Legal Disclaimer

Capital Commercial Investments, Inc. shall not be responsible for any errors or delays in the content in its web site or for any actions taken in reliance thereon. This web site contains links to third-party web sites that are not under the control of Capital Commercial Investments. Capital Commercial Investments makes no representations whatsoever about these third-party web sites. When you access a non-Capital Commercial Investments web site, you do so at your own risk and Capital Commercial Investments is not responsible for the accuracy or reliability of any information, data, opinions, advice, or statements on these sites. Capital Commercial Investments provides these links solely as a convenience and the inclusion of such links does not imply that Capital Commercial Investments endorses or accepts responsibility for the content or use of such web sites. Capital Commercial Investments and its subsidiaries and affiliates (the "Company") are not licensed in all jurisdictions. This web site does not purport to offer real estate services or mortgage brokerage services in locations in which the Company is not licensed.

Introduction
The Capital Commercial family of companies has created this privacy policy in order to demonstrate its commitment to your privacy. Our web site, www.capitalcommercial.com (the "Web Site"), allows users to learn more about our products and services and those of our parent companies, subsidiaries, affiliates and affiliated funds. Also, our customers may use the Web Site to access their accounts with us. 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 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 gather your IP address when you use the Web Site. We use IP addresses for diagnostic and statistical purposes and to administer 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.

Links to Other Web Sites
This Web Site contains 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.

Introduction
The Capital Commercial family of companies (“CCI”) considers nonpublic personal information about our customers to be private and confidential, and we hold ourselves to the highest standards of trust in the safekeeping and use of such information. (The Capital Commercial family of companies consists of Capital Commercial Investments, Inc.; Capital Commercial Partners, Capital Commercial Development, Capital Commercial Medical Partners, Capital Commercial Investments, LLC, Capital Commercial Holdings.

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 Capital Commercial companies or with other parties. Our Privacy Policy is effective January 1, 2003, and may be amended from time to time.

Our Privacy Policy applies to nonpublic personal information collected or used when Capital Commercial offers investment products or services to individuals for personal, family, or household purposes. This disclosure is made on behalf of the aforementioned Capital Commercial family of companies.

Our Privacy Policy applies only to individual Capital Commercial customers who have a direct relationship with one of the Capital Commercial family of companies. If you own Capital Commercial investment products or receive Capital Commercial services in the name of a third-party broker dealer, investment adviser, or other financial service provider, that third party's privacy policies may apply to you.

Our Privacy Policy also applies to nonpublic personal information we have collected concerning former Capital Commercial customers.

Collection of Information by Capital Commercial
We collect information from and about you in order to:

identify you as our customer; establish and manage your customer accounts; complete your customer 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 Capital Commercial investment products and services, as well as information about the transactions and accounts you have with Capital Commercial. Nonpublic personal information about you may include: your name, mailing address, e-mail address, tax identification number, age, account information, investment amounts in our companies, marital status, number of dependents, assets, debts, income, employment history, beneficiary information, personal bank account information, broker dealer, financial advisor, IRA custodian, account joint owners and other similar parties, Capital Commercial account balance or transactional history, your financial circumstances and credit history, Capital Commercial investment products and services you purchased and the fact that you are or have been a customer of or investor in a Capital Commercial sponsored investment.

We may collect nonpublic personal information about Capital Commercial customers 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 Internet web site, www.capitalcommercial.com (the “Web Site”), information you submit to us on our Web Site forms and information we collect through Internet “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
Capital Commercial does 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 email 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 companies, or determine and disclose the average income of investors in our funds. Capital Commercial Affiliated Companies. Capital Commercial offers investment products and services through certain of its affiliated companies, and we may share all of the nonpublic personal information we collect on you with such 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, Capital Commercial uses outside companies 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 financial institutions. We may disclose all of the nonpublic personal information we collect as described above to such companies. 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 customer information confidential and secure and to use it only as authorized by us. Other Nonaffiliated Third Parties. Capital Commercial does not sell or share your customer information with marketers outside of Capital Commercial, for example, retail department stores, grocery stores or discount merchandise chains, who may want to offer you their own products and services.
Other Uses and Disclosures. Capital Commercial companies 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.

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 of Personal Information
We store your personally identifiable information indefinitely.

Availability of Our Privacy Policy
Capital Commercial 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.capitalcommercial.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 customers 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. If you object to the change to our Privacy Policy, then you must contact us using the information provided in the notice. We will otherwise use and disclose a user’s or a customer’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 Capital Commercial 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 our operation of the Web Site. The privacy policy of the succeeding legal entity will then govern the personally identifiable information that we have 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: