Last Updated: May 13, 2024

Royal Oak Realty Trust Inc., a Maryland corporation (“Royal Oak,” “our,” “us,” or “we”), is committed to protecting the privacy and security of the information of our users (“you”).  We want you to understand how we collect and use information from our website (the “Site”) so you can interact with us with confidence.  By using the Site, you accept and agree to the practices this Privacy Policy describes.  This policy applies to information we collect from this Site and in email and other messages between you and this Site.  It does not apply to information collected by us offline or through any other means, including on any other website operated by a third party.  If you do not agree to any of the terms in this Privacy Policy, you should not use the Site.

What Information Do We Collect?

When you use our Site, we may collect, store, and process various kinds of data, including personal information about you.  “Personal information” refers to information about you that can be used to identify you, such as your name, address, telephone number, or e-mail address.  We may also collect information that is about you but individually does not identify you, such as real property information.

Specifically, we may collect, store, or process information when you:

  • Register for a Stockholder Portal account on our Site (“Account”);
  • Submit a form on the Site;
  • Contact us with inquiries, including via email;
  • Subscribe to receive communications; or
  • Voluntarily provide information.

Information About You

While you may use parts of our Site anonymously, certain features may require you to provide information that can directly identify you.  The types of information we may collect directly from you may include, but is not limited to, the following:

  • Name;
  • Email address;
  • Log-in credentials, if you create an Account;
  • Phone number;
  • Information about your real property;
  • Demographic information, if you choose to provide it; or
  • Any other information you choose to provide to us.

Automatic Collection

We may also collect details of your visit to our Site and the pages you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, device type, the date and time you accessed or left the Site, and which pages you viewed.  Some parts of our Site uses cookies and other technologies to collect this information about your general internet usage.  See the section below called “How We Use Tracking Technologies” to learn more.

Information Collected From Third Parties

If you access the Site through a third-party social network connection or log-in, you may allow us to have access to and store certain information from your social network profile. We may also receive information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other third parties that we may attribute to you. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our Site.

Why We Collect Information

We use your information for the following purposes:

  • To present our Site to you;
  • To fulfill any other purpose for which you provide it;
  • To notify you about changes to our Site;
  • To improve our Site;
  • To perform analytics to learn about the behavior of our Site users;
  • To send periodic emails relating to company news;
  • For any other purpose with your consent;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site visitors is among the assets transferred.

How We Use Tracking Technologies

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your online activities) (“Tracking Technologies”). Tracking Technologies collect information that tells us how you use our Site. The use of Tracking Technologies does not give us access to the rest of your computer.

This, in turn, helps us make our Site relevant to your interests and needs.  We use a number of different Tracking Technologies, including functional, performance, and social media or content cookies.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. Most browsers accept cookies automatically. You may be able to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. For instructions, check your browser’s technical information. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.  Please note that cookie-based opt outs must be performed on each device and browser that you wish to have opted out.
  • Google Analytics. We may use Google Analytics to improve our Site’ functions.  You can choose not to be included in Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

“Do Not Track” Requests

Our Site currently do not respond to “do not track” or similar signals.

How Do We Share Your Personal Information?

We may disclose your personal information as follows:

  • To our subsidiaries and affiliates, including Cambridge Street Asset Management, LLC, our asset management company (“Asset Manager”);
  • With affiliates, contractors, Site providers, and other third parties we use to support our business and/or our Site, including our stock transfer agent,
  • To fulfil the purpose for which you provide it;
  • For any other purpose disclosed by us when you provide the information;
  • With social media companies, as explained below;
  • For any purpose with your consent;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about the Site’ users is among the assets transferred;
  • To enforce any agreement, including any applicable terms of Site;
  • To establish or exercise our right to defend against legal claims;
  • To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Site’ information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
  • If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of Royal Oak or others.

Security of Information

To protect your personal information, we have implemented measures designed to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your personal information, we cannot guarantee that it will be 100% secure. Your transmission of your information to our Site thus is done entirely at your own risk and you acknowledge that: (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential.

Third-Party Websites and Social Media

Our Site may contain links to other sites, including those of third parties or partners.  While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use.  By accessing other third-party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites.  It is possible that other parties may collect personally identifiable information about your online activities over time and across different websites when you use our Site.

Our Site may include social media features, that require cookies to be set to function properly.  These features may also collect personal information such as your IP address.  These features are governed by the Privacy Policy of the social media platform.  Please review the Privacy Policy of the social media platforms to learn how they protect your information.

International Visitors

Our Site are hosted and operated in the United States (“US”).  By using the Site, you are consenting to the transfer of your personal information to the US.  We may also store your information outside of the United States or may in the future transfer it to third parties located in other countries for the purposes described in this Privacy Policy.  If you are accessing our Site from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction. Those who access the Site from outside of the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information and the exact scope of these rights may vary by state.  We recommend you contact your state government for additional information regarding your rights.  Please note, we do not disclose your personal information to third parties for their direct marketing purposes.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to investorservices@royaloakrealtytrust.com.

Users Only of Legal Age of Majority

Our Site are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features/register on the Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 without verifiable parental consent, please contact us immediately by emailing investorservices@royaloakrealtytrust.com.

Limitation of Liability and Disclaimers

IN NO EVENT SHALL ROYAL OAK, ITS AFFILIATES OR ASSET MANAGER, OR THEIR RESPECTIVE RELATED PERSONS (AS DEFINED BELOW) BE LIABLE TO ANY PARTY FOR ANY CLAIMS, LIABILITIES, LOSSES, COSTS OR DAMAGES, INCLUDING BUT NOT LIMITED TO ANY DIRECT, INDIRECT, PUNITIVE, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES (“DAMAGES”) ARISING OUT OF OR IN CONNECTION WITH ANY ACCESS, USE (OR INABILITY TO USE) OR DISTRIBUTION OF THE SITE, INCLUDING DAMAGES CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF OR USE OF ANY ASSET, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR, NEGLIGENCE OR UNDER ANY OTHER CAUSE OF ACTION, OR ANY CONTENT OBTAINED THROUGH USE OF THE SITE. THIS IS TRUE EVEN IF ROYAL OAK, ITS AFFILIATES OR ASSET MANAGER OR THEIR RESPECTIVE RELATED PERSONS HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.

Royal Oak, its affiliates and asset manager, and their respective officers, directors, managers, partners, members, shareholders, employees, affiliates and agents (collectively “Related Persons”) make no representations or warranties and specifically disclaim any and all warranties of any kind, express or implied, with respect to the Site, including any representations or warranties with respect to merchantability, fitness for a particular purpose, title, non-infringement, availability, security, accuracy, freedom from viruses or malware, completeness, timeliness, functionality, reliability, sequencing or speed of delivery.

While we use reasonable efforts to obtain information from reliable sources, Royal Oak does not warrant that the information in this Site is accurate, reliable, complete or correct, or that this Site will be available at any particular time or location. Such information or materials are provided “as is” and “as available”.

Governing Law and Forum

The laws of the State of New York govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the Site shall be resolved solely in a federal or state court located in Rochester, New York. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute or action and agree to waive trial by jury in any such dispute or action. If any provision of this Privacy Policy is held to be unenforceable, such provision will be reformed only to the extent necessary to make it enforceable. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any third party.

Review and Correction of Your Information

You may review and edit the information we collected about you at any time by contacting us at the addresses listed at the end of this Privacy Policy.  If your information has been shared with a third party, as described elsewhere in this Privacy Policy, then that third party has received its own copy of your data.  If you have been contacted by one of these third parties and wish to correct or delete your information, please contact them directly.

Privacy Policy Updates

We update the Privacy Policy from time to time, so please review it regularly.  If we materially change our Privacy Policy, we will notify you by contacting you through your provided e-mail address or by posting a notice on our Site. Your continued use of our Site will be deemed your agreement that your information may be used in accordance with the new policy.  If you do not agree with the changes, then you should stop using the Site and notify us that you do not want your information used in accordance with the changes.

Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy.  Please do not hesitate to contact us at:

Royal Oak Realty Trust Inc.
600 East Avenue, Suite 200
Rochester, NY 14607
Phone: (585) 434-1660
Fax: (585) 434-1670
info@royaloakrealtytrust.com