Privacy Policy

Updated Date: September 19, 2023

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.

1. The personal information we collect about you

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 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:

• Contact information: name, address, and other contact information provided to Harrison Street in the course of its business;
• Business information: personal data identifying you in relation to transactions with us, in particular as provided in subscription agreements and other investment documents;
• Information necessary to comply with Harrison Street regulatory and reporting obligations: in particular, personal data, including name, address, Social Security Number (SSN) or other governmental identification, and date of birth, necessary to comply with the relevant anti-money laundering laws, sanction screening and regulatory checks related to individual investors and individuals holding at least 10 percent of the equity interest in a legal entity you use to invest with Harrison Street. For a copy of the Harrison Street Anti‐Money Laundering and Counter‐Terrorism Financing Policy, please contact us at the contact information provided below;
• Personal Information in connection with investigations or proceedings: where this is necessary to conduct an investigation or proceeding;
• Attendance records: to record your attendance at our offices for security purposes;
• Supplier data: contact details and other personal information about you or your company or organization where you provide services to Harrison Street;
• Subscriptions/marketing: your contact information and email address so you can receive information on investment opportunities, our updates or newsletters;
• Events personal data: attendance at and provision of feedback forms in relation to our events;
• Technical personal information: when you access our website and our technology services, certain information may be captured, including IP address, browser type and version, time zone setting, browser plug-in types and versions, the operating system you are using, device type, hardware model, unique identifiers and mobile network information;
• Online personal data: when you access this website and our technology services, information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information  and whether you click on particular links or open our emails;
• Social media personal data: posts, likes, tweets and other interactions with our social media accounts on platforms such as LinkedIn; and
• Criminal record data: where permitted by applicable law and appropriate to do so, such as existence of prior criminal offences (or confirmation of clean criminal record) for such activities such as anti-money laundering, sanctions screening and regulatory checks.

2. Why we use your personal information

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

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 any aspect of the products or services we offer, including servicing your Investor Account.
• Processing and executing securities transactions or funds movements at your direction by electronic or other means.
• Providing you with information about our products and services, which may be of interest to you, including investment-related information.
• Assessing an application for a product or service, including to determine whether or not to offer you the product or service and to determine whether you are eligible to invest in our products.
• Establishing and administering customer accounts which involves determining, maintaining, recording, and storing account holdings and transaction information in applicable client records.
• Updating your personal information and records.
• Ensuring personal information in our records is accurate and verifying previously given personal information when necessary.
• Providing you with account statements and other account related information, financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your customer account, including through our online customer portal.

Managing our business operations. We use your personal information in connection with our business operations, which include:

• Exercising due diligence to prevent or reduce our commercial risk, such as administering our good governance requirements and auditing of our business operations.
• Ensuring the security of our information, system or network.
• Complying with contractual, legal and regulatory obligations, requirements and guidance (e.g., securities legislation applicable for opening an account and applicable legislation respecting anti-money laundering, including respecting the identity of account holders).
• Satisfying regulatory audits, assessments, requests or requirements.

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.

• Legal Obligation legal basis – Processing is necessary to comply with UK or EEA legal or regulatory obligations: for example, anti-money laundering, mandatory client screening checks, disclosure to law enforcement, and complying with court orders.
• Contract Performance legal basis – Processing is necessary to perform a contract with you or take pre-contractual steps at your request: for example, contacting you to confirm payment instructions or providing information about potential investments.
• Legitimate Interests legal basis – Processing is necessary for our legitimate interests or those of a third party provided any interests or rights that you have as an individual do not override our rights.
• Vital Interests legal basis – Processing is necessary to protect the vital interest of an individual.

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:

• Contract Performance – Everyday business: maintaining your account within a Harrison Street-sponsored fund or with an affiliated registered investment adviser, managing and running transactions with you, your company or an otherwise affiliated entity;
• Contract Performance – Business relationship: managing and administering our relationship with you, your company or organization including keeping records about business contacts, services and payments; enforcing payment and other obligations;
• Legal Obligations – UK Regulatory and compliance: compliance with our UK legal and regulatory obligations as a real estate private equity firm including auditing and reporting requirements, due diligence (under anti−money laundering, sanctions screening and other crime prevention and detection laws and regulatory requirements), which may involve automated screening checks to ensure that clients and contacts are genuine, and to prevent fraud or crime; we may not be able to provide our services if you do not provide the information we need to do these checks; complying with the law, a judicial proceeding, court order, or other legal process; exercising, establishing and defending legal claims;

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.

• Contract Performance – Events: running briefings, roundtables and other events;
• Contract Performance – Managing suppliers: who deliver services to us;
• Legitimate Interest in improving our performance and promoting our business to grow our revenues – Analytics and Marketing; Communications: sending emails, newsletters and other messages to keep you informed of investment opportunities, recent developments, market insights and of our offerings; identifying what our clients want and developing our relationship with you, your company or organization; understanding how visitors use our websites; analyzing and improving our communications, services and offerings; introducing investment opportunities, managing inquiries and feedback; receiving information from other Harrison Street entities; developing relationships with business partners;
• Legitimate Interest in protecting our employees and clients, or Vital Interests where vital interests of clients, staff or other persons are at stake – Physical site security and emergency management: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings) and to manage emergencies;
• Legitimate Interest in ensuring the effectiveness of our website – Website monitoring: to check the website and our other technology services are being used appropriately and to optimize their functionality;
• Legitimate Interest in protecting our assets – Online security: protecting our information assets and technology platforms from unauthorized access or usage and to monitor for malware and other security threats;
• Legitimate Interest in protecting our assets – Enforcing rights: investigating, preventing, or taking action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved;
• Legitimate Interest in operating our business efficiently – Business Reorganization: sharing data in connection with investments, acquisitions, divestitures and transfers of a business or assets; participating in a bankruptcy or liquidation or similar proceeding;
• Consent – Any other specific purpose: any other specific purpose where you have otherwise consented to the processing of your personal information, such as to receive marketing messages.

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.

3. With whom do we share your personal information

We share your personal information with others as follows:

• Harrison Street affiliates: including their management, staff and contractors;
• Suppliers and/or Service providers: we disclose the information we collect from you to service providers, contractors or agents who may perform operational or IT functions on our behalf (e.g., cloud storage providers, communication suppliers, outsourced business support, and back up suppliers.
• Screening service providers: so that we can comply with legal obligations in relation to the prevention of crime, anti-money laundering, sanctions screening and other required checks;
• Website users: if you post to our website, including, without limitation, reviews, comments, and text, your username and content may be available to other users of the websites and services.
• Business Partners and Third Parties, Including Third-Party Ad and Social Media Platforms, Providers, and Networks: to better understand how users access and use the website and services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our website, services and business operations, to develop services and features, and for internal quality control and training purposes. We also share information to provide or make available certain features or portions of the website and services, or as necessary to respond to your requests. We may also make certain information (such as browsing information) available to third parties in support of our marketing, advertising, analytics, and campaign management.

We also disclose information in the following circumstances:

• Business Transfers: if (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company, in compliance with applicable law. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process: we disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena or a regulatory inquiry, etc.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information, to the extent permitted by law, including to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and act in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and De-identified Information: Unless otherwise stated in this Policy, we may use, disclose, and otherwise process aggregate and de-identified personal  information related to our business and the website and services with third parties for quality control, analytics, research, development, and other purposes.
• Protect Us and Others: we disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to safety or security, violations of this Policy, or as evidence in litigation or in other legal proceedings.
• Other Appropriate Parties: in the event of an emergency or to protect the health and safety of our clients, staff and organizations (e.g., first responders, public safety).
• Other Disclosures. We may disclose personal information in other ways not described above, but if legally required, we will notify you and, if necessary, obtain your consent.

4. Security

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.

5. How long do we keep your personal data

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.

6. Commercial Electronic Messages

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.

7. Minors

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.

8. Use of cookies and other tracking mechanisms and your choices

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:

• Necessary cookies are required for the operation of our site, such as to ensure security. Other necessary cookies allow us to provide services that you expressly request. These cookies do not require your consent and cannot be switched off (although in some cases you can change your requests). You can set your browser to block or alert you about these cookies, but some parts of our site may not work if you block these types of cookies.
• Analytics cookies allow us and third parties to analyze site usage, including to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps improve the way our Site works, for example, by ensuring that visitors are finding what they are looking for easily.
• Functionality cookies are used to provide certain functionalities to you by recognizing you when you return to our Site so that we can offer you a better experience on this Site. For instance, this enables us and third parties to set a cookie to store your preferences regarding the cookies on our Site.
• Advertisement cookies are used to tailor advertising and content to your interests both within and beyond our Sites. We and third parties will use this information to make our site, advertising, and  marketing messages more relevant to your interests. They may be used to build a profile of your interests and show you relevant adverts on other sites. If you do not consent to these types of cookies, you will still see advertisements, but they will not be customized to your interests.

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:

• U.S. Users: aboutads.info/choices (Digital Advertising Alliance).
• EU Users:  youronlinechoices.eu (European Interactive Digital Advertising Alliance) 
• Canadian Users:  youradchoices.ca/choices/ (Digital Advertising Alliance of Canada) 
• Japanese Users: http://www.ddai.info/optout (Data Driven Advertising Initiative in Japan)  

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.

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.

9. Third-party Ad Networks

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.  

10. Cross-border Transfers

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.

11. Your Rights under Canadian Law

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.

12. Changes to this Policy

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.

13. How to Contact Us

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

DataPrivacy@harrisonst.com

If you have questions about the privacy or would like to make a complaint, please contact us as directed above.

14. Additional Information under GDPR and DPL

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.

• Information: you are entitled to be informed as to how we collect and use your personal data;
• Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it unless prevented by applicable regulation (e.g., on professional secrecy), or if it would adversely affect rights and freedoms of others (e.g., Intellectual Property, trade secrets);
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
• Erasure: you are entitled to ask us to delete or remove personal data in specific circumstances. There are exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law;
• Restriction: under certain conditions you are entitled to ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it;
• Data Portability: when we process your personal data based on contract performance or your consent, you may ask us to transfer certain of your personal data to another party;
• Objection: where we are processing your personal data on the legal basis of our legitimate interest (or those of a third party) you may object on grounds particular to you. However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
• Consent: where we are processing personal data with consent, you have the right to withdraw consent at any time and require us to stop processing or restrict the processing, or not begin the processing, of your personal data, without affecting the lawfulness of processing based on consent before its withdrawal,

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:

• We have your explicit consent: for processing such information;
• This is necessary to protect your vital interests or those of another person: for example, in medical emergencies;
• You have manifestly made the data public;
• Processing is necessary to deal with legal claims: for example, involving court proceedings;
• Processing is necessary for substantial public interest: for example, to prevent or detect unlawful acts.

Our Representatives

The UK and EEA representatives of Harrison Street Real Estate Capital, Ltd. can be reached at: DataPrivacy@harrisonst.com.

15. Additional Information under US State Laws

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:

• Identifiers. Such as name, alias, email, phone number, billing address, unique personal identifier, online identifier, IP address, account name, or other similar identifiers.
• Customer Records. Includes your account and profile information and customer records that contain personal information, such as name, account name, other characteristics or descriptions, email, address, phone number, and other contact information, account credentials, communications preferences, billing and payment information, customer service and support tickets and records, and other information you provide in order to use our services.
• Commercial Information. Such as records relating to company products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information. Includes, but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our Site, mobile application, advertisements, or emails, including other usage data related to your use of any of our services or other online services.
• Geolocation Data. Such as location information about a particular individual or device.
• Audio, Electronic, Visual, Thermal or Similar Information. Includes information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, user profile images, temperature readings and CCTV/video footage to secure our offices and premises.
• Professional and Employment Information. Includes current and former employer(s) and position(s), business contact information, educational institutions attended, and professional memberships, interests, skills or certifications.
• Inferences. Such as inferences drawn from any of the personal information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.
• Sensitive Personal Information. In limited circumstances, we may collect social security numbers, driver’s license numbers, and precise geolocation].

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

• administer and support the contracts and relationships we have with you or your employer and the authorized users of and subscribers to our services.
• provide updates about our services,
• monitor compliance with the terms on which we offer our services,
• enable third parties to provide services related to our provision of services,
• improve the services,
• provide you relevant content,
• deliver support related to the services to you or your employer,
• manage billing and other client inquiries,
• send you information about other products or services that may be of interest to you.

Website Visitors

• send you the data, tools and other information you have requested,
• inform you about products and services we offer,
• improve the services, and,
• in some cases, to directly or indirectly provide you with third-party advertisements across your devices and sites you visit which may be of interest to you and may be based on any preferences you have indicated in your registration or request form.

Suppliers

• administer and support the contracts we have with you or your employer.
• We also may use this personal information to improve the services, to contact you for purposes of dealing with support, billing and other inquiries about your products and services.

Business professionals

• We provide this information to other business professionals and to third party advertisers.

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):

• Opt out of sales and sharing: to opt-out of our sale and sharing of their personal information.
• Limit uses and disclosures of sensitive personal information: to limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA. However, we do not use your sensitive personal information in this way so not limitation is needed.
• Deletion: to request deletion of their personal information.
• To know/access: to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information (all of which is the same for all consumers and is described in this Privacy Policy), and the specific pieces of personal information we have collected about them.
• Correction: to request correction of inaccurate personal information.
• Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.

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.

How to Contact Us

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