Privacy Policy & Terms of Use

TERMS OF USE
These Terms of Use (“Terms and Conditions”) are a binding agreement between you and Bluefin capital, LLC and its affiliates (collectively “Bluefin Capital”). By using or accessing this website, you accept and agree to be bound by these Terms and Conditions. For the avoidance of doubt, any references herein to “we,” “our,” “us” or any derivation thereof refer to Bluefin Capital.

NO INVESTMENT ADVICE
This website is intended only for your personal, non-commercial use, unless you and Bluefin Capital have agreed otherwise in writing. The information on this website is provided for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to purchase interests in any investment vehicle sponsored by Bluefin Capital and may not be used or relied upon in connection with any offer or sale of securities. No investment or other advice, is intended and nothing on this website is to be deemed a recommendation that an investor buy, sell or hold any security or other investment or that such investor pursue any investment style or strategy. Investors should consult with their own investment, accounting, tax or legal advisers with respect to their individual circumstances and needs.

Disclaimer of Warranties
This website is provided on an “AS IS,” “WHERE IS” and “WHERE AVAILABLE” basis. Bluefin Capital does not make any express or implied warranties about this website (including the “Investor Portal”) or the information or services provided herein, including any implied warranties of merchantability, non-infringement, or fitness for a particular purpose. Bluefin Capital will not be responsible for any loss or damage that could result from interception by third parties of any information or services made available to you via this website. Although the information provided to you on this website is obtained or compiled from sources we believe to be reliable, Bluefin Capital cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data.

Limitations of Liability
Neither Bluefin Capital, nor any of its affiliates, related parties, directors, officers or employees (the “Affiliates”), will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this website (including the Investor Portal), or resulting from the act or omission of any other party involved in making this website, the data contained herein, or from any other cause relating to your access to, inability to access, or use of the website or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Bluefin Capital or of any vendor providing software or services. In no event will Bluefin Capital, its Affiliates or any service provider parties be liable to you, whether in contract or tort, for any direct, special, indirect, consequential or incidental damages or any other damages of any kind even if Bluefin Capital or any other such party has been advised of the possibility thereof. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (e.g., you cannot access your internet service provider), unauthorized access, theft, operator errors, strikes or other labor problems or any force majeure. Bluefin Capital cannot and does not guarantee continuous, uninterrupted or secure access to the website.

Indemnity
By accessing this website, you agree to indemnify Bluefin Capital and its Affiliates, and our and their respective direct or indirect partners, owners stockholders, members, managers, officers, directors, employees and agents (collectively, the ” Bluefin Capital Indemnities”) against, and hold the Bluefin Capital Indemnities harmless from, any and all claims and expenses, including attorneys’ fees, arising from your use of this website. You hereby release the Bluefin Capital Indemnities from any and all claims, demands, debts, obligations, damages (actual, consequential or special), costs and expenses of any kind whatsoever that you may have against the Bluefin Capital Indemnities’ arising out of or in any way related to such disputes.

Restrictions on Use of Website
You agree not to:

take any action that imposes an unreasonable or disproportionately large load on this website’s infrastructure;
use any device, software or routine to interfere or attempt to interfere with the proper working of this website or any activity being conducted on this website;
use or attempt to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search this website to harvest or otherwise collect information from this website to be used for any commercial purpose;
allow any other person or entity to use your user-id or password on the Investor Portal; or
attempt to decipher, decompile, disassemble or reverse engineer any of the software comprising or in any way making up a part of this website.

You further agree not to violate or attempt to violate the security of this website, including, without limitation:

accessing data not intended for you or logging into a server or account that you are not authorized to access;
attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; or
attempting to interfere with service to any user, host or network, including, without limitation, by way of submitting a virus to, or overloading, “flooding”, “spamming” or “crashing”, this website.

We may investigate occurrences that may involve violations of the security of this website or of the law and we may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. We reserve the right to disclose any information about you or your use of our website in connection with any investigations by us or law enforcement authorities.

We cannot and do not assure that other users are or will be complying with these Terms and Conditions, and, as between you and us, you hereby assume all risk of harm or injury resulting from any such lack of compliance.

We may change this website or delete content or features in any way, at any time and for any reason or no reason.

Restrictions on Use of Materials
Any person using this website is permitted to copy and print a minimal number of individual website pages solely for informational use. Users may also copy or print a minimal number of copies of any research or reports posted on the site solely for informational use. These copies must not alter the original website content, including, without limitation, any legal notices or legends. Our prior permission is required for (a)any commercial use of materials on this website; (b) making more than a minimal number of copies of such materials; and (c) copying portions of our website, such as by bots, robots or spiders that “harvest” the website.

Linking and Framing
We do not permit others to link to or frame this website or any portion thereof.

Please note that this Privacy Policy and Terms and Conditions applies only to this website and not to other websites that may be accessible from this website via hyperlink. We encourage you to review the privacy policies and terms and conditions of all other websites that you visit.

These third- party websites are not maintained by Bluefin Capital and are provided only as a convenience. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification or monitoring by Bluefin Capital of any information contained in any third- p a r ty website. In no event shall Bluefin Capital be responsible for the information contained on that site or your use of or inability to use such site. Bluefin Capital expressly disclaims any responsibility for access to our use of such other websites.

Ownership
All content included on this website, such as graphics, logos, articles and other materials, is the property of Bluefin Capital or others and is protected by copyright and other laws. All trademarks and logos displayed on this website are the property of their respective owners, who may or may not be affiliated with our organization. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, frame, create derivative works from, transfer, or otherwise use in any other way for commercial or public purposes in whole or in part any information, software, products or services obtained from this website, except for the purposes expressly provided herein, without Bluefin Capital’s prior written approval.

Submissions
As our website indicates, the information on these pages is intended solely for the benefit of persons who might be aware of investment opportunities that would interest Bluefin Capital. Please be advised that any comments, suggestions, ideas or other information that you send to us through our website will not be treated as confidential, and that we will own and have the right to use them as we choose, without payment to you. Bluefin Capital’s services are provided only to a limited number of private investment funds, private separate account vehicles and certain investors; Bluefin Capital does not make its services available to the public.

International Use
Due to the global nature of the Internet, this website may be accessed by users in countries other than the United States. This website is provided for informational purposes only and is not directed at, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject that Bluefin Capital and/or its subsidiaries or Affiliates to any registration or licensing requirements with such jurisdiction. Those who choose to access this site outside the United States do so on their own initiative and are responsible for compliance with all local laws and regulations.

Financial Information
This website may contain information that includes or is based upon forward- looking statements within the meaning of federal securities laws. Forward-looking statements are made based on Bluefin Capital’s current expectations and beliefs concerning future developments and their potential effects. You can identify these statements by the fact that they do not relate solely to historical or current facts. They generally include words such as “believe”, “expects”, “anticipates”, “intends” and similar words. There can be no assurance that future developments will be in accordance with Bluefin Capital’s expectations or that the effect of future developments will be those anticipated by Bluefin Capital. The following important factors, risks, and uncertainties are among those that may affect such statements: (a) changes in performance of financial markets and interest rates; (b) development of new financial products; and (c) regulatory, accounting or tax changes that may affect the cost of, or demand for, our financial products or services. While Bluefin Capital periodically reassesses material factors, risks and uncertainties, we do not intend to revise any forward-looking statements to reflect changes in events, circumstances or expectations or to reflect the occurrence of unanticipated events after the date on which a statement is made.

Miscellaneous
Any failure or delay by us in enforcing an obligation or exercising a right under this Privacy Policy and Terms and Conditions does not amount to a waiver of that obligation, or right or any other obligation or right. If any term or provision hereof is illegal or invalid for any reason whatsoever, such term or provision will be enforced to the maximum extent permitted by law and, in any event, such illegality or invalidity shall not affect the validity of the remainder of this Privacy Policy and Terms and Conditions.

PRIVACY POLICY
Bluefin Capital respects the privacy of visitors to this website, those who invest in Bluefin Capital and tenants or others who visit Bluefin Capital properties. This Privacy Policy governs the online information and other personal information collection practices of Bluefin Capital. It outlines the types of information that we may gather about you and the ways in which we use and do not use this information.

What Information is Collected and How it May be Used

What is Personal Information:
The term “Personal Information” as used in this policy means any information that identifies, relates to, describes, or is reasonably capable of being associated with, directly or indirectly, a particular individual or household. The kinds of Personal Information that Bluefin Capital may collect depends on the nature of our relationship with you, but may include name, telephone number, e-mail address or SSN. In addition to the information stated above, Bluefin Capital may collect certain information about your use of our online services, for example, we may capture information such as IP address, operating system, browser, or other information collected through cookies.
How Personal Information May be Collected, Used, or Shared
Through your use of our website:
This website may collect information, such as your IP address, which is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP). Information such as is this may be collected from you and other users to perform statistical analyses of user behavior and characteristics, such as the frequency with which people visit various parts of this website. Aggregated statistics may be used to improve this website and for other business purposes.This website may also collect information through a variety of technical methods, including, without limitation, cookies. Cookies are pieces of information that a website sends to your computer while you are viewing the website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may use cookies to store information such as which of our web pages you have visited and other session information so that we can better understand how the website is used, resolve technical problems, monitor traffic, and enhance your experience at this website.Your voluntary submission of additional Personal Information: If you voluntarily submit information to us through this website (for example, in a request for general information or through the submission of a business proposal) we may record and use any personally information that you provide, such as your name, telephone number and e-mail address. This information may be used to fulfill your request or for internal business purposes.Investors of Bluefin Capital and Bluefin Capital personnel may have access to our Investor Portal. In order to obtain a user-id and password to access our Investor Portal, you may be asked to provide us with your name, telephone number and e-mail address. We may record and use any such Personal Information to monitor access to our Investor Portal and to ensure the security thereof.
We may collect personal information about you from other sources, including from our properties’ tenant files, our investor master subscription materials, and from our joint venture partners.
How We May Share Your Personal Information
Bluefin Capital does not sell your Personal information. However, we may share your Personal Information with service providers who are contracted to operate our website, and employ other service providers to perform work on our behalf, such as hosting this website or operating our Investor Portal. These persons may have access to the Personal Information you submit through this website, but only for the purpose of performing their duties in connection with this website. These persons may not use your Personal Information for any other purpose.We may also share your personal information for our business purposes with, for example, our joint venture partners, fund administrators, accountants, attorneys or other service providers as necessary to conduct business processes on behalf of Bluefin Capital.

California Residents Privacy Notice
This California Consumer Privacy Act of 2018 (“the CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”) privacy notice (together this “CCPA Notice”) is included in our Privacy Policy and applies to Bluefin Capital, LLC and its affiliates (collectively “Bluefin Capital”) processing of “personal information,” as defined in the CCPA/CPRA, of California residents (collectively, “Consumers,” “you” or “your”). Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the CCPA/CPRA. To the extent of any conflict between this CCPA Notice and the rest of our Privacy Policy, this CCPA Notice shall control only with respect to Consumers and their personal information.

General
This CCPA Notice provides further detail regarding (a) how we have processed Consumers’ personal information within the past twelve (12) months and (b) your rights under the CCPA/CPRA.

Personal Information We May Collect
We collect and disclose the following personal information for our business purposes.

Categories of Personal Information	Examples	Source of Personal Information
Identifiers	Name Alias Postal address Online identifier Internet Protocol address E-mail address Account name Social security number Driver’s license number, passport number or other similar identifiers Unique personal identifier(i.e. – persistent identifier such as device identifier, cookies, beacons, pixel tags, mobile ad identifiers or similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers)	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)
Legally Protected Characteristics	Gender National origin	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)
Internet or Network Activity	Browsing history Search history Interaction with an internet website, application, or advertisement	Website, Investment Portal, Verbal or written correspondence, or other services provided (information collected directly from user)
Professional or employment related information	Employment history Professional associations Other experience	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)
Education information	Schools attended Degrees earned Academic status	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)
Inferences drawn from any of these personal information categories	Preferences Characteristics Predispositions Behavior Attitudes Intelligence Abilities Aptitudes	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)
Financial Information (information described in CA Code §1798.80)	Bank account number Credit card number Debit card number Other financial information Credit Score	Website, Investment Portal, Verbal or written correspondence, lease applications, leases, guarantees, corporate documents, loan documents, joint venture agreements, security files/data, background or risk management searches, meetings, conversations or other services provided (information collected directly from user)

For each of the above categories of personal information, we use your personal information to carry out the following business purposes and any other purpose identified by us at the time the information is collected:

Responding to Requests: We use information about you to respond to your requests or questions. For example, for example, in a request for general information or through the submission of a business proposal.
Providing Services and Improving our Website: We use information about you to provide you services and improve our websites and the information we provide. We might use your personal information to provide new or updated online content to you and/or to customize your experience with us. For example, we may use your personal information to improve our services, our website, and our other internal business purposes.
Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection. We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.
Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Communications: We use personal information to communicate with you about your account or our relationship. We may contact you about your account or feedback. We might also contact you about our Privacy Policy or our website’s Terms of Use.
Debug and Identify Errors: We use your personal information to debug and identify and repair errors that impair existing intended functionality.
Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.
Perform Business Operations: We may use your information to perform operations for the business purposes of Bluefin Capital or its managed investment vehicles and their subsidiaries.

Your CCPA Rights
Access
You may request that Bluefin Capital disclose certain information regarding our use of your personal information over the past twelve (12) months. You may only make such requests twice per twelve (12) months. Upon verifying your request (see below), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
The specific pieces of personal information we collected about you.
Our business purpose for collecting that personal information.
The categories of third parties with whom we share personal information.

Correction
You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion
You have the right to request that Bluefin Capital delete any of the personal information collected from you and retained by us, subject to certain exceptions. Once your request is verified (see below) and we have determined that we are required to delete that information in accordance with applicable law, we will delete, and direct our service providers to delete, your personal information from our records. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Exercising Your Rights
To exercise any of the rights described above, please submit a request to us by:

Filling out the form located on our contact’s page.

Please note that Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, including a person permitted by you in accordance with our written investment agreements, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. Your verifiable consumer request must:

Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf; and
Describe your request with sufficient detail to properly understand and respond to it.

We will only use the personal information that you have provided in a verifiable consumer request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Making a verifiable consumer request does not require you to create an account with us on our Website or through our Investment Portal.

Verifying Your Request
Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. In all cases, your request must be verified before we take action (and shall take such action pursuant to the timing permitted under the CCPA). Verifying your request may require you to:

Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf; and
Describe your request with sufficient detail to properly understand and respond to it.

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Response Timing and Format
We aim to respond to customer requests within forty-five (45) days of receipt. If we are unable to deliver a response to verifiable consumer requests within this timeframe, we will inform you of the reason and estimated extension period in writing. We will deliver a response to your existing account with us, if applicable, or a written response by mail or electronically, at your option.

Any disclosures will cover only the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Data portability requests will be issued in a format that is readily useable, we do not charge a fee unless your request is excessive, repetitive, or manifestly unfounded. If the request warrants a reasonable fee, we will tell you why and provide you with a cost estimate before completing your request.

Fees
Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Changes to this Privacy Statement
If, in the future, we intend to process your personal information for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately (either within this Privacy Policy or elsewhere), and the “Effective Date” at the top of this page will be updated accordingly.