GLOBAL PRIVACY POLICY

Last Updated: December 12, 2011

AIG Global Real Estate Investment Corp. and its affiliated U.S. registered investment advisor (collectively, "AIG Global Real Estate") operate the website owned and controlled owned and controlled by us from which you are accessing this Privacy Policy (the "Site").  AIG Global Real Estate, together with its affiliated international investment companies (each, a "Company", "we" or "us"), form a group of international companies which invest in and actively manage real estate for clients and AIG member companies.  We are committed to protecting the privacy of the individuals we encounter in conducting our business.  "Personal Information" is information that identifies you and relates to you as an identifiable individual.  This Privacy Policy describes how we handle Personal Information that we may collect about individuals (for example, from your new account documents, telephone calls, e-mails and other communications with us, or from third parties involved in our business dealings with you) as well as other information that we may collect through this Site.

  1. Who To Contact About Your Personal Information

    If you have any questions about our use of your Personal Information you can e-mail: AIGGlobalRealEstateClientRelations@aig.com or write to: AIG Global Real Estate Client Relations, 32 Old Slip, New York, New York 10005.  

  2. Personal Information That We Collect

    Depending on your relationship with us, Personal Information collected about you may include: 

    • General identification and contact information
      Your name; address; e-mail and telephone details; gender; marital status; dependents; date of birth; and citizenship.
    • Identification numbers issued by government bodies or agencies
      Social Security or national insurance number; tax identification number; military identification number; passport number; or driver’s or other license number.
    • Customer information
      Bank account number and account details; tax status; net worth, income or other financial information; credit score, credit history or other information from consumer reporting agencies; account balance; payment history; and passwords.
    • Other sensitive information
      We may obtain sensitive information incidentally if you voluntarily provide it to us. 

  3. How We Use Personal Information 

    We may use this Personal Information to:

    • Respond to your inquiries and communicate with you and others as part of our business.
    • Send you important information regarding changes to our policies, terms and conditions, and other administrative information.
    • Process your payments.
    • Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
    • Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
    • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data hosting; business continuity; and records, document and print management.
    • Resolve complaints, and handle requests for data access or correction.
    • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
    • Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

  4. International Transfer of Personal Information

    Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based).  We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.

  5. Sharing of Personal Information 

    We may make Personal Information available to:

    • Our group companies

      The list of our group companies that may have access to and use of Personal Information follows:

      • American International Group, Inc.
      • AIG Global Services, Inc.
      • AIG Asset Management (US), LLC
      • AIG Asset Management (Europe), Limited
      • AIG Global Real Estate Investment Corp.
      • AIG Global Real Estate Investment (Europe) Limited
      • AIG Global Real Estate Investment de Mexico, S.de. R.L.
      • AIG GRE Investment Corp Moscow Representative Office
      • AIG Korean Real Estate Development YH
      • AIG Global Real Estate Advisers India Pvt. Ltd.
      • AIG Europe II Holdings Sarl

      The Company entity with which you deal is responsible for the management and security of jointly used Personal Information.  Access to Personal Information within the relevant Company is restricted to those individuals who have a need to access the information for our business purposes.

    • Our service providers

      External third-party service providers, such as accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; call center service providers; IT systems, support and hosting services; print management service providers; advertising,  marketing and market research and analysis service providers; banks and financial institutions; document and records management providers; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

    • Governmental authorities and third parties involved in court action 

      We may also share Personal Information with governmental or other public authorities; and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.  

    • Other Third Parties

      We may share Personal Information with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.

  6. Security 

    We will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us.  (See the "Who to Contact About Your Personal Information" section above.)
    When we provide Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information. 

  7. Retention of Personal Information 

    We take reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy.  We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

  8. Personal Information of Other Individuals

    If you provide Personal Information to us regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Information about the individual in accordance with this Privacy Policy. 

  9. Access and Correction Requests, Questions and Concerns

    In certain countries, an individual may have the right to access, correct, object to the use of, or request deletion or suppression of Personal Information on certain grounds.  Please contact us as set out in the "Who to Contact About Your Personal Information" section above with any such requests or if you have any questions or concerns about how we process Personal Information.  Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws. 

  10. Other Information We Collect Through the Site 

    "Other Information" is any information that does not reveal your specific identity, such as:

    • Browser information;
    • Information collected through cookies, pixel tags and other technologies;
    • Demographic information and other information provided by you; and
    • Aggregated information.

    Other Information We Collect

    We and our third-party service providers may collect Other Information in a variety of ways, including: 

    • Through your internet browser:  Certain information is collected by most websites, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, time of the visit and the page(s) visited.  We use this information for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

    • Using cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent on the Site, pages visited, and language preferences.  We may use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while visiting the Site, or to gather statistical information about the usage of the Site.  Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you.  We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites.

      You can refuse to accept other cookies we use by adjusting your browser settings.  However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products.

    • Using pixel tags, web beacons, clear GIFs or other similar technologies:  These may be used in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates. 

      We use Adobe’s Omniture analytics service, which uses cookies and web beacons to help us understand more about how our website is used by consumers so we can continue to improve it.  Adobe does not have the right to use the information we provide to them beyond what is necessary to assist us. For more information on Adobe’s Omniture service, including how to Opt-Out, go to http://www.omniture.com/privacy/policy#optout.

    • By aggregating information:  We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

    Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect" section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

  11. Third Party Websites

    This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link.  The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our group companies.

  12. Use of Site by Minors

    The Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information to us. 

  13. Changes to This Privacy Policy

    We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.  We will notify you of any material changes to our privacy practices.
    Please take a look at the "LAST UPDATED" date at the top of this Privacy Policy to see when it was last revised. 

  14. Companies to Which this Privacy Policy Applies

    This Privacy Policy describes the privacy practices of the following companies:  AIG Global Real Estate Investment Corp., AIG Global Real Estate Investment (Europe) Limited, AIG Global Real Estate Investment de Mexico, S.de. R.L., AIG GRE Investment Corp Moscow Representative Office, AIG Korean Real Estate Development YH, AIG Global Real Estate Advisers India Pvt. Ltd., AIG Europe II Holdings Sarl.