Please Read Carefully

This is the privacy policy ("Privacy Policy"), effective as of February 1, 2018, for the websites available at ,, and (the "Sites") made available by FGG, Inc., d/b/a First Guardian Group, the legal owner of the Sites. This Privacy Policy sets forth our policies regarding the collection, use, and disclosure of certain information relating to your use of these Sites. Your use of these Sites signifies your understanding and acceptance of the terms of this Privacy Policy. We recognize the importance of protecting your privacy and our Privacy Policy is designed to assist you in understanding how we collect, use, and safeguard the personal information you provide to us, and to assist you in making informed decisions when using the Sites. This Privacy Policy will be continuously assessed against new technologies, business practices, and our clients’ needs. As we update and diversify our products and services, this Privacy Policy may evolve. Please check this page for updates periodically. We will try to post any changes to this Privacy Policy before they become effective. If we make any material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our Site’s home page. If you have questions or concerns regarding this Privacy Policy or wish to exclude your personal information from our direct marketing purposes, please feel free to contact us via email at or by writing to us at First Guardian Group, 777 North First Street, Suite 720, San Jose, CA 95112. Please note: by using or registering with our Sites or by providing personal information, you agree to the terms of this Privacy Policy.

The types of information we collect:

We have several areas where you can submit information to us, and we also have features that automatically collect information from the users of our Sites. References to "personal and account information" contained in this Privacy Policy means your name, company name, telephone number, email address, subscription details (i.e., particular types of markets or property types on which you request information), and any other information that personally identifies you or would permit us to contact you.

Information voluntarily provided by you via registration:

When you visit or transact business on our websites, you may be required to register with us or be requested to provide us with personal and account information. When you provide us with this information, we will let you know how we may use such information. If you tell us that you do not want us to use this information as a basis for further contact with you (by accessing our opt-out procedure described below), we will respect your wishes. We may also offer options for you to sign up for our newsletters. During the registration process, you must provide us with your name, phone number, and a valid email address. 
Communications from us; newsletters and promotional offers: In order to keep our users informed about our latest news, products, and services, we may send emails and announcements to your personal email address that you provided to us while registering on our Sites. If you elected to opt–in to any of our email lists and later decide that you no longer wish to receive newsletters or promotional email from us, you may unsubscribe from such list by following the instructions contained in each email we send to you to unsubscribe from such email list.

Contacting Us: You are always free to contact us with a question or problem related to your use of the Sites. Our standard business practice is to retain any communications from our Sites visitors to help us to serve each of you better.

Third-party information provided to us

Links: When using our Sites, you may click through certain links or promotions that will enable you to purchase products or use services provided by our partners. Some of these partners may share certain information that you provide to them with us. By clicking on and through to a link or promotion on our Sites, you agree to allow us to receive and use any information that you may provide to our partners, under the same terms and conditions as if you provided your information directly to us. We are not, however, responsible for any other website, or their respective privacy policy or how they treat information about their users. We strongly advise you to review their privacy policies to find out how they are treating your personal information.

Third-Party Usage: You may also separately share your information with other websites or entities, such as those that create professional marketing lists, to receive special offers and promotions from their affiliates. These websites or entities may agree to share your information with us. Whether or not any third-party actually shares your information with us and to what extent they do share your information with us will depend on their agreement with us and their respective privacy policies. First Guardian Group is not responsible for, and will assume no liability, if a partner or other website or entity collects, uses, or shares, any information about you in violation of its own privacy policy or applicable law.

Marketing Data: We may purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may also associate this marketing data to the personally identifiable information that you provide to us.

Automatic data collection

Cookies: We use what are commonly called cookies when you use our websites. We use these cookies to identify you as a valid user, to ensure that no one else can sign on simultaneously with your account from another computer, and to help us serve you better based on your registration preferences. We may also use cookies to help us facilitate any promotions or surveys that we provide.

Performance tracking: We sometimes use cookies, as well as tracking technology, such as web beacons, within the promotional emails that we send to our subscribers or advertisements for our Sites. These performance tracking devices help us to track whether an email recipient has completed an event, such as signing up for a free trial for example. Such information is non-personally identifying and collected on an aggregate level. We sometimes utilize third-party service providers to help us track the activity within our Sites. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking but the data would not be tracked in a personally identifiable way. Third parties whose products or services are accessible on our Sites may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

When and with whom we may share your information

Vendors: We may share your personal information with companies acting as our authorized agents in providing our service (e.g., credit card processing, customer/support services, marketing, etc) to you, all of which agree to use it only for such specified purposes. Each vendor must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification or disclosure. Because we operate globally, we may transfer your information to countries or jurisdictions that do not provide the same level of data protection as the country in which you are based. If we make such a transfer, we will, or our vendors will, as applicable, provide for the proper safeguards required by applicable law to ensure that your information is protected.

Legally affiliated entities: In the event that First Guardian Group is merged, or in the event of a transfer of our assets, websites or operations, First Guardian Group may disclose or transfer your personal information in connection with such transaction.

Legally compelled disclosure: We will also disclose your personal information when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency’s request, or in special cases, when we have reason to believe that disclosing your personal information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (whether intentionally or unintentionally) our rights or property.

Bankruptcy: You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your personal information to be shared or transferred to third parties without your permission.

Consent to processing: By providing any personal information to us, you fully understand and unambiguously consent to the transfer of such personal information to, and the collection and processing of such personal information in, the United States and other countries or territories. Your personal information will be stored and processed on our computers in the United States. The laws on holding personal information in the United States may vary and be less stringent than laws of your state or country. We will use commercially reasonable efforts to hold and transmit your personal information in a safe, confidential, and secure environment. If you object to your personal information being transferred or used in this manner, please do not register with or use our websites.


First Guardian Group endeavors to protect the security of your personal information and your choices for its intended use. We use Secure Socket Layers or SSL technology to protect the transmission of sensitive personal information such as your credit card number. We store your personal information on a secure server, and use procedures designed to protect the personal information we collect from unauthorized access, destruction, use, modification or disclosure. Although we will take (and require our third-party providers to take) commercially reasonable security precautions regarding your personal information collected from and stored on our websites, due to the open nature of the Internet, we cannot guarantee that any of your personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using our websites, you acknowledge that you understand and agree to assume these risks.

Opt-out right: If you would like to opt out of any of our marketing programs, or wish to withdraw your consent to contact you via your email, fax, or phone number, or if your personal details change, please contact us through one of the following: (i) by telephone, at 408-392-8822 and ask for Investor Relations; (ii) by facsimile, at 408-392-8822; (iii) by email, by following the Opt-Out instruction contained in the body of any marketing email from us or by sending us an email at by including a copy of the email you have received and by typing “Remove” in the subject line of your email; or (iv) by mail, care of Investor Relations, First Guardian Group, 777 North First Street, Suite 720, San Jose, CA 95112.

Your election not to receive newsletters or promotional and marketing correspondence from us will not: (a) preclude us from corresponding with you, by email or otherwise, regarding your existing or past relationship with us, and (b) preclude us, including our employees, contractors, agents, and other representatives, from accessing and viewing your personal information in the course of maintaining and improving our websites.

Your acceptance of this Privacy Policy: By using our websites, you signify your acceptance of our Privacy Policy. If you do not agree to this Privacy Policy, please do not use our websites. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time so visitors are encouraged to review this Privacy Policy from time to time. Your continued use of our websites following the posting of changes to these terms means you accept these changes.

Your continued use of our sites means that you have read and understand the following risks and disclosures:

Risks and disclosures:

First Guardian Group securities offerings are generally for accredited investors (generally described as having a net worth of over $1 million dollars exclusive of primary residence) and accredited entities only. If you are unsure if you are an accredited investor and/or an accredited entity, please verify with your CPA and Attorney prior to considering an investment. You may be required to verify your accreditation status. The information herein has been prepared for educational purposes only and does not constitute an offer to purchase securities real estate investments. Such offers are only made through the sponsors Private Placement Memorandum (PPM) which is solely available to accredited investors and accredited entities. IRC Section 1031, IRC Section 1033, IRC Section 721 and real estate crowdfunding investments are complex tax concepts; therefore, you should consult your legal or tax professional regarding the specifics of your particular situation prior to considering an investment. This material is not to be interpreted as tax or legal advice. Please speak with your own tax and legal advisors for advice/guidance regarding your particular situation. There are risks associated with investing in real estate, real estate crowdfunding investments, and Delaware Statutory Trust (DST) properties including, but not limited to, loss of entire investment principal, declining market values, tenant vacancies, and illiquidity. Investors should read the PPM carefully before investing paying special attention to the risk section. Because investors situations and objectives vary, this information is not intended to indicate suitability for any particular investor. Please speak with your CPA and Attorney to determine if an investment in real estate investments and DST properties is suitable for your particular situation/circumstances. Past performance is not indicative of future returns. Potential distributions/cash flows/returns/appreciation are not guaranteed and could be lower than anticipated. There are significant limitations on the ability to sell or transfer interests. Expected distributions, cash flows, and returns may not be realized, and a loss of invested capital is possible. Please do not invest if you cannot afford to lose your entire principal amount invested. This material does not constitute an offer to sell nor a solicitation of an offer to buy any security. Such offers can be made only by the confidential PPM. Please be aware that this material cannot and does not replace the PPM and is qualified in its entirety by the PPM. This material contains information that has been obtained from sources believed to be reliable. However, First Guardian Group and LightPath Capital, Inc. and their representatives do not guarantee the accuracy and validity of the information herein. Investors should perform their own investigations before considering any investment. Securities offered through registered representatives of LightPath Capital, Inc., Member FINRA/SIPC. LightPath Capital, Inc. and First Guardian Group and FGG1031 are not affiliated. LightPath Capital Address: 1453 Third Street Promenade, Suite 315, Santa Monica, CA 90401, Phone 310-260-9187.