PRIVACY POLICY

Last updated: January 11, 2021

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS.  IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR INTERACT WITH US.

INTRODUCTION

GTJ REIT, Inc. (also referred to as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process.

When does this Policy apply? This Privacy Policy (the “Policy”) describes our practices regarding your personal information when you visit our website, www.gtjreit.com (the “Site”), or otherwise contact or interact with us online and in person. However, this Policy does not apply to employees or job applicants with respect to application and employment-related information.

HOW DO WE COLLECT AND PROCESS YOUR INFORMATION?

How do we collect personal information? We collect the information described below via the Site and when you interact with us. Where permitted by law, we may also receive information from our parents, subsidiaries, affiliates, and other third parties.

Is entry of personal information required? You may choose not to provide us with any personal information, and you may still access and use much of the Site. However, if you do not provide any information, you will not be able to access any portions of the Site that require your personal information, and we will not be able to contact you about our services.

What personal information do we collect and receive and how do we process it? We collect and receive the following information:

Category Description
Contact Information We may collect or receive your name, email address, street address, city, state, zip code, country, telephone number, or other contact details.

We process Contact Information to provide our services to you, to communicate with you, to keep records of our communications with you, to honor and enforce our contracts, to operate the Site, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, and to manage our relationships with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Your Communications If you contact us, in addition to your Contact Information, we will collect the information in your message and any other information needed to respond to your inquiry or to answer your question. When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services.

If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information that may be collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page.

We process Your Communications to provide our services to you, to communicate with you, to keep records of our communications with you, to honor and enforce our contracts, to operate the Site, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, and to manage our relationships with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Usage Information When you visit our Site, we automatically collect information from your browser or your device, which includes the date and time of your visit, your location, time zone, Internet Protocol (IP) address or unique device identifier, domain server, operating system, browser type, access time, what websites or search terms referred you to the Site and data about which pages you visit.

We process Usage Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to enhance your experience, to track visits to the Site, and to provide you with a more personal and interactive experience on the Site. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Cookies and Similar Technologies When you visit our Site, we may collect cookies and/or use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies (to the extent similar technologies are present on the Site), some areas and features of the Site may not work properly.

We may process cookies and similar technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, and to enhance your experience The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business.

 

Cookies and Similar Technologies

First-Party and Third-Party Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website:

  • Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
  • Social Widgets: These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
  • UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

What Cookies Are in Use and Why Do We Use Them?

We use the following cookie to improve the functionality of our website.

Cookie Description Type Duration
X-Mapping-omicphef This cookie is necessary for routing your browsing session to the correct server. Strictly Necessary Session

 

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may be able to set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:

Google Chrome:          https://support.google.com/chrome/answer/95647?hl=en

Firefox:                       https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer:      http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari:                         https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html.

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.

Other Third-Party Technologies

Although this Site does not use automated data collection technologies, some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Other Processing Activities. In addition to the processing activities described above, but only where permitted by applicable law, we may process personal information:

  • When necessary for the establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.);
  • When necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.);
  • When required by applicable law;
  • To create, use, retain, or disclose de-identified or aggregated data; or
  • For other purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

 

We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:

  • Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
  • To comply with our legal obligations as well as to keep records of our compliance processes;
  • Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
  • Because you have chosen to publish or display your personal information on a public area of the Websites, such as a comment area;
  • Because it is necessary to protect your vital interests;
  • Because it is necessary in the public interest; or
  • Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

How do we disclose or share your information? Where permitted by applicable law, we may share the information described above in the following contexts:

Category Description
Affiliates We may share your information with our corporate parents, subsidiaries, and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.
Acquisitions and Similar Transactions We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Disclosures with Your Consent We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.  We will only disclose your information in this context with your consent.
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants) We may disclose the information described in this Policy in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws.  We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Third Parties We may provide information about you to third parties that may offer products and services specifically requested by you.
Service Providers We may share information with our service providers that need access to information to provide operational or other support services on our behalf.  Among other things, service providers help us to administer the Site; support our provision of services requested by you; provide technical support; send communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.
Professional Advisors We may share your information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data We may disclose aggregated information or de-identified information about our users that does not identify any specific individual, such as groupings of demographic data or customer preferences.

 

HOW LONG DO WE STORE AND PROCESS YOUR INFORMATION?

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your information if we believe it is incomplete, inaccurate, or that our continued storage of your information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

TRANSFERS OF PERSONAL INFORMATION

We are located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.

HOW DO WE PROTECT YOUR INFORMATION?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.

While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Site.  Your use of the Site is at your own risk.  We cannot guarantee that your data will remain secure in all circumstances.

We have implemented reasonable security measures to detect fraudulent identify-verification activity and to prevent the authorized access to or deletion of personal information.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.

Communication Preferences. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” details provided at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process.  Once we receive your instruction, we will promptly take action.

Cookies.  You may set your browser to refuse all or some browser cookies or to alert you when cookies are being set.  If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.  For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.

 

Online Tracking Signals.  We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions.  “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities.  We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals.

Accuracy and Updating Your Information. Our goal is to keep your personal information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy.  For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response.  As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at privacy@gtjreit.com.

Nevada Residents. You may submit a verified request to us at the “Contact Us” details provided at the end of this Policy to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.

THIRD-PARTY SITES AND SERVICES

This Policy only applies to the Site, and it does not apply to any third-party websites or applications.

The Site may contain links to, and media or other content from, third parties.  These links are to external resources and third parties that have their own privacy policies.  Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to external, third-party resources.  If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website.  You can check the URL to confirm that you have left the Site.

We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Site.

Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.  If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.  Our Site and services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13.  No one under the age of 13 may access, browse, or use the Site or provide any information to or on the Site.  If you are under 13, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username).  If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us via the “Contact Us” details provided at the end of this Policy.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We may add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in the law. Should this Policy change, we will post all changes to this Policy on this page. If we make material changes to how we treat your information, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. Any such changes, updates, or modifications will be effective immediately upon posting on the Site. The date on which this Policy was last modified is identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy.  If you do not agree with this Policy and our practices, you should not use the Site.

CONTACT US

For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, that if your communication is sensitive, you may wish to contact us by postal mail or telephone.

Company Name: GTJ Reit

Address: 1399 Franklin Avenue, Suite 100, Garden City, NY 11530

Data Protection Contact Name: Privacy and ADA Compliance Officer

Telephone: 516-693-5500

 Email: privacy@gtjreit.com