Last Updated:
1. Introduction
AJR Capital Group LLC ("AJR Capital," "Company," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit or use https://www.ajrcapitalgroup.com and any related pages, features, content, or services that link to this Privacy Policy (collectively, the "Services").
AJR Capital Group is a commercial real estate investment and development firm. Our website is intended to provide general information about our company and is not an offer to sell, or a solicitation of an offer to buy, any security. Securities offerings, if any, are made only to qualified investors pursuant to confidential offering materials and applicable exemptions from registration.
This Privacy Policy does not cover websites, apps, or services operated by third parties, even if linked from the Services.
2. Who We Are
Company Name: AJR Capital Group LLC
Address: 12424 Wilshire Boulevard, Los Angeles, CA 90025
Contact Email: Contact@ajrcapitalgroup.com
Phone: 310-741-8782
3. Information We Collect
We collect personal information from you and about your use of the Services.
A. Information You Provide
Contact details: name, email address, phone number, company or organization, mailing address, and the content of any messages you send us.
Inquiry and form submissions: information you provide through contact forms, investor inquiry forms, leasing inquiry forms, or similar channels.
Investor information (if you become a prospective or actual investor in one of our funds or deals): accreditation and qualification representations, financial and tax information (including taxpayer identification numbers, financial account information, and wire instructions), subscription documents, and related know-your-customer information. This information is collected primarily through our subscription documents and investor portals, not through the public website, and is governed by the privacy notice provided with those materials.
Career or vendor inquiries: resumes, work history, references, and similar information you submit.
B. Information Collected Automatically
Device and usage data: IP address, device identifiers, browser type and version, operating system, pages viewed, time spent, links clicked, and referring URLs.
Approximate location inferred from IP address.
Log and security data: access logs, error logs, and authentication events.
C. Cookies and Similar Technologies
We and our service providers may use cookies, pixels, tags, local storage, and similar technologies to operate the Services, remember preferences, understand usage and performance, and (where enabled) measure marketing effectiveness. See Section 6 for details and your choices.
D. Information from Third Parties
We may receive information from:
Service providers that help us operate the Services (hosting, analytics, email delivery, customer relationship management).
Professional service providers (legal, accounting, fund administration, insurance) in connection with our business operations.
Public sources and business contacts in the ordinary course of evaluating real estate transactions and capital relationships.
E. Sensitive Personal Information
Some of the information described above (such as taxpayer identification numbers, financial account information, and precise financial information collected from prospective and actual investors) may qualify as “sensitive personal information” under California law. We use this information only for the purposes for which it was provided, such as administering investments, issuing tax documents (including IRS Schedule K-1s), and complying with legal obligations. We do not use sensitive personal information to infer characteristics about you.
4. How We Use Information
We use personal information to:
Provide, operate, maintain, and improve the Services and our business operations.
Respond to inquiries and provide information about AJR Capital and our investment activities.
Communicate with prospective and actual investors, tenants, vendors, and counterparties.
Administer investments, including issuing K-1s, capital calls, distributions, and investor reports.
Send administrative messages, including updates and security notices.
Analyze performance and usage trends and improve the Services.
Detect, prevent, and investigate fraud, security incidents, and misuse.
Comply with legal, tax, regulatory, audit, and contractual obligations and enforce our agreements.
5. Legal Bases for Processing (EEA/UK Visitors)
If the EU/UK General Data Protection Regulation applies to our processing of your personal information, we rely on one or more of the following legal bases:
Performance of a contract (for example, to provide services to investors, tenants, or counterparties).
Legitimate interests (for example, securing and improving the Services, communicating with business contacts, and preventing fraud).
Consent (for example, for certain cookies or marketing communications, where required).
Compliance with legal obligations (including tax, securities, and anti-money-laundering laws).
6. Cookies, Analytics, and Preferences
A. Categories of Cookies and Similar Technologies We May Use
Strictly necessary: required for the Services to function (security, network management, basic site functionality).
Analytics: help us understand how visitors use the Services so we can improve them.
Preferences: remember choices you make to improve your experience.
Marketing (only if enabled): measure campaigns and, where applicable, deliver relevant content.
B. Managing Cookies and Tracking
You can control cookies and similar technologies by:
Using our cookie preference tool, where available: [COOKIE PREFERENCES LINK / BUTTON LABEL].
Adjusting your browser settings (note that strictly necessary cookies may still be required for the Services to function).
Using opt-out mechanisms described in Section 9, including, where applicable, Global Privacy Control browser signals.
C. Do Not Track
Some browsers offer a “Do Not Track” signal. The Services may not respond to all such signals. Where required by law, we honor recognized opt-out preference signals such as Global Privacy Control.
7. How We Disclose Information
We disclose personal information to:
Service providers and processors that help us operate the Services and our business, such as hosting providers, analytics providers, email and CRM providers, IT and security vendors, fund administrators, investor portal providers, and property management software providers.
Professional advisors, including outside legal counsel, accountants and tax preparers, auditors, and insurance brokers and carriers.
Affiliates and joint venture partners in connection with specific investments, developments, or transactions, subject to appropriate confidentiality protections.
Lenders, title companies, escrow agents, brokers, appraisers, and other counterparties as reasonably necessary to evaluate, finance, close, and administer real estate transactions and investments.
Government authorities, regulators, and other parties when required by law, legal process, or to protect rights, safety, and security, including filings required by tax authorities (such as IRS Schedule K-1 filings) and securities regulators.
Acquirers or successors in connection with a merger, acquisition, financing, sale of assets, or similar business transaction.
We do not sell personal information for money. We do not currently “share” personal information for cross-context behavioral advertising as those terms are defined under California law. If this practice changes, we will update this Policy and provide the disclosures and choices required by law.
California “Shine the Light”
We do not share personal information with third parties for those third parties’ own direct marketing purposes within the meaning of California Civil Code Section 1798.83.
8. International Transfers
The Services are operated from the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States and other countries where we or our service providers operate. Where required by applicable law, we use appropriate safeguards (such as standard contractual clauses) for international transfers.
9. Your Privacy Rights and Choices
Your rights depend on where you live.
A. California (CCPA/CPRA)
California residents may have the right to:
Know and access the personal information we collect, use, and disclose about you.
Delete personal information, subject to legal exceptions.
Correct inaccurate personal information.
Opt out of the “sale” or “sharing” of personal information as defined by California law.
Limit the use and disclosure of sensitive personal information, where applicable.
Not be discriminated against for exercising these rights.
To submit a request, email us at [PRIVACY EMAIL] or use [WEB FORM LINK, if available]. We may need to verify your request using information you provide. You may use an authorized agent to submit certain requests on your behalf, subject to verification.
Where required or supported, we process recognized opt-out preference signals (such as Global Privacy Control).
B. EEA/UK (GDPR/UK GDPR)
If GDPR or UK GDPR applies to our processing of your personal information, you may have the right to access, correct, delete, or restrict processing; object to processing; request data portability; withdraw consent (where processing is based on consent); and lodge a complaint with a supervisory authority.
C. Other U.S. State Privacy Laws
Residents of certain other U.S. states may have similar rights to access, correct, delete, or opt out of certain processing of their personal information. To exercise these rights, contact us at [PRIVACY EMAIL].
D. Marketing Communications
You can opt out of marketing emails by using the unsubscribe link in any marketing message or by contacting us at [PRIVACY EMAIL]. You may still receive transactional or service-related messages, including investor communications required by our agreements with you or by law.
10. Investor Privacy Notice (GLBA)
If you are or become an investor in a fund or investment vehicle managed or sponsored by AJR Capital, additional privacy practices apply under the Gramm-Leach-Bliley Act and related laws. A separate privacy notice will be provided with the relevant subscription or offering documents and on at least an annual basis where required. That notice governs how we handle non-public personal information collected in connection with your investment.
11. Data Retention
We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, administer investments, comply with legal, tax, regulatory, audit, and contractual obligations, resolve disputes, and enforce our agreements.
Retention periods vary by type of data and purpose. For example:
General website inquiries and contact form submissions are typically retained for up to 24 months unless a longer business or legal need exists.
Investor records, tax documents, and financial records are retained for the periods required by applicable tax and securities laws (generally at least seven years from the end of the relevant tax year or termination of the investment).
Logs and security records are retained for the period reasonably necessary for security and operational purposes.
12. Security
We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
13. Children’s Privacy
The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, please contact us at Contact@ajrcapitalgroup.com and we will take appropriate steps to delete it.
14. Changes to This Privacy Policy
We may update this Policy from time to time. We will post the updated version and revise the “Last Updated” date. Material changes may be communicated through the Services or by email where appropriate.
15. Contact Us
For questions about this Privacy Policy or to exercise your privacy rights, contact us at:
AJR Capital Group LLC
12424 Wilshire Boulevard, Suite 670, Los Angeles, CA 90025
Email: Contact@ajrcapitalgroup.com