Privacy Policy

At Cole Capital, we are committed to maintaining the confidentiality of your personal and financial information. The purpose of this Privacy Policy is to explain the types of Personally Identifiable Information or Non-Personally Identifiable Information Cole Capital collects, how the information is obtained, how it is used and the choices you have regarding our use of, and your ability to review and correct, the information.

This Privacy Policy applies for all business activities, including users accessing our website or parties engaging in communications or transactions with Cole Capital.

Why We Collect Information About You

Our primary goals in collecting information are to provide clients with superior service and to provide all individuals a smooth, efficient and personalized experience. We utilize this information to:

  • Identify your relationship with Cole Capital and assist you in creating and maintaining an account;
  • Process transactions in your account;
  • Oversee distribution processing, transfers, etc.;
  • Evaluate and improve our methods of communication;
  • Communicate information with the custodians, transfer agents, and, if applicable, your broker/dealer or financial advisor, or other parties involved in the processing, servicing or management of your account;
  • Market investment products or services that may be consistent with your financial profile; and
  • Comply with all applicable federal and state regulatory obligations.

What Information We Collect

The information we collect generally falls into the following two categories: Personally Identifiable Information; and Non-Personally Identifiable Information.

  • Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. The Personally Identifiable Information we collect may include your name, mailing address, phone number, email address, employer, job title, date of birth, Social Security number, bank account information, financial information such as your income and net worth and information about your transactions with us such as the investment amount and any contributions and/or distributions.
  • Non-Personally Identifiable Information: This refers to information that does not, by itself, identify a specific individual. The Non-Personally Identifiable Information we collect may include aggregated statistical data or data not attributable to a specific person or entity.

We do not connect or otherwise make association between the Personally Identifiable Information and the Non-Personally Identifiable Information we collect.

How We Collect Information

We may request Personally Identifiable Information when you request information or correspond with us. When you contact our Investor Services department for assistance, or invest in a new program with us, we may ask for Personally Identifiable Information to fulfill your requested service and to contact you in the future.

Our web servers may automatically recognize a visitor’s device, browser, domain name (such as .com, .edu, etc.), the web page from which a visitor enters our website, which pages a visitor visits on our website and on some websites, how much time a visitor spends on each page. This information does not reveal a visitor’s identity. We aggregate this information and use it to evaluate and improve our websites.

Whether you choose to provide specific information requested by Cole Capital is completely your own choice. But, if you choose not to provide the information we request, you may be unable to receive or access certain services, offers and information.

Using Information About You

Cole Capital does not sell or share customer information to outside marketers without your consent.

We may share your Personally Identifiable Information with others, but only in certain limited situations: (i) within our corporate group or among our affiliated entities, all of which follow this Privacy Policy or equivalent privacy policies; (ii) with our service providers or other parties who agree to keep the information confidential and use it only on behalf of Cole Capital; (iii) if your investment is transferred from our current custodian to another custodian, we provide your general information, tax identification number and other transfer documents to the new custodian on your behalf; and (iv) as otherwise agreed by you.

In some cases, we may be required to disclose certain information to comply with the law, the charter of the applicable entity into which you invest, or an investigation or a legal process, such as a court order or subpoena. We may disclose information when we believe that such a release is reasonably necessary to enforce or protect our rights.

Your Choices

On occasion, we may send communications about our company and our products. If you change your mind about receiving marketing communications from Cole Capital and wish not to receive further marketing communications from Cole Capital, let us know that you would like to “opt out” by email at investorservices@colecapital.com or by calling us at 866.907.2653. You can opt out at any time.

All email communications from us include instructions on how to stop receiving them. Please follow these instructions if you no longer wish to receive the email messages. If you would like to update or correct your email address, street address or other personal information with us, please contact us at investorservices@colecapital.com or by calling us at 866.907.2653.

Please remember, if you opt to delete certain information you may not be able to continue to access other portions of our websites without entering additional information.

Protecting Your Information

Our policy is to restrict access to your Personally Identifiable Information to only those employees, service providers and other third parties who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic and procedural safeguards consistent with industry standards and other applicable standards as required by law and we require service providers and third parties to do the same.

Links to Third Party Sites

Our websites may contain links to websites operated and maintained by third parties, over which we have no control. Privacy policies on such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk. You should always read the Privacy Policy of a linked website before disclosing any personal information on such website.

Policy Changes

To improve the services we can offer you, Cole Capital may opt to expand our capabilities for obtaining information about users in the future. Cole Capital will update this privacy statement when necessary to ensure that you are aware of developments in this area.

We will post those changes on our websites and update our Privacy Policy so that you will know what information we collect online, how we use it and what choices you have. Please be sure to check this page before proceeding to use our websites. Regardless of any changes we make to our Privacy Policy, we will always use your Personally Identifiable Information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you give your express consent for us to do otherwise.

Additional Privacy Terms

In conducting business with Cole Capital or using the websites, you may be required to agree to additional written or electronic agreements, including additional privacy terms and conditions (“Additional Privacy Terms”), as a condition to visiting the websites, or receiving products, services and other information. In the event of any conflict between the Additional Privacy Terms and this Privacy Policy, the Additional Privacy Terms shall prevail.

Business Transfers

As Cole Capital continues to develop its business, we may sell or buy entities, subsidiaries or business units. In such transactions, customer information generally is one of the transferred business assets. Such information remains subject to any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). In the event that Cole Capital, its parent company, VEREIT, Inc., or related parties are acquired in whole or in part, Personally Identifiable Information may be one of the transferred assets.

Your Feedback

To help us improve our Privacy Policy and practice, please give us your feedback. You may email us at investorservices@colecapital.com or write to us at 2325 East Camelback Road, Suite 1100, Phoenix, Arizona 85016.

Telephone: 866.907.COLE (2653) or Fax: 602.778.8780.