Privacy Policy

Freehold Properties, Inc. and its affiliates (collectively, the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”); and
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you.
• Collectively, we refer to the Websites and emails as the “Services.”

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• First and last name
• Email
• Phone number
• Job title
• Company/organization name and website
• Company/organization industry
• IP address (we may also derive your approximate location from your IP address)

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.
  We collect Personal Information through the Services, for example, when you submit project information to us, sign up for our newsletter, or contact us.
• From Other Sources.
  We receive your Personal Information from other sources, for example:
  o publicly available data;
  o joint marketing partners, when they share the information with us;
  o other business partners, who for example may employ you.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
  – To provide the Services’ functionality to you, such as providing you with information about our services and partnerships.
  – To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us information about your project proposal or when you contact us about a potential partnership.
  – To complete your requests, verify your information, and provide you with related services and offers.
  – To send administrative information to you, such as changes to our terms, conditions, and policies.
• Providing you with our newsletter and/or other marketing materials.
  – To send you marketing related emails, with information about our services, new products, and other news about our company.
• Analyzing Personal Information for business reporting and providing personalized services.
  – To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  – To better understand your interests and preferences, so that we can personalize our interactions with you.
• Accomplishing our business purposes.
  – For data analysis, for example, to improve the efficiency of our Services;
  – For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  – For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  – For developing new services;
  – For enhancing, improving, repairing, maintaining, or modifying our current services and offerings, as well as undertaking quality and safety assurance measures;
  – For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
  – For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

Disclosure of Personal Information

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• To our third-party service providers, to facilitate services they provide to us.
  – These can include providers of services such as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, email delivery, auditing, and other services.

Other Uses and Disclosures

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others. We may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Project information (e.g., type, city and state, stage, description)
• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

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

• Your browser or device.
  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Cookies.
  Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals.
  If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
• Pixel tags and other similar technologies.
  Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Uses and Disclosures of Other Information

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, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us on a going-forward basis by clicking on the “unsubscribe” link in our marketing related emails.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

THIRD PARTY SERVICES

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 website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal
Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at privacypolicy@freeholdprop.com, or:
232 3rd Avenue North
Franklin TN 37064

Because email communications are not always secure, please do not include sensitive information in your emails to us.