Guggenheim Real Estate: Privacy Policy

Guggenheim Real Estate LLC ("Guggenheim Real Estate") is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. As required by law, we are providing this privacy notice to help you understand how we handle the personal nonpublic information about you that we collect and how we use it to service your account. For purposes of this document, the term "our customers" and "you" refers to you whether you are a current or former investor or whether you are just browsing our website located at www.guggenheimrealestate.com ("Website").

Categories of Nonpublic Personal Information that We Collect
Guggenheim Real Estate collects nonpublic personal information about you that is provided to us by you or obtained by us with your authorization. This includes financial and any other information about you that is nonpublic and personally identifiable. We use the information collected about you in order to provide you with better service. We may collect confidential personal information about you from the following sources:

Subscription documents or forms (i.e., name, address, Social Security number, e-mail address, phone number, assets, income and sources of funds);
Transactional activity in your accounts (i.e., trading history and balances);
Other interactions within Guggenheim Real Estate (i.e., discussions with employees);
Other general information, such as data from public records; and
As required by the USA PATRIOT Act or other applicable laws, we also collect information and take actions necessary to verify your identity

In addition, when you visit Guggenheim Real Estate's Website, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Website design and functionality. When you use the contact features of the Website, you consent to the review and internal use of your communication by Guggenheim Real Estate. If our customers visit the Website, we may use a "cookie" in order to provide better service, to facilitate our customers' use of the Website, to track usage of the Website, and to address security hazards. A cookie is a small piece of information that a website stores on a personal computer and which it can later retrieve.

Disclosures to Third Parties
We do not sell your personal information to third parties for any reason. We do not disclose your nonpublic personal information to unaffiliated third parties who may want to offer you their own products and services unless you have requested or authorized us to do so. We may, however, disclose nonpublic personal information about our customers as permitted or required by law. For example, nonpublic personal information about customers may be disclosed in connection with a subpoena or similar legal process, to prevent or investigate fraud or other illegal activity, for risk management and security purposes, and to record documents in public records as may be required by law or regulation.

Disclosure to Affiliates and Third Party Service Providers
Guggenheim Real Estate is affiliated with a number of companies, including operations and servicing affiliates. We may disclose nonpublic personal information about our customers to our affiliates in order to provide our customers with access to product offerings and product upgrades, and in order for our affiliates to provide services to us, such as data processing, account servicing, and reporting purposes. We also may disclose nonpublic personal information about our customers to nonaffiliated third parties, with whom we have contracted to perform services on our behalf, such as, outside counsel and auditors, printing, mailing, fraud detection and prevention, and data processing services, as well as custodians, third party administrators and banks. Companies that act on our behalf are contractually obligated to keep the information we provide to them confidential and to use the nonpublic personal information we share only to provide the services we ask them to perform for you and us. We may disclose to our affiliates and these non-affiliated companies all of the information that we collect, as described above.

Confidentiality and Security
Guggenheim Real Estate considers the protection of personal information to be a sound business practice and a foundation of customer trust. We protect personal information we collect about you by maintaining physical, electronic and procedural safeguards that meet applicable legal requirements. For example, for the security of your online session with us, we may make use of firewall barriers, encryption techniques and authentication procedures.

In addition, within Guggenheim Real Estate, we restrict access to confidential personal information about you to those employees who need to know that information to provide investment products or services to you. Our employees are bound by a code of ethics and other requirements that require them to maintain the confidentiality of your nonpublic personal information. Employees who violate these requirements are subject to disciplinary action, up to and including termination.

Unfortunately, no data transmission can be guaranteed to be absolutely secure. As a result, while we strive to protect your personal information, Guggenheim Real Estate makes no representations or warranties with regard to the sufficiency of these security measures. Guggenheim Real Estate shall not be responsible for any actual or consequential damages that result from a lapse in compliance with this Privacy Policy as a result of a security breach or technical malfunction. In the event of a breach of the confidentiality or security of your nonpublic personal information, we will notify you as necessary so you can take appropriate protective steps. Unless you indicate otherwise, we may notify you under such circumstances using the e-mail address you provided to us.

Accuracy of Your Information
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please call or write to us, so that we may update or correct your information.

Upon your written request, we also will make available for your review any file we maintain containing your personal information. However, any information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If you notify us that any information in such file is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in any future disclosure of the disputed information.

Retention and Disposal of Your Personal Information
We endeavor to keep your personal information only for so long as is necessary for business purposes or to meet legal and regulatory requirements. When we no longer need to retain your personal information, it is our policy to dispose of your information in a manner that ensures your information will not be accessed by unauthorized persons.

Confidence and Trust
Your confidence and trust are important to us. If you have any questions or concerns regarding the privacy of your nonpublic personal information, please contact us at 617.536.5515 for further information or explanation. Guggenheim Real Estate will provide notice of our Privacy Policy annually, as long as you maintain an ongoing relationship with us. In the meantime, to view the most up-to-date Privacy Policy, you can visit our website (www.guggenheimrealestate.com/privacy.html) or call us at 617.536.5515.