Privacy Policy

Our commitment to protecting your privacy

We are committed to maintaining the confidentiality, integrity and security of all nonpublic personal information entrusted to us by our customers and the customers of the broker/dealers who participate in the sale of securities sponsored by our affiliates.  In the course of servicing your account, we collect personal information about you ("Nonpublic Personal Information").  This Privacy Policy (the "Privacy Policy") describes the standards we follow for handling your personal information and how we use the information we collect about you.  This Privacy Policy applies only to the Web site owned by Hines Securities, Inc. having a Uniform Resource Locator, or URL, of www.hinessecurities.com and does not apply to other online or offline sites owned or operated by Hines, Hines Securities, any investment program offered by Hines Securities or any affiliate.

USE OUTSIDE THE UNITED STATES. This Web site, with a Uniform Resource Locator of www.hinessecurities.com, is solely for users located in the United States of America.  Because our privacy practices and policies may or may not comply with foreign laws, we do not recommend use of this Web site if you are located outside of the United States.  We explicitly disclaim any responsibility to notify you in the event the confidentiality of any information provided to us by you through this Web site or to any e-mail address provided in this Web site is compromised.

1. Information we may collect

We may collect Non Public Personal Information about you from the following sources:

  • Information on applications, subscription agreements or other forms delivered to us or our affiliates, which may include your name, e-mail address, telephone number, driver's license or government-issued identification card number, passport number, date of birth, assets, income, tax information, beneficiary information, personal bank account information, broker/dealer, financial advisor, custodian, and similar parties;
  • Information about your transactions with us, our affiliates and/or broker/dealers or other financial service providers participating in the sale of the securities offered through us, such as your account balances and transactional history; and
  • Personal information provided by you through this Web site when completing a form or questionnaire.

2. Why we collect Nonpublic Personal Information

We collect information from and about you in order to:

  • identify you as a customer;
  • establish and maintain your customer accounts and/or process transactions in your account;
  • communicate and share information with the custodians, transfer agents, and, if applicable, your broker/dealer or investment advisor, or other similar parties involved in the processing, servicing or administering of your account or the transactions effected in your account;
  • market investment products or services that may be consistent with your financial profile; and
  • meet our obligations under the laws and regulations that govern us.

3. Additional Information we collect from use of this Website

We may use "cookies" as part of its interaction with your browser, if your computer accepts cookies. Cookies consist of files of information that a Web site transfers to a site visitor's hard drive to track site and user activity. Cookies can make your use of www.hinessecurities.com more pleasing and efficient by, for example, "personalizing" your user interface or identifying which parts of the site you have previously visited.  Cookies have not been known to harm your computer.  Many Web sites use cookies; however, most browsers enable you to refuse cookies or to determine if and how cookies will be accepted by your hard drive.  If you prohibit or restrict placement of cookies, you may still use our Web site.  

We utilize the general Web site tracking information to give us a summary view of how our Web site is used. Currently, we do not track individual users, but we may implement the capacity to do so in the future.  In any case, we currently analyze the data, and will analyze the data in the future, only in an effort to determine how to improve the Web site. This information is and will continue to be used strictly for internal purposes.

We may conduct surveys regarding our products and services, including the operation of our Web site.  The information you provide is used only on an aggregated basis and is analyzed only to improve our products and services and for company management and planning purposes. You will not receive communications as a result of your participation in one of our surveys if you notify us not to contact you.

4. Use and Disclosure of Information

We may disclose all of the Nonpublic Personal Information we collect about you as described above to the followig types of third parties:

  • Our Affiliated Companies. We may offer investment products and services through certain of our affiliated companies, and we may share all of the Nonpublic Personal Information we collect about you with such affiliates.  We believe that by sharing information about you and your accounts among our companies, we are better able to serve your investment needs and to suggest services or educational materials that may be of interest to you.  
  • Nonaffiliated Service Providers and Joint Marketing Partners. From time to time, we use outside companies to perform services for us or functions on our behalf. We may disclose all of the Nonpublic Personal Information we collect as described above to such companies. However, before we disclose Nonpublic Personal Information to any of our service providers, we require them to agree to keep your Nonpublic Personal Information confidential and use the information only for the purposes for which disclosure to them is made.
  • Other Nonaffiliated Third Parties. We do not sell or share your Nonpublic Personal Information with nonaffiliated outside marketers.  We may disclose your Nonpublic Personal Information to the extent permitted or required by law. For example, to:
    • protect the security and integrity of our Web site;
    • effect, administer or enforce a transaction requested or authorized by you;
    • protect the security and integrity of our records;
    • protect our rights and property and the rights and property of others;
    • take precautions against liability;
    • respond to claims that your information violates the rights and interests of third parties;
    • take actions required by law or to respond to judicial process;
    • assist with detection, investigation or reporting of actual or potential fraud, misrepresentation or criminal activity; and
    • provide information to law enforcement agencies or for an investigation on a matter related to public safety to the extent permitted under other provisions of law.

5. Protecting Your Information

Our employees are required to follow the procedures we have developed to protect the integrity of your inforamtion. These procedures include:

  • Restricting physical and other access to your Nonpublic Personal Information to persons with a legitimate business need to know the information in order to service your account;
  • Contractually obligating third parties with whom we share information to keep your Nonpublic Personal Information confidential and secure and to use it only for authorized purposes;
  • Providing information to you only after we have used reasonable efforts to verify your identity; and
  • Maintaining reasonably adequate physical, electronic and procedural safeguards to protect your information.
  • Special security measures apply to your communications with us on this Web site. Internally, we employ encryption technologies, user authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to secure access to our computer systems and files.  We employ firewalls for our Internet-based systems.

We will continue to maintain the confidentiality of your Nonpublic Personal Information after the termination of the customer relationship.  Residents of some states may have additional privacy rights.  We adhere to all applicable state laws.  

6. Disclaimer of Responsibility for Privacy Policy and Content at Linked Sites

At certain places on this Web site, live links to other Internet addresses can be accessed.  This Privacy Policy does not apply to any information that you may provide to third parties, such as through other sites linked to www.hinessecurities.com. We are not responsible for such third party sites.  We do not control or review or pass on the merits of the data security measures, if any, employed by those sites or any other third party sites.

7. Keeping you Informed

If we amend this Privacy Policy, we will post the amended policy on our Web site. The most current version of this Privacy Policy can be reviewed by clicking on the "Privacy Policy" hyper text link at the bottom of our web pages. You may use your browser to print out a copy of this Privacy Policy for your records. If you are a customer of Hines Securities, if we decide to use or disclose your Nonpublic Personal Information in a manner different from what has been communicated to you in our Privacy Policy, we will notify you in writing, which may or may not be by e-mail.

8. Questions About Our Privacy Policy

If you have any questions about our Privacy Policy, please contact us via e-mail at: privacypolicy@hines.com.