Hines Private Wealth Solutions Privacy Policy

Hines Pri­vate Wealth Solu­tions LLC (“Hines Pri­vate Wealth Solu­tions,” ​“we,” or ​“us”) wants you to be famil­iar with how we col­lect, use, and dis­close infor­ma­tion. This Pri­va­cy Pol­i­cy describes our prac­tices in con­nec­tion with infor­ma­tion that we col­lect through our offline activ­i­ties as well as our online activ­i­ties, includ­ing through our web­site locat­ed at http://​hine​spri​vatewealth​.com/, our social media pages, and any oth­er site from which you are access­ing this Pri­va­cy Pol­i­cy (col­lec­tive­ly, the ​“Ser­vices”). This Pri­va­cy Pol­i­cy does not apply to oth­er web­sites owned or oper­at­ed by Hines, Hines Glob­al Income Trust, Inc., Hines Pri­vate Wealth Solu­tions, or any invest­ment pro­gram offered by Hines Pri­vate Wealth Solu­tions or any affiliate.

PER­SON­AL INFORMATION

Col­lec­tion of Per­son­al Information 

“Per­son­al Infor­ma­tion” is infor­ma­tion that iden­ti­fies you as an indi­vid­ual or relates to an iden­ti­fi­able indi­vid­ual. We col­lect Per­son­al Infor­ma­tion through our Ser­vices, including:

• Name
• Postal address
• Tele­phone number
• Email address
• Broker/​dealer, finan­cial advi­sor, cus­to­di­an and sim­i­lar parties
• Date of birth
• Gov­ern­ment-issued IDs, such as driver’s license num­ber or Social Secu­ri­ty number
• Income, assets, bank account, tax, and oth­er finan­cial and trans­ac­tion-relat­ed infor­ma­tion, includ­ing invest­ment amounts, pur­chase dates, and share class

If you are a Cal­i­for­nia res­i­dent, please see our Cal­i­for­nia Pri­va­cy Notice for more infor­ma­tion about how we han­dle your Per­son­al Infor­ma­tion and how to exer­cise your pri­va­cy rights.

Use of Per­son­al Information 

We and our ser­vice providers may use Per­son­al Infor­ma­tion for the fol­low­ing purposes: 

• Pro­vid­ing the Ser­vices func­tion­al­i­ty and ful­fill­ing your requests
  • To pro­vide the Ser­vices’ func­tion­al­i­ty and relat­ed ser­vices to you.
  • To respond to your inquiries, cre­ate and main­tain your reg­is­tered accounts, and ful­fill your trans­ac­tions and requests.
  • To send admin­is­tra­tive infor­ma­tion to you, such as changes to our terms, con­di­tions, and policies.

• Pro­vid­ing you with our newslet­ter and/​or oth­er mar­ket­ing materials
  • To send you mar­ket­ing relat­ed emails, with infor­ma­tion about our ser­vices, new prod­ucts, sur­veys, and oth­er news about our company.

• Ana­lyz­ing Per­son­al Infor­ma­tion for busi­ness report­ing and pro­vid­ing per­son­al­ized services.
  • To ana­lyze or pre­dict our users’ pref­er­ences, so we can improve our Services.
  • To bet­ter under­stand your inter­ests and pref­er­ences, so that we can per­son­al­ize our inter­ac­tions with you and pro­vide you with infor­ma­tion tai­lored to your interests.

• Aggre­gat­ing and/​or anonymiz­ing Per­son­al Information.
  • We may aggre­gate and/​or anonymize Per­son­al Infor­ma­tion so that it will no longer be con­sid­ered Per­son­al Infor­ma­tion. We do so to gen­er­ate oth­er data for our use, which we may use and dis­close for any pur­pose, as it no longer iden­ti­fies you or any oth­er individual.

• Accom­plish­ing our busi­ness purposes.
  • For data analy­sis, for exam­ple, to improve the effi­cien­cy of our Services;
  • For audits, to ver­i­fy that our inter­nal process­es func­tion as intend­ed and to address legal, reg­u­la­to­ry, or con­trac­tu­al requirements;
  • For fraud and secu­ri­ty mon­i­tor­ing pur­pos­es, for exam­ple, to detect and pre­vent cyber­at­tacks or attempts to com­mit iden­ti­ty theft;
  • For enhanc­ing, improv­ing, repair­ing, main­tain­ing, or mod­i­fy­ing our Services;
  • For iden­ti­fy­ing usage trends, for exam­ple, under­stand­ing which parts of our Ser­vices are of most inter­est to users; and
  • For deter­min­ing the effec­tive­ness of our pro­mo­tion­al cam­paigns, so that we can adapt our cam­paigns to the needs and inter­ests of our users.

If you dis­close any Per­son­al Infor­ma­tion relat­ing to oth­er peo­ple to us or to our ser­vice providers in con­nec­tion with the Ser­vices, you rep­re­sent that you have the author­i­ty to do so and to per­mit us to use the infor­ma­tion in accor­dance with this Pri­va­cy Policy. 

Dis­clo­sure of Per­son­al Information 

We may dis­close Per­son­al Information: 

• To our affil­i­at­ed com­pa­nies, for the pur­pos­es described in this Pri­va­cy Policy.

• To our third par­ty ser­vice providers, to facil­i­tate ser­vices they pro­vide to us.
  • These can include providers of ser­vices such as web­site host­ing, data analy­sis, trans­ac­tion pro­cess­ing, fraud pre­ven­tion, infor­ma­tion tech­nol­o­gy and relat­ed infra­struc­ture pro­vi­sion, cus­tomer ser­vice or sup­port, mar­ket­ing and ad agen­cies, email deliv­ery, audit­ing, and oth­er services.

• To third par­ties with which we do busi­ness that have a pre-exist­ing rela­tion­ship with you, such as broker/​dealers, finan­cial advi­sors and custodians.

• To oth­er third-par­ty busi­ness part­ners, such as [finan­cial insti­tu­tions and oth­er enti­ties that are involved in the invest­ment process.

• By using the Ser­vices, you may elect to dis­close Per­son­al Information.
  • On mes­sage boards, online groups, and oth­er ser­vices to which you are able to post infor­ma­tion and con­tent. Please note that any infor­ma­tion you post or dis­close through these ser­vices will become pub­lic and may be avail­able to oth­er users and the gen­er­al public.

Oth­er Uses and Disclosures

We may also use and dis­close Per­son­al Infor­ma­tion as we believe to be nec­es­sary or appro­pri­ate: (a) to com­ply with applic­a­ble law, to respond to requests from pub­lic and gov­ern­ment author­i­ties, to coop­er­ate with law enforce­ment, or for oth­er legal rea­sons; (b) to enforce our terms and con­di­tions; and (c) to pro­tect our rights, pri­va­cy, safe­ty or prop­er­ty, and/​or that of you, or oth­ers. We may use, dis­close or trans­fer your Per­son­al Infor­ma­tion to a third par­ty in the event of any reor­ga­ni­za­tion, merg­er, sale, joint ven­ture, assign­ment, trans­fer or oth­er dis­po­si­tion of all or any por­tion of our assets or stock (includ­ing in con­nec­tion with any bank­rupt­cy or sim­i­lar proceedings).

OTH­ER INFORMATION

Col­lec­tion of Oth­er Information 

“Oth­er Infor­ma­tion” is any infor­ma­tion that does not reveal your spe­cif­ic iden­ti­ty or does not direct­ly relate to an iden­ti­fi­able indi­vid­ual. We and our ser­vice providers may col­lect Oth­er Infor­ma­tion through the Ser­vices in a vari­ety of ways, including: 

• Your brows­er or device.
  • Cer­tain infor­ma­tion is col­lect­ed by most browsers or auto­mat­i­cal­ly through your device, such as your Media Access Con­trol (MAC) address, com­put­er type (Win­dows or Mac), screen res­o­lu­tion, oper­at­ing sys­tem name and ver­sion, device man­u­fac­tur­er and mod­el, lan­guage, and Inter­net brows­er type and ver­sion. We use this infor­ma­tion to ensure that the Ser­vices func­tion properly.

• Cook­ies.
  • Cook­ies are pieces of infor­ma­tion stored direct­ly on the com­put­er that you are using. Cook­ies allow us to col­lect infor­ma­tion such as brows­er type, time spent on the Ser­vices, pages vis­it­ed, lan­guage pref­er­ences, and oth­er traf­fic data. We and our ser­vice providers use the infor­ma­tion for secu­ri­ty pur­pos­es, to facil­i­tate nav­i­ga­tion, to dis­play infor­ma­tion more effec­tive­ly, and to per­son­al­ize your expe­ri­ence. We also gath­er sta­tis­ti­cal infor­ma­tion about use of the Ser­vices in order to con­tin­u­al­ly improve their design and func­tion­al­i­ty, under­stand how they are used, and assist us with resolv­ing ques­tions. We do not cur­rent­ly respond to brows­er do-not-track sig­nals. If you do not want infor­ma­tion col­lect­ed through the use of cook­ies, most browsers allow you to auto­mat­i­cal­ly decline cook­ies or be giv­en the choice of declin­ing or accept­ing a par­tic­u­lar cook­ie (or cook­ies) from a par­tic­u­lar web­site. You may also wish to refer to http://​www​.allabout​cook​ies​.org/​m​a​n​a​g​e​-​c​o​o​k​i​e​s​/​i​n​d​e​x​.html. If, how­ev­er, you do not accept cook­ies, you may expe­ri­ence some incon­ve­nience in your use of the Services.

• Ana­lyt­ics and Pix­el tags
  • Ana­lyt­ics. We use Google Ana­lyt­ics, which uses cook­ies and sim­i­lar tech­nolo­gies to col­lect and ana­lyze infor­ma­tion about use of the Ser­vices and report on activ­i­ties and trends. This ser­vice may also col­lect infor­ma­tion regard­ing the use of oth­er web­sites, apps and online resources. You can learn about Google’s prac­tices by going to www.google.com/policies/privacy/‌partners/, and exer­cise the opt-out pro­vid­ed by Google by down­load­ing the Google Ana­lyt­ics opt-out brows­er add-on, avail­able at https://​tools​.google​.com/​d​l​p​a​g​e​/​g​a​o​ptout.
  • Pix­el tags. Pix­el tags (also known as web bea­cons and clear GIFs) may be used to, among oth­er things, track the actions of users of the Ser­vices (includ­ing email recip­i­ents), mea­sure the suc­cess of our mar­ket­ing cam­paigns, and com­pile sta­tis­tics about usage of the Ser­vices and response rates.

• IP Address
  • Your IP Address is a num­ber that is auto­mat­i­cal­ly assigned to your com­put­er by your Inter­net Ser­vice Provider. An IP Address may be iden­ti­fied and logged auto­mat­i­cal­ly in our serv­er log files when­ev­er a user access­es the Ser­vices, along with the time of the vis­it and the pages vis­it­ed. We use IP Address­es for pur­pos­es such as cal­cu­lat­ing usage lev­els, diag­nos­ing serv­er prob­lems, and admin­is­ter­ing the Ser­vices. We may also derive your approx­i­mate loca­tion from your IP Address.

Uses and Dis­clo­sures of Oth­er Information 

We may use and dis­close Oth­er Infor­ma­tion for any pur­pose, except where we are required to do oth­er­wise under applic­a­ble law. If we are required to treat Oth­er Infor­ma­tion as Per­son­al Infor­ma­tion under applic­a­ble law, we may use and dis­close it for the pur­pos­es for which we use and dis­close Per­son­al Infor­ma­tion as detailed in this Pol­i­cy. In some instances, we may com­bine Oth­er Infor­ma­tion with Per­son­al Infor­ma­tion. If we do, we will treat the com­bined infor­ma­tion as Per­son­al Infor­ma­tion as long as it is combined.

SECU­RI­TY

We seek to use rea­son­able orga­ni­za­tion­al, tech­ni­cal and admin­is­tra­tive mea­sures to pro­tect Per­son­al Infor­ma­tion with­in our orga­ni­za­tion. Unfor­tu­nate­ly, no data trans­mis­sion or stor­age sys­tem can be guar­an­teed to be 100% secure. If you have rea­son to believe that your inter­ac­tion with us is no longer secure, please imme­di­ate­ly noti­fy us in accor­dance with the ​“Con­tact­ing Us” sec­tion below.

YOUR CHOIC­ES

We give you choic­es regard­ing your Per­son­al Infor­ma­tion. You may opt out from: 

• Receiv­ing mar­ket­ing-relat­ed emails from us. If you no longer want to receive mar­ket­ing relat­ed emails from us on a going-for­ward basis, you may update your email pref­er­ences, includ­ing opt­ing out of all mar­ket­ing emails from us, by click­ing the ​“Update Email Pref­er­ences or Unsub­scribe” link at the bot­tom of each such email.

Please note that if you opt out of receiv­ing mar­ket­ing relat­ed emails from us, we may still send you impor­tant admin­is­tra­tive mes­sages, from which you can­not opt out.

RETEN­TION

We retain Per­son­al Infor­ma­tion for as long as need­ed or per­mit­ted in light of the purpose(s) for which it was obtained and con­sis­tent with applic­a­ble law. The cri­te­ria used to deter­mine our reten­tion peri­ods include: 

• The length of time we have an ongo­ing rela­tion­ship with you and pro­vide our ser­vices to you; 
• Whether there is a legal oblig­a­tion to which we are sub­ject, for exam­ple, cer­tain laws require us to keep records of your trans­ac­tions for a cer­tain peri­od of time before we can delete them; or 
• Whether reten­tion is advis­able in light of our legal posi­tion, such as in regard to applic­a­ble statutes of lim­i­ta­tions, lit­i­ga­tion or reg­u­la­to­ry investigations. 

THIRD PAR­TY SERVICES

This Pri­va­cy Pol­i­cy does not address, and we are not respon­si­ble for, the pri­va­cy, infor­ma­tion, or oth­er prac­tices of any third par­ties, includ­ing any third par­ty oper­at­ing any web­site or ser­vice to which the Ser­vices link. The inclu­sion of a link on the Ser­vices does not imply endorse­ment of the linked site or ser­vice by us. In addi­tion, we are not respon­si­ble for the infor­ma­tion col­lec­tion, use, dis­clo­sure, or secu­ri­ty poli­cies or prac­tices of oth­er orga­ni­za­tions, such as any oper­at­ing sys­tem provider, wire­less ser­vice provider, or device manufacturer.

ADVER­TIS­ING

We may use third-par­ty adver­tis­ing com­pa­nies to serve adver­tise­ments regard­ing goods and ser­vices that may be of inter­est to you when you access and use oth­er web­sites or online ser­vices that are not con­trolled by us. You may receive adver­tise­ments based on infor­ma­tion relat­ing to your access to and use of these oth­er web­sites or online ser­vices on any of your devices. 

USE OF THE SER­VICES BY MINORS

The Ser­vices are not direct­ed to indi­vid­u­als under the age of thir­teen (13), and we do not know­ing­ly col­lect Per­son­al Infor­ma­tion from indi­vid­u­als under 13.

JURIS­DIC­TION AND CROSS-BOR­DER TRANSFER

We are locat­ed in the Unit­ed States. We may store and process your Per­son­al Infor­ma­tion in any coun­try where we have facil­i­ties or in which we engage ser­vice providers. By using the Ser­vices, you under­stand that your infor­ma­tion will be trans­ferred to coun­tries, states and/​or provinces out­side of your place of res­i­dence, includ­ing the Unit­ed States, which may have data pro­tec­tion rules that are dif­fer­ent from those of your coun­try. In cer­tain cir­cum­stances, courts, law enforce­ment agen­cies, reg­u­la­to­ry agen­cies or secu­ri­ty author­i­ties in those oth­er coun­tries may be enti­tled to access your Per­son­al Information. 

UPDATES TO THIS PRI­VA­CY POLICY

The ​“LAST UPDAT­ED” leg­end at the top of this Pri­va­cy Pol­i­cy indi­cates when this Pri­va­cy Pol­i­cy was last revised. Any changes will become effec­tive when we post the revised Pri­va­cy Pol­i­cy on the Services. 

CON­TACT­ING US

If you have any ques­tions about this Pri­va­cy Pol­i­cy, please con­tact us at privacypolicy@​hines.​com. Because email com­mu­ni­ca­tions are not always secure, please do not include cred­it card or oth­er sen­si­tive infor­ma­tion in your emails to us.

ADDI­TION­AL INFOR­MA­TION REGARD­ING NEVA­DA RESIDENTS

We do not sell Cov­ered Infor­ma­tion as defined under Neva­da law. If you would like to make a fur­ther inquiry regard­ing the sell­ing of your Cov­ered Infor­ma­tion, as defined under Neva­da law, please email us at privacypolicy@​hines.​com.

ADDI­TION­AL INFOR­MA­TION REGARD­ING CANADA

Indi­vid­ual Rights

If you would like to request to access, cor­rect, update, sup­press, restrict, or delete Per­son­al Infor­ma­tion, if you would like to request to receive a copy of your Per­son­al Infor­ma­tion for pur­pos­es of trans­mit­ting it to anoth­er com­pa­ny, or with­draw your con­sent for pro­cess­ing of your Per­son­al Infor­ma­tion, you may con­tact us in accor­dance with the ​“Con­tact­ing Us” sec­tion above. We will respond to your request con­sis­tent with applic­a­ble law.

For your pro­tec­tion, we may only imple­ment requests with respect to the Per­son­al Infor­ma­tion asso­ci­at­ed with the par­tic­u­lar email address that you use to send us your request, and we may need to ver­i­fy your iden­ti­ty before imple­ment­ing your request. We will try to com­ply with your request as soon as rea­son­ably prac­ti­ca­ble. Please note that we may need to retain cer­tain infor­ma­tion for record­keep­ing pur­pos­es and/​or to com­plete any trans­ac­tions that you began pri­or to mak­ing your request.

Data Pro­tec­tion Officer

The Chief Com­pli­ance Offi­cer is the data pro­tec­tion offi­cer respon­si­ble for Cana­da and may be con­tact­ed at compliance@​hines.​com.