Privacy Policy: Sentio Healthcare Properties

Introduction
Sentio Investments, LLC has created this privacy policy in order to demonstrate its commitment to your privacy. Our web site, www.sentiohealthcareproperties.com
(the "Web Site"), allows users to learn more about our products and services and those of our subsidiaries, affiliates and affiliated programs.

Use of the Web Site is subject to our Web Site Terms and Conditions and to our personal information gathering and dissemination practices and policies as described below.

Please note that third party companies may operate and host the Web Site or portions of the Web Site on our behalf. If such companies do so, then they will collect the information described below on our behalf and disclose it to us.

Users Outside the United States
The Web Site is for users located exclusively in the United States of America. Please do not use the Web Site if you are located outside the United States, because the Web Site’s personal information practices and policies may or may not comply with applicable foreign laws.

IP Address
We may gather your IP address when you use the Web Site. We may use IP addresses for diagnostic and statistical purposes and to administer the Web Site. However, at our sole discretion, we reserve the right to utilize this information to investigate users whom we suspect of in violation of the Terms and Conditions of the Web Site..

Cookies
We may also use "cookies" to store your preferences in order to make your use of the Web Site more productive. Cookies are small files created by web sites that reside on your computer's hard drive and store information about your use of a particular web site. Cookies permit authorized users to access web pages without re-authenticating and allow the preservation of user preferences when using the Web Site. We may also use a third-party tracking service that uses cookies to gather statistical information about how our site is used. This information is not connected to any of your personal information.

Keeping Your Information Secure
Except for the disclosures and uses described below, we restrict access to nonpublic personal information about you to personnel who have a legitimate business need for the information. Those personnel and companies are required to maintain the confidentiality of information provided to them and not use it except as required to accomplish legitimate business. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. Information you provide to us via our Web Site is transmitted to us through a secure sockets layer (SSL) transmission. In addition, information we collect is subject to numerous measures designed to help protect it from unauthorized access or alteration, including for example, internal and external firewalls, physical security measures, and encryption of certain information. Of course, you must do your part to ensure the security of your information. For example, you must guard any password you use to access your account and not permit unauthorized use of your account. No security measures can provide absolute protection of data, but we will strive to provide a superior level of protection for your information.

Children's Privacy
The Web Site is intended for use only by adults. We do not knowingly collect nonpublic personal information from children online.

Links to Other Web Sites
The Web Site may contain links to other web sites. We are not responsible for and shall not have any liability arising from the privacy practices or the content of other web sites.


Consumer Information Privacy Policy

Introduction
The Sentio Investments, LLC family of companies ("we" or "Sentio Entities") considers nonpublic personal information about our investors to be private and confidential, and we hold ourselves to the highest standards of trust in the safekeeping and use of such information. .

Our Consumer Information Privacy Policy ("Privacy Policy") explains what nonpublic personal information we collect, why we collect it, how we protect your nonpublic personal information, and how and why, in certain cases, we share such information among Sentio Entities or with other parties. Our Privacy Policy is effective February 15, 2012, and may be amended from time to time.

Our Privacy Policy applies to nonpublic personal information collected or used when a consumer accesses the Web Site and when we offer investment products or services to individuals for personal, family or household purposes. This disclosure is made on behalf of the Sentio Entities listed in the "Application of Privacy Policy to the Sentio Entities" section below.

Our Privacy Policy applies only to individuals who have a direct relationship with one of the Sentio Entities.

Collection of Information by Sentio Entities
We collect information from and about you in order to:

  • identify you as an investor;
  • establish and manage your investor accounts;
  • complete your investor transactions;
  • market investment products and services that meet your particular financial and investing needs;
  • communicate and share information with your broker dealer, financial advisor, IRA custodian, joint owners and other similar parties acting at your request and on your behalf; and
  • comply with legal and regulatory requirements.

Nonpublic personal information includes information you provide us in order to obtain Sentio Entity products and services, as well as information about the transactions and accounts you have with Sentio Entities. Nonpublic personal information about you may include: your name, physical and mailing addresses, e-mail address, telephone number, tax identification number, age, account information, investment amounts in our companies, marital status, number of dependents, assets, debts, income, net worth, employment history, financial statements, beneficiary information, personal bank account information, credit history information, broker dealer, financial advisor, IRA custodian, account joint owners and other similar parties, the Sentio Entity investment products and services you purchase, your Sentio Entity account balance or transactional history, the fact that you are or have been an investor in a Sentio Entity investment and particulars related to any such investment.

We may collect nonpublic personal information about Sentio Entity investors such as you from the following sources:

  • Information we receive from you on applications, subscription agreements or other forms;
  • Information about your transactions with us, our affiliates, and others;
  • If you visit our Web Site, information you submit to us on our Web Site forms and information we collect through "cookies";
  • If you create a login and password on the Web Site to access your account with us, we will collect and use the login and password to verify your identity and for our internal use in maintaining your Web Site account; and
  • Information obtained from others, such as from consumer credit reporting agencies.

Use and Disclosure of Information
Sentio Entities do not disclose any nonpublic personal information about you to anyone except as permitted by law.

  • Internal Use. We will use your personally identifiable information within our business for the purposes of furthering our business, including analyzing your information, matching your information with the information of others, and other possible uses.
  • Aggregate Use and Disclosure. We will use and disclose your personally identifiable information on an aggregate basis, which means that we combine parts of your information with parts of the information from our other users without including your name, complete telephone number, complete e-mail address or your street address, in the combination. For example, we might determine the most common zip code among the users of the Web Site and disclose that zip code to other parties, or determine and disclose the average income of investors in our funds.
  • Affiliated Companies. Sentio Entities may offer investment products and services, and we may share all of the nonpublic personal information collected on you with our affiliates. We believe that by sharing information about you and your accounts among our companies, we are better able to serve your investment needs and to suggest services or educational materials that may be of interest to you.
  • Nonaffiliated Service Providers and Joint Marketing Partners. From time to time, we use outside parties to perform services for us or functions on our behalf, including marketing of our own investment products and services or marketing products or services that we may offer jointly with other parties. We may disclose all of the nonpublic personal information we collect as described above to such parties. However, before we disclose nonpublic personal information to any of our service providers or joint marketing partners, we require them to agree to keep our investor information confidential and secure and to use it only as authorized by us. When required by law, we will ask your permission before we share your information for this type of marketing.
  • Other Nonaffiliated Third Parties. Sentio Entities do not sell or share your investor information with outside marketers (for example, retail department stores, grocery stores or discount merchandise chains) who may want to offer you their own products and services to you

We may use and disclose your personally identifiable information to the extent reasonably necessary to:

  • correct technical problems and malfunctions in how we provide our products and service to you and to technically process your information;
  • protect the security and integrity of the Web Site and our Internet service, including without limitation to enforce our Terms and Conditions with you;
  • protect our rights and property and the rights and property of others;
  • take precautions against liability;
  • respond to claims that your information violates the rights and interests of third parties;
  • the extent required by law or to respond to judicial process; and
  • the extent permitted under other provisions of law, to provide personal information to law enforcement agencies or for an investigation on a matter related to public safety.

You understand and agree that technical processing of your information is and may be required to:

  • send and receive messages regarding your use of the Web Site;
  • conform to the technical requirements of connecting networks;
  • conform to the limitations of our service; or
  • conform to other, similar technical requirements.

Storage and Security of Personal Information
We store your personally identifiable information indefinitely, subject to information management policies adopted by us from time to time. We maintain technology and information management systems designed to protect the confidentiality and security of your nonpublic personal information. In addition, we restrict access to nonpublic personal information about you to personnel who have a legitimate business need for the information.

Availability of Our Privacy Policy
We will provide notice of our Privacy Policy annually, as long as you maintain an ongoing relationship with us. The most up-to-date Privacy Policy is posted on our Web Site at www.sentiohealthcareproperties.com.

Notification of Changes to Our Privacy Policy
If we decide to change our Privacy Policy, we will post those changes on the Web Site so our users and investors are always aware of what information we collect, use and disclose. If at any point we decide to use or disclose your personally identifiable information in a manner different from that stated at the time it was collected, we will notify you in writing, which may or may not be by e-mail. We will otherwise use and disclose a user's or an investor’s personally identifiable information in accordance with the Privacy Policy that was in effect when such information was collected.

Change in Control
If any of the Sentio Entities experiences a "change in control" (defined below), then we may amend our information practices as described in this Privacy Policy. We will disclose your personally identifiable information to the company or other legal entity that succeeds the company subject to the change in control or the operation of the Web Site. The privacy policy of the succeeding legal entity will then govern the personally identifiable information that the applicable Sentio Entity had collected from you under this Privacy Policy. However, if applicable law prohibits the succeeding legal entity's privacy policy from governing your personally identifiable information, then this Privacy Policy shall continue to govern.

"Change in control" means any of the following events:

  • a reorganization, merger, consolidation, acquisition or other restructuring involving all or substantially all of the Sentio Entity's voting securities and/or assets, by operation of law or otherwise;
  • the Sentio Entity becomes insolvent;
  • the Sentio Entity makes a general assignment for the benefit of creditors;
  • the Sentio Entity suffers or permits an appointment of a receiver for its business or assets;
  • the Sentio Entity becomes subject to any proceedings under any bankruptcy or insolvency law, whether domestic or foreign; or
  • the Sentio Entity is liquidated, voluntarily or otherwise.

Questions About Our Privacy Policy
If you have any questions about our Privacy Policy and/or the personal information practices of our Web Site, please call 1-888-811-1753.

Application of Privacy Policy to the Sentio Entities
This Privacy Policy applies to the following Sentio companies: Sentio Investments, LLC, Sentio Healthcare Properties, Inc., and their respective subsidiaries and all other funds or entities created in the future that offer investment products or services to individuals for personal, family or household purposes.