PRIVACY POLICY

General
Welcome to Griffin Capital’s website. This privacy policy (this “Privacy Policy”) only applies to information collection and use practices on the Griffin Capital website. This Privacy Policy is subject to the Terms and Conditions of Use. Griffin Capital’s website is directed to financial professionals, e.g., independent and insurance broker-dealers, national wirehouses, registered investment advisors and their employees, owners, directors, officers, and contractors (collectively, “Financial Professionals”), and our investors and employees.

Links
There might be links from the Griffin Capital website or portals on the Griffin Capital website to other websites. This Privacy Policy only applies to the Griffin Capital website and not to websites of any other company or organization linked to or through the Griffin Capital website, which may have different policies. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.

Gathering, Modifying and Removing Information
We may request and/or collect personal information on the Griffin Capital website that you might elect to provide to Griffin Capital (“Personal Information”) when, via the Griffin Capital website, you: (a) contact Griffin Capital; (b) use Griffin Capital services; and/or (c) send requests for information, questions, inquires, or comments to Griffin Capital. You are not required to provide Personal Information to access the Griffin Capital website. Personal Information may include: (a) contact information (e.g., name, address, phone number and email address); (b) information regarding certain of your preferences related to Griffin Capital or the Griffin Capital website; and/or (c) information regarding how you became aware of the Griffin Capital website.

If you would like to review, correct or remove your Personal Information, please contact Griffin Capital at the address listed under “Contact Us”. Griffin Capital will then make all reasonable efforts to correct your Personal Information from the Griffin Capital active database or discontinue the use of your Personal Information.

Gathering Anonymous Information
Griffin Capital might collect non-personal and aggregate information about the use of the Griffin Capital website, such as page hits, number of visits, web pages viewed and the length of visits to the Griffin Capital website (collectively, “Non-Personal Information”). Griffin Capital does not tie this Non-Personal Information to your Personal Information.

Use and Disclosure of Information
The Personal Information that you provide will be available to Griffin Capital, our agents, representatives and service providers and contractors, as appropriate, to be used to respond to your inquiries or questions about Griffin Capital and for the purposes indicated or which may reasonably be inferred by your voluntary provision of such Personal Information and otherwise in connection with the conduct of Griffin Capital’s business and operations. For Financial Professionals, this use may include periodic telephone calls and postal and email mailings from Griffin Capital about new products, services or upcoming events offered by Griffin Capital. Griffin Capital may also use your Personal Information, alone or in combination with the information submitted by other users, to improve our navigation or infrastructure. Also, we may use Non-Personal Information to improve your experience on the Griffin Capital website and to enhance the Griffin Capital website. Third party contractors or providers of services to Griffin Capital that have access to your Personal Information are also expected to protect such Personal Information in a manner consistent with this Privacy Policy and to use such Personal Information only to carry out the activities or services they are performing for you or for Griffin Capital. Griffin Capital might disclose Personal Information and Non-Personal Information, if in our opinion such disclosure is required: (a) by law; (b) to protect and/or defend Griffin Capital rights; and/or (c) to protect the personal safety of any individual. In addition, in the event that all or substantially all of Griffin Capital’s ownership and/or assets are transferred or sold to, or Griffin Capital is merged with, another entity, or there is a change of control of Griffin Capital, Griffin Capital may transfer Personal Information and Non-Personal Information to the successor entity. Investors may find more information about our privacy practices at our financial privacy notice.

Internet Communications
Communications and submissions over the Internet might not be secure. Please consider this fact before communicating or submitting any personal or confidential information through the Griffin Capital website.

Notice to California Residents (Do Not Track)
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how Griffin Capital responds to “Do Not Track” browser settings. Griffin Capital does not currently take actions to respond to Do Not Track signals.

Children’s Privacy
Our website is not directed to minors, and we do not knowingly collect personal information from minors.

Changes
Griffin Capital reserves the right to change, modify, amend and/or update this Privacy Policy at any time with or without prior notice at the sole and absolute discretion of Griffin Capital. Your use of the Griffin Capital website following any such changes, modifications, amendments and/or updates constitutes your unconditional agreement to follow and be bound by this Privacy Policy as so changed, modified, amended and/or updated. You are responsible for reviewing this Privacy Policy each time you use or access the Griffin Capital website.