1. Introduction

RTL Partners, LLC ("we," "us," or "our") operates rtl-re.com (the "Site"). This Privacy Policy describes how we collect, use, disclose, and protect personal information submitted through or collected on our Site. By using our Site, you consent to the practices described herein.

Our Site supports commercial real estate services. It does not maintain user accounts or collect highly sensitive personal information. We do, however, use third-party analytics, marketing automation, and email delivery tools that collect data as described below.

2. Information We Collect

A. Information You Provide Through Forms

Our Site includes four forms through which you may voluntarily submit personal information. Each form is described below with the specific fields it collects.

We do not sell or share any of the information discussed below with third parties.

Request Information (Property Listing Pages)

Used to contact our team about a specific property. Collects:

• Name
• Phone number
• Email address
• Comments or questions

Share Listing

Used to email a property listing to a third party on your behalf. Collects:

• Your name
• Your email address
• Recipient's email address
• Optional selections: Include Listing Link and Attach PDF Brochure

The recipient's email address is used solely to deliver the listing you have chosen to share. It is transmitted via Mailgun for that one-time delivery and is not retained for marketing purposes or added to any contact list.

Request Advanced Demographics

Used to request a demographics report for a specific area or property. Collects:

• Your name
• Your email address
• Free-text field: "What can we help you find?"

Information submitted through this form is used solely to prepare the requested demographics report or to follow up regarding commercial real estate opportunities.

Subscribe to Our Mailing List

Used to receive property updates and marketing communications. Collects:

• First name and last name
• Email address (required)
• Broker status (checkbox: "Are you a broker?")
• Company name
• Comments (optional free text)

By subscribing, you consent to receiving marketing communications from us. You may unsubscribe at any time using the link in any email we send.

B. Analytics & Tracking Data

We use HubSpot and Google Analytics to understand how visitors interact with our Site. Both services are activated only after you provide consent through our cookie banner. No analytics or tracking cookies are set before consent is given.

HubSpot

HubSpot provides our forms, CRM, cookie consent banner, and visitor analytics. After consent, HubSpot may collect:

• Visitor identifiers and session information
• Page views and form submissions
• Marketing attribution and returning visitor recognition
• Browser and device information

HubSpot sets the following cookies on your device after consent:

• hubspotutk - tracks visitor identity across sessions for contact association
• __hstc - tracks visitor session history
• __hssc - tracks activity within a session
• __hssrc - determines whether the browser session was restarted

HubSpot also sets hs_cookie_cat_, which stores your cookie consent preferences.

Google Analytics

We use Google Analytics for website traffic and usage analytics. Google Analytics is integrated with our HubSpot consent banner and activates only after you provide consent. Google Analytics may collect:

• Page views and session duration
• Device type, browser, and operating system
• Approximate geographic location
• Referral source and traffic statistics
• User interactions and navigation patterns

Google Analytics data is processed by Google LLC. For more information, see Google's Privacy Policy.

C. Email Delivery - Mailgun

When you submit a contact or property inquiry form, or use the Share Listing feature, we use Mailgun to securely process and deliver your message to our team or to your designated recipient. The information you provide - which may include your name, email address, phone number, and message - is transmitted through Mailgun solely for delivery purposes.

Mailgun does not set browser cookies, does not track your activity on our Site, and does not use submitted information for its own marketing purposes.

D. Server Logs - GoDaddy Hosting

Our Site is hosted on GoDaddy, which automatically records standard server log data including:

• IP address
• Browser and operating system
• Pages requested and HTTP status codes
• Date and time of access
• Referring URL

These logs are used for security monitoring and technical troubleshooting. They are maintained by GoDaddy in accordance with GoDaddy's Privacy Policy.

E. Infrastructure - Cloudflare

HubSpot's content delivery network uses Cloudflare for bot management and security. As a result, Cloudflare may set the following cookie on your device:

• __cf_bm - a bot-management cookie set by Cloudflare to distinguish human visitors from automated traffic

This cookie is infrastructure-level and functions for security purposes. It is not used for advertising or behavioral tracking.

3. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our Site. The categories in use are summarized below.

Necessary Cookies

Required for basic Site functionality and security. These are set regardless of consent and include the Cloudflare bot-management cookie (__cf_bm) and the HubSpot consent preference cookie (hs_cookie_cat_). These cannot be disabled without affecting core Site operation.

Analytics Cookies (Consent Required)

Set only after you accept our cookie banner. These include cookies from HubSpot Analytics (hubspotutk, __hstc, __hssc, and __hssrc) and Google Analytics. These help us understand how visitors use the Site.

Advertising Cookies (Consent Required)

HubSpot's tracking functionality supports marketing automation and visitor attribution. These cookies activate only after consent is given through our banner.

Managing Your Cookie Preferences

You can accept or decline non-essential cookies through our consent banner, which appears on your first visit. You may update your preferences at any time using the Cookie Settings button below. Declining analytics and marketing cookies will not affect your ability to use any part of the Site.

4. Third-Party Services

Our Site integrates with the following third-party services. Each operates under its own privacy policy:

• HubSpot - Forms, CRM, cookie consent banner, and visitor analytics. View Privacy Policy
• Google Analytics - Website traffic and usage analytics through HubSpot consent integration. View Privacy Policy
• Mailgun - Email delivery for form submissions and Share Listing. View Privacy Policy
• GoDaddy - Web hosting and server infrastructure. View Privacy Policy
• Cloudflare - CDN and bot-management security through HubSpot infrastructure. View Privacy Policy
• Google Fonts - Typeface rendering; requests may be logged by Google servers. View Privacy Information
• Google Maps API - Embedded maps that may set cookies and collect interaction data. View Privacy Policy
• YouTube - Embedded videos that may collect viewing data under Google's Privacy Policy. View Privacy Policy

5. How We Use Your Information

We use the information we collect to:

• Respond to property inquiries and contact requests
• Deliver listing shares to recipients you designate
• Prepare advanced demographics reports upon request
• Send marketing communications to mailing list subscribers with consent
• Discuss available commercial real estate properties and leasing opportunities
• Analyze Site performance and visitor behavior to improve our services
• Maintain server security and prevent fraudulent or automated access
• Comply with applicable legal obligations

We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.

6. California Privacy Rights

A. California Consumer Privacy Act (CCPA / CPRA)

If you are a California resident, you have the following rights with respect to your personal information:

• Right to Know - Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purposes, and the third parties with whom we share it.
• Right to Delete - Request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct - Request correction of inaccurate personal information we hold about you.
• Right to Opt Out of Sale or Sharing - We do not sell personal information. We use HubSpot and Google Analytics in ways that may constitute "sharing" for cross-context behavioral advertising under California law. You may opt out at any time through our cookie consent banner.
• Right to Limit Use of Sensitive Personal Information - We do not collect sensitive personal information as defined by the CPRA.
• Right to Non-Discrimination - We will not discriminate against you for exercising any of these rights.

To submit a rights request, contact us at info@rtl-re.com or 212-792-2600.

We will respond within 45 days of a verified request. We may extend this period by an additional 45 days when reasonably necessary and will notify you of any extension.

B. California Invasion of Privacy Act (CIPA)

California Penal Code Sections 630-638.55 (CIPA) govern the interception and recording of electronic communications and require all-party consent for such interception in California.

Session Replay and Real-Time Tracking: Our Site uses HubSpot tracking, which may capture your interactions with the Site in real time, including form interactions, clicks, and navigation. By accepting our cookie consent banner, you consent to this tracking. You may withdraw consent at any time through the cookie banner.

Third-Party Scripts: Analytics and tracking scripts from HubSpot and Google Analytics may intercept data in transit once consent is provided. No such scripts activate before consent is given.

Do Not Track: Our Site does not currently respond to browser "Do Not Track" signals. To opt out of cookies or other tracking software, use the cookie banner or update your preferences through the Cookie Settings button on this page.

C. California Shine the Light (Cal. Civ. Code Section 1798.83)

We do not disclose personal information to third parties for their own direct marketing purposes.

7. New York SHIELD Act

RTL Partners, LLC is headquartered in New York and complies with the New York Stop Hacks and Improve Electronic Data Security Act (SHIELD Act, N.Y. Gen. Bus. Law Section 899-aa et seq.), which requires businesses that own or license computerized data including private information of New York residents to implement and maintain reasonable data security safeguards.

What Qualifies as Private Information

Under the SHIELD Act, "private information" includes a person's name combined with any of the following: Social Security number, driver's license or ID number, financial account numbers, or biometric data. It also includes usernames and email addresses combined with passwords or security answers. Our Site collects names and email addresses through our forms; we treat this information with the same security safeguards applied to all personal data we hold.

Our Security Program

We maintain a reasonable administrative, technical, and physical security program that includes:

• Administrative safeguards - Designating employees responsible for the security program, training staff on security practices, and selecting service providers capable of maintaining appropriate safeguards.
• Technical safeguards - Using secure transmission protocols (HTTPS) for all data submitted through our Site, ensuring analytics and tracking tools activate only after consent, and relying on established third-party platforms such as HubSpot, Mailgun, and GoDaddy that maintain their own security programs.
• Physical safeguards - Protecting systems that store personal data from unauthorized physical access.

Data Breach Notification

In the event of a breach of the security of our system that exposes private information of New York residents, we will notify affected individuals and the New York Attorney General as required by the SHIELD Act. Notification will be made in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement and any measures necessary to determine the scope of the breach and restore the integrity of the system.

8. Data Retention

• Form submission data, including inquiries, demographics requests, and mailing list subscriptions, is retained only as long as necessary for business purposes or as required by law.
• Recipient email addresses collected through the Share Listing form are used for one-time delivery only and are not retained in our CRM or marketing lists.
• Analytics data is retained according to settings configured within HubSpot and Google Analytics, typically up to 26 months for Google Analytics.
• Server log data is retained by GoDaddy in accordance with its standard hosting policies.
• Mailgun transmission records are retained for the period necessary to confirm delivery and resolve disputes.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, or destruction. Our cookie consent system ensures that tracking technologies do not activate until you have provided affirmative consent.

No method of internet transmission or electronic storage is completely secure. We cannot guarantee absolute security. In the event of a data breach affecting California residents, we will provide notification as required by California Civil Code Sections 1798.29 and 1798.82.

10. Children's Privacy

Our Site is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you believe we have inadvertently collected such information, please contact us immediately and we will take steps to delete it.

11. Your Privacy Choices

Regardless of your state of residence, you may:

• Accept or decline non-essential cookies through our consent banner on your first visit
• Update cookie preferences at any time using the Cookie Settings button on this page
• Unsubscribe from marketing emails using the unsubscribe link in any email we send
• Request access to, correction of, or deletion of your personal information by contacting us

To exercise any of these rights, contact us at info@rtl-re.com. We may need to verify your identity before processing your request.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page. Your continued use of the Site following the posting of changes constitutes your acceptance of the updated policy.

13. Contact Us

For privacy-related questions, requests, or concerns: