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The Lockett Circle Global Privacy Policy

Effective | Last revision on the 18th of December, 2024

1. Introduction

The Lockett Circle and its affiliated brands and entities, including but not limited to Lockett Investment, Lockett Development, Lockett Living, and any current or future subsidiaries, operating companies, managed brands, or affiliated entities under common ownership or control (collectively, “The Lockett Circle,” “we,” “us,” or “our”) respect your privacy and are committed to protecting your personal information.

This Global Privacy Policy explains how we collect, use, disclose, store, and protect information about individuals who interact with us through our websites, digital platforms, investor materials, residential or property-related services, business relationships, communications, events, and other online or offline touchpoints.

This Privacy Policy is intended to provide a broad, global framework for our privacy practices and may be supplemented by additional notices where required by applicable law or specific services.

2. Scope

This Privacy Policy applies to personal information collected by or on behalf of The Lockett Circle in connection with:

  • our websites and digital properties;

  • inquiries submitted through contact forms or email;

  • investor, business, development, residential, leasing, hospitality, or service-related interactions;

  • marketing, brand, and communications activities;

  • vendor, consultant, contractor, and professional relationships;

  • event participation, meetings, and correspondence; and

  • any other interactions that reference or link to this Privacy Policy.

This Privacy Policy does not apply to information that is not governed by privacy law, such as anonymized or de-identified data, or to third-party websites, platforms, or services that we do not control.

3. Information We Collect

Depending on how you interact with us, we may collect the following categories of information:

A. Personal Information You Provide Directly

This may include:

  • full name;

  • email address;

  • phone number;

  • mailing address;

  • company or organization name;

  • job title or professional affiliation;

  • communications you send to us;

  • inquiry details or service requests;

  • account credentials, if applicable;

  • residential, leasing, tenant, or property-related information you choose to provide;

  • information submitted in connection with investor, development, vendor, or partnership inquiries; and

  • any other information you voluntarily submit.

B. Automatically Collected Information

When you visit our websites or use our digital services, we may automatically collect certain technical and usage information, such as:

  • IP address;

  • browser type and version;

  • device identifiers;

  • operating system;

  • referring URLs;

  • pages viewed;

  • date and time of visits;

  • clickstream and usage data;

  • approximate geolocation derived from IP address; and

  • cookie and similar tracking information.

C. Information From Third Parties

We may receive information from third parties such as:

  • analytics providers;

  • advertising or marketing partners;

  • social media platforms;

  • public databases;

  • business partners;

  • service providers;

  • professional advisors; and

  • publicly available sources.

D. Sensitive Information

We do not intend to collect sensitive personal information unless necessary for a legitimate business purpose and permitted by law. Where sensitive information is collected, it will be handled in accordance with applicable legal requirements.

4. How We Use Information

We may use personal information for the following purposes:

  • to operate, manage, and improve our business, brands, and services;

  • to respond to inquiries and communicate with you;

  • to provide information about our companies, services, developments, properties, opportunities, and offerings;

  • to administer websites, accounts, portals, or digital experiences;

  • to evaluate and manage investor, business, vendor, partnership, leasing, or residential relationships;

  • to personalize user experiences and improve site functionality;

  • to send newsletters, updates, invitations, and marketing communications where permitted by law;

  • to perform analytics, research, and internal reporting;

  • to maintain security, prevent fraud, and protect our rights and assets;

  • to comply with legal, regulatory, tax, accounting, and compliance obligations; and

  • to enforce our terms, policies, and other contractual rights.

5. Legal Bases for Processing

Where required under applicable law, we process personal information on one or more of the following legal bases:

  • your consent;

  • performance of a contract or steps taken at your request before entering into a contract;

  • compliance with legal obligations;

  • our legitimate business interests, provided those interests are not overridden by your rights; and

  • other lawful bases recognized by applicable privacy laws.

6. Cookies and Similar Technologies

We may use cookies, pixels, tags, scripts, and similar technologies to:

  • remember user preferences;

  • enable site functionality;

  • measure traffic and engagement;

  • analyze website performance;

  • improve content and user experience; and

  • support marketing or advertising efforts where permitted.

You may be able to manage cookie preferences through your browser settings or, where available, through cookie consent tools on our websites. Blocking certain cookies may affect site functionality.

7. How We Disclose Information

We may disclose personal information to the following categories of recipients:

  • affiliated entities within The Lockett Circle;

  • service providers, vendors, and contractors performing services on our behalf;

  • advisors, auditors, insurers, accountants, and legal counsel;

  • property managers, leasing partners, consultants, or development-related service providers, where applicable;

  • technology, analytics, communications, and hosting providers;

  • marketing and event partners, where permitted;

  • government authorities, regulators, courts, or law enforcement where required;

  • counterparties involved in corporate transactions; and

  • other parties with your direction or consent.

We may also disclose information in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets, joint venture, or similar business transaction.

We do not sell personal information in the traditional sense unless expressly disclosed in a jurisdiction-specific notice. We also do not share personal information for cross-context behavioral advertising except as described in applicable cookie or regional privacy notices.

8. International Transfers

Because we operate in a business environment that may involve cross-border communications, vendors, advisors, and digital infrastructure, personal information may be transferred to and processed in countries other than the one in which you reside.

Where required by law, we will implement appropriate safeguards for international transfers, which may include contractual protections, data transfer agreements, or other approved mechanisms.

9. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

  • provide services and maintain relationships;

  • fulfill contractual obligations;

  • comply with legal, tax, accounting, and regulatory requirements;

  • resolve disputes; and

  • enforce our agreements and policies.

Retention periods may vary depending on the nature of the information and the context in which it was collected.

10. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no system, website, transmission method, or storage platform can be guaranteed to be completely secure. You provide information at your own risk to the extent permitted by law.

11. Your Privacy Rights

Depending on your location and the laws that apply to you, you may have the right to:

  • access the personal information we hold about you;

  • request correction of inaccurate information;

  • request deletion of your personal information;

  • object to or restrict certain processing;

  • withdraw consent where processing is based on consent;

  • request portability of certain information;

  • opt out of certain marketing communications;

  • opt out of certain targeted advertising or profiling activities, where applicable; and

  • lodge a complaint with a regulator or supervisory authority.

We will respond to eligible requests in accordance with applicable law. We may need to verify your identity before processing certain requests.

12. U.S. State Privacy Rights

Residents of certain U.S. states may have additional rights under applicable privacy laws, including rights to know, access, delete, correct, and opt out of certain uses of personal information.

Where required, we will honor verified requests and will not discriminate against individuals for exercising their privacy rights.

If applicable law requires us to recognize browser-based opt-out preference signals, we will do so where technically supported and legally required.

13. EEA, UK, and Other International Rights

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with comparable privacy rights, you may have rights under applicable law regarding access, correction, erasure, restriction, objection, portability, and complaints to a supervisory authority.

Where required, we will also provide additional jurisdiction-specific notices regarding legal bases, data transfers, and complaint rights.

14. Marketing Communications

You may opt out of promotional emails or marketing communications by using the unsubscribe link in the message or by contacting us directly.

Even if you opt out of marketing messages, we may still send you transactional, administrative, relationship, or service-related communications where appropriate.

15. Children’s Privacy

Our websites, services, and business activities are not directed to children, and we do not knowingly collect personal information from children under the age required for consent under applicable law. If we learn that we have collected such information without appropriate authorization, we will take reasonable steps to delete it.

16. Third-Party Links and Services

Our websites and communications may contain links to third-party websites, platforms, applications, or services. We are not responsible for the privacy, security, or content practices of third parties. You should review their privacy policies before providing information to them.

17. Business-to-Business and Professional Information

In the course of conducting investment, development, residential, operational, brand, vendor, and professional activities, we may collect and use business contact information relating to representatives of companies, institutions, consultants, brokers, contractors, and other partners. We process such information for legitimate business purposes, including relationship management, diligence, communications, and operational administration.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, operations, legal obligations, or privacy practices. When we do, we will revise the “Last revision” date above. Any updated version will become effective when posted, unless otherwise required by law.

19. Contact Us

For questions, requests, or concerns regarding this Privacy Policy or our privacy practices, please contact:

The Lockett Circle
Email Legal Relations: globalprivacypolicy@lockettcircle.com

20. Entity Coverage

For purposes of this Privacy Policy, “The Lockett Circle” includes, where applicable:

  • The Lockett Circle

  • Lockett Investment

  • Lockett Development

  • Lockett Living

  • any affiliated holdings, subsidiaries, controlled entities, managed brands, operating divisions, and future related entities under common ownership or control, unless a separate privacy policy applies to a particular entity or service.