Privacy Policy

AMERICAN REALTY CAPITAL, INC. ("AMERICAN REALTY CAPITAL")

Privacy Policy

PRIVACY NOTICE

EFFECTIVE MAY 2011

Committed To Protecting Your Privacy

American Realty Capital II, LLC and its affiliates are proud of the strong relationships we have built over the years - relationships based on common goals and mutual trust. In serving you, we are committed to providing you with the investment products and services you need now and in the years ahead, and to protecting your personal information along the way. This privacy notice contains information about how we fulfill this commitment to you.

We do not disclose any Client Information, except as permitted by law. We do not sell or disclose any Client Information to a third party for their independent use. The sections that follow will describe our information collection and sharing practices, and the safeguards we use to protect your non-public personal information.

We Collect Information That May Include:

• Information that we receive from you personally on applications, forms, or other correspondence, or our website, such as your name, address, phone number, social security number and e-mail address.
• Information about your transactions with us, such as your account holdings and transaction history.
• Information we receive about you from third parties, such as transfer agents, custodians, financial institutions and credit or service bureaus.

In selected situations, as permitted or required by law, we may have to disclose all of the information we collect described above (the “Client Information”).

We Carefully Limit Client Information Sharing, Use and Disclosure

We use and share Client Information solely to provide quality investment products and service to our customers. For example, this information enables us to serve and administer your accounts with efficiency and accuracy.

We do not disclose any Client Information, except as permitted by law. Under the following circumstances we may disclose Client Information:

• When requested by you;
• When necessary, in our opinion, to verify or complete a transaction initiated by you;
• When complying with law, regulation or a court of government order or request; and
• In connection with any merger or consolidation with, or sale of, all or substantially all of our assets to a third party.

The Client Information described above may be shared within Realty Capital Securities, LLC, American Realty Capital II, LLC and any of its affiliates, including, but not limited to: American Realty Capital Trust, Inc., American Realty Capital Advisors, LLC, American Realty Capital Trust II, Inc., American Realty Capital Advisors II, LLC, American Realty Capital Trust III, Inc., American Realty Capital Advisors III, LLC, American Realty Capital Healthcare Trust, Inc., American Realty Capital Healthcare Advisors, LLC, American Realty Capital – Retail Centers of America, Inc., American Realty Capital Retail Advisor, LLC, Phillips Edison – ARC Shopping Center REIT, Inc., American Realty Capital II Advisors, LLC, ARC-Northcliffe Income Properties, Inc., American Realty Capital Income Properties Advisors, LLC, Business Development Corporation of America, BDCA Adviser, LLC, American Realty Capital Properties, Inc. and ARC Properties Advisor, LLC.

We may also share Client Information with selected non-affiliated third parties, each of which is bound by written agreements of confidentiality with respect to the use and disclosure of Client Information. The sharing of Client Information with non-affiliated third parties is carefully limited as described in this section.

We may disclose Client Information to the following types of third parties:

• Financial service providers that assist us in servicing your accounts, such as the distributor of the American Realty Capital programs, Realty Capital Securities, LLC and the transfer agent.
• Non-financial companies, such as service providers that fulfill product information requests or maintain our website.
• Others, such as joint account holders and those with whom you have consented in writing to our sharing your Client Information.

In addition, we may share the Client Information with other companies with whom we have teamed through a joint marketing agreement to provide you with a particular benefit or service. We may also share Client Information with other companies that perform specific or contracted services on our behalf in connection with the products and services provided or offered to you and as otherwise permitted by law.

We Protect Client Information About Former Customers

If you terminate your relationship with us, we will continue to adhere to the privacy policies and practices provided in this notice and shall retain all collected Client Information in accordance with Federal law.

We Have Safeguards In Place

We have physical, electronic and procedural safeguards in place to protect the confidentiality, security and integrity of your Client Information.

We restrict access to Client Information to those who need that information in order for us to provide our products and services to you.

Our Commitment To You

We value the trust of our customers and will continue to recognize the importance of holding your Client Information as confidential.

We will maintain accurate Client Information and respond promptly to customer requests to correct information.

We will require companies with whom we do business to use Client Information appropriately and to safeguard the confidentiality of such information.

We appreciate the opportunity to serve your investment needs. We pledge to follow the policies, safeguards and guidelines as described in this notice, and to protect the confidentiality of your information. Your relationship is very important to us, and we will take great care to honor these commitments to you. Thank you for choosing American Realty Capital. This notice applies to individuals and covers information in connection with consumer transactions. In compliance with government regulations, we provide this notice at the time the customer relationship commences and, to the extent required by law, annually during which the relationship exits. If we change our policies or practices, we will update this Privacy Statement.

If you would like to contact us about this Privacy Policy or any data privacy or confidentiality issues, below is our contact information:

Jesse Galloway
American Realty Capital
405 Park Avenue
12th Floor
New York, NY 10022
(212) 415-6500