checks and suitability.

Visitors/Guests Online

We may also collect and process the personal information of visitors and guests on our online Services in connection with:

Operating and improving our Services, maintaining the integrity of our network, addressing security issues, investigating or taking action regarding complaints, violations or suspected violations of law or our terms of service;
Communicating with you about upcoming events or other products and services offered by us, our affiliates or others in which we believe you may have an interest;
Measuring and analyzing activity of visitors; and
Other purposes as noted in the privacy notice specific to that service.

Sources of Information

We generally collect and maintain certain personal information from the following sources:

Information we receive from you on forms, contracts or that you otherwise submit to us;
Information about your transactions with us, our affiliates, and nonaffiliated third parties;
Information obtained from meetings and telephone conversations with you;
Information you provide when requesting us to contact you or respond to an inquiry;
Information obtained automatically about your activity on our online Services;
Information obtained from public databases, such as the OFAC list;
Information obtained from affiliated and non-affiliated third parties; and
Certain other information, depending on the specific product or service you have requested from us and/or the nature of your interaction with us, as further detailed below.

Investors

We may also collect and maintain personal information of our investors from the following sources:

Information we receive from you on subscription agreements, investor questionnaires, other forms, or that you otherwise submit to us or contracts that you enter into with us; and
Information obtained from third parties, including transfer agents, escrow agents, brokerage firms, account managers, portfolio managers, and similar third party providers.

Visitors/Guests Online

We may also collect and maintain personal information of visitors and guests of our online Services from the following sources:

Information we receive from you on sign-up forms for newsletters, information or events, other forms, or that you otherwise submit to us;
Information from cookies and non-cookie technologies;
Other sources as noted in the privacy notice specific to that service; and
Information obtained from third parties, such as from digital marketing and public relations service providers.

Information Disclosed/Shared with Third Parties

In order to provide you with the applicable products and services or fulfill our contract with you, we may disclose such personal information to our affiliates and nonaffiliated third parties as permitted by law, including:

Service providers to our company, such as accounting, legal, and tax preparation services;
Other third party service providers we may engage to provide services such as analytics and marketing, advertising, communications, customer service, payment processing, infrastructure and information technology services, and others as appropriate;
A third party in the event of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business;
For purposes of preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws; and
Other parties depending on your relationship with us, as detailed below.

If one of the foregoing service providers needs to access Personal Information to perform services on our and your behalf, they are only authorized to collect, use, disclose, and store the Personal Information as described in our contract with them, including requirements to maintain reasonable security procedures.

We do not sell your personal information to third parties, and we do not rent, or share your personal information with third parties for such third parties’ direct marketing. As described in the Cookies and Other Technologies section, we use certain standard advertising tools on our websites which, provided you have allowed it in your cookie preferences, sends personal data to the tool providers, such as Google. This is not a “sale” of your data in the traditional sense of the word sale. However, California’s privacy laws have a very broad definition of “sale” under which using these tools to send the personal data to the third-party tool providers may be considered a “sale”. If you are a California resident, please see the “Jurisdiction Specific Information” section for California Residents for additional information.

Please see below for information on additional third parties with which we may disclose your personal information in the context of your relationship with us.

Investors

We may also disclose the personal information of investors to:

Transfer agents, portfolio companies, brokerage firms, platform providers, escrow agents, account managers, and the like in connection with processing payments and distributions.

Visitors/Guests Online

We may also disclose personal information of visitors and guests of our online Services to:

Others as noted in the privacy notice specific to that service.

How to Access and Control your Information

We may send you marketing materials in which we believe you may have interest, and will comply with your request to stop sending any such further communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.

Where appropriate and where applicable by law, we shall provide you with the individual rights with respect to your personal information. See the “Jurisdiction Specific Information” sections for California Residents, Virginia Residents and EEA Residents below for more information on your rights in these jurisdictions. You can exercise your rights with respect to your personal information by contacting privacy@jamestownlp.com, completing the web form or calling 1-888-914-9661 (enter PIN: 773 067).

Cookies and Other Technologies

Cookies are small pieces of text that are transferred to your browser to enable our Services to recognize your device and to help us improve how our Services work. We use first party cookies, which are served directly by us to your browser as well as third party cookies which are served by a third party on our behalf. We use cookies which allow us to remember your preferences (such as your location or your preferred language) and help our Services to function properly. We also use cookies to authenticate users, prevent fraudulent use of login credentials and protect user data from unauthorized parties. We use other cookies to remember your recent searches and your interactions with certain ads and websites, and use this information to show you customized content tailored to your interests. The cookies we use include both session cookies, which are deleted after you close down your browser, and persistent cookies, which are more permanent and store certain information about your use of the Services.

The “help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to receive notifications from the browser when you receive a new cookie, or how to disable cookies altogether. If you do not wish to have cookies placed on your browser by our Services, we recommend that you adjust your browser settings and delete cookies which have already been placed using your internet browser’s help menu. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.

We also use non-cookie technologies and pieces of code or scripts that collect certain information automatically through our website or other services (sometimes referred to as pixels/pixel tags, web beacons, web bugs, and similar technologies). This includes information such as your IP address, pages that you visit, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, preferences you set, and data that you enter into certain forms. This information is used to help us understand how you engage with our Services, to track user behavior and conversions, to engage with customers, for measurement and analytics, and to provide you with the Services.

We use Google Analytics to help us understand how you engage with our Services. This tool collects data, including the URL of the page you’re visiting and your Internet Protocol (IP) address, and sends it to Google. This information is collected in order to provide and protect the security of the Service, and to give us a sense of which country, state, or city in the world you come from. Google Analytics may also set cookies on your browser or read cookies that are already there. For more information on Google Analytics, please see the site “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/ or other URL Google may provide from time to time). If you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on (located at https://tools.google.com/dlpage/gaoptout or other URL Google may provide from time to time).

We also use Google Analytics Advertising Features. We use Google advertising cookies together with the Google Analytics cookies to help show you more relevant ads and to measure interactions with the ads that are shown. You can opt-out of the Google Analytics Advertising Features we use through Google Ads Settings (http://www.google.com/settings/ads/onweb/, or any other URL Google may provide from time to time) or the Google Analytics browser add-on noted above.

If you want to learn more about controlling cookies and opting-out of certain internet-based advertising by third parties, please visit:

http://www.aboutcookies.org for guidance on how to control, disable, and delete cookies
http://optout.aboutads.info/ for the Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (if you are located in the United Sates.)
https://youradchoices.com/appchoices for mobile application-based “AppChoices” download page (if you are located in the United States.)
http://optout.networkadvertising.org/ for the Network Advertising Initiative (NAI)’s self-regulatory opt-out page (if you are located in the United States.)
http://youronlinechoices.eu for the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (if you are located in Europe.)

Security

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law and industry standards. These measures include computer safeguards and secured files and buildings. We restrict access to personal information to those employees, affiliates, agents, and third parties who have a need to know the information to perform a business purpose. We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control.

Data Retention and Disposal

The personal information may be stored in our technology systems or those of our service providers, or in paper files. We will delete your personal information when it is no longer reasonably required for the uses described herein, or when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. All employees are subject to a Record Retention policy which defines data retention periods based on legitimate business purposes, compliance obligations, and legal obligations.

Since we maintain our applications and systems to protect against accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or made unusable where deletion is not possible.

Jurisdiction Specific Information

California Residents

Details of Data Collected, Used and Disclosed

Please see above for the categories of personal information collected, the categories of sources from which information is collected, the business purpose for which the information is collected, and the categories of third parties with whom the information is shared.

Details of sale of data to third parties

As described in the Cookies and Other Technologies section, we use certain standard advertising tools on our websites which, provided you have allowed it in your cookie preferences, sends personal data to the tool providers, such as Google. This is not a “sale” of your data in the traditional sense of the word sale. However, the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) have a very broad definition of “sale” under which using these tools to send the personal data to the third-party tool providers may be considered a “sale”. Because of this interpretation, we provide a “Do Not Sell or Share My Personal Information” link at the bottom of our website. You can use this link to change your cookie preferences and opt out of the use of these advertising tools. If you opt out, Personal Data that was used by these tools will no longer be shared with third parties in a way that could constitute a “sale” under CCPA and CPRA.

Details of Processing of Sensitive Personal Information

We do not collect or process sensitive personal information as defined in section 1798.140 of the CPRA for the purpose of inferring characteristics about a consumer.

Your Privacy Rights

If you are a California resident, you also have certain rights pursuant to the CCPA and CPRA, including:
The right to request that we disclose to you the specific pieces of personal information that we have about you;
The right to request that we disclose to you the categories of personal information that we have collected about you;
The right to request that we disclose to you the categories of sources from which the personal information is collected,
The right to request the categories of personal information that we sold or disclosed for a business purpose;
The right to request the categories of third parties to whom the personal information was sold or disclosed for a business purpose;
The right to request the business or commercial purpose for collecting or selling personal information;
The right to opt-out of the sale or sharing of your personal information to third parties;

The right to request that we delete any personal information about you which we have collected from you;
The right to request the correction of inaccurate personal information;
The right to limit the use of sensitive personal information to what is necessary and reasonably expected;
The right to not be discriminated or retaliated against following opt-out or exercise of other rights described above.

You also have the right, under California Civil Code Section § 1798.83, to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Your options for making such a request are listed below.

Request Process

You can make a request under the CCPA and CPRA using the web form, email or toll-free phone number listed in the “Contact Information” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request.

Upon receipt of a request, we will first need to determine that the individual making the request is the individual about whom we have collected personal information. The specific steps in the verification process will depend on the type and sensitivity of the request. After verification, we will review the request and contact you if any follow-up information is needed to process your request. We will then determine whether your request can be fulfilled or whether there are exceptions that apply. We will respond to your request within the time frames set forth in the rules.

Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose.

Authorized Agents

You have the right to designate an authorized agent to make a request under the CCPA and CPRA on your behalf. Such authorized agent must be a natural person or a business entity registered with the Secretary of State. In order to process a request by your authorized agent, we will need to receive proof that the authorized agent is authorized to act on your behalf. This may be in the form of a Power of Attorney executed pursuant to the California Probate Code sections 4000 to 4465. If you do not have such a Power of Attorney, we may require that you provide a copy of the written documentation authorizing the agent to act on your behalf and also require you to verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized to act on your behalf.

Financial Incentives

Jamestown does not offer financial incentives or price or service differences in exchange for the retention or sale of your personal information.

Do Not Track Signals

Do Not Track (DNT) is a privacy preference that users may be able to set in some web browsers to signal that they have requested to opt out of tracking by websites and online services. Currently, there is no legal or industry standard regarding DNT signals, and therefore, we do not alter our data collection and use practices when we see a DNT signal from your browser. Please see the Cookies section above for additional information on what information is gathered, the purpose and the third parties that collect information about your activity on our site.

Contact Information

If you have any questions or concerns about our privacy practices or wish to exercise your rights with respect to your personal information, please direct your inquiry to:

Online: Web Form

Email: privacy@jamestownlp.com

Toll-Free: 1-888-914-9661 (PIN: 773 067)

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308

Virginia Residents

Details of Data Collected, Used and Disclosed

Details of Processing of Sensitive Personal Information

We do not collect or process sensitive personal information as defined in § 59.1-575 of the Virginia Consumer Data Protection Act (“VCDPA”).

Your Privacy Rights

If you are a Virginia resident, you also have certain rights pursuant to the VCDPA, including:

The right to request information on whether or not a controller is processing the consumer’s personal data and to access such personal data;
The right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data;
The right to delete personal data provided by or obtained about the consumer;
The right to obtain a copy of the consumer’s personal data that the consumer previously provided to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
The right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Request Process

You can make a request under the VCDPA using the web form, email or toll-free phone number listed in the “Contact Information” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request.

Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose.

Contact Information

If you have any questions or concerns about our privacy practices or wish to exercise your rights with respect to your personal information, please direct your inquiry to:

Online: Web Form

Email: privacy@jamestownlp.com

Toll-Free: 1-888-914-9661 (PIN: 773 067)

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308

EEA Data Subjects

Legal Basis for Processing

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where: (i) we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; (ii) it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; (iii) you give us consent to do so for a specific purpose; or (iv) we need to process your data to comply with a legal obligation. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

International Data Transfers

The Services may be accessed or used by individuals located outside the United States. If you choose to use the Services from the European Union (EU) or other regions with laws governing data collection that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

Automated Decision Making

We do not subject you to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Rights

Where appropriate and where applicable by law, we shall provide you with the following individual rights with respect to your personal information: (1) the right to access your personal information, (2) the right to correct or erase your personal information, (3) the right to restrict the processing of your personal information, (4) the right to object to the processing of your personal information, (5) the right to portability of your personal information, and (6) the right not to be subject to a decision based solely on automated processing. You have the right to lodge a complaint with supervisory authorities regarding the processing of your personal information.

You can exercise your rights with respect to your personal information by using the web form, email or toll-free phone number listed in the “Contact Information” section below. To the extent we are processing the personal information based on your consent, you may withdraw such consent at any time, provided that such personal information is not required by a legal obligation. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.

Consequences of failure to provide data

We require certain information to provide our Services to you. For example, we must collect certain personal information from investors, tenants and vendors to comply with legal obligations. We also require certain personal information to provide you with access to certain websites, apps and networks. If you do not wish to share such required personal information, we may not be able to provide you with certain Services. If you delete or refuse certain cookies, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.

Controller/EU Representative

Your information is controlled by Jamestown, L.P. If you are a resident of the European Economic Area and you have any questions regarding how your information is handled, or have questions about our privacy practices, please direct your inquiry to our EU Representative.

Controller:
Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308
Email: privacy@jamestownlp.com

EU Representative:
Jamestown US-Immobilien GmbH
Marienburger Str. 17
50968
Köln-Marienburg
Germany
Email: privacy@jamestown.de

Children’s Online Privacy Protection Act (COPPA)

We are committed to protecting the privacy of children. The Services are not intended for use by children, and we do not knowingly collect personal information from children under the age of 13. If we learn that personal information has been collected from persons under the age of 13 through the Services, then we will take appropriate steps to delete this information. If a child under 13 provides us with personal information without parental or guardian consent, the parent or guardian may contact us privacy@jamestownlp.com and we will remove the information. No information should be submitted to or via our Services by users under the age of 13.

Accessibility Statement

We are committed to ensuring effective communication and digital accessibility to all users. If you encounter accessibility barriers in accessing this Privacy Policy and would like to request this notice in an alternate format, please email privacy@jamestownlp.com.

Changes to Policy

We may periodically modify this Privacy Policy and will promptly post an updated Privacy Policy on https://www.jamestowninvest.com/privacy-policy/ showing the date of the update. Please check regularly for the most recent version of our Privacy Policy. You agree that the act of posting a revised Privacy Policy electronically on the website satisfies our obligation to deliver the Privacy Policy to you. Your continued use of the Services after such posting constitute consent to the collection and use of your information as described in the then-current Privacy Policy. If you disagree with any changes made to this Privacy Policy you will need to stop using the Services. We will keep prior versions of this policy which you may request via email to privacy@jamestownlp.com. You agree that the act of posting a revised Privacy Policy electronically on the website satisfies our obligation to deliver the Privacy Policy to you.

Contact Us

If you have any questions regarding how your information is handled, or have questions about our privacy practices, please direct your inquiry to Jamestown, L.P. as set forth below.

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308
Email: privacy@jamestownlp.com
Toll Free: 1-888-914-9661 (PIN: 773 067)
Online: Web Form

If you are a resident of the European Economic Area, please contact our EU Representative (see “EEA Data Subject” section above).

https://www.jamestowninvest.com/privacy-policy