Privacy Policy

EFFECTIVE DATE: September 23, 2026

The why

Capital Square Realty Advisors, LLC, Capital Square Apartment REIT, Inc. d/b/a Capital Square Housing Trust and the affiliates identified as “Covered Entities” below (“Capital Square,” “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our websites at capitalsq.com and capitalsquarereit.com and our investor portals (each, a “Site”) and the services available through our sites.

This Policy describes our information practices. Where applicable law requires your consent before we collect or use your information, we will obtain that consent separately, through our cookie banner or at the point of collection. Your use of our site, and any dispute over privacy, is subject to this Policy and our Terms of Use for the Site you are visiting.

This Policy applies to the following affiliated entities (“Covered Entities”):

Capital Square Realty Advisors, LLC, its subsidiaries and its offerings
Capital Square Housing Trust, its subsidiaries and its offerings
Capital Square Asset Management, LLC
Capital Square Development, LLC
Capital Square Living, LLC
Capital Square Apartment Operating Partnership, L.P.

The what

This Policy applies to the sites, our investor portals, our marketing communications and our offline interactions with prospective and current investors. The following relationships are governed by separate notices, available at the links below or on request:

Investors: Our financial privacy notice delivered under the Gramm-Leach-Bliley Act and Regulation S-P, which includes your right to limit certain sharing
Residents and rental applicants at communities we own or manage: Our Resident and Applicant Privacy Notice, which addresses rental applications, tenant screening and consumer report information
Employees, personnel and job applicants: Our Personnel Privacy Notice
Cookies and similar technologies: The Cookie Notice linked from each site

We collect information about you directly from you and from third parties, as well as automatically through your use of our site.

Information we collect directly from you:

The information we collect from you depends on how you use the site.
When you register, we collect your name, email address, and your password for the site.
To access our investment offerings, you must provide your address, phone number, and your accredited investor status.
You may also provide us with information about your professional activities, such as your employer’s name, your job title, and the industry in which you work.

If you would like to invest in one of our offerings, we will require the following:

Phone number
Date of birth
Social Security number/tax identification information
Information about your income, net worth, assets, liabilities, and liquidity
Banking information
Information about your investing experience/ plans
A copy of your government-issued identification and any other documents we use to verify your identity
Investment objectives and risk tolerance

We also collect information about you when you contact us, including recordings or transcripts of telephone calls where permitted by law and where we have given you notice.

If you invest through a legal entity, we will collect information about that legal entity, such as:

Its legal name and address
Assets and liabilities
Banking information to associate the entity with your account

We also collect beneficial ownership information about the individuals who own or control that entity, as required by federal anti-money laundering rules.

Information we collect from third parties includes:

If you invest through a custodial account, retirement plan, a trust, or a legal entity, we will collect information about you from the respective plan or entity
If you are investing through a legal entity, we will collect information about the entity’s individual investors.

This third-party information includes:

Individuals’ PII: names, addresses, phone numbers, dates of birth and Social Security numbers/tax identification information
We also collect information about you from the broker-dealer or registered investment adviser through which you invest, our transfer agent, IRA and other custodial trustees, identity verification providers, accreditation verification vendors
Credit/background screening vendors, marketing and data enrichment providers, public sources, including securities filings and public records

We may also automatically collect the following information about your use of our site through cookies, web beacons, and other technologies:

Your domain name, browser type and operating system, web pages you view, links you click, your IP address, approximate location derived from your IP address, and mobile and device identifiers
Information collected through software development kits and through session replay or heatmap tools
The length of time you visit or use the site; and the referring URL, or the webpage that led you to our site

We may combine this automatically collected information with other information that we have collected about you, including your name and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Sensitive personal information:

Some of the information described above is treated as sensitive under applicable privacy laws, including your Social Security number and taxpayer identification information, your financial account and payment information, your government-issued identification and your account log-in credentials.
We collect and use this information only as reasonably necessary to verify your identity, determine your eligibility to invest, administer your investment, meet our tax reporting obligations, comply with anti-money laundering and sanctions requirements.
We do not use or disclose sensitive personal information to infer characteristics about you.
Residents of certain states may direct us to limit our use of sensitive personal information, as described in the Your Privacy Rights and Choices section below.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.

Please notify us immediately at IR@capitalsq.com or by calling (888) 818-1031 if you believe your credentials have been lost or compromised or that your account has been accessed without your authorization.

The how

How we use your information

We use your information:

To provide our services to you, communicate with you about your use of our services, respond to your inquiries, fulfill your orders, and for other customer service purposes
To determine your eligibility for investment offerings
For antifraud purposes, to comply with applicable Know Your Customer and anti-money laundering requirements, including customer due diligence and beneficial ownership requirements under the Bank Secrecy Act and sanctions screening administered by the Office of Foreign Assets Control
To satisfy suitability and Regulation Best Interest obligations, including those applicable to the broker-dealers or investment advisers through which you invest
To prepare and deliver tax reporting, including Internal Revenue Service Forms 1099-DIV and Schedule K-1; administer distributions, distribution reinvestment and any redemption program
To maintain required books and records under federal securities laws, including Securities Exchange Act Rules 17a-3 and 17a-4, Investment Advisers Act Rule 204-2
To tailor the content and information we may send or display to you, offer personalized help and instructions, and personalize your experiences while using the site
For marketing and promotional purposes: a) To use your information, such as your email address, to send you news, newsletters, special offers, promotions, or otherwise contact you about products or information we think may interest you; and b) To use information, we learn about you to assist us in advertising our services on third-party websites
To better understand how users’ access, use our site on an aggregated or individualized basis, improve our site and services, respond to user desires and preferences, conduct other research, and perform analytical activities
To administer surveys and questionnaires
To comply with legal obligations, as part of our general business operation and for other business administration purposes
To secure our sites, systems, detect, respond to security incidents, and meet our incident response, notification obligations
Where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy

We do not use automated processing alone to make decisions about your eligibility to invest.

How we disclose your information

Financial Advisors: At your direction, we may share your information with your financial advisor in accordance with your instructions or in order to administer your investment.
Broker-Dealers and Investment Advisers: We disclose your information to a) the dealer manager, b) the broker-dealers, and c) registered investment advisers participating in the offering through which you invest.
Transfer Agent and Administrators: We disclose your information to our Transfer agent and Fund administrator and their subcontractors to maintain the ownership register, process subscriptions and redemptions and pay distributions.
Plan Administrators or Investment Entities: If you make your investments with Capital Square through a legal entity, custodial account, or retirement plan, we will share your information with the respective plan or entity in order to administer your investment.
Tax Preparers: We disclose your information to the accountants and administrators who prepare and deliver your tax reporting.
Professional Advisers and Insurers: We will disclose your information, in each case subject to confidentiality obligations, to a) our auditors, b) outside counsel, c) appraisers and valuation providers, and d) insurance brokers and carriers.
Property Managers and Lenders: Where relevant to a property in which you have invested, we may disclose information to the property manager, to lenders and loan servicers, and to agency counterparties.
Other Stockholders: If you are a stockholder of Capital Square Housing Trust, Inc., your name, address and holdings may be furnished to another stockholder who exercises a statutory right to inspect the stockholder list and may be included in filings we make with the Securities and Exchange Commission where required.
Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
Service Providers: We may disclose the information we collect from you to a) third-party vendors, b) service providers, c) contractors or agent who perform functions on our behalf, d) registered investment advisers participating in the offering through which you invest, and e) in each case under a written contract that limits their use of the information to performing those functions and prohibits them from selling it or using it for their own purposes.

We may also disclose your information in the following circumstances:

Business Transfers: a) If we are acquired by or merged with another company; b) if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process: We also may disclose the information we collect from you in order to comply with the law: a) Judicial proceeding; b) Court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others: We also may disclose the information we collect from you where we believe it is necessary to: a) Investigate, prevent, or take action regarding illegal activities; b) Suspected fraud; c) Situations involving potential threats to the safety of any person; d) Violations of our Terms of Use or this Policy; e) As evidence in litigation in which Capital Square is involved.
Aggregate and De-Identified Information: We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes: a) Where we de-identify information, we maintain technical safeguards and business processes that prohibit reidentification; b) We do not attempt to reidentify the information, and we contractually require recipients to do the same.

Sale and sharing of personal information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under applicable state privacy laws.

Access your My Apps page through your preferred browser.

Our use of cookies and other tracking mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our site.
We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
We group these technologies into four categories: strictly necessary, functional, analytics, and advertising.
Other than strictly necessary technologies, we deploy them in accordance with the preferences you set through our cookie banner.

Cookies

Cookies are alphanumeric identifiers that we store on your device for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our site, while others are used to enable a faster log-in process or to allow. There are two types of cookies:

Session cookies: Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the site. This allows us to process your online transactions, verify your identity after you have logged in, as you move through our site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising on third-party sites.

Disabling cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future.
The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Visitors to our site who disable cookies will be able to browse certain areas of the site, but some features may not function.
You may also change your choices at any time using the “Cookie Preferences” link in the footer of each site.

Local storage

We may use browser local storage and similar device-based storage to remember your site preferences.
You can clear local storage through your browser settings, generally in the same place you clear cookies and site data.

Clear GIFs, pixel tags, and other technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies.
In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.
We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our site to, among other things, track the activities of site visitors, help us manage content, and compile statistics about site usage.
We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track e-mail response rates, identify when our emails are viewed, and track whether our emails are forwarded.
We may also transmit information about interactions with our sites to advertising and analytics providers through server-side interfaces, sometimes called conversion application programming interfaces, rather than through code running in your browser.

Third-party analytics

We use automated devices and applications, such as Google Analytics, to evaluate usage of our site.
We also may use other analytic means to evaluate our services.
We use these tools to help us improve our site, services, performance and user experiences.
These entities may use cookies and other tracking technologies to perform their services.
The analytics providers we currently use on each site, and links to their opt-out mechanisms, are listed in the Cookie Notice for that site.
We deploy analytics technologies in accordance with the preferences you set through our cookie banner.

Opt-out preference signals

Our Sites recognize the Global Privacy Control and other opt-out preference signals approved under applicable state law.
When we detect such a signal from your browser or device, we treat it as a request to stop selling and sharing your personal information and to stop using it for targeted advertising for that browser or device.
Because the signal is tied to the browser or device, you will need to enable it on each browser and device you use.
If you have an account with us and are logged in when we detect the signal, we will apply your choice to your account as well.
You may also opt out using the “Your Privacy Choices” link in the footer of each site.

Third-party ad networks

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms).
This enables us and these third parties to target advertisements to you for products and services in which you might be interested.
Third-party ad network providers, advertisers, sponsors, traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), other tracking technologies to measure ad effectiveness and personalize advertising content to you.
These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.
Depending on the technologies in use, these activities may constitute a sale of personal information or sharing for cross-context behavioral advertising under applicable state privacy laws.
You may opt out as described in the Opt-Out Preference Signals section above and in the Your Privacy Rights and Choices section below.

Third-party links

Our site may contain links to third-party websites and may include embedded content or social media features operated by third parties.
Any access to and use of such linked websites is not governed by this policy, but instead is governed by the privacy policies of those third-party websites.
We are not responsible for the information practices of such third-party websites.

Security of your personal information

We maintain administrative, technical, and physical safeguards designed to protect personal information within our custody or control from unauthorized access, use, disclosure, alteration, or destruction.
We periodically review our information security practices and take reasonable measures appropriate to the nature and sensitivity of the personal information we maintain.
Certain information may be collected, processed, or stored through third-party platforms that maintain their own security practices. For example, information submitted through the Juniper portal is maintained within Juniper’s systems and is subject to Juniper’s applicable privacy and security practices. See Juniper Security Policy Optimization (PDF).
While we take reasonable measures to protect personal information within our custody or control, no method of electronic transmission or storage can be guaranteed to be completely secure.
You may modify personal information that you have submitted by logging into your account and updating your profile information.

Incident response

We maintain a written incident response program designed to detect, respond to and recover from unauthorized access to or use of customer information:

If we determine that sensitive customer information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify affected individuals as soon as practicable and in any event within 30 days after becoming aware of the incident, unless we determine the information has not been and is not reasonably likely to be used in a manner that would result in substantial harm or inconvenience.
We will also provide any notice required under applicable state breach notification laws.

Your privacy rights and choices

Depending on where you live, you may have some or all of the following rights with respect to your personal information. Some information we hold about you is subject to the federal Gramm-Leach-Bliley Act and is addressed by our financial privacy notice rather than by this section

Right to know and access. To request the categories and specific pieces of personal information we have collected about you, the sources, our purposes, and the categories of third parties to whom we disclosed it.
Right to correct. To request that we correct inaccurate personal information
Right to delete. To request that we delete personal information we collected from you, subject to the limits described below.
Right to portability. To receive a copy of your personal information in a portable format
Right to opt out of sale, sharing and targeted advertising. To direct us not to sell or share your personal information and not to use it for targeted advertising.
Right to limit use of sensitive personal information. To direct us to limit our use of sensitive personal information to the purposes permitted by law.
Right to opt out of profiling. To opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Right against discrimination. We will not deny you services, charge you a different price, or provide you a different level of service because you exercised any of these rights, and we will not retaliate against you for exercising them.

How to submit a request

You may submit a request using the form Privacy Rights Request Form (PDF), by emailing Marketing@capitalsq.com, or by calling (877) 626-1031. You may designate an authorized agent to submit a request on your behalf. We will ask the agent for proof of your written authorization and may ask you to verify your identity directly.

Timing. We will confirm receipt of your request within 10 business days and respond within 45 days. If we need more time, we will notify you and may extend our response by an additional 45 days.
Appeals. If we decline to act on your request, you may appeal by contacting us at Legal@capitalsq.com with the subject line “Privacy Appeal” within a reasonable period after you receive our decision. We will respond in writing within 45 days. If we deny your appeal, we will provide you with a method to contact your state attorney general to submit a complaint.

How long we keep your information

We retain personal information for as long as necessary to fulfill the purposes described in this Policy and thereafter for the periods required by applicable law.
In determining retention periods, we consider the nature and sensitivity of the information, the purposes for which we hold it, applicable legal and regulatory requirements, and any applicable legal hold.
Records relating to your investment or account will be retained for as the periods required by applicable federal securities laws and other legal or regulatory obligations.
Certain records may be subject to longer retention periods based on the type of record, applicable requirements, or other circumstances.

What choices do I have regarding promotional emails? Other communications

We may send periodic promotional emails to you.
You may opt out of such communications by following the opt-out instructions contained in the email.
Please note that it may take up to five business days for us to process opt-out requests.
If you opt out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

Text messages

If you provide your mobile number and consent to receive text messages from us, we may send you messages about your account, our offerings or our events.

Message frequency varies. Message and data rates may apply. You may opt out at any time by replying STOP or reply HELP for assistance.
We will honor a request to stop within 10 business days.
Consent to receive text messages is not a condition of investing.
You may ask us to add you to our internal do-not-call list by contacting us using the information below.

Children under 18

Our site and services are not designed for children under 18.

If we discover that a child under 18 has provided us with personal information, we will delete such information from our systems.
We do not knowingly sell or share the personal information of consumers under 16 years of age, and we do not use the personal information of a consumer we know to be under 18 for targeted advertising.
If you are a California resident under 18 and have posted content on our site, you may request its removal by contacting us using the information below.

State-specific disclosures

Residents of certain states may have additional privacy rights and may be entitled to additional disclosures under applicable state privacy laws.

These rights may vary by state and may include rights to access, correct, delete, or opt out of certain uses or disclosures of personal information. These are set out in the State-Specific Disclosures exhibit to this Policy, which addresses California, Virginia, Colorado, Connecticut, Texas, Nevada and the other states with comprehensive privacy laws in effect.
California residents may also request information regarding certain disclosures of personal information to third parties for those parties’ direct marketing purposes, as provided under California Civil Code Section 1798.83.

Visitors outside the United States

Our investment offerings are limited to eligible U.S. residents and are not offered to residents of other countries.

While our sites are intended primarily for U.S. audience, they may be accessible from locations outside the United States.
Individuals accessing our sites from outside the United States should be aware that we may collect certain personal information through cookies, analytics technologies, or information voluntarily submitted through online forms. Such information may be processed or stored in the United States in accordance with this Privacy Policy and applicable law.

Accessibility

If you need this Policy in an alternative accessible format, please contact us using the information below and we will provide it.

Contact us

If you have questions about the privacy aspects of our site or would like to make a complaint, please contact us at Marketing@Capitalsq.com or call (877) 626-1031.

You may also submit a privacy rights request by mail to: Capital Square, 4851 Lake Brook Drive Glen Allen VA ,23060, Attn: Legal Department -Privacy.

If you are not satisfied with our response, you may appeal as described in the Your Privacy Rights and Choices section.

Changes to this policy

This Policy is current as of the September 23, 2026. We may change this Policy from time to time, and we review it at least once every 12 months. We will post any changes on our Sites and update the Last Updated date above. If we make changes that materially affect how we handle personal information we previously collected from you, we will provide notice before the change takes effect by posting a prominent notice on the Sites and, if you have an account with us, by emailing the address associated with your account.

Attachments

Privacy Rights Request Form (PDF)

Juniper Security Policy Optimization (PDF)