Privacy Statement

This Privacy Policy sets forth how Sunstone Properties Trust, LLC, its subsidiaries, and affiliates (referred to herein collectively as “Sunstone” or “we”) collect and process personal information about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which Sunstone conducts business. These regulations require that Sunstone ensure that you understand how we collect, use, process and share your personal information.

This Privacy Policy applies to visitors to this website (the “Site”), visitors to our offices, individuals who call, e-mail, text, or otherwise communicate electronically with Sunstone personnel in certain of our offices, third-party service providers, vendors and suppliers, business contacts and prospective clients and investors, and the information collected in connection therewith. Sunstone may provide separate privacy notices to other categories of individuals, such as current clients and investors, job applicants, and persons connected with underlying investments of Sunstone funds and as such information regarding these categories of individuals may not be included here to the extent such other privacy notices are delivered. If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used.

If you visit this Site, you should review this Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site, which detail other important information surrounding your use of the Site. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using this Site, you agree to this Privacy Policy. This policy may change from time to time (see Updates to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This Site is not intended for use by children under the age of 18. We do not knowingly collect information from or relating to children. If you believe we might have any information from or about a child under 18, please contact us pursuant to the contact information set forth below.

Categories of Personal Information Sunstone Collects

We collect, and have collected in the last twelve months, information that identifies, relates to, describes, references, or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly with you, your household, or device (“personal information”), including:

  • Identifiers including your name, alias, signature, postal address, email address, telephone number, other contact information, a unique personal or online identifier, IP addresses, account names, social security numbers, a driver’s license, or other governmental identification number such as a passport number, bank account number and other financial information, and other similar identifiers
  • Personal information categories described in the California Customer Records statute, including the above identifiers, professional, employment and employment information.
  • Commercial Information regarding your eligibility for investments.
  • Characteristics of protected classifications under California or federal law including national origin and gender.
  • Online Activity including internet and other electronic network activity information, including without limitation browsing history, search history, your interactions with websites.
  • Audio or visual information when you visit Sunstone’s offices.
  • Geolocation data.
  • Other information you create or provide.
  • Inferences drawn from the above.

How Sunstone Collects Personal Information

Website Visitors
Depending on how you choose to use the Site, we may need you to provide information:

  • to contact us, including name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide;
  • by filling out forms on the Site, including information requested in order to determine eligibility to provide further services or access restricted portions of the Site; and
  • to subscribe to certain communications, including email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).

In addition, we automatically collect certain information when you use the Site, which include usage details, IP addresses, information collected through cookies. For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.

Office Visitors and Other Communications and Contacts
When you visit Sunstone offices or telephone, email, or otherwise contact certain Sunstone employees, we
may collect certain personal information such as:

  • name, organization, and other contact details;
  • video images of you in certain areas of the buildings in which our offices are located from CCTV footage;
  • date and time of your visit to Sunstone offices;
  • voiceprints and telephone numbers during the recording of telephone calls; and
  • other information you may provide to Sunstone or its employees during these communications.

Third-Party Service Providers, Vendors and Suppliers
In the process of engaging third-party service providers, vendors and suppliers, Sunstone may collect certain personal information about them and/or about their individual representatives and associates including:

  • name, job title, telephone number, email address and other contact details;
  • the name of the third-party service provider, vendor, or supplier with whom you are associated and its address; and
  • information required to process payments, such as a tax I.D. number and wire instruction details. We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

Business Contacts and Prospective Clients and Investors
Sunstone may collect personal information about individuals or representatives of organizations with whom Sunstone has a business relationship (or with whom Sunstone seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

  • name, address, telephone number, email address and other contact details;
  • organization name and address, job title;
  • investor eligibility information;
  • investor type, strategy, product, and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication); and
  • any other information provided.

Use of Personal Information

Your personal information may be processed, used, disclosed, or sold: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information in order to comply with our obligations under contract; and/or (iii) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

  • to present the Site and its contents to you and to notify you about changes to the Site or any products
    or services we offer or provide through it;
  • to provide you with information, products, or services you request from us,
  • to respond to your questions and handle and resolve complaints;
  • to perform research with respect to the usage of the Site (applicable to website visitors);
  • to personalize and enhance your website experience (applicable to website visitors);
  • to maintain the security of our premises, personnel, assets, systems, and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
  • to pay you for your services (applicable to third-party service providers, vendors, and suppliers);
  • in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Sunstone conducts business (applicable to office callers, third-party service providers, vendors, and suppliers);
  • to maintain and provide appropriate management of our relationship with you;
  • to engage your services in the future (applicable to third-party service providers, vendors, suppliers, and business contacts);
  • to contact you to set up meetings and/or phone calls between you and your Sunstone business contact(s);
  • to process your subscription requests and to send marketing communications about Sunstone to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors);
  • to determine your eligibility for Sunstone offerings, products, or services;
  • to fulfill any other purpose for which you provide it; and
  • any other purposes we described when you provide specific information or with your consent.

Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications.

For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.

Where Sunstone is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.

Disclosure of Personal Information

We may share the personal information we store about you with:

  • Sunstone affiliated entities;
  • Third-party service providers, vendors, contractors, and agents of Sunstone as part of normal business operations, including providers:
    • engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors,
      and suppliers);
    • of accounting, banking, and other data processing services;
    • of information technology services and platforms/applications;
    • of call recording and storage services (applicable to office callers);
  • third party outsourcing providers;
  • building security personnel (applicable to office visitors);
  • third parties acting on your behalf such as consultants and other agents;
  • governmental authorities and/or law enforcement officials where required;
  • parties as required to comply with any court order, law, or legal process, including to respond to any governmental or regulatory request;
  • financial institutions to wire payments to you (applicable to third-party service providers, vendors, and suppliers);
  • advisors who provide audit, financial and legal advice to Sunstone;
  • the other parties in a merger, acquisition, reorganization, asset sale, or bankruptcy, in which case personal information may be an acquired or transferred asset; and
  • to enforce or apply our Terms and other agreements we may have with you.

Sunstone may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfil other applicable requirements.

In the prior twelve (12) months, Sunstone has not sold any personal information.

In the prior twelve (12) months, Sunstone has disclosed to the following categories of personal information for a business purpose:

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for Sunstone, but the service providers will be bound by contractual obligations to keep the personal information confidential and to prohibit from using such information for other purposes.

Your personal information may be transferred to or shared with entities located in the United States, the European Union or in other countries which are deemed to offer an adequate level of protection, or in countries where data protection laws might not exist or be of a lower standard than in the European Union. This includes the transfer of personal information among the Sunstone affiliated entities and the jurisdictions in which they operate. In addition, we may transfer or share your personal information with non-affiliated parties located in the same jurisdictions as Sunstone entities as well as other jurisdictions and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this
Privacy Policy.

Safeguarding of Personal Information

Sunstone maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use, or disclosure. We endeavor to limit access to personal information about you to those employees, agents and other authorized parties who need to know the information to enable Sunstone to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Sunstone’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

Retention of Personal Information

Personal information stored by Sunstone is generally retained for a period of ten years from (a) the date the data record was created or (b) a particular trigger event depending on the type of data record containing the personal information. Examples of trigger events are (i) the tax filing year in which an invoice for services received is paid, (ii) date of contract expiration or termination, and (iii) account closure or fund dissolution date.

Use of Technology and Cookies

Sunstone may collect certain information about you through the use of technology, such as cookies. Cookies are pieces of information, or files, placed on your device’s disk that provide information including how and when pages on the Site are accessed by users. To find out more about cookies please visit www.allaboutcookies.org, or see www.youronlinechoices.eu which contains further information about behavioral advertising and online privacy.

We use the following types of cookies on our Site:
Required Cookies – These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.

Analytics Cookies – These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. Sunstone uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.

When visiting the Site, you may receive a pop-up consent banner informing you of our use of cookies and asking you to agree to allow us to use particular analytics cookies while you browse the Site. In the consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may also configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by Sunstone to help maintain and improve the information provided on this Site for users. Sunstone may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. Sunstone may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, Sunstone may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. Sunstone may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

Your Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding your personal information.

Cookies. As set forth above, you may limit cookies using the Site’s interface or using your browser setting. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Opt-Out of Third-Party Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional or marketing purposes, you can opt-out by sending us an email with your request to Info@Sunstonept.com.

We do not sell your personal information to third parties.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Subject to certain limitations and exceptions, the California law provides California residents the right to request (1) to know more details about the categories or specific pieces of personal information we collect, use, and disclose, (2) to request deletion of their personal information, and (3) to not be discriminated against for exercising these rights.

California residents may make a rights request by contacting us at Info@Sunstonept.com. We will verify your request by asking you to provide information related to your recent interactions with us.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please email us at Info@Sunstonept.com.

California Do Not Track Notice Disclosures

We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

General Data Protection Regulation (GDPR) Compliance

If you are a resident of the European Union or the United Kingdom, you may not use the Site.

Your Rights

The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask Sunstone for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, Sunstone may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information, we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request, you make because your rights are limited, we will inform you of the reasons as to why when responding.

Should you have any questions or requests in relation to your rights, please email Info@Sunstonept.com. We will attempt to deal with all requests at the earliest opportunity. In addition, if you have unresolved concerns, you have the right to complain, where permitted, to competent data protection authorities.

Links to Third-Party Websites

The Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. Sunstone encourages you to read the privacy policies of other websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

Updates to this Privacy Policy

Sunstone reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting, and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended. If we make significant changes, we will provide notice on the homepage of our website or through other means prior to the effectiveness of such changes.

Contact Us

Please direct any questions regarding Sunstone’s Privacy Policy to Info@Sunstonept.com.
Sunstone Properties Trust, LLC
2820 Townsgate Road, Suite 207
Westlake Village, CA 91361
p +1 818 699-6234