Privacy Policy

Effective as of April 23, 2021

Please click here to view our Gramm-Leach-Bliley Financial Notice.

This Privacy Policy describes the privacy practices of Island Capital Group LLC and our subsidiaries and affiliates (collectively “Island Capital,” “we”, “us” or “our”) and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our websites and our investor portals located at https://investors.islandcapital.com/ (collectively, the “Service”).

In some cases we may provide a different privacy policy for a service that we offer or for a particular event, in which case that privacy policy will apply in accordance with its terms.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email and mailing addresses, residence, postal code, phone number, professional title, and organizational affiliation.
  
• Profile data, such as your username and password that you set to establish an online account with us, age, gender, biographical details, interests, preferences, information on your execution of certain account-related documents, and information that may be related to a service, account or an event you register for.
  
• Identity data, such as a national identification number (e.g., social security number where permitted, tax identification number, passport number), or state or local identification number (e.g., driver’s license or state ID number), which may be used to conduct Know Your Customer (“KYC”) checks and other screens permitted by law.
  
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
  
• Financial data, such as your economic or financial status, financial account details, investment holdings and preferences, and ability to invest.
  
• Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
  
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may obtain personal information from other sources, such as:

• Data providers, such as information services and data licensors.
  
• Business partners, such as joint marketing partners and event co-sponsors.
  

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
  

Cookies and similar technologies. Like many online services, we use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

• provide, operate and improve the Service and our business;
• execute your transactions;
• conduct KYC checks and other screens permitted by law;
• establish and maintain your user profile on the Service;
• enable security features of the Service, such as by sending you security codes via email and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development.We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We may send you Island Capital-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as IT, hosting, customer relationship management and support, print and mail fulfillment, data management, event services, email delivery, marketing, website analytics, and providers of background, credit, and other screening services).

Third parties related to the Service. Brokers, custodians, attorneys, auditors, insurers, administrators, investment funds and their respective managers and other non-affiliated third parties as necessary to provide the Service.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and operations purposes described above.

Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Island Capital or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your choices

You have the following choices with respect to your personal information.

Access or update your information.If you have registered for an account with us, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use Google Analytics to help us understand user activity on the Service. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage and about how Google protects your data at https://business.safety.google/compliance. You can prevent the use of Google Analytics relating to your use of our sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en-GB.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

You can reach us in the following ways:

Email: privacy@islecap.com

Mail: Island Capital Group LLC, 717 Fifth Avenue, 18th Floor, New York, NY 10022

Phone: (212) 705-5000