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Privacy Policy

Last Revised: August 2022

This privacy policy (this “Policy”) describes the policies and procedures of Claros Mortgage Trust, Inc.  (“we,” “our,” “us”) with respect to personal data that we collect, hold, use or process when you visit our website at www.ClarosMortgage.com (the “Site”). This Policy also covers the measures we take to protect the confidentiality, integrity and security of that personal data, and your rights regarding such personal data. 

By visiting the Site, you acknowledge that you have read this Policy, which we may update at any time. If we update this Policy, we will post the updated version here. Any such changes will be effective as to you when you first access the Site after we post the changes here. If we make any material changes in the way we collect, hold, use, process or share your personal data, we will endeavor to provide you with appropriate notice.

The Terms of Use, which govern the use of the Site, can be found here.

This Policy sets out:

  • the types of personal data that we collect from individuals when they use the Site;
  • the purposes and legal basis for our processing and use of individuals’ personal data;
  • how we may disclose or use personal data;
  • how we transfer personal data outside of the European Economic Area (“EEA”) or United Kingdom (“UK”); and
  • individuals’ rights with respect to our use or disclosure of their personal data.

Queries regarding how (1) our policies may apply to your personal data; (2) to exercise your right to question or object to our use of your personal data, in accordance with applicable laws; or (3) to access, correct or delete your personal data, should be sent to us using the contact information set forth below.

Who Controls the Data We Collect

We are a data controller with respect to your personal data. We “control” the data you submit to the Site and make certain decisions as to how to use and protect it, but only to the extent that we have informed you about such use or as otherwise permitted by applicable law. 

What Personal Data Do We Collect

We collect personal data from individuals who visit the Site.

We provide the opportunity for you to submit your email address to subscribe to investor alerts related to our business in the category or categories that you specify (collectively, “Investor Alerts”).

You will always have the ability to opt out of receiving further Investor Alerts from us, either on the Site or by following the opt out instructions on emails.

In addition, we may record details of visits to the Site, such as traffic data, IP addresses, location data, weblog information about the device you use to interact with the Site, the type of operating system and browser you use, access times, pages viewed, URLs clicked on, and the pages visited before navigating to the Site, using cookies or other technologies.

Cookies are small text files stored by your browser on your device when you visit websites, which allow for the collection of certain information about your use of the websites. Some of these cookies are essential, but you have the choice to refuse the use of all non-essential cookies through your browser settings or by clicking on the options on the Site. To find out more about cookies, please visit: www.allaboutcookies.org or www.youronlinechoices.eu.

Why We Collect and Process Personal Data

We may process the personal data described in this Policy for the following purposes:

  • to provide you with Investor Alerts;
  • to communicate with you regarding your use of the Site;
  • to provide service and support or address complaints relating to the Site;
  • to monitor, improve and safeguard use of the Site;
  • where you give us consent:
    • by means of cookies and similar technologies in accordance with the information above and the information provided to you as to when those technologies are used; or
    • for the purposes we explain at the time you give us such consent;
  • in connection with legal claims and to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, including cooperating with government or law enforcement authorities conducting an investigation; and
  • as otherwise described in this Policy. 

Marketing 

We will not use your personal data for marketing purposes, nor will we share it with third parties for their own marketing purposes. 

How and With Whom Do We Share Personal Data

We may share your personal data as set forth below:

  • among our affiliated companies;
  • with service providers, suppliers and subcontractors, including Q4 Inc. (“Q4”), as detailed below, for the purpose of providing the Site and the services accessible on the Site; 
  • with analytics and search engine providers, such as Google Analytics, that use such information to help improve and optimize the Site (to learn more about Google Analytics and how Google collects and processes data, see www.google.com/policies/privacy/partners);
  • if we sell or buy any businesses or assets or merge any business or operations into or with those of another person or entity, in which case we may disclose your personal data to the prospective counterparty in such transaction and such data may be one of the assets transferred in such transaction; 
  • to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend against legal claims, to protect our and others’ rights, property or safety, and for the purposes of crime and fraud prevention and remediation;
  • as required to conduct our business and pursue our legitimate interests; or
  • to any other party with your consent. 

One of the service providers that assists us with the Site is Q4. To access certain information referenced on the Site, such as webcasts of presentations and earnings calls, you will need to link to a webpage hosted and operated by Q4.  You will then be required to register on the Q4-hosted webpage by providing your name, business name, and business email address. Q4 shares this registration information with us and we use it only for internal purposes, including to learn the identity and number of people who signed up to watch or listen to the webcasts or presentations. Q4 acts as both a controller and processor with respect to such personal data that you provide on Q4’s website. When you visit any Q4-hosted webpage, you will be subject to Q4’s Terms of Use and Privacy Policy, which we encourage you to review. Q4 is required under its contract with us to: (1) maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of personal data; (2) manage such data in compliance with law; and (3) not use, sell, rent, transfer, distribute, or otherwise disclose or make available such data for the benefit of anyone other than us, unless we consent.

Transfers of Personal Data Outside the EEA or UK

In some cases, disclosure of personal data to other persons will involve transferring personal data from a country in the EEA or UK to a country which has been held not to provide a level of protection of personal data equivalent to that provided in the EEA or UK. In particular, personal data from the EEA or UK will be transferred to, stored in and processed in the United States. If we transfer your personal information out of the EEA or UK to a country not deemed to provide an adequate level of personal information protection for purposes of applicable data protection laws such that additional safeguards are required, the transfer will be performed only with your consent, to pursue our legitimate business interests, or as otherwise permitted by applicable laws.

Your Rights

You have various rights with respect to our use, processing and sharing of your personal data, as described below. We make these options available to all users, regardless of whether you reside in a jurisdiction that expressly provides for a particular right. There may be exceptions to these rights under applicable law. If you wish to contact us to exercise any of these rights, please email us at [email protected] or write to us at Claros Mortgage Trust, Inc., c/o Mack Real Estate Group, Attention: Legal & Compliance, 60 Columbus Circle, 20th Floor, New York, NY 10023, USA. If such personal data is retained by one of our service providers, such as Q4, we will facilitate your communication with the service provider for this purpose.

We will not deny you services, charge you a different price, provide a different level or quality of services or otherwise discriminate against you just because you exercised any of these rights; however, if you decline to provide your personal information or ask us to delete it or stop disclosing it, we may be unable to provide you with certain services.

Only you, or a person whom you authorize to act on your behalf, may make a request related to your personal data. The request must:

  • provide sufficient information for us to reasonably verify you are the person about whom we collected personal data or an authorized representative of such person; and
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use personal data provided in a request only to verify your identity or authority to make the request.

  • Access: You may request a copy of the personal data that we have collected, used, or shared about you, and why we collected, used or shared that personal data, including the categories of personal data collected, the specific items of personal data collected, the categories of sources from which we collected personal data, the purposes for which we use the personal data, the categories of third parties with whom we share the personal data, and the categories of information that we disclose to third parties. 
  • Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes.
  • Objecting/Deletion: You have the right to object to processing of your personal data and to ask us to block, delete or restrict your personal data, subject to certain exceptions. Once we receive your request and verify your identity, we will delete your personal data from our records and direct our service providers to delete your personal data from their records, unless an exception applies under applicable law.
  • Portability: You have the right to request that your personal data be provided to you, or to another data controller, in a commonly used, machine-readable format. 
  • Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.

California’s Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits users who are California residents to request and obtain from businesses a list of what personal data (if any) they disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests are free of charge. We do not use your personal data for direct marketing purposes and we do not share your personal data with third parties for their direct marketing purposes.

How Long We Keep Your Personal Data

We will only retain your personal data for as long as required for the purpose for which it was provided.

Do Not Track

We do not track visitors to the Site over time or across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) browser settings. 

Contact Information

If you have any questions or comments about this Policy, please email us at [email protected] or write to us at Claros Mortgage Trust, Inc., c/o Mack Real Estate Group, Attention: Legal & Compliance, 60 Columbus Circle, 20th Floor, New York, NY 10023, USA.