Last updated: June 12 2025

Pensam – Global Privacy Notice

You are receiving this Privacy Notice because you may need to provide Personal Data to Pensam or its affiliates in one of the following roles:

Investor: when subscribing to, lending to, or maintaining an interest in a Pensam-managed Investment Vehicle;
Borrower or Sponsor: when entering into, or being evaluated under, a loan or preferred-equity agreement with Pensam;
Service Provider/Partner: when providing goods or services to Pensam.

Pensam means Pensam Management Services II, Inc., its subsidiaries and affiliates. “Investment Vehicle” refers to any fund or similar collective investment scheme managed or advised by Pensam or its affiliates.

If you proceed with such an investment, transaction, or providing goods or services, you must supply Personal Data to Pensam. This Notice explains how and why we collect, use, store, and process your Personal Data. Personal Data means any information relating to an identified or identifiable individual under applicable data protection law.

Responsible Parties

Pensam, a private real estate investment firm focused on the U.S. multi-housing sector, issues this Privacy Notice on behalf of (i) the Investment Vehicle in which you invest and (ii) its Pensam-affiliated entities, general partners, managers, or investment advisers (together, the Investment Vehicle Parties). In this Notice, “Pensam,” “we,” “us,” and “our” refer to those entities.

Please consult your subscription agreement, private placement memorandum, or other offering documents for the exact entities and their contact details. Any Investment Vehicle Party that decides how and why your Personal Data is used is a “data controller.” Likewise, any other Pensam-controlled entity that processes your Personal Data for its own purposes is also a data controller.

Personal Data We Collect

The types of Personal Data we process about you as an investor, borrower/sponsor or service provider/partner, depend on the nature of the investment and the particular products or services you have with us. The categories of Personal Data we may collect include, but are not limited to, the following:

Contact Information: Your name, email address, postal address, and telephone number.
Demographic Information: Your date and country of birth, gender, country of residence, nationality, and citizenship.
Government Identification: Government-issued identification numbers provided in connection with your subscription to an Investment Vehicle, including your Social Security number, driver’s license number, passport number, national identification number, and tax identification number.
Professional and Employment Information: The name of your employer or the organization you represent, and your title or position.
Financial Information: Information related to your financial accounts and transactions with us or third parties, including:
- Bank account details;
- Financial account history;
- Information concerning the source of funds used for investments;
- Investment history (such as types and amounts of investments);
- Details regarding assets, income, financial returns, and positions;
- Details regarding beneficial ownership and controlling parties, when applicable;
- Details regarding trustees, grantors and beneficiaries, when applicable.
Investment Preferences: Information regarding your investment objectives and strategies.
Due Diligence and Compliance Information: Information collected through background checks, including:
- Know-your-client (KYC) verification;
- Anti-money laundering (AML) and sanctions screenings;
- Information regarding political exposure or sanctions status;
- Information regarding any other applicable restrictions.
Other Information You Provide:
Information you or the organization you represent choose to provide to us, such as responses to eligibility questionnaires, onboarding forms, and ongoing investor relations communications.

How We Collect Your Personal Data

We collect Personal Data about you from a variety of sources, including directly from you, from your representatives, and from third-party sources.

Information You Provide to Us Directly

This includes Personal Data you give us when you:

Complete application forms, account opening documentation, or related paperwork. This may include:
- Full name, home and/or business address
- Date and country of birth
- Passport number or other national identifiers
- Driver’s license number
- National Insurance or Social Security number
- Employment information
- Income and financial details, including investment or retirement portfolio information, financial positions, and expected returns
Complete loan or preferred-equity underwriting questionnaires (for Borrowers/Sponsors).
Correspond with us by email, telephone, or other electronic means, or when you engage in in-person discussions.
Make transactions in relation to your investments with the Investment Vehicle.
Interact with our websites and online platforms, including through:
- Online forms
- Account access portals
- Cookies, web beacons, and other tracking technologies
Provide instructions regarding purchases or transfers of securities or the disbursement of funds.
Visit our offices or attend meetings.

Information We Obtain from Third Parties

We may also collect Personal Data about you from external sources, including:

Public records and databases, such as:
- Publicly accessible directories
- Bankruptcy and court registers
Regulatory and governmental authorities, including:
- Tax authorities in your jurisdiction or abroad
- Other competent regulatory bodies where we have reporting obligations
Financial and compliance-related sources, such as:
- Credit reference agencies
- Risk intelligence platforms for KYC screening, AML, and sanctions compliance.
- Anti-fraud and financial crime prevention organizations.
- Transaction counterparties involved in your dealings with the Investment Vehicle.
- Credit reference agencies and property data providers used for underwriting Borrower/Sponsor applications, and credit and background authorizations.

How We Use Your Personal Data

We process your Personal Data under several legal bases, as described below:

Contractual Necessity

We process your Personal Data where it is necessary to perform our contract with you, including in order to:

Administer, manage, and establish your investor account(s) to enable you to acquire a holding (of shares or interests) in an Investment Vehicle;
Fulfill our contractual obligations to you;
Facilitate the continuation or termination of the contractual relationship between you and the Investment Vehicle;
Facilitate the transfer of funds, and administer and execute any other transactions, between you and the Investment Vehicle; and
Evaluate, underwrite, and approve investments in, or loans to, Investors, Borrowers, Sponsors, and other counterparties as part of our investment-committee decision process.

Compliance with Legal or Regulatory Obligations

We process your Personal Data where it is necessary to comply with applicable legal or regulatory obligations, including in order to:

Conduct client and investor due diligence and onboarding procedures;
Carry out identity verification, KYC, anti-terrorism financing, sanctions, and AML checks;
Verify the identity and addresses of investors (and, where applicable, their beneficial owners);
Respond to requests from regulatory, governmental, tax, and law enforcement authorities;
Conduct surveillance, investigations, and audit activities;
Maintain statutory registers;
Prevent and detect fraud;
Comply with applicable sanctions requirements; and
Conduct borrower/sponsor KYC, AML, and sanctions screening prior to credit approval.

Legitimate Interests

We may also process your Personal Data where it is necessary for our legitimate interests or those of a third party (such as transaction counterparties or lenders), provided such interests are not overridden by your interests, rights, or freedoms. These purposes include:

Managing and administering your holdings and any related accounts on an ongoing basis;
Assessing and processing applications or other requests made by you;
Opening, maintaining, or closing accounts in connection with your investment activities;
Communicating with you regarding your investment, including sending updates, notices, and other correspondence;
Addressing or investigating complaints, claims, legal proceedings, or disputes;
Informing you about and providing our investment products and services;
Monitoring and enhancing our relationships with investors;
Supporting regulatory compliance, including KYC, AML, and sanctions checks;
Assisting our transaction counterparties in meeting their own compliance obligations;
Managing risks, operations, and accounting, audit, and tax-reporting requirements;
Maintaining internal compliance with our corporate policies and governance standards;
Keeping internal records and preparing incident or accident reports;
Safeguarding our business against fraud, breaches of confidence, theft of proprietary materials, and other financial or business crimes;
Analyzing and managing commercial and operational risks;
Seeking and obtaining professional advice, including legal counsel;
Facilitating transfers or assignments of Investment Vehicle rights or obligations;
Enabling business asset transactions involving the Investment Vehicle or its affiliates;
Monitoring communications conducted through our information technology systems;
Protecting the security and integrity of our information technology systems and physical locations;
Operating and managing online meetings, webinars, and conferences (including through platforms such as Zoom);
Managing our financing arrangements with financial institutions, intermediaries, and correspondent or agent banks;
Monitoring the operation of Investment Vehicle distribution platforms operated by third parties or service providers; and
Assessing and monitoring the creditworthiness and performance of Borrowers/Sponsors.

We only rely on legitimate interests after determining that such interests are not overridden by your fundamental rights and freedoms.

How We Disclose Your Personal Data

We only disclose your Personal Data where permitted or required by applicable law, and solely for the purposes described in this Privacy Notice. We may disclose your Personal Data to the following categories of recipients:

Investment Vehicle Associates

We may share your Personal Data with our affiliates, group entities, and related parties in order to:

Manage our relationship with you;
Facilitate third parties’ compliance with AML, KYC, and other regulatory obligations; and
Carry out the purposes outlined in this Privacy Notice.

Investment Vehicle Managers, Depositaries, Custodians, Distributors, and Investment Advisers

We share Personal Data with service providers involved in the management and operation of Investment Vehicles in order to:

Deliver services you have requested;
Manage your investment;
Support and administer investment-related activities; and
Comply with applicable investment, AML, KYC, and other regulatory obligations.

Tax Authorities

We may disclose your Personal Data to domestic and foreign tax authorities as required to:

Comply with applicable tax laws and regulations;
Respond to lawful requests from tax authorities.

Financing Counterparties, Lenders, and Correspondent and Agent Banks

We may share Personal Data with financing transaction counterparties to:

Support regulatory compliance efforts;
Facilitate credit sourcing and financing arrangements; and
Support underwriting and loan monitoring.

Professional Advisers

We may share your Personal Data with our legal advisers, auditors, and other professional service providers in order to:

Provide investment-related services to you; and
Support the purposes described in this Privacy Notice.

Service Providers

We may disclose any Personal Data we receive with Service Providers retained in connection with the provision of our products and services. We require that our Service Providers use your Personal Data disclosed by us solely for the purposes of performing services for us and that they maintain the confidentiality, security and integrity of such Personal Data.

Merger, Sale, or Other Asset Transfer

We may transfer your Personal Data to advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Consent

We may also disclose your Personal Data with your permission.

Other Disclosures

In exceptional circumstances, we may disclose your Personal Data to:

Competent regulatory authorities, law enforcement agencies, prosecuting authorities, or litigation counterparties; and
Other third parties where disclosure is required by applicable law.

International Transfers of Personal Data

Pensam, together with its affiliates and subsidiaries, is headquartered in the United States of America. As a result, if you are located outside of the United States, your Personal Data will be transferred to, and processed in, the United States, where data protection standards may differ from those in your jurisdiction.

To safeguard your Personal Data when it is transferred internationally, we implement appropriate measures in accordance with applicable data protection laws. These measures may include entering into data transfer agreements incorporating standard contractual clauses, relying on adequacy decisions, or obtaining your consent where required.

Retention and Deletion of Your Personal Data

We retain your Personal Data for as long as necessary to fulfill our legitimate business purposes, perform our contractual obligations, or comply with legal and regulatory requirements. The retention period will also be governed by Pensam’s data retention policy.

In general, we will:

Retain your Personal Data for the entire duration of any investment or relationship you have with us.
Retain certain Personal Data even after the conclusion of your relationship with us, to comply with legal, regulatory, or business requirements.

As a general principle, we do not keep your Personal Data longer than necessary. Once your involvement as an investor in any Investment Vehicle ends, we will typically delete your Personal Data when there is no longer any legal, regulatory, or business reason for retaining it.

Your Rights

Depending on the data protection laws applicable to the processing of your Personal Data, and subject to certain limitations, you may have the following rights:

Access to your Personal Data.
The right to rectify incomplete or inaccurate Personal Data.
The right to request the deletion of your Personal Data in specific circumstances.
The right, in certain cases, to request the portability of your Personal Data in a structured, commonly used, and machine-readable format to another organization (where feasible).

If you wish to exercise any of these rights, please refer to the ‘Contact Us’ section for further information.

Contact Us

If you have any questions about this Privacy Notice or the Personal Data we hold about you, please contact us:

By email: legal@pensamcapital.com

U.S. Privacy Addendum

California & Other U.S. States Notice at Collection

Categories of Personal Information Pensam Receives: Pensam may collect, or process on behalf of our investors, the following categories of personal data, as described above, in the “What Personal Data We Collect” section.

Category	Examples	Collected?	Purpose of Collection
Identifiers	Name, alias, mailing address, email address, passport number, driver’s license number, Social Security number, taxpayer ID	✅ Yes	To identify and verify investors; fulfill legal and contractual obligations
Personal Information (per Cal. Civ. Code § 1798.80)	Signature, contact details, bank account number, other financial information	✅ Yes	To process transactions, manage investments, and comply with AML/KYC laws
Protected Classification Characteristics	Gender, nationality, citizenship	✅ Yes	For regulatory reporting, sanctions screening, and compliance obligations
Commercial Information	Records of products or investments purchased, obtained, or considered	✅ Yes	To manage investor relationships
Internet or Network Activity	IP address, browsing behavior on our websites or portals, device data	✅ Yes	To secure our platforms and enhance user experience
Geolocation Data	Approximate location data derived from IP addresses	✅ Yes	For security and fraud prevention
Professional or Employment Information	Job title, employer name, business contact information	✅ Yes	For due diligence and to administer institutional relationships
Sensitive Personal Information	Government IDs (e.g., SSN, passport), financial account numbers, citizenship/immigration status	✅ Yes	For identity verification, AML/KYC screening, and compliance with applicable laws
Borrower/Sponsor Data	Name, alias, mailing address, email address, passport number, driver’s license number, Social Security number, taxpayer ID	✅ Yes	To identify and verify borrowers/sponsors; fulfill legal and contractual obligations

Sources: We receive information from sources as described in the “How We Collect Your Personal Data” section, including: from you; from third parties; and from publicly available sources.

Pensam’s business and commercial purposes for use: Pensam uses personal data for the following business and commercial purposes: to provide Pensam services; for authentication, integrity, security, and safety; to communicate with you; and for legal reasons. For more information, please see “How We Use Your Personal Data”; Categories of third parties to whom we disclose Personal Information for business purposes are described in “How We Disclose Your Personal Data”.

Pensam may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website which may constitute a “sale” or “sharing” of data for targeted advertising purposes under certain state privacy laws. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.

Retention: Pensam retains personal data for as long as required to engage in the uses described in this Privacy Notice, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention and Deletion of Your Personal Data, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA/CPRA), residents may have a right to:

Access the categories of Personal Data Pensam has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Pensam has shared Personal Data, and obtain the Personal Data in a portable format;
Delete Personal Data under certain circumstances;
Correct Personal Data under certain circumstances; and
Opt out of the “sale” of Personal Data or “sharing” of Personal Data for targeted advertising purposes. We do not sell your Personal Data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You can get more information and opt out of the use of cookies and other trackers on our website by clicking the Cookies Settings Your Privacy Choices, also on our homepage, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. Residents of California, Colorado, Connecticut, Montana, Nebraska, New Hampshire, and Texas may also set the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal information for targeted advertising for each participating browser system that you use. Pensam does not have actual knowledge that it “sells” or “shares” the personal information of consumers under 16 years of age.
Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing legal@pensamcapital.com.

Pensam will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

Sensitive Information. Pensam receives information that may be considered sensitive under some state laws, such as Government IDs, Passport Information or SSNs. Pensam processes sensitive personal information to provide Pensam services, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. Pensam does not use or disclose sensitive personal information for purposes of inferring characteristics about an investor, or in any way that would require Pensam to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. Pensam does not engage in this type of profiling of individuals.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account with us (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified request by providing written permission and verifying your identity, or through proof of power of attorney.

Changes to this Privacy Notice

We regularly review and update this Privacy Notice. Any changes will be reflected in this document, and we encourage you to check periodically for updates.