Greystone Housing Impact Investors Privacy Notice

Last modified:  December 2, 2022

1. Introduction

Greystone Housing Impact Investors LP (“Greystone Housing Impact,” “we,” “our,” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect, use, maintain, protect, disclose, or otherwise process about you when you visit our website www.ghiinvestors.com (the “Website”) and our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information.

This policy applies to information we collect:

  • on our Website;
  • when you contact us for support; and
  • in email, text, and other electronic messages between you and our Website.

It does not apply to information collected by:

  • except as described above, us offline or through any other means, including on any other website operated by Greystone Housing Impact or any third-party (including our affiliates and subsidiaries), or any information you provide when you apply to be an investor.
  • us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
  • any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

2. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at through the contact information below.

3. Information We Collect About You and How We Collect It

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information.

Generally

We collect Personal Data from various sources, including:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Website;
  • from third parties, for example, social media companies and our business partners.

Information You Provide to Us

We may collect the following types of Personal Data directly from you when you access or use our Website: real name, postal address, unique personal identifier (username) and password, email address, telephone number. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.

The Personal Data we collect on or through our Website through:

  • information that you provide by filling in forms on our Website. This includes information provided at the time of submitting an applying for an investment, or requesting further services. We may also ask you for information when you report a problem with our Website; and
  • if you contact us, records and copies of your correspondence (including email addresses).

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Website, including information about your equipment, browsing actions, and patterns:

  • details of your visits to our Website. This includes: browsing history, search history, traffic data, IP-based location data (city, state), logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on the Website;
  • Information about your computer and internet connection, i.e., your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences;
  • customize our Website according to your individual interests;
  • speed up your searches; and
  • recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Website may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
  • Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Website and track which pages of the Website you access. Session cookies are required to use the Website.
  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Greystone Housing Impact, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or technology on the Website may be served by third-parties, including ad networks and servers, analytics providers, social media companies, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information We Collect from Third Parties

We may collect Personal Data from third parties, such as business intelligence services and social media companies. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, postal address, additional email addresses, telephone numbers, title, employer name, friend lists or information about the people and groups you are connected with and how you interact with them, visual information (photographs), and other information that you may make public in connection with your use of the social media service.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

  • to provide and personalize our Website and its contents to you;
  • to provide you with notices and information that you request from us;
  • to support, develop, troubleshoot, and debug our Website;
  • to process your requests;
  • to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • to help maintain the safety, security, and integrity of our Website, databases and other technology assets, and business;
  • for internal testing, research, analysis, including to develop and improve our Website;
  • auditing relating to a current interaction with you and concurrent transactions, including, but not limited to, auditing compliance with any applicable specification and other standards;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our terms of use;
  • to notify you about changes to our Website;
  • to allow you to participate in interactive features on our Website;
  • in any other way we may describe when you provide the information;
  • to fulfill any other purpose for which you provide it; and
  • for any other purpose with your consent.

We may also use your information to contact you about our company. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by contacting us through the contact information below and stating your request. For more information, see Choices About How We Use and Disclose Your Information.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties we use to support our business. This may include cloud service providers and other similar organizations;
  • to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Greystone Housing Impact’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Greystone Housing Impact about our Website’s users is among the assets transferred;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; and
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our terms of use and other agreements; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Housing Impact, its affiliates, our or their customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
  • Informational Notices from Greystone Housing Impact. If you do not want us to use your contact information to provide you with information regarding our company, you can opt-out by contacting us at the contact information below. If we have sent you a promotional email, you may click the unsubscribe link in the body of that email to be omitted from future email distributions. This opt out does not apply to information provided to Greystone Housing Impact as a result of an investment, application, or other transactions.

7. Accessing, Correcting, and Deleting Your Personal Data

You may contact us at the contact information below to request access to, correct or delete any Personal Data that you have provided to us. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more Information.

8. Jurisdiction-Specific Privacy Rights

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your state that is attached to this Privacy Notice.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described in the California Privacy Addendum.

9. Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

10. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.

11. Consent to Processing of Personal Data in the United States

Our Website is meant only for individuals located in the United States. If you choose to use our Website from another country, you do so at your own risk and you acknowledge and agree that in order to provide our Website, products, and services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

12. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page with a notice that the Privacy Notice has been updated on the Website’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’ home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

Your continued use of our Website following the posting of changes constitutes your acceptance to such changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website.

Greystone Housing Impact Investors LP

14301FNB Parkway, Suite 211

Omaha, NE 68154

855.428.2951

Privacy Notice Addendum for California Residents

Effective Date: December 2, 2022

1. Introduction

This Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Greystone Housing Impact Investors’ Privacy Notice and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”) and any terms defined in the CPRA have the same meaning when used in this notice.

2. Scope of this California Privacy Addendum

This California Privacy Addendum applies to information that we collect on our Website (as defined in the Privacy Notice) that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“Personal Information”). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CPRA) are not considered Personal Information and this California Privacy Addendum does not apply.

This California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals (“Personnel”). Please contact your local human resources department if you are part of our California Personnel and would like additional information about how we process your Personal Information.

This California Privacy Addendum also does not apply to Personal Information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). Please see our California Privacy Addendum for B2B Personal Information for information regarding our practices regarding your B2B Personal Information.

This California Privacy Addendum also does not apply to certain Personal Information that is excluded from the scope of the CPRA, like Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Some of these exceptions may apply to information we collect as part of your application or participation in an investment.

3. Information We Collect About You and How We Collect It

Greystone Housing Impact’s Website may collect, and over the prior twelve (12) months may have collected, the following categories of Personal Information about Consumers:

Category

Applicable Pieces of Personal Information Collected

A. Identifiers.

A real name; alias; online identifier (username); Internet Protocol address; email address; and other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name.

Some Personal Information included in this category may overlap with other categories.

F. Internet or other similar network activity.

Browsing history; search history; information on a Consumer’s interaction with a website, application, or advertisement.

G. Geolocation data.

Physical location or movements. We collect IP-based geolocation data for security purposes, which can only identify your location to a geographic region, such as city, state.

Greystone Housing Impact will not collect additional categories of Personal Information without providing you notice.

4. Sources of Personal Information

We collect Personal Information about you from the sources described in our Privacy Notice.

5. Purposes for Our Collection of Your Personal Information

We only use your Personal Information for the purposes described in our Privacy Notice. Greystone Housing Impact will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes

Greystone Housing Impact may disclose your Personal Information to third parties for one or more business purposes. When we disclose Personal Information to non-affiliated third-parties for a business purpose, we enter a contract that describes the purpose, requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes for which the Personal Information was disclosed and requires the recipient to otherwise comply with the requirements of the CPRA.

In the preceding twelve (12) months, Greystone Housing Impact may have disclosed the following categories of Personal Information for one or more of the business purposes described below to the following categories of third parties:

Personal Information Category

Categories of Non-Service Provider and Non-Contractor Third Party Recipients

A. Identifiers.

Advertisers and advertising networks; business partners (i.e., cloud service and hosting providers, postal services); affiliates, parents, and subsidiary organizations of Greystone Housing Impact; and social media companies.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Business partners (i.e., cloud service and hosting providers, postal services); affiliates, parents, and subsidiary organizations of Greystone Housing Impact.

F. Internet or other similar network activity.

Advertisers and advertising networks; business partners (i.e., cloud service and hosting providers); affiliates, parents, and subsidiary organizations of Greystone Housing Impact; social media companies; internet cookie information recipients, such as analytics and behavioral advertising services.

G. Geolocation data.

Business partners (i.e., cloud service and hosting providers); affiliates, parents, and subsidiary organizations of Greystone Housing Impact.

 

We disclose your Personal Information to the categories of third parties listed above for the following business purposes:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Helping to ensure security and integrity of our IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short–term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us. Our agreements with third parties prohibit your Personal Information from disclosure to another third-party and from using your Personal Information to build a profile about the you or otherwise alter your experience outside your current interaction with us.
  • Performing services on behalf of us, including verifying visitor information, providing analytic services, providing storage, or providing similar services on behalf of us.
  • Providing advertising and marketing services, except for cross-context behavioral advertising, to Consumers.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to:

  • comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
  • comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
  • comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury; or
  • exercise or defend legal claims.

7. To Whom Do We Sell or Share Your Personal Information

“Sale” of Your Personal Information for Monetary or Other Valuable Consideration

In the preceding twelve (12) months, Greystone Housing Impact has not “sold” Personal Information for either monetary or other valuable consideration, including any Personal Data for children under the age of 16.

“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising

In the preceding twelve (12) months, Greystone Housing Impact has not “shared” Personal Information for the purpose of cross-context behavioral advertising, including any Personal Data of children under the age of 16.

8. Consumer Data Requests

The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CPRA Privacy Rights.

  • Right to Know. You have the right to request that Greystone Housing Impact disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” Consumer Request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information came from; (c) our purposes for collecting this Personal Information; (d) the categories of third parties with whom we have shared your Personal Information; and (e) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
  • Access to Specific Pieces of Information (Data Portability). You also have the right to request that Greystone Housing Impact provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third-party about you (a “Data Portability” Consumer Request). If you make a Data Portability Consumer Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. We will not provide any information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Information, your account with Greystone Housing Impact, or the security of our systems or networks. We will also not disclose any Personal Information that may be subject to another exception under the CPRA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
  • You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may review and correct some Personal Information about yourself by submitting a request that we correct the Personal Information we have about you as described below under Exercising Your CPRA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Information is subject to another exception under the CPRA.
  • You have the right to request that Greystone Housing Impact delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Consumer Request (see Exercising Your CPRA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CPRA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.
  • Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not do any of the following as a result of you exercising your CPRA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CPRA Privacy Rights

To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:

  • Calling us at 855.428.2951.
  • Submitting a form via US mail. This form is available online at ghiinvestors.com.

If you (or your Authorized Agent) submit a Consumer Request to delete your information online, we will use a two-step process in order to confirm that you want your Personal Information deleted. This process may include verifying your request through your email address on record, calling you on your phone number on record (which may include an automated dialer), sending you a text message and requesting that you text us a confirmation, sending you a confirmation through US mail. By making a Consumer Request, you consent to us contacting you in one or more of these ways.

If you fail to make your Consumer Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Consumer Requests must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person. This may include:
    • Comparing non-public information that you provide (or that we ask you to provide) against information that we already have on file.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

Making a Consumer Request does not require you to create an account with us.

We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

Authorized Agents

You may authorize your agent to exercise your rights under the CPRA on your behalf by registering your agent with the California Secretary of State or by providing them with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Response Timing and Format

We will respond to a Consumer Request within ten (10) days of its receipt. We will generally process these requests within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

In response to a Right to Know or Data Portability Consumer Request, we will provide you with all relevant information we have collected or maintained about you on or after January 1, 2022. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability Consumer Request, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, such as comma-separated-values (CSV) or Adobe PDF.

We do not charge a fee to process or respond to your Consumer Request unless it is excessive, repetitive, or manifestly unfounded. We reserve the right to consider more than two (2) total Right to Know or Data Portability Consumer Requests (or combination of the two) in a twelve (12) month period to be repetitive and/or excessive and require a fee. If we determine that your Consumer Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9. Your Choices Regarding our Use and Disclosure of Your Sensitive Personal Information

10. We do not collect any sensitive personal information (as defined by the CPRA). Personal Information Retention Periods

We may retain any or all categories of Personal Information when your information is subject to one of the following exceptions:

  • When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.
  • When necessary for us to exercise or defend legal claims.
  • When necessary to comply with a legal obligation.
  • When necessary to help ensure the security and integrity of our Website and IT systems.

Your Personal Information will otherwise be deleted when we no longer require your Personal Information for any of the above purposes or for any of the purposes for which we have collected it.

11. Changes to This CPRA Privacy Addendum

Greystone Housing Impact reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

12. Contact Information

If you have any questions or comments about this California Privacy Addendum, the ways in which Greystone Housing Impact collects and uses your information described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 917-421-4575

Postal Address:         Greystone Housing Impact Investors LP

Attn: Legal Department

152 West 57th St. 60th Floor

New York, NY 10019