PRIVACY POLICY

Spyglass Apartments 138 HoldCo, LLC (the "Company," "we," or "us") created this Privacy Policy for the Web site www.seabridgeliving.com (the “Site”) to demonstrate our commitment to respecting the privacy of visitors to our Site and to providing an appropriate level of protection and management of their personally identifiable information in our possession. Our current operations are intended for users located solely in the United States of America (USA). So, this policy applies only if you are using our Site in the USA. If we expand operations in the future outside the USA, we will develop a privacy policy at that time to apply to those operations.

This Privacy Policy will inform you of the categories of personally identifiable information we collect, categories of third parties with whom the information may be shared, and the choices you have to review and request changes to the your personally identifiable information. The phrases "personally identifiable information" and "personal information" mean any information that permits you to be contacted physically or online such as your first and last name, physical address, email address, telephone number, or other identifying information maintained in combination with any of the foregoing.

Collecting Information about You and Use of Cookies.

You may visit our Site without revealing any of your personal information. If you enter into a transaction or request information, then you will be requested to provide personal information. When you visit the Site or communicate with us via the Site or email, we may collect the following types of information:

We may automatically track and collect the internet domain address, domain server, type of computer and type of web browser used to visit our Site. That type of information (often referred to as traffic data) will remain anonymous and is not considered personal information unless you voluntarily tell us personally identifiable information and it is combined with the traffic data. Traffic data helps us analyze how the Site is used and is helpful for analyzing usage of the Site and improving your experience on the Site.

Like many Web sites, we use computer "cookies," which are small amounts of data that we transfer to your computer's hard drive through your web browser. We collect the information in the cookie when you visit the Site. The cookies enable our systems to recognize you, provide features to you, track your visits and sales, process your orders and/or analyze your use of the Site. You may be able to set your browser to reject cookies or to ask you whether to accept a particular cookie. There are also third party utilities designed to help you visit Web sites anonymously. If as a result of your settings we cannot recognize you, we will not be able to provide you with a personalized experience at our Site, for example, you will be required to re-enter personal information each time you place a request through the Site.

We may collect personal information from you when you voluntarily provide it to us when you fill out an online form (such as when you request property leasing, sales or other information on the Site). At such times, you may provide us with information about you such as your name, physical address, telephone number, fax number, e-mail address, age, income, birth date, gender, occupation, etc. It is completely your choice whether to provide this information. But, if you choose not to provide some or all of the information, you may be unable to receive newsletters, catalogs or other information or access other services, features or content on the Site.

We may also maintain a record of your transactions with the Site.

We may maintain all or portions of e-mails that you send to our staff or company e-mail accounts, and may combine that information with other information. To help us with our e-mail initiatives, we may receive a confirmation when you open e-mail that we send to you, if your computer supports such capabilities.

We may sometimes receive updated personal information about you from other sources such as suppliers, couriers, or other companies so that we can correct your personal information in our records.

Using Information About You.

We use your personal information to conduct our business, such as sending you information, offers or promotions, or to contact you for other reasons (such as to ask for updated or corrected information, or to inform you of updates to content, products or services). In conducting our business we may also analyze personal information on an individual or aggregate basis, such as to conduct statistical analysis of demographics of users, assess use of various portions of the Site, our products and services, and to amend existing and develop new content, services and products.

Sharing Information About You.

We may share personal information with companies and individuals that perform functions on our behalf, or they may collect the personal information on our behalf and provide it to us. Examples include fulfilling information requests and other orders, management and use of computer cookies, sending postal mail and e-mail, data management, removing repetitive information from customer lists, analyzing data, providing marketing assistance, and providing customer service. They have access to the personal information needed to perform their functions, but are not authorized to use it for other purposes.

From time to time we might establish relationships with companies and individuals and share and cross-reference information, including your personal information, that will enable us to serve you better, and will enable them to contact you regarding their products and services. These companies and individuals include landlords, marketing companies and property management companies.

If you are a tenant at one of our properties, we may share your personal information with other third parties with which we have business relationships in order to perform services for us, you or others, such as parties that provide building, customer or tenant services (for example, building repairs and concierge services), or the landlord and parties that provide services for the landlord.

We may share with other third parties, such as website developers, anonymous traffic data and results of analysis of various types of personal information that do not include the personal information itself.

In operating our business, we might sell or buy sites, companies or assets. In such transactions, personal information generally will be one of the transferred business assets. Also, in the unlikely event that the Company, or substantially all of its assets are acquired, personal information will of course be one of the transferred assets.

We will release your personal information when we believe such disclosure is appropriate to:

Security.

We include security measures in the Site intended to protect access to, and prevent loss, misuse or alteration of your personal information on our Site. Unfortunately, no data transmission over the Internet or on a computer can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we are not able to guarantee the security of your personal information in our possession. It is also important for you to protect against unauthorized access to or use of your computer.

Links to Other Sites.

The Site contains links to other Internet websites. If you use these links, you will leave this Site. We are not responsible for the privacy or other practices or the content of such websites. We do not endorse, warrant or make any representations about any such website, or any information, software or other products or materials found there, any results that may be obtained from using such websites. If you decide to access any of the third party sites linked to this Site, your access, use of or interaction with such other websites is entirely at your own risk.

Conditions of Use, Revisions.

If you choose to visit the Site, your visit and any dispute over privacy is subject to the Privacy Policy posted on the Site from time to time and our Terms of Use, including limitations on damages and application of the law of the state of California.

Questions and Comments.

If you have any concern about privacy at the Site, please send us a thorough description to info@seabridgeliving.com and we will try to consider and resolve it in a manner that is respectful of your concerns while permitting us to conduct our business.

Updates and Changes to Privacy Policy; Effective Date.

We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Site. Any such change, update or modification will be effective immediately upon posting on the Site. Information we gather is subject to the Privacy Policy in effect at the time of use. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Site frequently to see recent changes. The effective date of this policy is September 12, 2011.

LEGAL NOTICES

Limitations on Use.

You may use the Site only as intended by the Company as indicated by the Site content, including, but not limited to, the Privacy Policy and Legal Notices.

You shall not

Questions and Comments.

If you have any concern about privacy at the Site, please send us a thorough description to info@seabridgeliving.comand we will try to consider and resolve it in a manner that is respectful of your concerns while permitting us to conduct our business.

If you have any other questions about the Site, our products or services, please send your questions to info@seabridgeliving.com and we will try to respond in a reasonable timeframe. No response given to inquiries should not be interpreted as advice of any type.

Trademarks.

RESMARK and RESMARK EQUITY PARTNERS are trademarks and service marks of Resmark Equity Partners, LLC and are protected by law. You may not use those marks without express written permission of the owner. Certain other names, brands and marks are used for identification purposes only and may be trademarks or registered trademarks of their respective owners. Fair use of the trademarks and service marks requires proper acknowledgment.

Copyrights.

All materials and software published on or used on the Site are protected by copyright, and owned or controlled by or licensed to the Company or the party listed as the provider of the materials or software. UNAUTHORIZED COPYING, REPRODUCTION, REPUBLISHING, UPLOADING, DOWNLOADING, POSTING, TRANSMITTING OR DUPLICATING ANY OF THE MATERIAL IS PROHIBITED. ALL RIGHTS RESERVED.

e-mail May Not Be Used to Provide Notice.

Communications made through the Site or the Site's e-mail or messaging systems shall in no way be deemed to constitute legal notice to the Company or any of its officers, employees, agents or representatives, such as where notice to the Company is required by contract, or any federal, state or local laws, rules or regulations.

General Disclaimer.

THE SITE (INCLUDING, WITHOUT LIMITATION, ALL PRODUCTS, SERVICES, CONTENT, SOFTWARE, FUNCTIONS, MATERIALS AND INFORMATION MADE AVAILABLE OR DESCRIBED ON THE SITE OR ACCESSED BY MEANS THEREOF) IS PROVIDED "AS IS," WITHOUT REPRESENTATIONS OR WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF INTELLECTUAL PROPERTY, SECURITY OR ACCURACY. RESMARK EQUITY PARTNERS, LLC FURTHER DOES NOT WARRANT THE ACCURACY, ADEQUACY OR COMPLETENESS OF THE MATERIALS AT THIS SITE AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS AND OMISSIONS THEREIN.

Limitation of Liability.

IN NO EVENT WILL THE COMPANY, THE PROPERTY OWNER, LANDLORD, OR ANY OF THEIR RESPECTIVE EMPLOYEES, OFFICERS, OWNERS, CONTRACTORS, SUPPLIERS, OR OTHER THIRD PARTIES MENTIONED AT THIS SITE BE LIABLE FOR ANY ACTUAL, DIRECT, INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES THAT MAY ARISE OUT OF THE USE, INABILITY TO USE, OR THE RESULTS OF USE OF THIS SITE, ANY WEB SITES LINKED TO THIS SITE, OR THE MATERIALS, INFORMATION, PRODUCTS OR SERVICES DISPLAYED ON OR AVAILABLE OR ORDERED THROUGH ANY OR ALL SUCH SITES, WHETHER BASED ON WARRANTY, CONTRACT, TORT OR ANY OTHER LEGAL THEORY AND WHETHER OR NOT ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOUR USE OF SUCH MATERIALS, INFORMATION, PRODUCTS OR SERVICES RESULTS IN THE NEED FOR SERVICING, REPAIR OR CORRECTION OF EQUIPMENT OR DATA, YOU ASSUME ALL COSTS THEREOF. APPLICABLE LAW MAY NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU.

Applicable Laws; Jurisdiction.

Any dispute regarding the Privacy Policy, any use of the Site, or products or services provided by the Company will be governed by and construed in accordance with the laws of the State of California in the USA as applied to agreements made and performed entirely within the State of California, without giving effect to any principles of conflicts of laws, and the federal law of the USA, as applied to agreements made and performed entirely within USA, without giving effect to any principles of conflicts of laws. Any action brought in connection with the Privacy Policy, any use of the Site, or products or services provided by the Company shall be brought exclusively in either the state or federal courts with jurisdiction in Los Angeles County, California.

Investments Disclaimer.

None of the information contained in this Site constitutes a recommendation, solicitation or offer by the Company or its affiliates to buy or sell any securities or provide any investment advice or service.