Updated Date: July 2, 2025
Harrison Street Real Estate Capital, LLC, and its affiliates, including registered investment advisers, and investment vehicles sponsored or managed by Harrison Street Real Estate Capital, LLC (collectively, “Harrison Street”, “we”, “our”, or “us”) provides this privacy policy (“Policy”) in order to describe how we collect, use and protect information that relates to any identified or identifiable person or as described in your jurisdiction (“personal information” or “personal data”). This Policy describes your rights in relation to applicable privacy laws including, United States federal and state laws, the UK and EU General Data Protection Regulation (“GDPR”), laws implementing European Commission Directive 2002/58/EC on privacy and electronic communications, Canada Personal Information Protection and Electronic Documents Act and equivalent provincial privacy legislation (collectively, “Canadian privacy laws”) and the Data Protection Law, 2017 of the Cayman Islands (the “DPL”) as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto. Specifically, the purpose of this Policy is to explain how and for what purposes Harrison Street collects, uses, shares or otherwise processes your personal information This Policy applies when you interact with Harrison Street or when you can access Harrison Street’s website at https://www.harrisonst.com/ (the “website”), including when accessing your online Investor Account.
The “Additional Information under GDPR and DPL” section of this Policy sets out additional information if you are working with our UK office, or are a UK or EEA resident, or if the DPL applies. California employees and applicants should review our separate California Employee and Applicant Privacy Notices.
For persons outside the UK or EEA, or persons transacting with Harrison Street entities outside the UK or EEA: By visiting the website, or using any of our services, you agree that your personal information will be handled as described in this Policy. Your use of our website or services, and any dispute over privacy will be handled in accordance with this Policy.
We are present in the UK through our subsidiary and some of our investment funds. We are present in the Cayman Islands through some of our investment funds. We are present in Canada through our subsidiaries and some of our investment funds VII, VIII, and IX.
If the DPL applies, the relevant fund will be characterized under the DPL as a ‘data controller’, while certain of the fund’s service providers, affiliates and delegates may act as ‘data processors’ under the DPL.
If you are a nominee investor or a corporate entity, this notice will be relevant for those individuals connected to you, and you should transmit this document to such individuals for their awareness and consideration.
Harrison Street collects personal information from various sources for the purposes outlined in the Why we use your personal information section. Specifically, Harrison Street collects personal information as described below:
Personal Information Collected from You
Harrison Street obtains most of the personal information it requires directly from you when you open your account with us – whether in person, by telephone or electronically (e.g., by email), or the user agreement. Harrison Street may verify this personal information.
Personal Information Collected from Third Parties
Harrison Street may receive additional information, including background information such as criminal history data, from other financial institutions, your employer, or service providers whom you may have authorized to provide us with such information and/or who assist us with our legal obligations, in particular to conduct anti-money laundering, sanctions screening and regulatory checks. This information may relate to your finances, employment, or other personal characteristics, as well as interactions with or through Harrison Street or others. We may also collect data from advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and publicly available sources.
Personal Information Collected from You
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Personal Information Collected Automatically
When you visit our sites or services, we and third parties may collect information, including personal information, through the use of cookies, pixel tags, and other similar technologies including IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique or online identifiers, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information and activities and usage information. We also collect activity information such as information about links clicked, searches conducted, features used, items viewed, time spent on certain pages, your interactions with us, log file information, and other activity and usage information.
See the Use of cookies and other tracking mechanisms and your choices section for more information.
Categories of Personal Information Collected
Harrison Street collects, uses and stores the following categories of personal information in connection with providing you with its services:
The above data will be provided to us by you, your employer, the company or organization who is our client or screening providers who assist us with our legal obligations, in particular to conduct anti−money laundering, sanctions screening and regulatory checks. We may also collect personal data from publicly available sources
A. Use of Personal Information
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
We may use your personal information for general business purposes such as providing or delivering a product or service requested from Harrison Street, managing our business and website, preventing or reducing commercial risk, as well as for purposes relating to information, system, personal or network security.
More specifically, we may use your personal information for the following general business purposes:
Providing or delivering our products and services. We use your personal information for activities that are necessary to provide or deliver our products and services, for instance:
Managing our business operations. We use your personal information in connection with our business operations, which include:
Managing our website. When you visit our website, we may use your personal information to manage and facilitate the use of our website, which may include using cookies and other similar technologies.
Marketing purposes. We may use your personal information to provide you with personalized content and services, such as tailoring our products and services, our customer experience and offerings, and deciding which offers or promotions to show you. For more information on this topic, see the Third-Party Ad Networks and Choices section.
Please advise that we may also use your Personal Information in other ways we notify you about at the time we collect your Personal Information or as otherwise permitted or required by law.
B. Legal Basis
Please advise that we may also use your Personal Information in other ways we notify you about at the time we collect your Personal Information or as otherwise permitted or required by law.
Note that in Canada, we rely on your consent to process your personal information, unless otherwise permitted under applicable laws. When applicable law requires your express consent, you will be asked to grant Harrison Street the right to access and process your personal information in accordance with the identified purposes. In some cases, your consent may be “implied”, meaning that your agreement is assumed based on your action or inaction at the point of processing your personal data.
We use your personal information for the following purposes and legal bases in the UK/EEA:
Where we carry out these activities to comply with US laws and regulations, our legal basis for purposes of UK/EEA compliance is our Legitimate Interest in protecting our assets and our reputation by conducting our business in compliance with applicable laws.
We will use your personal data for the purposes for which we collected it, as set out in this Policy and, if applicable, in Fund documents, which are available to investors upon their subscription and/or investment, as applicable. As previously mentioned, note that we may also use your personal information in other ways we notify you about at the time we collect your personal information or as otherwise permitted and/or as required by law.
We share your personal information with others as follows:
We also disclose information in the following circumstances:
While we have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized disclosure, please be aware that despite our efforts, no data security measures can guarantee security.
There are also certain steps you can take to better protect against unauthorized access to your personal information. For example, you should choose a strong password that is unique to the services (and do not reuse passwords across multiple sites and services or share your password with others). If you believe that your password or account has been compromised, please reset your password, and promptly notify us.
Depending on the jurisdiction in which you reside, we generally keep your personal data as reasonably needed to provide our services, comply with applicable law and regulations, securely render our business, close transactions and to deal with claims. This will depend on several factors such as whether you or your company or organization are an existing client or have interacted with recent client mailings or bulletins or attended recent events. We will retain your information as necessary to comply with legal, accounting or regulatory requirements. We will endeavor not to retain your personal data for longer than is necessary for the purposes explained above and in accordance with Harrison Street’s Document Retention Policy.
We may use the information you give us for direct marketing purposes to provide emails, newsletters and other commercial electronic messages to keep you informed of investment opportunities, recent developments, market insights and of our services including events that we think may interest you where permitted by applicable law.
You can opt-out of receiving direct marketing from us at any time. You can do this by contacting us at the contact details provided below or clicking the unsubscribe link in any email we send you.
We do not intend to or knowingly collect information from children or other persons, who are under 18 years old or fall within the definition of a minor under applicable law. If you are a minor, you may not submit any personal data to us. If we discover that a child or minor has provided us with personal information in violation of applicable law, we will delete such information from our systems.
We and advertising, measurement and analytics companies use cookies and other tracking mechanisms to track information about your use of our website, products or services. We may combine this information with other personal information we collect about you. Any tracking done by third parties through cookies and other mechanisms are subject to those parties’ own privacy policies. You may manage Google cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.
Session cookies are stored only temporarily during a browsing session and are deleted from the visitor’s device when the browser is closed while persistent cookies are saved on your device for a fixed period of time and are not deleted when the browser is closed. Cookies can be categorized generally as follows:
Retention. The various cookies used by our site have different lifespans. Generally, session cookies will be deleted once you close your browser. Persistent cookies implemented on our site will generally be kept for a period of time that does not exceed 13 months.
Managing and Disabling Cookies. Where required by law, we will obtain your consent to the use of the cookies when you first access the Site. Most web browsers automatically accept cookies, but if you prefer, you can use our “Cookies Settings” tool on our website to refuse cookies on our website, or you can edit your browser options to block future cookies. How to do this will depend on the browser you use.
You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at:
Please note that opting out of participating ad networks does not opt you out of being served advertising, and you will continue to receive generic or contextual ads. You may also continue to receive targeted ads on other websites from companies that do not participate in the above programs.
Please note that opting out of participating ad network does not mean that you will not see advertisements at all, and you will continue to receive advertisements on other websites and from companies that do not participate in the above programs.
Third-Party analytics and tools. We use third party tools, such as Google Analytics, to evaluate usage of our services and our website and to help us improve performance and user experiences. These third-party tools may use cookies and other tracking technologies, such as pixel tags, to perform their services. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
You can find further information on managing cookies here: http://www.allaboutcookies.org/.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section and see below for a discussion of the Global Privacy Controls we deploy in certain jurisdictions.
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 and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to 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. We may provide these third-party advertisers with information, including personal information, about you such as your web-browsing histories or IP address.
You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and those of third parties, in order to display more relevant targeted advertising to you as described in the Use of cookies and other tracking mechanisms and your choices section above.
Some of our external third-party service providers may based outside of your home country including, Canada, the United States, United Kingdom, and European Union, and their processing of your personal information will therefore involve a transfer of information outside of your home country. Organizations based outside of your home country may not be subject to privacy laws that provide you with the same rights and protections as your home country. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
Depending on the jurisdiction in which you reside, you may be entitled to access your personal information and request the correction of inaccurate information, subject to limited exceptions set out in applicable laws.
Your right to access your information. You have the right to ask us whether we are using or storing your personal information. You may also ask us to access that personal information.
Your right of rectification. You have the right to ask us to rectify any personal information that you consider to be incorrect, inaccurate, or equivocal, and to complete any information that you consider to be incomplete. You may also have the right to request rectification of your personal information if the collection, disclosure or retention of that information is not permitted by law.
If you desire to exercise any of the rights listed above, please submit a written request us by using the information provided in the How to Contact Us section. Please be advised that we may verify your request to correct or access your information by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
Your right to opt-out. Please be advised that you have a right to withdraw your consent to Harrison Street’s collection, use, and communication of your personal information. If you desire to do so, please contact Harrison Street using the information provided in the How to Contact Us section.
However, note that if you withdraw your consent, Harrison Street will be unable to establish an account for you as the processing of your personal information, including its communication to third parties, is necessary to establish and maintain your account. Further, all other information sharing in which we participate is required by Harrison Street’s regulators and/or law enforcement agencies. Additionally, Harrison Street reserves its right to share appropriate personal information about you with our attorneys, accountants, auditors and service providers in order to effectively discharge its obligations with applicable laws, including securities laws and regulations.
Please see the Additional Information under GDPR and DPL and Additional Information under U.S. State Laws sections for details on this section’s application in specific jurisdictions.
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our website. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our website or by contacting you if we have your contact information.
If you would like more information about the way we manage personal data that we hold about you, please contact us:
Compliance Department
+1 312‐920-0500
DataPrivacy@harrisonst.com
Harrison Street Real Estate Capital, LLC
444 West Lake Street, Suite 2100
Chicago, IL 60606 USA
For European Union:
Harrison Street Real Estate Capital, Ltd.
20 St. James’s Street
London SW1A 1ES
United Kingdom
If you have questions about the privacy or would like to make a complaint, please contact us as directed above.
Your Rights
If you are working with our UK office or are a UK or EEA resident or if the DPL applies, you may have certain rights in relation to your personal data. The availability of these rights and the ways in which you can use them are set out below in more detail.
Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at the contact details here.
If you want to exercise any of these rights, please contact us at DataPrivacy@harrisonst.com or see “How to contact us” above.
You also have a right to lodge a complaint with a data protection supervisory authority in the UK or EEA where you are habitually resident, your place of work, or where an alleged infringement of the GDPR or the applicable local data protection law has taken place. If the DPL applies, you have the right to complain to the Data Protection Ombudsman of the Cayman Islands (you can access their website here: ombudsman.ky).
Please note that if you do not wish to provide us with requested personal information or subsequently withdraw your consent, you may not be able to invest in one of our Funds or remain invested in one of our Funds as it will affect our ability to provide our services to you and manage your investment.
Where will your information be held?
We are present in U.S., Europe and Asia, and your information may be transferred out of your local jurisdiction or region. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the UK, EEA or certain other jurisdictions. Harrison Street will take steps to protect your information in line with locally applicable data protection requirements. For transfers of data from the UK or EEA jurisdictions Harrison Street has implemented appropriate safeguards where required, notably contractual terms. If you would like copies of the terms applicable to transfers from the UK or EEA, please contact us at: DataPrivacy@harrisonst.com.
Our reasons for using special category data
“Special category data” in the UK and EEA and certain other jurisdictions refers to sensitive personal data such as your racial or ethnic origin, religious beliefs or health data. We may also collect data about criminal convictions. As a general rule, we will not process this data, but in exceptional cases, we may process this data where:
Our Representatives
The UK and EEA representatives of Harrison Street Real Estate Capital, Ltd. can be reached at: DataPrivacy@harrisonst.com.
California Notice at Collection
This section of the Privacy Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.
This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information, information governed by the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or deidentified or aggregated information. Please note that we collect and consolidate public information about public and private equity markets for its products and services. Some of this public information may include information about individuals. Generally, since it is public data, it is not governed by this Privacy Policy or applicable law; however, if you would like to remove information such as your name, business email, and business phone number, you can contact us as described below.
Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
Personal Information We Collect. We may collect (and have collected) the following categories of personal information about you depending on how you use the services:
Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; our affiliates and subsidiaries; our business partners; customers and clients; social networks; internet service providers; operating systems and platforms; and our vendors and service providers.
Purposes for Collecting and Disclosing Personal Information. In general, we collect and process the personal information we collect for the following business or commercial purposes:
Clients and authorized users
Website Visitors
Suppliers
Business professionals
Disclosure of Personal Information to Third Parties and Other Recipients. The categories of personal information we have disclosed for a business purpose include: identifiers, customer records, commercial information, Internet or other electronic network activity information, geolocation data, audio, video, thermal, and other electronic data, and inferences.
The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: affiliates, subsidiaries, and business partners, vendors and service providers, acquirers of business assets, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.
Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising. We may “sell” or “share” the following categories of personal information: identifiers, professional and employment information, and Internet or other electronic network activity information. We disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share personal information about individuals we know are under age sixteen (16).
Sensitive Personal Information. Notwithstanding the purposes described above, we do not use or disclose of sensitive personal information beyond the purposes authorized by the CCPA.
Retention. We generally keep your personal data as needed to provide our services, comply with applicable law and regulations, securely render our business, close transactions and to deal with claims.
This will depend on several factors such as whether you or your company or organization are an existing client or have interacted with recent client mailings or bulletins or attended recent events. We will retain your information as necessary to comply with legal, accounting or regulatory requirements. We will endeavor not to retain your personal data for longer than is necessary for the purposes explained above.
California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below.
California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us online by using a GPC enabled browser or plug in (as described below), changing their privacy settings through the cookie banner, by submitting an opt out request via our webform, or emailing us at DataPrivacy@harrisonst.com.
We will take steps to verify your request by sending you an email confirmation link which you must click to confirm your request; and matching the information provided by you with the information we have in our records. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us at DataPrivacy@harrisonst.com. Authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
GPC. Our website responds to global privacy control or “GPC” signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our site. Note that if you come back to our site from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/. We do not respond to Do Not Track signals.
If you would like more information about the way we manage personal data that we hold about you, please contact us:
Compliance Department
+1 312‐920-0500 (call toll free)
DataPrivacy@harrisonst.com
Harrison Street Real Estate Capital, LLC
444 West Lake Street, Suite 2100
Chicago, IL 60606 USA