Privacy Policy

NORTHWOOD – WEBSITE PRIVACY POLICY

Effective Date: [•] May 2018

GENERAL

Northwood Investors LLC and its affiliates (“Northwood”) are committed to protecting the privacy of our website visitors. This Privacy Policy seeks to help you understand how we collect and process information about you when you visit our website, and how we use such information. For the purposes of EU data protection laws, Northwood is the data controller (i.e. the company responsible for, and which controls the processing of your personal information). This Privacy Policy does not address our privacy practices concerning any personal information we collect as to our investors; we address those practices in separate notices sent to our investors or potential investors.

This Privacy Policy applies when you visit this website. Please note that this Privacy Policy applies only to this website, and not to any other website that may be linked to it. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

If you have any questions or comments about this Privacy Policy, you can e-mail us at privacy@northwoodinvestors.com or write to us at Privacy Matters, Northwood Investors LLC, 575 Fifth Avenue, 23rd Floor, New York, NY 10017.

HOW WE COLLECT, USE, SHARE AND PROTECT YOUR INFORMATION

We do not collect any personal information from you through our website except as described below. Personal information is any information that personally identifies you or from which you are identifiable, such as your name, postal address, e-mail address, or credit card information.

Website Visits: In general, we automatically gather certain technical information from our website visitors through our automatic data collection tools, including server logs, which may collect certain standard information that your browser sends to the website such as the number and frequency of your visits. This information may include the URL of the last and next website you visit, your browser and operating system, your IP address, how long you spend on our website and what pages you view here. We may use this information on an aggregate basis to understand better how our visitors use our website, research our visitors’ demographics, interests, and behavior, improve our website, provide visitors with customized services and information, and for other similar purposes.

Please see below for information concerning our use of cookies and other tracking technologies.

We do not control any cookies, web beacons or other similar devices that may be placed on our website by third parties.

Other: We will collect any other personal information from you if you voluntarily provide it through our website—such as by providing your e-mail address and other personal information to receive further information about us—and will use such personal information for the purpose of processing and responding to your inquiries and requests, and to improve our website and offerings. You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to contact you and respond to your requests and enquiries; (ii) for business administration, including statistical analysis; (iii) to personalize your visit to the website and to assist you while you use the website; (iv) to improve the website by helping us understand who uses the website; and (v) to comply with applicable laws, regulations or codes of practice.

We may share your non-personally identifiable information with others, such as investors, for informational or promotional purposes. Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data.

YOUR RIGHTS

Individuals in the EEA (“European Economic Area”) have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the: (i) right to request access to and rectification or erasure of their personal information; (ii) right to obtain restriction of processing or to object to processing of their personal information; and (iii) the right to data portability. Individuals in the EU also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.

If you have any questions as to this Privacy Policy, or wish to notify us of any errors or changes as to any personal information you provide us through this website, or if you are based in the EEA and would like to exercise your data subject rights, you can e-mail us at privacy@northwoodinvestors.com or write to us at Privacy Matters, Northwood Investors LLC, 575 Fifth Avenue, 23rd Floor, New York, NY 10017.

We may use service providers to facilitate our services and perform functions on our behalf, such as providing technical, analytical and hosting functions for our website. We may also share your personal information with affiliates of Northwood and with advisers of Northwood. These companies and individuals may have access to your personal information we collect through our website, as permitted by law and as needed to perform their functions in compliance with the privacy practices and policies of Northwood but may not use it for any other purpose. We require that these companies and individuals otherwise keep this information confidential. Northwood reserves the right to transfer any and all information that we collect from users, or that we otherwise collect in connection with the website, including, without limitation, to third parties, in the event of any liquidation or dissolution, or a sale or transfer of assets or of any portion of, our business. We will not otherwise share your personal information, except as required by law, requested by governmental entity or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to liability. We can (and you authorize us to) disclose any of your information in such circumstances.

The security of your information is important to us. We employ several different technical, administrative and physical security measures to protect any personal information you provide through our website from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use our website and send us such information at your own risk. Northwood retains your personal information for as long as necessary to fulfil the purposes for which such personal information was collected and in compliance with applicable laws or otherwise for a period of 26 months.

COOKIES

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our website, we may place a “cookie” or other online tracking device (e.g. Web beacons) in order to improve your experience by recognizing you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your Internet Protocol (“IP”) address or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.

We also use cookies provided by Google Analytics to help us measure how visitors use the website. The information collected is used for a variety of purposes, including, but not limited to, site traffic reporting, unique visitor counts, and content optimization. Although Google Analytics logs the information coming from the website on our behalf, we control how the data may and may not be used. If you do not want to help us learn how to improve the website, you can opt-out of this website analysis tool by clicking: http://tools.google.com/dlpage/gaoptout.

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.

INTERNATIONAL USE

You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and website access. When you are located in the EEA, personal information collected from you, including via the website, will be transferred to recipients in countries located outside the EEA, (including the United States where this website is hosted) which do not provide a similar or adequate level of protection to that provided by countries in the EEA. You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You can withdraw your consent at any time.

PRIVACY POLICY CHANGES

 We may revise or supplement this policy from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a prominent announcement on our website prior to the change becoming effective. You may determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date noted at the top of this page. We encourage you to refer to this policy on an ongoing basis so that you understand our current Privacy Policy.

Effective Date: [•] May 2018

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