Privacy Policy

1. Overview

Owlish Investments LLC is a real estate investment and management firm. In the course of operating our business and providing our services, we may collect personal information from prospective clients, existing clients, property owners, tenants, investors, job applicants, and visitors to our website.

This Policy is intended to comply with applicable privacy laws, including the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA"), and the European Union General Data Protection Regulation ("GDPR"), including as retained in United Kingdom law.

2. Information We Collect

We collect personal information in a variety of ways, including directly from you, automatically through our website, and from third parties.

Information You Provide Directly

• Contact details such as name, email address, phone number, and mailing address
• Inquiry and correspondence content submitted through our contact form or by email
• Financial information provided in connection with investment, leasing, or management services (such as income verification or credit information)
• Government-issued identification where required by applicable law or KYC obligations
• Employment and professional information provided by job applicants

Information Collected Automatically

• IP address, browser type, operating system, and device identifiers
• Pages visited, time spent on pages, and referring URLs
• Cookie and similar tracking technology data (see Section 9)

Information from Third Parties

• Background screening and credit reporting agencies (with your consent where required)
• Business partners and referral sources
• Publicly available government and property records

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to inquiries and communicate with you about our services
• To provide property management, investment advisory, and related services
• To enter into and perform contracts with clients, tenants, and investors
• To conduct due diligence, credit checks, and background screening as permitted or required
• To comply with legal and regulatory obligations, including anti-money laundering (AML) and Know Your Customer (KYC) requirements
• To send service-related communications and, where you have consented, marketing communications
• To analyze website usage and improve our online presence
• To protect the security and integrity of our business and systems
• To evaluate job applications and manage our hiring processes

Legal Bases for Processing (GDPR)

For individuals in the EEA or UK, we rely on the following legal bases for processing personal data:

• Contract: Processing necessary to perform a contract with you or to take steps at your request before entering a contract
• Legal Obligation: Processing necessary to comply with applicable laws and regulations
• Legitimate Interests: Processing necessary for our legitimate business interests (such as fraud prevention and service improvement), where those interests are not overridden by your rights
• Consent: Where you have provided explicit consent, such as for marketing communications

4. Sharing of Information

We do not sell your personal information. We do not share your personal information with third parties for their own marketing purposes. We may disclose personal information in the following circumstances:

Service Providers

We engage trusted third-party service providers who process personal information on our behalf, including IT and hosting providers, professional advisors (attorneys, accountants, auditors), payment processors, and background screening agencies. These providers are contractually obligated to use personal information only as directed by us and in accordance with applicable law.

Business Transactions

In the event of a merger, acquisition, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate confidentiality protections.

Legal Compliance and Protection

We may disclose personal information where required by law, regulation, court order, or governmental authority, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

With Your Consent

We may share personal information with third parties where you have provided your explicit consent to such sharing.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. Factors that determine retention periods include the nature of our relationship with you, the type of information collected, applicable legal and regulatory retention requirements, and the need to resolve disputes or enforce agreements.

When personal information is no longer required, we securely delete or anonymize it in accordance with our data management practices.

6. Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

If you have reason to believe that your personal information has been compromised, please contact us immediately at privacy@owlishinvestments.com.

7. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the following rights under the CCPA as amended by the CPRA:

Right to Know

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the purposes for collection, and the categories of third parties with whom we share it.

Right to Delete

You have the right to request deletion of personal information we have collected about you, subject to certain exceptions permitted by law (such as information needed to complete a transaction, comply with a legal obligation, or detect security incidents).

Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

Right to Opt-Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information. As noted above, we do not sell or share personal information for cross-context behavioral advertising.

Right to Limit Use of Sensitive Personal Information

To the extent we use sensitive personal information, you have the right to direct us to limit such use to purposes permitted under the CPRA.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your California privacy rights. You will not receive a different level or quality of service as a result of exercising your rights.

How to Exercise Your California Rights

To submit a verifiable consumer request, contact us at privacy@owlishinvestments.com. We will respond to verifiable requests within 45 days, with a possible 45-day extension where reasonably necessary. You may designate an authorized agent to make a request on your behalf, provided we can verify the agent's authorization.

8. European Privacy Rights (GDPR)

If you are located in the European Economic Area or the United Kingdom, you have the following rights under the GDPR:

Right of Access

You have the right to request a copy of the personal data we hold about you and information about how we process it.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies.

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing.

Right to Data Portability

Where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.

Right to Object

You have the right to object to processing based on legitimate interests, including for direct marketing purposes. Where you object to direct marketing, we will cease processing for that purpose immediately.

Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects. We do not engage in such automated decision-making.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection supervisory authority. In the EU, this may be the supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement. In the UK, this is the Information Commissioner's Office (ICO).

International Data Transfers

Where personal data is transferred outside the EEA or UK, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or equivalent mechanisms under UK law, to ensure your data receives an adequate level of protection.

How to Exercise Your GDPR Rights

To exercise any of the rights listed above, please contact our privacy team at privacy@owlishinvestments.com. We will respond within 30 days, extendable by an additional two months where necessary for complex requests.

9. Cookies & Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your experience, analyze traffic, and support our business operations. Cookies are small text files stored on your device when you visit our website.

Types of Cookies We May Use

• Essential Cookies: Required for the website to function properly and cannot be disabled
• Analytics Cookies: Help us understand how visitors interact with our website (e.g., pages visited, time on site)
• Preference Cookies: Remember your settings and preferences to improve your experience

You may manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect website functionality. For California residents, we do not use tracking technologies for the purpose of cross-context behavioral advertising or the sale of personal information.

10. Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal information from a child under 16, we will take steps to delete such information as soon as practicable. If you believe we have collected information from a child, please contact us at privacy@owlishinvestments.com.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify affected individuals directly. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

Your continued use of our website or services after any updates constitutes your acknowledgment of the revised Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: