Privacy Policy

Cobblestone Real Estate – Privacy Notice

Effective Date: 12/17/2020

This Privacy Notice (“Notice”) applies to all Cobblestone Real Estate (“Cobblestone,” “we,” “us,” “our”) sites on which it appears (the “Sites”). This Notice governs data collection and usage in connection with your interactions with us when you use our Sites.

This Notice does not apply to information which does not reasonably permit the identification of a household or individual, to anonymized or aggregated data, or to the websites of third parties linked to from our Sites. 

1. Information We Collect

Information You Give Us. Cobblestone may collect information that you provide when you visit our Sites, including to support actual or potential investments in one or more of our offerings. For example, we may collect name, home or other physical address (including street name and name of a city or town, e-mail addresses, phone numbers, tax identification or social security numbers (e.g., if you are an investor),  financial information, other identifiers that permit physical or online contact of a specific individual, and information concerning users that we maintain in a personally identifiable form in combination with any other information described in this section. 

Automatically Collected Information. When you visit our Sites or use our online services, we may automatically collect information that your browser or device provides. This information may include: your IP address; the type of browser, devices and operating systems you use; identifiers associated with the device(s) you use to access our Sites; the pages you visit and the features you use; access dates and times; if you navigated from or navigate to another website, the address of that website; and information regarding your internet service provider. 

In addition, we may collect information about your activities on our sites via first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as Data Tools.

We may allow third parties to use Data Tools on our sites. The information collected by Data Tools may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy notices. Information collected by Data Tools may be used on this site or on other websites or services, including those that may not be operated by us. Other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses our web sites or online services.

Email. We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you.

Information from Other Sources. We may obtain information about you from our affiliates, partners, and other third parties. This information may include information about your use of our Sites, your use of other websites, your interests and preferences and other information about you or your household. We may combine the information we obtain from third parties with information that we or our affiliates have collected about you.

2. How We May Use the Information We Collect

Cobblestone uses your information to conduct its business, operate its websites, and support actual or prospective investments in our offerings, including to: 

• Facilitate our everyday business purposes, such as establishing and managing your account, providing our Sites, and offering investments or investment management options to you;
• Manage our business and to protect ourselves, you, and other persons;
• Monitor and analyze traffic and page visits for our Sites and related online services;
• Comply with our policies and obligations, including, but not limited to, providing disclosures and responses related to any requests from law enforcement authorities or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order, regulatory authority of competent jurisdiction, discovery request, advice of counsel or similar legal process;
• Protect against illegal activity, fraud, and potential improper use of our Sites and related online services, which may involve the processing of IP addresses and location information associated with those IP addresses;
• Investigate suspected misconduct or violation of our policies;
• Troubleshoot problems;
• Communicate with you through telephone, email, direct mail or using other contact information we may have about you, as permitted by law; and
• Protect the legal rights or interests of ourselves and others.

We may use the information we gather for other purposes where you consent. 

3. Information We Share

We may disclose the information we gather with our affiliates and third parties. For example, we may share information with:  

• Service providers and/or data processors that perform services and functions at our direction, on our behalf, or in support of our business. This includes Juniper Square, which facilitates our investor portal. Juniper Square may use your information according to their privacy policy, for which we are not responsible.
• Other third-parties for our business purposes or as permitted or required by law, including:
  • To comply with any legal, regulatory or contractual obligation, or with any legal or regulatory process (such as a valid court order or subpoena) or advice of counsel;
  • For audit or diligence purposes; 
  • To third parties to market their investments, products or services to you;
  • To establish, exercise, or defend legal claims or our policies;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, or others; or
  • In connection with the purchase, sale, merger, consolidation or transfer of all or part of our business, whether potential or actual. 

We may also disclose information we gather in order to fulfill the purposes for which you provide it consistent with the context in which the personal information was collected or for other purposes with your consent.

4. Your Choices

As of the Effective Date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.

Your browser and your device may provide you the option to limit the use of cookies or other Data Tools. You should consult documentation for your browser or device for more information. You may not be able to use all features of our Sites if you limit the information you share with us. 

You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails and adjusting your email preferences.

If you are an investor, we may provide access to a portal which enables automated investment operations, investment reporting, and related investor tools and functionality. By accessing this portal, investors may update their information. 

5. Security of Your Personal Information

We use administrative, technical, and physical security designed to safeguard personal information in our possession. However, we cannot guarantee the security of the information that we collect and store. 

6. Updates to this Notice

We reserve the right to modify our privacy policies from time to time. If we do, we will notify you of these changes by adjusting this Notice and updating the Effective Date listed above. We encourage you to periodically review this Notice to be informed of how Cobblestone is handling your information.

7. How to Contact Us

You may contact us at:

Oakbrook Terrace Atrium

17W220 22nd Street, Suite 220, 

Oakbrook Terrace, IL 60181

Phone:  (630) 352-0872

Email Address: ehagen@cobblestoneassets.com