Terms of Service

Service Description: Griffin Partners Inc. provides proprietary online and mobile tools on the Site to assist potential real estate investors in accessing the investment class of private market real estate (“the Service”). The Service allows investors to co-invest with Griffin Partners Inc. to maximize investment performance by executing a unique business plan for each asset.

Your Registration Obligations: You will be required to register with Griffin Partners Inc. in order to access and use certain features of the Service. By registering for the Service, you agree to provide and maintain true, accurate, current, and complete information about yourself as prompted by Griffin Partners Inc’s registration form. Registration data and certain other information about you are governed by the Privacy Policy that follows. Persons under 18 years of age are not authorized to use or access the Service under any circumstances at any time.

Member Account, Password, and Security: You are fully responsible for maintaining the confidentiality of your account and any password(s), and for any and all activities that occur under your account or password(s). You agree to (a) ensure that you completely exit from your account at the end of each user session when accessing the Service; (b) not share your account or your password with anyone else or any third party; (c) keep your password in a secure location; and (d) immediately notify Griffin Partners Inc. of any unauthorized use of your password or account, or any other breach of security. Griffin Partners Inc. will not be liable for any loss or damage arising from your failure to comply with this Section.

Modifications to Service: Griffin Partners Inc. reserves the right to modify or discontinue, temporarily or permanently, the Service (or any part thereof) with or without notice. You agree that Griffin Partners Inc. will not be liable to you or to any third party for any modification, suspension, or discontinuance of the Service.

General Practices Regarding Use and Storage: You acknowledge that Griffin Partners Inc. may establish general practices and limits concerning use of the Service, including without limitation the maximum period of time that data or other content will be retained, and the maximum storage space that will be allotted on Griffin Partners Inc.’s servers on your behalf. You agree that Griffin Partners Inc. has no responsibility or liability for the deletion or failure to store any data or other content maintained or uploaded in conjunction with the Service. You acknowledge that Griffin Partners Inc. reserves the right to terminate accounts that are inactive for an extended period of time. You further acknowledge that Griffin Partners Inc. reserves the right to change these general practices and limits at any time, at its sole discretion, with or without notice.

Mobile Services: The Service includes certain features that are available via a mobile device located in the Territory, including (1) the ability to monitor and make adjustments to your investment portfolio, (2) the ability to browse the Service from a mobile device, and (3) the ability to access certain services through a mobile application downloaded and installed on a mobile device (such application, “Application,” and such services collectively, “Mobile Services”). To the extent you access the Service through a mobile device, your wireless service carrier’s standard charges, data rates, and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Griffin Partners Inc. account information to ensure that your messages are not sent to the person that acquires your prior number.

License: Subject to the Terms of Service, Griffin Partners Inc. hereby grants to you a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to (i) install the Application on one mobile device located in the Territory and (ii) use the Application for your own personal use. For clarity, the foregoing is not intended to prohibit you from installing the Application for another device on which you also agreed to the Terms of Service. Each instance of the Terms of Service to which you agree grants you the aforementioned rights in connection with the installation and use of the Application on one device.

Open Source: The Application may contain or be provided together with open source software. Each item of open source software is subject to its own applicable license terms, which can be found at Griffin.com/open-source and/or in the Application documentation or the applicable Help, Notice(s), About, or source files. Copyrights to the open source software are held by the respective copyright holders indicated therein.   Griffin Partners Inc. provides no warranties to you and has no liability with respect to any open source software.

Borkerage Services: By using our website and/or conducting business with us, you acknowledge that as exclusively a brokerage services provider, Griffin Partners Inc. is not responsible for conducting all of the proper due diligence incumbent upon buyers, sellers, landlords, and tenants when buying, selling, or leasing commercial property. This due diligence includes but is not necessarily limited to matters of zoning, permitting, regulatory requirements, as well as financial underwriting of participating parties including research associated with bankruptcy, foreclosure, and financial capability. Neither Griffin Partners Inc. nor its employees, staff, or agents perform appraisals, provide tax or accounting services, or offer legal advice. Any and all parties involved in commercial real estate transactions should retain their own appraisal information as well as tax and legal counsel. Griffin Partners Inc. does not represent or warrant these matters, nor is it responsible for the statements of third parties.

User Conduct: You are solely responsible for any and all code, video, images, information, data, text, software, music, sound, photographs, graphics, messages, or other materials (“content”) that you upload, post, publish, or display (collectively, “upload”) or email or otherwise use via the Service. The following are examples of the kinds of content and/or use that are illegal or prohibited by Griffin Partners Inc. Griffin Partners Inc. reserves the right to investigate and take appropriate legal action against anyone who, in Griffin Partners Inc.’s sole discretion, violates this provision, including without limitation, removing the offending content from the Service, suspending or terminating the accounts of such violators, and reporting to law enforcement authorities. You agree to not use the Service to:

1) Email or otherwise upload any content that

1. Infringes any intellectual property or other proprietary rights of another party;
2. You do not have a right to upload under any law or under contractual or fiduciary relationships;
3. Contains software viruses or any other computer code, files, or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications equipment;
4. Poses or creates a privacy or security risk to any person; or
5. Is unlawful, harmful, threatening, abusive, harassing, tortious, violent, defamatory, vulgar, obscene, pornographic, libelous, racially or ethnically hateful, or otherwise objectionable;

2) Interfere with or disrupt the Service or servers or networks connected to the Service, or disobey any requirements, procedures, policies, or regulations of networks connected to the Service;

3) Violate any applicable local, state, national, or international law, or any regulations having the force of law;

4) Impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with a person or entity;

5) Further or promote any criminal activity or enterprise, or provide instructional information regarding the conduct of illegal activities; or

6) Obtain or attempt to access any materials or information through any means not intentionally made available or provided for through the Service.

Fees: There are fees and expenses (including any taxes) associated with investments you may make through the Service for which you will be responsible to pay. Any such fees will be disclosed in the offering documents with respect to such investments. 

Special Notice for International Use & Export Controls: Software available in connection with the Service and the transmission of applicable data, if any, is subject to United States export controls. No software may be downloaded from the Service or otherwise exported or re-exported in violation of U.S. export laws. Downloading or using the software is at your sole risk. Recognizing the global nature of the Internet, you agree to comply with all local rules and laws regarding your use of the Service, including as it concerns online conduct and acceptable content.

Commercial Use: Unless otherwise expressly authorized herein or in the Service, you agree not to display, distribute, license, perform, publish, reproduce, duplicate, copy, create derivative works from, modify, sell, resell, exploit, transfer, provide access to a third party or upload for any commercial purposes, any portion of the Service, use of the Service, or access to the Service. The Service is for your personal use only.

Consent to Electronic Transactions and Disclosures: Because Griffin Partners Inc. operates only on the Internet, it is necessary for you to consent to transact business with us online and electronically. Therefore, as part of doing business with us and our affiliates (“Our Affiliates”), you consent to our giving you certain disclosures electronically, either via the Site, or to the email address you provide to us. By agreeing to the Terms of Service, you agree to electronically receive all documents, communications, notices, contracts, and agreements (such as IRS Forms explained below) arising from or relating to your use of the Site and Service, including any notes you have purchased, your use of this Service, and the servicing of any notes you have purchased as either an investor of Griffin Partners Inc.(each, a “Disclosure”), from us, whether we are acting in the capacity as trustee or otherwise, or Our Affiliates. An IRS Form refers to any Form 1099, Schedule K-1, or other Form, Schedule or information statement, including corrections of such documents, required to be provided pursuant to U.S. Internal Revenue Service rules and regulations, and that may be provided electronically (each, an “IRS Form”), provided that you consent to such electronic delivery, as more fully described in the subscription document(s) applicable to you.

Electronic Communications: Any Disclosures will be provided to you electronically through griffinpartners.com, either on the Site itself or via electronic mail to the verified email address you provided. If you require paper copies of such Disclosures, you may write to us at the mailing address provided and a paper copy will be sent to you at a cost of up to $5.00. A request for a paper copy of any Disclosure will not be considered a withdrawal of your consent to receive Disclosures electronically. Any IRS Forms provided electronically will remain accessible for twelve (12) months following the end of the tax year to which the IRS Forms relate, or six (6) months after the date of issuance of the IRS Forms, whichever is later; after that time the IRS Forms may no longer be accessible electronically. We may discontinue electronic provision of Disclosures at any time and at our sole discretion, in which case we will provide you with paper copies.

Scope of Consent: Your consent to receive Disclosures and transact business electronically, and our agreement to do so, applies to any transactions to which such Disclosures relate, whether between you and Griffin Partners Inc. or between you and Our Affiliates. Your consent will remain in effect for so long as you are a User and, if you are no longer a User, will continue until such a time as all Disclosures relevant to transactions that occurred while you were a User have been made, subject to any special rules regarding consent to electronic delivery of IRS Forms, as more fully described in the subscription document(s) applicable to you.

Hardware and Software Requirements: Before you decide to do business electronically with Griffin Partners Inc. or Our Affiliates, you should consider whether you have the required hardware and software capabilities. In order to access and retain Disclosures electronically, you must satisfy the following computer hardware and software requirements: access to the Internet; an email account and related software capable of receiving email through the Internet; supported Web-browsing software (within the three most recent versions of Google Chrome, Microsoft Edge, or Firefox; Internet Explorer version 11 or higher; or Safari version 10 or higher); and hardware capable of running this software.

TCPA Consent: You expressly consent to receiving calls and messages, including auto-dialed and pre-recorded message calls, and SMS messages (including text messages) from Griffin Partners Inc., Our Affiliates, agents, and others calling at their request or on their behalf, at any telephone number(s) that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry.

Additional Mobile Technology Requirements: If you are accessing the Site and the Disclosures electronically via a mobile device (such as a smart phone, tablet, etc.), in addition to the above requirements you must ensure that you have software on your mobile device that allows you to print and save the Disclosures presented to you during the application process. These applications can be found for most mobile devices in the device’s respective “app store”. If you do not have these capabilities on your mobile device, please access the Site through a device that provides them.

Withdrawing Consent: You may not withdraw such consent as long as you have outstanding any investments made through the Site; provided, however, that you may withdraw consent to receive electronic delivery of IRS Forms, as more fully described in the subscription document(s) applicable to you. If you have no outstanding investments made through the Site and wish to withdraw consent to doing business electronically, you shall investorrelations@griffinpartners.com and we will terminate your registered user account within forty-eight (48) hours of receiving the request.

General.  Notwithstanding indications to the contrary in these Terms of Service, in no event shall anything contained herein be deemed to be a waiver, and we will not assert there has been a waiver, that would not be permissible under Section 14 of the Securities Act of 1933, as amended (the “Securities Act”), Section 29(a) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) or any other applicable provision of federal and state securities laws.

The securities offered on the Site have not been registered under the Securities Act, in reliance on the exemptive provisions of (i) Section 4(a)(2) of the Securities Act and Rule 506 of Regulation D promulgated thereunder (“Regulation D” or “Private Placements”), and/or (ii) Regulation A promulgated under the Securities Act (“Regulation A”). Securities sold through Private Placements are restricted and not publicly traded, and are therefore illiquid. Neither the U.S. Securities and Exchange Commission nor any state securities commission or other regulatory authority has approved, passed upon, or endorsed the merits of any offering on this Site.

Persons who are resident outside of the Territory are not allowed access to investment opportunities on the Griffin Partners Inc. Site. Our services (and certain pages of the Site) that relate to the viewing of actual investment opportunities or to making investments in the securities offered therein, may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules, or regulations of any governmental authority, or where Griffin Partners Inc. is not authorized to provide such information or services.

Investment overviews on the Site contain summaries of the purpose and principal business terms of the investment opportunities. Such summaries are intended for informational purposes only and do not purport to be complete, and each is qualified in its entirety by reference to the more detailed discussions contained in the investor document package relating to such investment opportunity—the most current version of each such document package being found at Griffinpartners.com. The information contained in the Site has been prepared by Griffin  Partners Inc. without reference to any particular user’s investment requirements or financial situation, and potential investors are encouraged to consult with professional tax, legal, and financial advisors before making any investment.

Griffin Partners Inc. is registered with the Securities and Exchange Commission as an investment adviser under the Investment Advisers Act of 1940. Financial advisory services are only provided to investors who become Griffin Partners Inc. "clients" pursuant to a written Client Agreement, after careful consideration as to whether such an agreement is suitable for their individual facts and circumstances.

There can be no assurance that an investment mix or any projected or actual performance shown on the Site will lead to the expected results shown, or perform in any predictable manner. It should not be assumed that investors will experience future returns, if any, comparable to those shown, or that any or all investors on the Site experienced such returns.

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK, AND MAY RESULT IN PARTIAL OR TOTAL LOSS.

You are urged to review our full disclosure and offering circulars with respect to the securities offerings on the Site, as well as the services provided by Griffin Partners Inc.

Service Content, Software, and Trademarks: You acknowledge and agree that the Service may contain content or features (“Service Content”) protected by copyright, patent, trademark, trade secret, or other proprietary rights and laws. Except as expressly authorized by Griffin Partners Inc., you agree not to modify, copy, frame, scrape, rent, lease, loan, sell, distribute, or create derivative works based on the Service or the Service Content, in whole or in part, except that the foregoing does not apply to your own “User Content” (as defined below) that you legally upload to the Service. In connection with your use of the Service, you will not engage in or use any data mining, robots, scraping, or similar data-gathering or extraction methods. If you are blocked by Griffin Partners Inc. from accessing the Service (including by blocking your IP address), you agree not to implement any measures to circumvent such blocking (e.g., by masking your IP address or using a proxy IP address). Any use of the Service or the Service Content other than as specifically authorized herein is strictly prohibited.

The technology and software (the “Software”) underlying the Service or distributed in connection therewith are the property of Griffin Partners Inc. , our affiliates and our partners. You agree not to copy, modify, create a derivative work of, reverse engineer, reverse assemble or otherwise attempt to discover any source code, sell, assign, sublicense, or transfer any right in the Software. Any rights not expressly granted herein are reserved by Griffin Partners Inc. The Griffin Partners Inc. name and logos are trademarks and service marks of Griffin Partners Inc. (collectively the “Griffin Trademarks”). Other company, product, and service names and logos used and displayed via the Service may be trademarks or service marks of their respective owners, who may or may not endorse or be affiliated with or connected to Griffin Partners Inc. Nothing in these Terms of Service or in the Service should be construed as granting, by implication, estoppel, or otherwise, any assignment, license or right to use any of Griffin Partners Inc. Trademarks or any other third party trademarks or service marks displayed on the Service, without our prior written permission in each instance. All goodwill generated from the use of Griffin Partners Inc. Trademarks will inure to our exclusive benefit.

Third Party Material: Under no circumstances will Griffin Partners Inc. be liable in any way for content or materials of third parties (including users), including, but not limited to, for any errors or omissions in any content, or for any loss or damage of any kind incurred as a result of the use of any such content. You acknowledge that Griffin Partners Inc. does not pre-screen content, but that Griffin Partners Inc. and its designees will have the right (but not the obligation) in their sole discretion to refuse or remove any content that is available via the Service. Without limiting the foregoing, Griffin Partners Inc. and its designees reserve the right to remove any content that violates these Terms of Service or is deemed by Griffin Partners Inc., in its sole discretion, to be otherwise objectionable. You agree that you must evaluate, and bear all risks associated with, the use of any content, including any reliance on the accuracy, completeness, or usefulness of such content.

User Content Transmitted Through the Service: With respect to the content, data, or other materials you input or upload through the Service (collectively, “User Content”), you represent and warrant that you own all right, title, and interest in and to such User Content, including, without limitation, all copyrights and rights of publicity contained therein. You hereby grant and will grant Griffin Partners Inc. and its affiliated companies a nonexclusive, worldwide, royalty free, fully paid-up, transferable, sublicensable, perpetual, irrevocable license to copy, display, upload, perform, distribute, store, modify, and otherwise use your User Content in connection with the operation of the Service, and the advertising, marketing, and promotion thereof.

You acknowledge and agree that any questions, comments, suggestions, ideas, feedback, or other information about the Service (“Submissions”), provided by you to Griffin Partners Inc. are non-confidential and Griffin Partners Inc. will be entitled to the unrestricted use and dissemination of these Submissions for any purpose, commercial or otherwise, without acknowledgment or compensation to you.

You acknowledge and agree that Griffin Partners Inc. may preserve content and may also disclose content if required to do so by law, or in the good-faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process, applicable laws, or government requests; (b) enforce these Terms of Service; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Griffin Partners Inc. , its users, and the public. You understand that the technical processing and transmission of the Service, including your content, may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

Either or both the Service and third parties may provide links or other access to external sites and resources on the Internet. Griffin Partners Inc. has no control over such sites and resources, and is not responsible for and does not endorse their content. You further acknowledge and agree that Griffin Partners Inc. will not be responsible or held liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, events, goods, or services available on or through any such site or resource. Any dealings you have with third parties found while using the Service are between you and the third party, and you agree that Griffin Partners Inc. is not liable for any loss or claim that you may have against any such third party.

You agree to release, indemnify, and hold Griffin Partners Inc. and its affiliates and their officers, employees, directors, and agents (collectively, “Indemnitees”) harmless from any and all losses, damages, and expenses, including attorneys’ fees, rights, claims, actions of any kind, and injury (including death) arising out of or relating to your use of the Service, any User Content, your connection to the Service, your violation of these Terms of Service, or your violation of any rights of another. Notwithstanding the foregoing, you will have no obligation to indemnify or hold harmless any Indemnitee from or against any liability, losses, damages, or expenses incurred as a result of any action or inaction of such Indemnitee. If you are a California resident, you waive California Civil Code Section 1542, which says: “A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor.” If you are a resident of another jurisdiction, you waive any comparable statute or doctrine.

Your use of the Service provided by Griffin Partners Inc. is at your sole risk. The Service is provided on an “as is” and “as available” basis. Griffin Partners Inc. expressly disclaims all representations and warranties of any kind, whether express, implied or statutory, including but not limited to the implied warranties of merchantability, fitness for a particular purpose, title, and noninfringement.

Griffin Partners Inc. makes no warranty that (i) the Service  will meet your requirements, (ii) the Service will be uninterrupted, timely, secure, or error-free, (iii) the results that may be obtained from the use of the Service will be accurate or reliable, or (iv) the quality of any products, services, information, or other material purchased or obtained by you through the Service will meet your expectations.

You expressly understand and agree that Griffin Partners Inc. will not be liable for any indirect, incidental, special, consequential, exemplary damages, or damages for loss of profits, including but not limited to damages for loss of goodwill, use, data, or other intangible losses (even if Griffin Partners Inc. has been advised of the possibility of such damages), whether based on contract, tort, negligence, strict liability, or otherwise, resulting from: (i) the use or the inability to use the Service; (ii) the cost of procurement of substitute goods and services resulting from any goods, data, information, or services purchased or obtained, or messages received or transactions entered into through or from use of the Service; (iii) unauthorized access to or alteration of your transmissions or data; (iv) statements or conduct of any third party on the service; or (v) any other matter relating to the Service. In no event will Griffin Partners Inc.’s total liability to you for all damages, losses, or causes of action exceed the amount you have paid Griffin Partners Inc. in the last six (6) months, or if greater, one hundred dollars ($100).

Some jurisdictions do not allow the disclaimer or exclusion of certain warranties or the limitation or exclusion of liability for incidental or consequential damages. Accordingly, some of the above limitations set forth above may not apply to you or be enforceable with respect to you. If you are dissatisfied with any portion of the Service or with these Terms of Service, your sole and exclusive remedy is to discontinue use of the Service.

If you are a user from New Jersey, the foregoing sections titled “Disclaimer of Warranties” and “Limitation of Liability” are intended to be only as broad as is permitted under the laws of the state of New Jersey. If any portion of these sections is held to be invalid under said state law, the invalidity of such portion shall not affect the validity of the remaining portions of the applicable sections.

You agree that Griffin Partners Inc., in its sole discretion, may suspend or terminate your account on the Site (or any part thereof) or use of the Service and remove and discard any content within the Service, for any reason, including, without limitation, for lack of use or if Griffin Partners Inc. believes that you have violated or acted inconsistently with the letter or spirit of these Terms of Service. Any suspected fraudulent, abusive, or illegal activity that may be grounds for immediate termination of your use of the Service, and may be referred to appropriate law enforcement authorities. Griffin Partners Inc. may also in its sole discretion and at any time immediately discontinue providing the Service, or any part thereof, with or without notice. You agree that any termination of your access to the Service under any provision of this Terms of Service may be effected without prior notice, and acknowledge and agree that Griffin Partners Inc. may immediately deactivate or delete your account and all related information and files in your account, and/or bar any further access to such files or the Service. Further, you agree that Griffin Partners Inc. will not be liable to you or any third party for any termination of your access to the Service.

Any controversy or claim arising out of or relating to this agreement are to be settled by binding arbitration in the state of Texas or another location mutually agreeable to the parties. The arbitration shall be conducted on a confidential basis pursuant to the Commercial Arbitration Rules of the American Arbitration Association. Any decision or award as a result of any such arbitration proceeding shall be in writing and shall provide an explanation for all conclusions of law and fact and shall include the assessment of costs, expenses, and reasonable attorneys' fees.   An award of arbitration may be confirmed in a court of competent jurisdiction.  The agreement to arbitrate requires (with limited exception) that (1) you will only be permitted to pursue claims against Griffin Partners Inc. on an individual basis, not as a plaintiff or class member in any class or representative action or proceeding; (2) you will only be permitted to seek relief (including monetary, injunctive, and declaratory relief) on an individual basis; and (3) you may not be able to have any claims you have against us resolved by a jury or in a court of law.

With respect to any disputes or claims not subject to arbitration, as set forth above, you and Griffin Partners Inc. agree to submit to the personal and exclusive jurisdiction of (i) the United States District Court for the Eastern District of Virginia (Alexandria division), or (ii) solely to the extent there is no applicable federal jurisdiction over such dispute or matter, in the Circuit Court for Fairfax County, Virginia. The failure of Griffin Partners Inc. to exercise or enforce any right or provision of these Terms of Service will not constitute a waiver of such right or provision. If any provision of these Terms of Service is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties’ intentions as reflected in the provision, and the other provisions of these Terms of Service remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Service or these Terms of Service must be filed within one (1) year after such claim or cause of action arose, or be forever barred.

These Terms of Service constitute the entire agreement between you and Griffin Partners Inc. and govern your use of the Service, superseding any prior agreements between you and Griffin Partners Inc. with respect to the Service. You also may be subject to additional terms and conditions that may apply when you use affiliate or third-party services, third-party content, or third-party software. These Terms of Service will be governed by the laws of the state of Texas, without regard to its conflict of law provisions.

A printed version of this agreement and of any notice given in electronic form will be admissible in judicial or administrative proceedings based upon or relating to this agreement, to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. You may not assign these Terms of Service without the prior written consent of Griffin Partners Inc., but Griffin Partners Inc. may assign or transfer these Terms of Service, in whole or in part, without restriction. The section titles in these Terms of Service are for convenience only, and have no legal or contractual effect. Notices to you may be made via either email or regular mail. The Service may also provide notices to you of changes to these Terms of Service, or other matters by displaying notices or links to notices generally on the Service.

This Data Privacy Policy (“Privacy Policy”) discloses the associated practices for Griffin Partners Inc., including those regarding “Personal Information” defined below. This Privacy Policy applies to Personal Information collected through our website, but does not apply to any Personal Information collected by third-party websites or apps not operated by Griffin Partners Inc. By accessing the Site and/or using our Services, you are consenting to our use of your Personal Information in accordance with this Privacy Policy.

We only have access to and collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.  We use your information to identify you, such as your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used for identification purposes.

Site Visitors. We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Services without revealing your identity or providing any Personal Information. However, if you wish to become an “Investor,” then we require you to provide certain Personal Information.

Investors. If you choose to access our Services as an Investor, Griffin Partners Inc. requires that you complete a registration form. An Investor is an individual who is over the age of 18, who resides in the Territory, and who has completed the registration process on the Site. Our registration forms will specify the information which you must provide in order to access the particular features to which you wish to subscribe, which may include such items as (i) name; (ii) email address; (iii) cell and land-line phone number; (iv) mailing address; (v) social security number (for IRS tax-reporting purposes); and (vi) birth date. Our registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Privacy Policy. Upon completion of our registration process, you will receive a user name and password.

We may also require you to provide information designed to verify your identity. This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law. Additionally, you may be requested to provide certain financial information. For example, we require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your social security number (or Taxpayer Identification Number, where applicable).

Furthermore, Griffin Partners Inc. policy requires that you provide us with certain account and other payment information, such as information needed to make payment via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.

Tenants. To rent an accommodation, we require you to complete an application and provide us your first and last name, home or other physical address, your telephone number, your e-mail address or other personal contact information, credit card number, social security number or other non-public financial information. You may choose not to provide your personal information; however, you will not be able to rent an accommodation with us.

Background Checks. We will use personal information disclosed by you to conduct background checks. We may verify any information that you submit to us in connection with your application for a lease through any means, including any consumer or criminal record reporting agencies, personal and professional references, employers, and other rental housing owners.

Automatically-Collected Information. Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our server the following information:

·  Logs from your browser;

·  Your Internet protocol (IP) address and location;

·  Your computer’s name;

·  Referrer addresses;

·  The type and version of your Web browser; and

·   Your operating system.

We also record page views (hit counts) and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes. We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our Web server before arriving at the destination Web page. We track this click-through data to help determine interest in particular topics, and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.

We use your Personal Information for the following business purposes to:

· Process transactions that you have authorized us to make;

· Facilitate your activities with respect to our Site;

· Contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;

· Verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are whom they claim to be;

· Prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including for example, activities prohibited by the Anti-Money Laundering Act;

· Help us operate our Site;

·  Deliver notices regarding your account;

·  Comply with IRS requirements, and for tax-reporting purposes;

·  Provide you with information, such as notices of investment opportunities via our Site, or updates concerning investments in which you have participated;

·  Send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information;

·  Enforce this Privacy Policy and our Terms of Service;

·  Conduct user surveys and questionnaires; and

·  Comply with applicable law.

We use aggregated information to analyze the effectiveness of our Site, to improve our Service, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Service and the characteristics of visitors to our Site, and may share aggregated information with third parties, including “Advertisers” as defined below. We may collect aggregated information through features of the software that support our Service through cookies, and through other means described in this Privacy Policy. To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine (i) the Personal Information an Investor provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.

Legal Requirements. We may disclose your personally identifiable information or otherwise use such information to communicate with you if required or permitted to do so by law, or in the good-faith belief that such action is necessary to: (i) conform to legal requirements or comply with legal process or any governmental request; (ii) protect and defend our rights or property; (iii) enforce our applicable service agreements; or (iv) protect the personal safety or interests of our employees and consultants, other users of the website, or members of the public in urgent circumstances. We may also disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

We do not disclose your Personal Information to unaffiliated third parties, except as provided in this Privacy Policy as follows:

Service Providers. To assist us in running our business and to perform certain services and functions, we may share your Personal Information with third-party providers of hosting, payment-processing, email communication and customer support services, analytics, marketing, and advertising service providers (including Google, IMPAK Solutions, and CrowdStreet Connect, among others), or companies providing integrated services to us as part of our product or Service. We will share with our Service Providers only that information necessary for them to perform their functions, and we require them to commit to refrain from using your Personal Information for any other purpose, i.e., they cannot use  such information to separately market to or contact you.

For customers who choose to link their bank accounts, we use to facilitate the automatic connection with, and gather required transaction data from, your financial institution. By using our joint services, you grant us and < transfer service > the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution.

Affiliates. We may share information with our affiliates, defined as an entity that controls, is controlled by, or is under common control with Griffin Partners Inc. Our affiliates are bound by this Privacy Policy and may use the Personal Information we share in a manner consistent with this Privacy Policy.

In Connection With a Corporate Transaction. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Griffin Partners Inc. or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information under obligations of confidentiality in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.

A “cookie” is a small amount of data, often including a unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive.

We use both “session” cookies and “persistent” cookies as follows:

Session cookies: We use session cookies that expire when you close your browser, in order to improve navigation on our Site and to collect aggregate statistical information. Because these cookies are strictly necessary to use the Site, you cannot refuse them.

"Persistent" cookies: Persistent cookies are bits of information that are placed on the hard drive of your computer, and can remain there for extended periods of time. Persistent cookies also enable us to provide enhanced, more personal features (such as showing/hiding notifications), and track and target the interests of our users to enhance the experience on our Site. The types of persistent cookies used on the Site are described in more detail below.

You may set your browser so that it does not accept cookies, and you may also use the direct opt-out tools provided by the parties described. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Service. We may also use so-called “pixel tags”—small graphic images (also known as “Web beacons” or “single-pixel GIFS”)—to tell us what parts of our website have been visited, and/or to measure the effectiveness of searches user perform on our Site. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on our Site. Pixel tags inform us whether emails have been opened, to help ensure that our messages are of interest to our registered users. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.

In particular, the Site uses:

Google Analytics, a service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users interact with the Site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators, and providing other services relating to Site activity and Internet usage—including tracking which pages of our Site you visit, so we can optimize your experience. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have implemented the IP 5 anonymization feature in Google Analytics, which anonymizes your IP address to protect individual privacy. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout.

Third-party advertising cookies and pixels, in connection with our marketing programs, including Google, IMPAK Solutions, and CrowdStreet Connect. We do not use such tools for marketing or re-targeting purposes in relation to users located outside the U.S.

Links to Other Sites

This privacy statement applies only to Personal Information collected by Griffin Partners Inc. Our Site contains links to other sites that are not owned or controlled by Griffin Partners Inc, and we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site, and to read the privacy statements of each and every website that collects personal information

We have put in place commercially reasonable security systems designed to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Personal Information against loss, theft, and unauthorized use, disclosure, or modification. Nevertheless, there is no such thing as 100% security of the networks, servers, and databases we operate, or that are operated on our behalf; for example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent possibilities and understand that you submit at your own risk.

We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

Griffin Partners Inc. is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone, and applying the relevant accessibility standards.

Conformance Status. The Web Content Accessibility Guidelines (WCAG) defines requirements for designers and developers to improve accessibility for people with disabilities. It defines three levels of conformance: Level A, Level AA, and Level AAA. Griffinpartners.com is fully conformant with WCAG 2.1 level AA. “Fully conformant” means that the content meets the accessibility standards without any exceptions.

In general, you may browse the Site without providing Personal Information. However, if you choose not to provide certain Personal Information through this Site, we may not be able to provide certain services or process certain requests. You will not be able to become an Investor or use all of the features and products that we offer through this Site.

Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain Personal Information on the Site. Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. However, please note that:

· We may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;

·  If you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated Services;  

·  Certain Personal Information may remain in our databases following the deletion of your account; and

·  You may not remove de-identified, anonymous, or aggregate data from our databases.

Any deletion requests may be sent to investorrelations@griffinpartners.com.

If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “Unsubscribe” link included in those emails, or by contacting us via email at investorrelations@griffinpartners.com. Please understand that you will not be allowed to opt-out of transactional notices, or other legal and related notices concerning your relationship to the Site or your account.

 This Site is not directed to children (persons under the age of 18), and use of the Site by such persons is not permitted. We do not knowingly seek to collect or maintain Personal Information or other information from minors, and will use commercially reasonable efforts to delete any Personal Information or other data later determined to be provided by them. If you become aware that a minor has provided Personal Information through our Site, please email us at webmaster@griffinpartners.com