EVOLVING REAL ESTATE
FOR THE NEXT GENERATION

Privacy Policy

Effective Date: October 26, 2026

We are committed to maintaining the privacy and security of your personal information. This Privacy Policy (“Policy”) describes the types of personal information Pacific Retail Capital Partners and its affiliates (“Pacific Retail,” “we,” “us,” and “our”) collect, how that personal information is used and disclosed, and your rights and choices regarding our use of your personal information.

This Policy explains our privacy practices when you engage with our services (the “Services”) which include our websites (“Websites”), emails, and other online services we control (together, the “Online Services”), or otherwise interact with us. This Policy also addresses personal information we collect from Pacific Retail job applicants. By accessing or using the Services, you confirm that you accept the terms of this Privacy Policy.

Please review the privacy policies of the properties we own and manage for information regarding their collection and use of personal information.

INFORMATION COLLECTION

In this Policy, “personal information” or “personal data” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include information that has been anonymized or de-identified in accordance with applicable law. The personal information we collect about you depends on your relationship with us, but may include the following.

  • Contact Information and Similar Identifiers. For example, we may collect your name, email address, mailing address, account username and password, alias, and phone number.
  • Device, Internet, and Network Activity Information. For example, if you use our Websites, we may collect information about your browser, device, operating system, signal strength, device identifiers, MAC address, advertising identifiers, and IP address. We might collect information about the website you came from, or the site you visit when you leave us. We may collect and record page interaction information and other electronic communications and content from your use of the Websites (such as content entry, mouse movements, screen captures, the date, time, and location of your visit, what areas of the Websites you visit and for how long, what search terms or other data you enter, and what content or links you view and click on). We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we, or our vendors, may send you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may engage or otherwise permit other parties to also collect information in these ways.
  • Communication Detail. For example, we may collect content of communications we receive, voicemail and recorded phone calls, mailed letters, calendar information, or other similar communications.
  • Financial Information. For example, we may collect business account payment details.
  • Geolocation Data. For example, we may collect the location of your device by inferring it from your IP address.
  • Audio-visual Information. For example, we may collect audio recordings of phone calls.
  • Employment-Related and Education Information. When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, and whether you need a visa or require sponsorship. We may also conduct a credit check, background check, and employment verification to the extent permitted by applicable law. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status. We may also collect your job title, qualifications, and information about your work experience when you interact with us in the business context, including as personnel of our vendors or existing or prospective commercial tenants or advertisers.
  • Inferences. For example, using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes and use them to create targeted-marketing audience segments, reports, and other models.

INFORMATION SOURCES

We may collect personal information from various sources including directly from you, indirectly when you use our Services, or from third parties such as social media platforms or advertising partners.

  • We collect personal information directly from you. For example, we collect information when you contact us or otherwise interact with us.
  • We collect personal information from your devices. For example, we use tracking tools like browser cookies and web beacons to passively collect information about you when you interact with our Websites, ads, or emails that we send to you.
  • We receive personal information from our affiliates. Affiliates of ours (i.e., companies that share common ownership or management control) may share information with us about you.
  • We receive personal information from vendors we hire to work on our behalf. For example, vendors that host or maintain our Websites or send promotional emails for us may give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information.
  • We receive information about you from other sources. Other parties may give us personal information about you. These other parties might include business and marketing partners that give us information they have collected either directly or indirectly from you. We may also receive employment-related information from your past employers or background screening companies. If you provide us with personal information about another person, you agree that you have their permission to do so.

INFORMATION USE

We use the above-referenced categories of personal information for the purposes set forth below.

  • We use information to provide our Services. For example, we use information in connection with the management, operation, leasing, acquisition, and divestiture of real estate holdings, developments, and properties.
  • We use information for marketing purposes. For example, we might use personal information to notify you of opportunities we think you might find interesting.
  • We use information to provide support and to respond to your requests or questions. We use information to contact you in response to your feedback or other matters related to our relationship with you.
  • We use information to test, develop, analyze, improve, and provide our Services. For example, we may use your information to make our Services better. We use your information to customize your experience with us and to conduct research and analysis regarding our customers, which may involve use of artificial intelligence.
  • We use information to comply with our legal obligations and support internal business operations. For example, we use personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; or to audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • We use information for security and safety purposes. For example, we may use personal information to protect the security of our company, customers, business partners and their respective personnel. We may also use personal information to protect our Services, as well as to detect and investigate activities that may be fraudulent, or otherwise illegal or prohibited (such as cybersecurity events or fraudulent transactions).

We also use personal information to evaluate job applicants for employment. We may also use personal information for other purposes if disclosed to you at time of collection. Additionally, we may de-identify and/or combine information that we have collected offline about you with information we collect online. Or we may combine information we get from another party with information we already have about you. We may also aggregate your information with other individuals’ information to understand preferences and trends over time.

INFORMATION DISCLOSURE

We disclose the types of personal information described above to the types of parties listed below.

  • We may share personal information with affiliated entities as well as our properties. We may disclose personal information to our affiliated entities and the properties we own or manage.
  • We may share your personal information with vendors and service providers who perform services on our behalf. For example, we may share personal information with vendors who assist us with the uses of personal information described in this Privacy Policy. This may include vendors who send emails for us; develop, enhance, or improve our Online Services; investigate and prevent data incidents; provide physical and digital security services; audit our business and financial statements; and provide legal advice.
  • We may share your personal information with advertising companies. For example, we may share information with companies that help us with our advertising and marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal information received by our advertising partners may also be subject to their own privacy policies and used for their own purposes. While we do not sell personal information in the traditional sense of the word, certain of our advertising activities may constitute a “sale” or “sharing” under state privacy laws. See the Privacy Rights Based on Jurisdiction of Residence section below for more information.
  • We may share your personal information with government, regulatory, or law enforcement agencies. For example, we may share personal information to respond to a court order or subpoena, or if a government agency or investigatory body requests it. We may also share your personal information in order to enforce our agreements and to protect our rights or the rights of others. We might also share your personal information when we are investigating a potential incident or fraud.
  • We may share your personal information as part of a transaction, merger, acquisition, financing, due diligence, bankruptcy, or other corporate event. For example, if part of our business (including any of our affiliates, divisions, and business units) is acquired by a third party, we may include personal information as part of that transaction. We may also share your personal information if there is a change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes.

If you choose to disclose personal information when you contribute content publicly through message boards, blogs, social media, reviews, or similar public forums on or related to the Websites, you voluntarily disclose any such content and personal information within such forums.

We may also share personal information for other reasons we may describe to you from time to time, with your consent, or as permitted or required by law.

COOKIES AND TRACKING TECHNOLOGIES

We use first-party and third-party cookies and similar technologies like pixels and web beacons (referred to collectively herein as “cookies” or “tracking technologies”) to collect information about your use of and interaction with our Websites. The information collected by these tracking technologies may include IP address, geolocation data, browser and device characteristics, operating system, language preferences, referring URLs, information about how and when you use the Website, and other technical details. We and our third-party partners utilize session cookies, which expire typically at the end of your visit to our Website, and persistent cookies, which are cookies that remain within your computer or mobile device over a period of time.

We may use some or all of the following types of cookies:

  • Strictly Necessary cookies. These are cookies that are required for the operation of the Website. They cannot be turned off.
  • Functional cookies. These cookies provide enhanced functionality and personalization. They remember choices you make and are used to recognize you when you return to the Website.
  • Analytics / Performance cookies. These cookies may be set by us or by third-party partners to allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the site.
  • Targeting / Marketing cookies. These cookies may be set by us or by our third-party advertising partners. They are used to track your online activity and deliver personalized advertisements. They may be used by third parties to build a profile of your interests and show you relevant ads on other sites. They may make advertising more relevant to you, limit how often you see an ad, and help measure the effectiveness of advertising campaigns, including across devices and over time.

You can opt out of Google Analytics directly by downloading Google’s Opt-Out Browser Add-on or Google Ads by visiting Google’s Ads Settings at https://adssettings.google.com. Some Internet browsers have “Do Not Track” or “DNT” features which, when turned on, send a signal to the website that the individual visiting the website does not wish to be tracked. Our Website does not honor DNT signals. However, you can control your cookie preferences in your Internet browser settings. Additionally, you can control your cookie preferences in our cookie preference center. See the section below titled “Privacy Rights Based on Jurisdiction of Residence” for additional rights that may be available to you based on your state of residence.

YOUR COMMUNICATION PREFERENCES

To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us. If you receive promotional text messages from us, you may opt out by replying “STOP,” or opt out of emails using the “unsubscribe” link. Even if you opt out of marketing messages, we may still send you transactional messages.

INFORMATION SECURITY

The security of your personal information is important to us. While we follow generally accepted security standards designed to safeguard the personal information submitted to us, it is not possible to guarantee the security or integrity of personal information. Therefore, we encourage you to take precautions to protect your personal information, including protecting your passwords and using secure networks to access the Internet.

INFORMATION RETENTION

We retain the personal information described in this Policy for as long as needed to satisfy the purpose for which it was originally collected or for which there is a legitimate business purpose. We determine the retention period for each category of personal information based on: (i) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (ii) any legal or regulatory requirements applicable to such information, (iii) internal operational needs, and (iv) the need for the information based on any actual or anticipated investigation or litigation. We may also maintain for an indefinite period of time certain personal information that has been de-identified. This information is no longer considered personal information and we commit not to attempt to re-identify such information.

CHILDREN’S DATA

Our Website is not directed to children under the age of 13. If we learn we have collected or received personal information from a child under 13, we will make reasonable efforts to delete that information.

INTERNATIONAL USERS

We operate in the United States. By using the Services, you acknowledge and agree that your personal information may be transferred, stored, and/or processed by us or our service providers in a country other than your country of residence, including but not limited to the United States, where laws regarding processing of personal information may be less stringent than the laws of your country of residence.

PRIVACY RIGHTS BASED ON JURISDICTION OF RESIDENCE

Depending on your jurisdiction of residence—for example, California, Indiana, New Jersey, Vermont, and Virginia—and your relationship with us, you may have some or all of the privacy rights listed below with respect to the personal information we maintain about you. Please note that these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  • Right to Confirm / Access / Know. You may have the right to request access to and obtain copies of personal information that we hold about you, including details relating to the ways in which we collect, use, and share your information. You may also have the right to obtain a list of third parties or the categories of third parties to which we have disclosed or sold personal information. Residents of California have the right to know the categories of personal information we have collected about them, the categories of sources from which the personal information is collected, the categories of personal information sold, shared, or disclosed, the business or commercial purpose for selling, sharing, or disclosing the personal information, and the categories of third parties to whom we have sold, shared, or disclosed their personal information. California’s “Shine the Light” law also permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
  • Right of Portability. You may have the right to receive a copy of the personal information we hold about you in a portable format and to request that we transfer it to a third party.
  • Right to Delete. You may have the right to request that we delete personal information we maintain about you.
  • Right to Correct. You may have the right to request that we correct inaccurate personal information we maintain about you.
  • Right to Withdraw Consent. You may have the right to withdraw your consent to the processing of your personal information.
  • Right to Opt-Out. You may have the right to opt out of certain uses of your personal information such as for (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. We do not engage in (iii), but you can opt out of activities (i) and (ii) by adjusting your cookie settings to reject all optional cookies. Additionally, if you visit our Website with the Global Privacy Control (“GPC”) opt-out preference signal enabled, where required by law, that signal will be treated as a request to opt out of “sale,” “sharing,” and targeted advertising. Learn more about the Global Privacy Control signal here. Please note your request (whether made through your cookie settings or the GPC signal) may apply only to the browser from which you submit the request—to opt out of offline sale or sharing, you must also contact us as set forth below.
  • Right to Appeal. You may have the right to appeal our decision if we decline to process your request in part or in full. You can do so by replying directly to our denial. If you are not satisfied with our response to your appeal, you may contact your state Attorney General.

Requests to exercise these rights may be made using the contact information listed at the end of this Policy or as otherwise set forth in this section. Only you, or as permitted by law, a person that you authorize to act on your behalf, may make a request related to your personal information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section provides additional disclosures for residents of California to satisfy the content requirements of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”) that are not already addressed elsewhere in this Policy.

CCPA Categories of Personal Information We Collect and How We Collect Them

We collect the following categories of personal information about California consumers. This information may be, or have been, collected directly from you, automatically when you use our Services, through third parties, or from publicly available sources.

  • Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, driver’s license number, or other similar identifiers.
  • Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, address, telephone number, credit card number, debit card number, or other financial information.
  • Characteristics of protected classifications under California or federal law, including age and date of birth, gender, race, ethnicity, veteran status, or disability.
  • Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, or information about a consumer’s interaction with our Website.
  • Geolocation data, including location data inferred from device or IP address as well as precise geolocation data.
  • Audio, electronic, visual, thermal, olfactory, or similar information, including photos or videos, or audio recordings of customer calls or support calls.
  • Professional or employment-related information, including information provided by job applicants and business contact information.
  • Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, or attitudes.
  • Sensitive Personal Information, including precise geolocation, username and password, and certain demographic information. We do not use sensitive personal information to draw inferences about consumers.

Use and Disclosure of CCPA Categories of Personal Information

We use the personal information we collect for the business and commercial purposes described in the “Information Use” section above. We also disclose the personal information we collect as described in the “Information Disclosure” section above.

CCPA Categories of Personal Information Sold or Shared

Under the CCPA, a “sale” of personal information does not necessarily involve an exchange of money. Instead, a sale also includes disclosures of personal information to third parties who may use the information for their own purposes, such as analytics and advertising partners. Similarly, under California law, “sharing” personal information refers to disclosing personal information to third parties for cross-context behavioral advertising. Per these definitions, we may sell and share the following categories of personal information to third-party analytics and advertising partners:

  • Identifiers
  • Personal Information described in Cal. Civ. Code § 1798.80(e)
  • Internet or other electronic network activity information
  • Geolocation data
  • Inferences
  • Sensitive Personal Information

We do not have actual knowledge that we sell or share the personal information of individuals between the ages of 13 and 15, but to the extent such occurs, it is done pursuant to opt-in consent via our cookie controls.

Privacy Rights for California Residents Relating to Your Personal Information

Please refer to the Privacy Rights Based on Jurisdiction of Residence section above for information regarding the rights you have with respect to your personal information and how to exercise them.

THIRD PARTY LINKS

Our Websites may contain links or references to other websites and services operated or controlled by third parties. For example, we may link to social media networking sites. Links or advertisements do not imply that we endorse or have reviewed such third parties or their privacy practices. For a description of how other sites handle your personal information, please refer to their privacy policies and terms of use.

CHANGES TO THIS POLICY

We may update this Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. If we make updates, we will post the updated version on this page and indicate the date the Policy was last updated. We encourage you to review this page from time to time to check for updates. By using the Services after changes to the Policy have occurred, you are deemed to have accepted such changes.

CONTACT INFORMATION

If you have any other questions or concerns relating to this Policy or our privacy practices or wish to exercise your privacy rights or choices, please contact us as follows:

Email: [email protected]

Mail:

Pacific Retail Capital Partners
2029 Century Park East

Suite 1550
Los Angeles, CA 90067

Phone: 310.641.8060

Website: https://pacificretail.com/contact/

We are committed to making this Policy accessible to everyone. If you encounter any difficulty accessing the information in this Policy or require access to it in an alternative format, please contact us.

Thank you for your interest.

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