Winston Warren Commercial (“we,” “us,” or “our”) is committed to protecting your privacy.

This Privacy Policy explains how we collect, use, and safeguard your personal information in connection with our commercial real estate business and communications programs, including SMS messaging, email outreach, and direct mail.

1. WHO WE ARE

Winston Warren Commercial is a commercial real estate firm specializing in site selection, development, and brokerage services. We operate primarily in the United States and are based in Bermuda.

2. INFORMATION WE COLLECT

We may collect the following categories of information about you:

• Contact information — name, phone number, email address, and mailing address.
• Business information — company name, job title, property ownership, and professional role within the commercial real estate industry.
• Property data — information about properties you own, manage, or have transacted on, sourced from public records or commercial real estate platforms such as CREXI, CoStar, and similar databases.
• Communication preferences — whether you prefer SMS, email, or no contact, and your opt-in or opt-out status.
• Interaction history — records of our communications with you, including missed calls, SMS exchanges, and email correspondence.

3. HOW WE COLLECT IT

Information is gathered through several sources:

• Directly from you when you provide your contact details, respond to our outreach, or fill out a form on our website.
• From publicly available sources, including county assessor records, deed transfers, and commercial listing databases (e.g., CREXI, CoStar, LoopNet).
• Through inbound communications — when you call, text, or email us, we retain those records.

4. HOW WE USE YOUR INFORMATION

We use the information we hold about you for legitimate business purposes, including:

• Responding to inquiries, missed calls, and inbound leads via SMS or email.
• Sharing commercial real estate opportunities, market updates, and development insights relevant to your property portfolio or investment interests.
• Sending postcards and direct mail about specific properties or market conditions.
• Maintaining our business relationship and following up on active transactions or discussions.
• Complying with legal obligations or resolving disputes.

We do not use your information for automated decision-making or profiling in ways that produce legal or similarly significant effects.

5. SHARING YOUR INFORMATION

We do not sell, rent, or share your personal information with third parties for their own marketing purposes. Period.

We may share limited information with:

• Service providers — vendors who support our business operations (e.g., SMS delivery platforms, CRM software, mailing services) who are bound by confidentiality agreements and only process data on our behalf.
• Legal or regulatory authorities — when required by law, court order, or to protect our legal rights.

6. SMS COMMUNICATIONS

If you have opted into our SMS program or responded to a missed-call text, you may receive SMS messages from Winston Warren Commercial. Message and data rates may apply.

Message frequency varies based on your interactions with us — typically no more than 2 messages per interaction.

You can opt out at any time by replying STOP to any message we send. You may request help by replying HELP. For additional assistance, email us at wparks@winstonwarren.com.

We do not share your phone number or SMS opt-in data with third parties for marketing purposes.

7. EMAIL COMMUNICATIONS

If you are on our email list, you can unsubscribe at any time by clicking the unsubscribe link in any email we send or by contacting us directly. We will honor opt-out requests promptly.

8. DATA RETENTION

We retain your information for as long as necessary to support our business relationship and comply with applicable law. If you opt out of all communications and have no active business

with us, we will remove or anonymize your data within a reasonable timeframe, typically within 90 days of your request.

9. DATA SECURITY

We take reasonable steps to protect your information against unauthorized access, disclosure, or misuse. While no system is perfectly secure, we use industry-standard practices to safeguard the data we hold.

10. YOUR RIGHTS

You have the right to:

• Know what personal information we hold about you.
• Request correction of inaccurate data.
• Request deletion of your personal information (subject to any legal retention obligations).
• Opt out of SMS communications at any time by replying STOP.
• Opt out of email communications at any time via the unsubscribe link or by contacting us.

To exercise any of these rights, contact us at the details below.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The updated version will be posted on our website with a revised effective date. We encourage you to review it periodically.

CONTACT US

Winston Warren Commercial

Email: wparks@winstonwarren.com

Phone: 615-544-6614

Website: winstonwarren.com

Hamilton, Bermuda