Accessibility Policy

Effective Date: 03.10.2026

Applies To: windfallusa.com and all Windfall Group-managed properties

Windfall Group believes that accessibility, diversity, and inclusion are fundamental to operating with integrity and serving our communities well. We are committed to ensuring that our website and physical properties are accessible to all individuals, including those with disabilities. Whether you use a screen reader, voice recognition software, magnification tools, or other assistive technology, we want your experience with Windfall Group to be seamless and respectful.

1. Our Commitment

Windfall Group is committed to compliance with:

• The Americans with Disabilities Act (ADA) – Titles II and III
• Section 508 of the Rehabilitation Act
• Web Content Accessibility Guidelines (WCAG) 2.1 Level AA
• The Illinois Human Rights Act
• Applicable accessibility standards in Canada and other jurisdictions where we operate

We pursue accessibility as an ongoing commitment, not a one-time project. Our team continuously evaluates and improves both our digital and physical environments.

2. Website Accessibility

We are actively working to ensure windfallusa.com meets WCAG 2.1 Level AA standards. Our digital accessibility efforts include:

Perceivable

• Providing text alternatives (alt text) for all non-text content including images and icons
• Ensuring all video and multimedia content includes captions or text transcripts
• Maintaining sufficient color contrast ratios throughout the site (minimum 4.5:1 for normal text)
• Avoiding reliance on color alone to convey information

Operable

• Ensuring full keyboard navigation throughout the site without requiring a mouse
• Providing visible focus indicators for keyboard users
• Avoiding content that flashes more than three times per second (seizure prevention)
• Providing skip navigation links to allow users to bypass repeated content

Understandable

• Using clear, plain language throughout site content
• Providing consistent navigation and layout across all pages
• Ensuring all form fields are clearly labeled and validated with helpful error messages

Robust

• Building the site to be compatible with current assistive technologies
• Using semantic HTML and ARIA landmarks to support screen reader navigation
• Testing with multiple assistive technology combinations

3. Assistive Technology Compatibility

The Windfall Group website is designed and tested for compatibility with:

• Screen readers: JAWS, NVDA, VoiceOver (macOS/iOS), TalkBack (Android)
• Voice recognition: Dragon NaturallySpeaking
• Screen magnification: ZoomText, Windows Magnifier, browser zoom
• Keyboard-only navigation
• High-contrast display modes
• Switch access and alternative input devices

4. Physical Property Accessibility

All Windfall Group-managed properties, including Pacifica Square, Burnsville Center, and other retail and mixed-use developments, are maintained to comply with ADA requirements and applicable state accessibility laws. Our physical accessibility standards include:

Site Access

• Designated accessible parking spaces at all locations
• Accessible drop-off and pickup zones
• Curb cuts, ramps, and level pathways at all entrances

Interior Access

• Wide, unobstructed common area walkways
• Accessible restroom facilities
• Elevators and ramps where level changes exist
• High-contrast and Braille signage at key locations
• Adequate lighting throughout indoor spaces

Customer Services

• Staff trained to assist visitors with disabilities upon request
• Accessible customer service and leasing office facilities
• Reasonable accommodations available upon advance request

Windfall Group works with property architects, contractors, and accessibility consultants on all new development and renovation projects to ensure accessibility is built in by design.

5. Known Limitations

While we work diligently toward full accessibility, some legacy content, third-party integrations, or older pages on our website may not yet fully meet WCAG 2.1 Level AA standards. We are actively prioritizing remediation of known issues. If you encounter a specific barrier, please contact us so we can address it promptly or provide an accessible alternative.

6. Accessibility Feedback and Requests

We welcome feedback from users about their accessibility experience. If you encounter a barrier on our website or at any Windfall Group property, or if you need a specific accommodation, please contact us:

 Website Accessibility:

Email: info@windfallusa.com (Subject: “Website Accessibility”)

Phone: (630) 463-2967

Physical Property Accessibility:

Contact the management office of the relevant Windfall property directly, or reach our corporate office:

Windfall Group, 1300 Kensington Rd, Oak Brook, IL 60523

Phone: (630) 463-2967  |  Email: info@windfallusa.com

 We will respond to all accessibility inquiries within 5 business days and work to provide a reasonable solution as quickly as possible.

7. Ongoing Improvement

Windfall Group treats accessibility as a continuous practice. Our commitments include:

• Conducting periodic third-party accessibility audits of windfallusa.com
• Incorporating WCAG 2.1 AA standards into all new web development and content creation
• Training staff on disability awareness and digital accessibility best practices
• Engaging with disability advocacy organizations for guidance and feedback
• Reviewing and updating this Accessibility Policy at least annually

8. Non-Discrimination Statement

Windfall Group does not discriminate against any individual on the basis of disability, race, color, national origin, religion, sex, age, or any other characteristic protected by federal, state, or local law. Any visitor, tenant, partner, or applicant who believes they have experienced discriminatory treatment may file a complaint with Windfall Group management or with the U.S. Department of Justice, Civil Rights Division (www.ada.gov).

9. Updates to This Policy

This Accessibility Policy will be reviewed and updated at least annually or when significant changes are made to our website or property portfolio. The current version is always available at windfallusa.com.

 

 

Terms of Use

Applies To: windfallusa.com and all Windfall Group digital platforms

These Terms of Use (“Terms”) govern your access to and use of windfallusa.com and any associated Windfall Group digital platforms (collectively, the “Site”). By accessing or using the Site, you agree to be bound by these Terms. If you do not agree, please do not use the Site.

This Site is intended for use by adults aged 18 or older located in the United States, or non-U.S. residents who agree to use the Site in accordance with applicable U.S. laws. Use of the Site is void where prohibited.

1. Acceptance

These Terms constitute a legally binding agreement between you and Windfall Group. By using the Site you represent that you have read, understood, and agree to be bound by these Terms and our Privacy Policy, which is incorporated by reference.

2. Intellectual Property and Ownership

The Site and all of its content — including but not limited to text, graphics, logos, photographs, videos, data, project information, and software — are the exclusive property of Windfall Group or its licensors and are protected by U.S. and international intellectual property laws.

The Windfall Group name, logo, trademarks, service marks, and trade dress are registered or unregistered intellectual property of Windfall Group. You may not use any Windfall Group marks without prior written authorization. Unauthorized use may result in legal action.

You may view and print portions of this Site for your personal, non-commercial informational use only, provided you retain all copyright and proprietary notices and do not modify, copy, reproduce, or distribute the content.

3. Permitted Use

You may use this Site to:

• Learn about Windfall Group’s portfolio, mission, and business activities
• Submit leasing, partnership, or investor inquiries
• Access press and media information
• Subscribe to corporate updates and newsletters

You may not use this Site to:

• Scrape, harvest, or collect data without written permission
• Transmit unauthorized advertising, spam, or solicitations
• Interfere with or disrupt the Site’s operation or security
• Introduce viruses, malware, or harmful code
• Impersonate Windfall Group or any person or entity
• Engage in any unlawful or unauthorized activity

4. Leasing and Business Inquiries

Information submitted through leasing, investment, or partnership inquiry forms is subject to our Privacy Policy. Submission of an inquiry does not constitute a binding offer or agreement. All business arrangements with Windfall Group are subject to separate written agreements negotiated and executed by authorized representatives.

5. User-Generated Content

If you submit any content to this Site (e.g., contact form messages, newsletter feedback), you grant Windfall Group a non-exclusive, royalty-free, worldwide license to use that content for legitimate business purposes. You represent that you own or have the right to submit such content and that it does not violate any third-party rights or applicable law.

You may not submit content that is false, defamatory, threatening, obscene, infringing, or otherwise unlawful. Windfall Group reserves the right to remove any content at its discretion.

6. Disclaimers

THE SITE AND ALL CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. WINDFALL GROUP MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING THE ACCURACY, COMPLETENESS, OR TIMELINESS OF ANY CONTENT ON THIS SITE, INCLUDING PROJECT INFORMATION, PORTFOLIO DATA, OR MARKET ANALYSIS. PROPERTY DETAILS AND AVAILABILITY ARE SUBJECT TO CHANGE WITHOUT NOTICE.

WINDFALL GROUP DOES NOT WARRANT THAT THE SITE WILL BE UNINTERRUPTED, ERROR-FREE, OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

7. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WINDFALL GROUP AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM YOUR USE OF OR INABILITY TO USE THE SITE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL WINDFALL GROUP’S TOTAL LIABILITY EXCEED TEN DOLLARS ($10.00) OR THE AMOUNT PAID BY YOU IN CONNECTION WITH THE SPECIFIC TRANSACTION, WHICHEVER IS GREATER.

8. Indemnification

You agree to indemnify, defend, and hold harmless Windfall Group and its affiliates, officers, agents, and employees from any claims, liabilities, damages, and expenses (including reasonable attorneys’ fees) arising from your use of the Site, your violation of these Terms, or your infringement of any third-party rights.

9. Dispute Resolution and Arbitration

Any dispute arising from your use of the Site or these Terms that cannot be resolved informally shall be resolved by binding individual arbitration under the rules of the American Arbitration Association (AAA). Class action lawsuits and class-wide arbitrations are expressly waived. This clause does not prevent either party from seeking emergency injunctive relief from a court of competent jurisdiction.

10. Governing Law

These Terms are governed by the laws of the State of Illinois, without regard to conflict of law provisions. Any dispute not subject to arbitration shall be brought exclusively in the state or federal courts of DuPage County, Illinois.

11. Severability and Waiver

If any provision of these Terms is found to be invalid or unenforceable, that provision will be modified to the minimum extent necessary and the remaining provisions will remain in full force. Windfall Group’s failure to enforce any right or provision does not constitute a waiver of that right.

12. Third-Party Links

Our Site may contain links to third-party websites, including property-specific websites, partner organizations, and media outlets. Windfall Group is not responsible for the content, privacy practices, or availability of any third-party site. Links do not constitute endorsement.

13. DMCA Notice

If you believe content on our Site infringes your copyright, please send a DMCA notice to info@windfallusa.com including: your signature; identification of the copyrighted work; location of the infringing content on our Site; your contact information; a good-faith belief statement; and an accuracy statement under penalty of perjury.

14. Updates to These Terms

Windfall Group reserves the right to modify these Terms at any time. Updated Terms will be posted with a revised effective date. Continued use of the Site after updates constitutes acceptance of the revised Terms.

 

Cookie Settings Policy

Applies To: windfallusa.com and Windfall Group digital platforms

This Cookie Settings Policy explains how Windfall Group uses cookies and similar tracking technologies on windfallusa.com. It describes what categories of cookies we use, why we use them, and how you can manage your preferences.

1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognize your browser and remember information about your visit, such as preferences and past interactions. Cookies may be “session cookies” (deleted when you close your browser) or “persistent cookies” (stored for a defined period).

We also use related technologies including web beacons, pixels, and local storage. These are collectively referred to as “cookies” throughout this policy.

2. Cookie Categories

Category 1: Strictly Necessary Cookies

These cookies are essential for windfallusa.com to operate. They enable core functions such as page navigation, contact form submissions, and security. You cannot opt out of strictly necessary cookies.

Examples:

• Session tokens and authentication
• Security and fraud-prevention mechanisms
• Cookie consent preference storage

Category 2: Performance and Analytics Cookies

These cookies collect anonymized data about how visitors use our website, helping us understand traffic sources, popular pages, and user behavior so we can improve the site.

Examples:

• Google Analytics (pageviews, session duration, traffic sources)
• Internal website performance monitoring

Opt-Out:

Opt out of Google Analytics via tools.google.com/dlpage/gaoptout. You may also disable analytics cookies through our Cookie Settings tool in the website footer.

Category 3: Functional Cookies

These cookies enable enhanced features and personalization, such as remembering your region, language, or display preferences. Disabling them may affect certain website functionality.

Examples:

• Region or language preferences
• Saved form field data for returning visitors

Category 4: Marketing and Targeting Cookies

These cookies are used by Windfall Group and select advertising partners to track online behavior and deliver relevant messaging to prospective tenants, investors, and business partners across digital channels.

Examples:

• LinkedIn Insight Tag (B2B remarketing and campaign performance)
• Google Ads conversion tracking
• Meta Pixel (where applicable)

Opt-Out:

• Digital Advertising Alliance: optout.aboutads.info
• Network Advertising Initiative: optout.networkadvertising.org
• Google Ad Settings: adssettings.google.com
• LinkedIn Ad Preferences: linkedin.com/psettings/advertising

Category 5: Third-Party Cookies

Our website may include embedded content or links to third-party platforms (e.g., LinkedIn, Google Maps, press publication embeds). These third parties may place their own cookies on your device. Their cookie practices are governed by their own privacy and cookie policies.

3. Managing Your Cookie Preferences

Cookie Settings Tool

You can manage your non-essential cookie preferences at any time by clicking “Cookie Settings” in the footer of our website. Changes take effect immediately.

Browser Settings

Most browsers allow you to view, block, and delete cookies through their privacy settings:

• Google Chrome: Settings > Privacy and Security > Cookies and Other Site Data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and Site Permissions

Disabling all cookies may impair the functionality of our website.

Global Privacy Control (GPC)

Where technically feasible, windfallusa.com honors Global Privacy Control (GPC) signals. If your browser transmits a GPC signal, we will treat it as an opt-out request for non-essential data sharing.

4. Cookie Retention Periods

• Session cookies: Deleted when you close your browser
• Persistent cookies: Typically stored for 30 days to 2 years depending on their purpose
• Third-party cookies: Subject to the retention schedules of the issuing party

A detailed cookie inventory is available upon request.

5. Updates to This Policy

We may update this Cookie Settings Policy from time to time. Changes will be posted on this page with a revised effective date. Continued use of our website constitutes acceptance of the updated policy.

 

 

Privacy Policy

Organization: Windfall Group (windfallusa.com)

Operations: United States, Canada, and China

Windfall Group (“Windfall,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals who interact with our company, including visitors to our website (windfallusa.com), prospective tenants and investors, business partners, press contacts, and job applicants. This Privacy Policy describes the types of information we collect, how we use and share it, and the choices available to you.

By using our website or engaging with Windfall Group, you agree to the terms of this Privacy Policy. If you do not agree, please do not use our website or submit personal information to us.

1. Scope

This Policy applies to personal information collected through:

• The Windfall Group website (windfallusa.com)
• Leasing and business development inquiries
• Investor relations communications
• Press and media engagement
• Job applications and recruitment activities
• Email, phone, or in-person interactions with Windfall staff

This Policy applies to our operations in the United States. Separate disclosures or addenda may apply to our activities in Canada and China in accordance with local laws.

2. Information We Collect

2a. Information You Provide

We collect personal information you voluntarily provide when you:

• Submit a contact, leasing, or inquiry form on our website
• Subscribe to our newsletter or press updates
• Apply for a position with Windfall Group
• Engage with us as an investor, partner, or vendor
• Communicate with us by email, phone, or in person

This may include your name, company name, job title, email address, phone number, mailing address, and any information you choose to include in your message or application.

2b. Information Collected Automatically

When you visit our website, we automatically receive technical data from your browser or device, including:

• IP address and general geographic location
• Browser type, version, and operating system
• Pages visited, links clicked, and time spent on each page
• Referring website or traffic source
• Date and time of visit

This data is not personally identifiable on its own but may be combined with other information to improve our website and communications.

2c. Cookies and Tracking Technologies

We use cookies and similar technologies to support website functionality and analyze traffic. See Section 5 (Cookie Policy) for full details.

2d. Third-Party Sources

We may receive information about you from third parties such as professional networks (e.g., LinkedIn), referral partners, or publicly available business directories, where permitted by applicable law.

3. How We Use Your Information

Windfall Group uses the information we collect to:

• Respond to leasing, investment, partnership, and general inquiries
• Evaluate and process job applications
• Send newsletters, press releases, and company updates (with your consent)
• Manage and maintain our business relationships
• Analyze website traffic and improve our digital presence
• Comply with legal and regulatory obligations
• Protect the security and integrity of our business and digital systems
• Enforce our policies and contractual agreements

4. Third-Party Sharing

Windfall Group does not sell personal information to third parties. We may share information in the following circumstances:

Service Providers

We work with trusted third-party vendors who support our website, communications, and business operations (e.g., email platforms, CRM systems, analytics tools). These providers access personal data only as needed to perform services on our behalf and are bound by confidentiality and data processing agreements.

Professional Advisors

We may share information with attorneys, accountants, auditors, and other advisors in connection with legal, financial, or compliance matters, subject to applicable professional privilege and confidentiality obligations.

Business Transactions

In connection with a merger, acquisition, joint venture, financing, or sale of assets, personal information may be disclosed to prospective counterparties under appropriate confidentiality protections. We will notify affected individuals if their information becomes subject to a materially different privacy policy.

Legal and Regulatory Disclosure

We may disclose personal information to law enforcement, regulators, or courts when required by law, to protect our legal rights, or to prevent harm to individuals or property.

Cross-Border Transfers

As Windfall Group operates in the United States, Canada, and China, personal information may be transferred across borders in connection with our business activities. We ensure such transfers comply with applicable laws, including through the use of data transfer agreements or other legal mechanisms where required.

5. Cookie Policy

What Are Cookies?

Cookies are small text files placed on your device when you visit our website. They help us understand how visitors use our site and support website functionality.

Types of Cookies We Use

Strictly Necessary Cookies

Required for the website to function. These cannot be disabled.

Analytics Cookies

We use Google Analytics and similar tools to analyze website traffic and visitor behavior. This data is anonymized and used solely to improve our website. You may opt out at tools.google.com/dlpage/gaoptout.

Functional Cookies

These remember your preferences (e.g., language or region) for a better experience on return visits.

Marketing Cookies

Where applicable, these cookies support targeted outreach to prospective partners, tenants, and investors. You may opt out through industry tools such as optout.aboutads.info.

Managing Cookies

You may manage cookie preferences through your browser settings or through the Cookie Settings tool in our website footer. Disabling certain cookies may affect website functionality.

6. Your Privacy Choices

You have the following choices regarding your personal information:

• Opt out of marketing and newsletter communications at any time via the unsubscribe link in any email or by contacting us directly
• Request access to the personal information we hold about you
• Request correction of inaccurate or outdated information
• Request deletion of your personal information, subject to legal retention requirements
• Opt out of analytics tracking via Google Analytics opt-out tools

To exercise any of these rights, contact us at info@windfallusa.com. We will respond within 45 days and may request identity verification before processing your request.

7. Children’s Privacy (COPPA)

The Windfall Group website is a corporate platform not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that such information has been submitted, we will delete it promptly.

8. Data Security

Windfall Group maintains appropriate administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction. These include access controls, encrypted communications, and periodic security reviews. No internet system is completely secure; we encourage all users to exercise caution when transmitting sensitive information.

9. Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to maintain our business records, and to comply with applicable legal obligations. Leasing and investment records may be retained for longer periods as required by law or contract.

10. State-Specific Rights

Residents of Illinois and Minnesota have additional rights under applicable state privacy laws. Please refer to our Illinois Privacy Addendum and Minnesota Privacy Addendum for details specific to those jurisdictions.

11. Links to Third-Party Websites

Our website may link to third-party websites, including those of our properties, partners, or media outlets. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party site you visit.

12. Updates to This Policy

Windfall Group reserves the right to update this Privacy Policy at any time. Material changes will be posted on our website with a revised effective date. Continued use of our website after posting constitutes acceptance of the updated Policy.

13. Contact

For privacy questions or to exercise your rights:

Windfall Group – Privacy Office

1300 Kensington Rd, Oak Brook, IL 60523

Email: info@windfallusa.com  |  Phone: (630) 463-2967

 

Your Privacy Choices

Applies To: Windfall Group – windfallusa.com

Windfall Group respects your right to control how your personal information is used. This page explains the privacy choices available to you as a visitor, partner, tenant, investor, or job applicant interacting with Windfall Group and its digital platforms.

 

1. Marketing and Newsletter Communications

If you have subscribed to Windfall Group newsletters, press updates, or marketing communications, you may opt out at any time by:

• Clicking the “Unsubscribe” link in any email communication
• Emailing info@windfallusa.com with your opt-out request

Please allow up to 10 business days for your opt-out to take effect. Note that opting out of marketing emails will not prevent transactional communications such as responses to your inquiries or updates related to active business engagements.

2. Cookie Preferences

You can control how cookies are used when you visit windfallusa.com. Manage your preferences at any time through the Cookie Settings tool in our website footer.

Cookies you can control:

Analytics Cookies

Opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout.

Marketing Cookies

Opt out of interest-based advertising via:

• Digital Advertising Alliance: optout.aboutads.info
• Network Advertising Initiative: optout.networkadvertising.org

Strictly Necessary Cookies

These cannot be disabled as they are required for the Site to function.

You may also adjust cookie settings directly through your browser. Note that disabling some cookies may affect website functionality.

3. Do Not Sell or Share My Personal Information

Windfall Group does not sell personal information to third parties for their own marketing purposes. We do not share personal data with data brokers or advertising networks for profiling or targeted advertising without your consent.

If any data practices on our platform could be characterized as “selling” or “sharing” under applicable state law (including the Illinois PIPA or Minnesota MCDPA), you may opt out by contacting us at info@windfallusa.com.

4. Access, Correction, and Deletion

You have the right to:

• Request a copy of the personal information Windfall Group holds about you
• Request correction of inaccurate or outdated personal information
• Request deletion of your personal information, subject to legal and contractual retention requirements
• Request that we restrict or limit processing of your personal information in certain circumstances
• Receive your personal data in a portable, machine-readable format

To submit a request, email info@windfallusa.com with your full name, contact details, and a description of your request. We will respond within 45 days. We may need to verify your identity before processing your request.

5. Appeal Rights

If Windfall Group denies your privacy request, you have the right to appeal. To do so, send a written explanation to info@windfallusa.com within 30 days of receiving our decision. We will respond to your appeal within 60 days and provide a written explanation of our determination.

6. Global Privacy Control (GPC)

Where technically feasible, Windfall Group honors Global Privacy Control (GPC) signals transmitted by your browser. If your browser sends a GPC signal indicating you do not wish your data to be shared or sold, we will treat this as a valid opt-out request for applicable data practices.

7. State-Specific Rights

Residents of Illinois and Minnesota have additional privacy rights under state law. Please refer to the applicable state addendum for details:

• Illinois residents: Illinois Privacy Addendum (BIPA, PIPA)
• Minnesota residents: Minnesota Privacy Addendum (MCDPA)

8. Job Applicants

Personal information submitted through job applications is used solely for recruitment and hiring purposes. You may request access to or deletion of your applicant information by contacting info@windfallusa.com. Windfall Group retains applicant records for a limited period following the conclusion of the hiring process, as required by law.

 

Property Conduct Policy

Applies To: All Windfall Group-managed properties in the United States

Windfall Group is committed to maintaining safe, professional, and welcoming environments across all of its properties, including retail centers, mixed-use developments, residential communities, and industrial facilities. This Property Conduct Policy establishes the behavioral expectations for all visitors, tenants, vendors, contractors, and members of the public accessing any Windfall Group-managed property.

 

1. Scope

This policy applies to all individuals who enter Windfall Group-managed properties, including:

• Retail and shopping center visitors (e.g., Pacifica Square, Burnsville Center)
• Tenants and their employees, guests, and customers
• Vendors, contractors, and service providers
• Investors, partners, and business visitors
• Event attendees and members of the public

2. General Conduct

All individuals on Windfall Group properties are expected to conduct themselves in a lawful, respectful, and professional manner. Windfall Group reserves the right to establish and enforce rules governing the use of its properties and common areas, consistent with applicable law.

3. Prohibited Conduct

The following behaviors are not permitted on any Windfall Group property:

Safety and Security

• Fighting, physical altercations, threatening behavior, or any conduct that endangers others
• Possession of firearms or illegal weapons, except as authorized by law
• Possession or use of illegal substances
• Conduct that creates a fire, safety, or health hazard
• Tampering with security systems, surveillance equipment, or safety infrastructure

Disruptive Behavior

• Harassment, intimidation, or abusive language or conduct directed at any individual
• Discrimination on the basis of race, color, national origin, religion, sex, disability, age, or any other protected characteristic
• Loud, disorderly, or disruptive behavior that interferes with business operations or the enjoyment of other visitors
• Excessive loitering in common areas
• Unauthorized solicitation, canvassing, distribution of materials, or demonstrations

Property Violations

• Vandalism, damage, theft, or destruction of property
• Unauthorized access to restricted areas, mechanical rooms, or tenant-only spaces
• Blocking or obstructing entrances, exits, walkways, loading docks, or fire lanes
• Unauthorized parking, overnight parking, or parking in restricted zones

4. Tenant and Vendor Responsibilities

Tenants and vendors operating on Windfall Group properties are responsible for ensuring that their employees, subcontractors, customers, and guests comply with this policy. Repeated or serious violations by a tenant’s employees or guests may result in lease enforcement action in accordance with the applicable lease agreement.

Vendors and contractors must comply with all posted site rules, Windfall Group safety requirements, and applicable OSHA and local building codes while performing work on the premises. All contractors must maintain appropriate insurance and provide certificates of insurance upon request.

5. Supervision of Minors

At Windfall Group retail properties open to the general public, children 15 years of age and under must be accompanied and supervised by a parent or guardian aged 21 or older at all times. Supervising adults are responsible for ensuring minors in their care comply with this policy.

6. Surveillance and Security

Windfall Group properties utilize security personnel and video surveillance systems in common areas to promote safety and protect tenants, visitors, and assets. Surveillance footage is used for security and operational purposes and may be shared with law enforcement when required or appropriate.

Windfall Group does not use surveillance for facial recognition or biometric identification unless expressly disclosed and compliant with applicable law, including the Illinois Biometric Information Privacy Act (BIPA).

7. Photography and Media

Personal non-commercial photography is generally permitted in public common areas of Windfall Group properties. Commercial photography, filming, or media production — including for advertising, press, or social media campaigns — requires prior written approval from Windfall Group property management or the corporate office. Unauthorized commercial filming may result in removal from the property.

8. Accessibility and Inclusion

Windfall Group is committed to maintaining an accessible and inclusive environment at all of its properties, in compliance with the Americans with Disabilities Act and applicable state laws. Conduct that discriminates against any individual on the basis of a protected characteristic is strictly prohibited. For accessibility accommodations or to report a concern, contact the relevant property management office or Windfall Group’s corporate office.

9. Parking

Vehicles must park in designated spaces only. No overnight parking is permitted unless expressly authorized. Windfall Group is not responsible for theft or damage to vehicles on its properties. Vehicles in violation of posted parking rules may be ticketed or towed at the owner’s expense.

10. Enforcement

Windfall Group and its authorized security personnel reserve the right to enforce this policy at their discretion. Individuals who violate this policy may be:

• Asked to immediately cease the prohibited behavior
• Required to leave the property
• Banned from future access to one or more Windfall Group properties
• Referred to law enforcement for arrest and/or prosecution for criminal trespass
• Subject to civil liability for damages caused

Tenants in violation of this policy through the conduct of their employees or guests may be subject to lease enforcement action in accordance with applicable lease terms.

11. Property Rights

All Windfall Group properties are privately owned. Windfall Group reserves the right to establish, modify, and enforce rules governing the use of its properties and common areas at any time, consistent with applicable law.

12. Dispute Resolution

Disputes arising from the enforcement of this policy that cannot be resolved through property management shall be governed by the dispute resolution provisions in Windfall Group’s Terms and Conditions or, for tenants, the applicable lease agreement.

13. Policy Updates

Windfall Group may update or modify this policy at any time. Updates will be communicated to tenants and posted at affected properties and on windfallusa.com.

14. Contact

Windfall Group Corporate Office

1300 Kensington Rd, Oak Brook, IL 60523

Email: info@windfallusa.com  |  Phone: (630) 463-2967