Privacy

Privacy Policy

Effective Date: May 1, 2026

1. Introduction

Gramercy Investment Group is the public-facing website brand for www.gramercyinvestors.com. Balaclava Investments LLC, HDB LLC, and their affiliates, related entities, members, managers, officers, employees, contractors, agents, and representatives, as applicable and collectively referred to in this Privacy Policy as "Gramercy," "we," "us," or "our," respect your privacy and are committed to protecting personal information that you provide to us.

This Privacy Policy explains how we collect, use, disclose, retain, and safeguard information when you visit www.gramercyinvestors.com, submit information through our website, communicate with us by email, phone, SMS/text message, or otherwise interact with us.

This website is intended for informational and business inquiry purposes only. It is not intended to display active investment opportunities or to process investments online.

2. Information We Collect

We may collect personal information that you voluntarily provide to us, including:

• Name
• Email address
• Mobile phone number
• Company name
• Business or brokerage affiliation
• General investment, acquisition, leasing, or brokerage-related inquiry information
• Any other information you choose to provide in a website form, email, phone call, SMS/text message, or other communication

We may also collect limited technical information automatically through our website hosting, security, analytics, or operational service providers, such as:

• IP address
• Browser type
• Device type
• Referring website
• Date and time of visit
• Pages viewed
• Basic security, diagnostic, and usage logs

We do not intentionally collect Social Security numbers, bank account information, credit card numbers, sensitive health information, or other highly sensitive personal information through the website. Please do not submit such information through the website contact form.

3. How We Use Information

We may use the information we collect to:

• Respond to inquiries submitted through our website or otherwise communicated to us
• Communicate with prospective investors, brokers, tenants, lenders, service providers, sellers, buyers, and other business contacts
• Evaluate potential business, brokerage, acquisition, leasing, lending, vendor, or investment relationships
• Coordinate follow-up communications by email, phone, or SMS/text message where permitted
• Operate, maintain, secure, and improve our website
• Keep business records and comply with legal, regulatory, tax, accounting, carrier, and compliance obligations
• Protect our rights, property, business operations, website, users, and communications channels

We do not use personal information collected through the website for unsolicited mass marketing. We do not sell personal information.

4. SMS/Text Message Communications

If you provide your mobile phone number and consent to receive SMS/text messages, Gramercy may send SMS/text messages for the limited purpose of responding to your inquiry or coordinating related communications.

Program Description: Our SMS program is used for inquiry responses and business communications only. We do not send recurring automated marketing text messages.

Consent: By providing your mobile phone number through our website contact form, by phone, verbally, by email, or through another communication channel, and by indicating your consent to receive text messages, you agree to receive SMS/text messages from Gramercy, Balaclava Investments LLC, HDB LLC, or their representatives in response to your inquiry or related business communication.

No Condition of Transaction: Consent to receive SMS/text messages is not a condition of any purchase, sale, investment, transaction, agreement, relationship, or service.

Message Frequency: Message frequency varies depending on the nature of your inquiry and communications with us.

Message and Data Rates: Message and data rates may apply depending on your mobile carrier and plan.

Opt-Out: You may opt out of SMS/text message communications at any time by replying STOP to any text message from us. You may also revoke SMS consent by any other reasonable method that clearly communicates your request to stop receiving text messages from us. After you opt out, we may send one confirmation message and then no further SMS/text messages will be sent, unless you later provide renewed consent.

Help: Reply HELP to any SMS/text message from us for assistance, or contact us using the information in Section 14 below.

Carrier Disclaimer: Wireless carriers are not liable for delayed or undelivered messages. SMS/text message delivery is not guaranteed and may depend on your carrier, device, location, and network conditions.

No Sharing of SMS Consent: We do not sell, rent, trade, or share SMS consent, SMS opt-in data, SMS opt-out data, or mobile phone numbers with third parties for marketing or promotional purposes.

5. How We Share Information

We may disclose personal information only in limited circumstances, including:

• Internally among Gramercy personnel, affiliates, and related entities as needed to respond to your inquiry or operate our business
• With service providers that support our website, email, hosting, security, communications, CRM, SMS platform, professional services, or other operational needs
• With attorneys, accountants, consultants, lenders, brokers, property managers, or other professional advisors where relevant to a business purpose
• In connection with a potential transaction, restructuring, financing, sale, merger, transfer, or similar business event involving our business or assets
• When required or permitted by law, subpoena, court order, regulation, government request, legal process, or to protect legal rights
• To prevent fraud, misuse, security incidents, illegal activity, or harm to our business, users, or others

We do not sell, rent, or trade personal information. We do not share SMS consent or mobile opt-in data with third parties for marketing or promotional purposes.

6. Cookies and Tracking Technologies

Our website may use cookies or similar technologies that are necessary for basic functionality, security, performance, diagnostics, or hosting operations. We may also use limited analytics tools to understand general website usage and improve website performance.

We do not intend to use cookies or tracking technologies to conduct behavioral advertising, sell personal information, or build consumer marketing profiles. If we materially change our use of cookies or analytics tools, we may update this Privacy Policy.

You may be able to adjust cookie settings through your browser. Disabling cookies may affect website functionality.

7. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to respond to inquiries, maintain business records, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect our rights.

SMS opt-in, opt-out, and related consent records may be retained as needed to comply with applicable law, carrier requirements, and communications compliance obligations.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no website, email system, SMS/text message system, mobile network, or internet transmission is completely secure. We cannot guarantee absolute security of information transmitted to or from the website.

You should not submit sensitive personal, financial, health, or confidential information through the website contact form unless specifically requested through a secure channel.

9. Your Privacy Rights

Depending on your state of residence and applicable law, you may have rights regarding your personal information, which may include the right to:

• Request access to personal information we maintain about you
• Request correction of inaccurate personal information
• Request deletion of certain personal information
• Opt out of certain communications
• Revoke SMS/text message consent
• Request information about how your personal information is used or disclosed

To exercise available rights, contact us using the information in Section 14 below. We may need to verify your identity before responding to certain requests.

10. No Sale of Personal Information

We do not sell personal information. We do not sell, rent, trade, or share SMS consent or mobile opt-in data with third parties for marketing or promotional purposes.

11. Children's Privacy

This website is intended for business and informational use by adults. It is not directed to individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from a minor, we will take reasonable steps to delete it.

12. Third-Party Links

Our website may contain links to third-party websites or resources. We are not responsible for the privacy practices, security, content, accuracy, or availability of third-party websites. You should review the privacy policies and terms of any third-party websites you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised effective date. Your continued use of the website or continued communication with us after an update means you acknowledge the updated Privacy Policy.

14. Contact Information