Privacy Policy

This Privacy Policy describes the privacy practices of NAI Global, a subsidiary of C-III Capital Partners (collectively, the “Company,” “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://www.naiglobal.com/(collectively, the “Service”), as well as through our marketing activities, our events, and other activities described in this Privacy Policy.

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.

You can download a printable copy of this Privacy Policy here.

California Residents: See the California privacy notice below for important information about our collection, use and disclosure of your personal information as well as your California privacy rights.

Table of Contents

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Choices
• Other Sites and Services
• Security
• International Data Transfer
• Children
• Changes to this Privacy Policy
• How to Contact Us
• California Privacy Notice
• How to Exercise Your Rights
• European Privacy Rights

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.
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
• 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, 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 — Some of the automatic collection described above is facilitated by 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 and helping us understand user activity and patterns.
• 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 and/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;
• 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 Company-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/or 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).
• Other users of the Service – Personal information that you choose to make publicly available on the Service may be accessed, copied, distributed and used by third parties outside of our control for any reason.
• Authorities and Others – Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance purposes described above.
• Business Transferees – Relevant participants (and their advisors) 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, the Company (including, in connection with a bankruptcy or similar proceedings).

Your Choices

You have the following choices with respect to your personal information. California residents and users located in the EU/UK/Switzerland can find additional information about their rights below.

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 info@naiglobal.com. 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 http://www.google.com/analytics/learn/privacy.html. 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 .

Do Not Track – Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Except as required by law, we currently do not respond to “Do Not Track.” 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.  You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

Children

The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 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: info@naiglobal.com
• Mail: New America Network, Inc. a Delaware Corporation d/b/a NAI Global 717 Fifth Avenue, 15th Floor, New York, NY 10022
• Phone: +1 212 405 2500

California Privacy Notice

Scope – This section applies only to California residents. It describes how we collect, use and disclose Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA, but does not include information exempted from the scope of the CCPA (such as information that is governed by the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act).

Your California Privacy Rights — As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information/Know — You can request the following information about how we have collected and used your Personal Information during the past 12 months:
• The categories of Personal Information that we have collected.
• The categories of sources from which we collected the Personal Information.
• The business or commercial purpose for collecting, sharing, and/or selling Personal Information.
• The categories of Personal Information that we sold or disclosed for a business purpose.
• The categories of third-parties with whom Personal Information was sold, shared, or disclosed for a business purpose.

• Access. — You can request a copy of the Personal Information that we have collected about you.
• Deletion. — You can ask us to delete the Personal Information that we have collected about you.
• Correction. — You can ask us to correct inaccurate personal information that we have collected about you.
• Nondiscrimination. — You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

How to Exercise Your Rights — You may submit requests to exercise your right by:

• Visiting https://www.naiglobal.com/ccpa-request-form/
• Calling us at +1 212 405 2500
• Emailing info@naiglobal.com

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information/know, access, deletion and correction requests and reserve the right to confirm your California residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury and/or provide additional information. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity. You may provide us with a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.

However, if you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.

Information Practices — The following describes our practices currently and during the past 12 months:

• Sources and Purposes – We collect all categories of Personal Information from the sources described in the section above entitled “Personal information we collect” and we use such Personal Information for the business/commercial purposes described in the section above entitled “How we use your personal information”.
• Sales and Sharing of Personal Information – We do “sell” or “share” Personal Information as those terms are defined in the CCPA , primary for targeted advertising purposes. Users are prompted to either accept, reject, or customize the cookies/trackers when visiting www.naiglobal.com via CookieYes. 
• Sensitive Personal Information – We do not use or disclose sensitive Personal Information for purposes that California residents have a right to limit under the CCPA.
• Retention – The criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
• Deidentification – We do not to attempt to reidentify deidentified information derived from personal information, except that we may do so to test whether our deidentification processes comply with applicable law.
• Collection and Disclosure – The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below.

European Privacy Rights

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis

We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented to a certain use of your personal data.
• Where we need to comply with a legal or regulatory obligation.

Data Controller

NAI Global, a subsidiary of C-III Capital Partners is the data controller of all personal data collected through our Service. To contact us, please email info@naiglobal.com.

If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager here: info@naiglobal.com.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources

We may obtain personal data and other information about you from public sources and through our third-party partners who help us provide our products and services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at info@naiglobal.com.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at info@naiglobal.com.

Use of your personal data for marketing purposes

We may use your personal data for marketing purposes, including to form a view on what we think may be of interest to you, and to decide which products, services, and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, if you have consented to our use of your personal data for marketing purposes.

Data Subject Rights

If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise your rights under the GDPR, please contact us at info@naiglobal.com.  Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.