Harrison Street Real Estate Capital, LLC, affiliates, including registered investment advisers, and investment vehicles sponsored or managed by Harrison Street Real Estate Capital, LLC or its affiliates (collectively, “Harrison Street“) is committed to protecting your privacy. This Policy describes how we collect, use it and protect information which may directly or indirectly identify you (“personal information”, or “personal data”). It also describes the rights you have and control you can exercise in relation to it under certain privacy laws including, where applicable, under the General Data Protection Regulation (“GDPR”), 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.
If the DPL applies, the relevant fund will be characterized under the DPL as a ‘data controller’, whilst 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.
Personal information is collected by each member of Harrison Street.
We are present in the European Union through our subsidiary and our investment funds. We are present in the Cayman Islands through some of our investment funds.
What personal information we collect and use
We collect and use the following personal information:
- Contact information: name, address, and other contact information provided to Harrison Street it the course of its business;
- Business information: data identifying you in relation to transactions with us, in particular provided in subscription agreements and other investment documents;
- Information necessary to comply with Harrison Street regulatory and reporting obligations: in particular, data 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 (including name, address, Social Security Number, date of birth); For a copy of the Harrison Street Anti‐Money Laundering and Counter‐Terrorism Financing Policy, please contact us at the contact information provided below.
- Information in connection with investigations or proceedings: where this is necessary to conduct the investigation or proceedings;
- Attendance records: to record your attendance at our offices for security purposes;
- Supplier data: contact details and other information about you or your company or organization where you provide services to Harrison Street;
- Subscriptions/marketing: when you subscribe to receive information on investment opportunities, our updates or newsletters;
- Events data: attendance at and provision of feedback forms in relation to our events;
- Technical information: when you access this website and our technology services, certain information may be captured, including IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug-in types and versions, the operating system you are using (e.g. Vista, Windows XP, MacOS, etc.), device type, hardware model, unique identifiers and mobile network information;
- Online 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 (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails;
Harrison Street does not collect personal data about your online activities across third party websites or online services.
- Special categories of personal data: such as dietary, disability or similar requirements for events and meetings. If you do not provide this information, we may not be able to respond to your needs or preferences;
- Social media: posts, Likes, tweets and other interactions with our social media presence;
- Criminal record data: where permitted by national law and appropriate to do so, such as existence of prior criminal offences (or confirmation of clean criminal record).
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.
How we use your personal information
We use your personal information for the following purposes:
- 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 otherwise affiliated entity;
- Business relationship: managing and administering our relationship with you, your company or organization including keeping records about business contacts, services and payments;
- Regulatory and compliance: compliance with our 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 and we may not be able to provide our services if you do not provide the information we need to do these checks;
- Communication: sending emails, newsletters and other messages to keep you informed of investment opportunities, recent developments, market insights and of our offerings;
- Managing suppliers: who deliver services to us;
- Site security: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings);
- Website monitoring: to check the website and our other technology services are being used appropriately and to optimize their functionality;
- Online security: protecting our information assets and technology platforms from unauthorized access or usage and to monitor for malware and other security threats;
- Events: running briefings, roundtables and other events;
- Legitimate interest: to pursue the legitimate business interests listed in the “Legitimate Interests” section of this Policy below;
- Any other specific purpose: any other specific where you have otherwise consented to the processing of your personal information.
Our reasons for using your personal information
We will process your personal data for a number of reasons:
- This is necessary to comply with legal or regulatory obligations: for example, anti-money laundering and mandatory client screening checks or disclosure to law enforcement.
- This is necessary to deal with legal and insurance claims and enforcement: for example, to comply with court orders.
- Processing is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual. Our legitimate interests are listed in the next section.
We will only use your personal data for the purposes for which we collected it as set out in this notice and, if applicable, in Fund documents. If we need to use your personal data for an unrelated purpose, we will contact you.
We have legitimate business interests in:
- everyday business, managing transactions;
- managing our business and relationship with you or your company or organization;
- introducing investment opportunities, manage the client inquiries, receive client feedback;
- identifying what our clients want and developing our relationship with you, your company or organization;
- improving our services and offerings;
- receiving information from other Harrison Street entities;
- ensuring our systems and premises are secure;
- managing our supply chain;
- developing relationships with business partners;
- ensuring debts are paid;
- sharing data in connection with acquisitions and transfers of our business;
- understanding how our clients use our websites.
Our reasons for using special category data
Special category data in the EU and certain other jurisdictions refers to sensitive 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 and in exceptional cases, we may process this data where:
- We have your explicit consent: for such information processing;
- 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:
- This is necessary to deal with legal claims: for example, involving court proceedings;
- This is necessary for substantial public interest: for example, to prevent or detect unlawful acts;
- As permitted by applicable law: outside the EU and other jurisdictions where these restrictions apply.
With whom do we share your personal data?
We share only that personal information that we are permitted by law to share and will only share such information in a manner that complies with applicable law, including GDPR and the DPL where applicable. Harrison Street has not sold, and we will not sell, the personal information you share with us, to anyone.
We share your information as with others as follows:
- Harrison Street affiliates: including their management, staff and contractors;
- Suppliers: who support our business including IT and communication suppliers, outsourced business support, advisors and consultants, law firms, back up suppliers. Our suppliers must meet minimum standards as to information security and they will only be provided data in line with their function and on the “must to know” basis;
- Law enforcement bodies and our regulators: or other competent authorities in accordance with legal requirements or good practice;
- Courts, tribunals, arbitration panels and counterparties in litigation: if necessary to handle disputes and litigation cases;
- Appropriate parties in the event of emergencies: to protect health and safety of our clients, staff and organisations;
- Screening service providers: so that we can comply with legal obligations in relation to the prevention or protection of crime, ant-money laundering, sanctions screening and other required checks;
- Other Third parties: in the context of the operations of our business, including the business of our investment vehicles and their subsidiaries, and the acquisition or transfer of any part of our business or in connection with the business reorganisation;
To protect your personal information, we maintain physical, electronic and procedural safeguards designed to comply with the applicable laws. We train our employees in the proper handling of personal data.
Where will your information be held?
We are present in USA, 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 EU 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 EU jurisdictions to third countries or international organisations within the meaning of the EU General Data Protection Regulation2016/679 (“GDPR”) (encompassing generally all countries outside of the European Economic Area) Harrison Street has implemented appropriate safeguards meeting the requirements of the GDPR. If you would like copies of the appropriate safeguards applicable to European data, please contact us.
How long do we keep your data?
We generally keep your information as needed to 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 organisation 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 not retain your personal information for longer than is necessary for the purposes explained above.
If you are working with our EU office or are EU resident or if the DPL applies, you may have certain rights in relation to your information. 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 provided below.
- 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 adversely affect rights and freedoms of other (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 certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law;
- Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- Data Portability: in certain circumstances you may ask us to transfer certain of your personal data to another party;
- Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may challenge this. 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;
- Data Breach: you have the right to be notified of a data breach (unless the breach is unlikely to be prejudicial to you).
If you want to exercise any of these rights, please contact us at the contact details provided below.
You also have a right to lodge a complaint with a data protection supervisory authority, in particular in the Member State in the European Union where you are habitually resident, your place of work or where an alleged infringement of the GPPR 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.
Right to object
If you are working with our EU office are EU resident you may have a right to object to us processing your information in certain circumstances. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
We may use the information you give us for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of investment opportunities, recent developments, market insights and of our services including events that we think may interest you.
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.
We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us.
Changes to this Policy
This Policy may be changed from time to time.
This Policy may be changed from time to time.
If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.
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:
Contact: Compliance Department
Telephone: +1 312‐920-0500
Address: Harrison Street Real Estate Capital, LLC
444 West Lake Street, Suite 2100
Chicago, IL 60606 USA
For European Union:
Address: Harrison Street Real Estate Capital, LLC
20 St. James’s Street
London SW1A 1ES