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).

• We employ cook­ies and sim­i­lar tools to enrich your brows­ing expe­ri­ence, refine site nav­i­ga­tion, ana­lyze usage pat­terns, and bol­ster our mar­ket­ing endeav­ors. If you con­sent to the acti­va­tion of these tools on your device, we may col­lect cer­tain online per­son­al data, such as your device ID or IP address. Addi­tion­al infor­ma­tion on this is pro­vid­ed below for your reference.

COOK­IES AND SIM­I­LAR TECH­NOLO­GIES

Our web­site uses cook­ies and sim­i­lar tech­nolo­gies to enhance user expe­ri­ence, improve web­site func­tion­al­i­ty, and ensure secu­ri­ty and com­pli­ance. Below, we pro­vide a trans­par­ent expla­na­tion of the types of cook­ies we use, their pur­pos­es, and how you can man­age your pref­er­ences.

Cook­ies are small data files stored on your device that help web­sites func­tion effec­tive­ly. Some cook­ies are ses­sion-based, mean­ing they are auto­mat­i­cal­ly delet­ed when you close your brows­er, while oth­ers are per­sis­tent, remain­ing on your device for a set peri­od.

We trans­par­ent­ly inform you about our use of cook­ies and sim­i­lar tech­nolo­gies in the sec­tions below. In case you would like to fur­ther under­stand more about these tech­nolo­gies, you can as well set your brows­er set­tings to inform you about the cook­ies or sim­i­lar tech­nolo­gies down­loaded to your device.

1. Strict­ly Nec­es­sary Cook­ies:
   These cook­ies are essen­tial for web­site secu­ri­ty, net­work man­age­ment, and over­all func­tion­al­i­ty. They enable key fea­tures such as page nav­i­ga­tion and access to secure areas of the site.
   • Pur­pose: Ensure web­site oper­a­tion and security.

   • Your Con­trol: these cook­ies are required to pro­vide you with the web­site ser­vices you request­ed, and can as such not be declined.

2. Option­al Cook­ies:
   All oth­er cook­ies, includ­ing those for pref­er­ences, ana­lyt­ics, mar­ket­ing, track­ing, pro­fil­ing, and chat func­tion­al­i­ty, will only be acti­vat­ed if you explic­it­ly consent.
   • Pur­pose:
     • Adver­tis­ing cook­ies store con­sent for per­son­al­ized adver­tis­ing, enable stor­age relat­ed to adver­tis­ing and set con­sent for send­ing user data to Google for online adver­tis­ing purposes;
     • Ana­lyt­ics & cus­tomiza­tion cook­ies ana­lyze usage for site opti­miza­tion and enable stor­age relat­ed to ana­lyt­ics (e.g. vis­it duration);
     • Per­for­mance & func­tion­al­i­ty cook­ies facil­i­tate mea­sure­ment and ana­lyt­ics for improved brows­ing expe­ri­ence, and enables stor­age that sup­ports the func­tion­al­i­ty of the web­site such as lan­guage set­tings and per­son­al­iza­tion like video recommendations.
   • Your Con­trol:
     • These cook­ies will not be placed on your device unless you opt-in.
     • You can man­age your pref­er­ences and with­draw con­sent at any time through our cook­ie settings.

Regard­ing your cook­ie pref­er­ences, please note that when you click ​“Dis­miss” on the cook­ie ban­ner, only essen­tial cook­ies nec­es­sary for the website’s basic func­tion­al­i­ty will be enabled. 

To get an overview of the types of cook­ies used on this web­site, what their pur­pos­es are, and how long they are stored, you can click on ​“cook­ie pref­er­ences” at the foot­er of the website.

Addi­tion­al­ly, we use sim­i­lar tech­nolo­gies, such as local shared objects, which enhance your brows­ing expe­ri­ence by stor­ing pref­er­ences and opti­miz­ing web­site functionality.

At last, third par­ties includ­ing Google, Meta and X may use cook­ies, web bea­cons, and oth­er stor­age tech­nolo­gies (e.g. Face­book Pix­el, X pix­el, GA4) to col­lect or receive infor­ma­tion of your online activ­i­ty and use that infor­ma­tion to pro­vide mea­sure­ment ser­vices, tar­get and deliv­er ads. Please note that this activ­i­ty is beyond our con­trol. For enhanced pro­tec­tion, you can opt-out of the col­lec­tion and use of infor­ma­tion for ad tar­get­ing con­trol so via your brows­er set­tings as described below.

Con­trol via Your Brows­er Settings

Most inter­net browsers are ini­tial­ly set up to auto­mat­i­cal­ly accept cook­ies. If you do not want our web­sites to store cook­ies on your device, you can change your brows­er set­tings so that you receive a warn­ing before cer­tain cook­ies are stored. You can also adjust your set­tings so that your brows­er refus­es most of our cook­ies or only cer­tain cook­ies from third par­ties. You can also with­draw your con­sent to cook­ies by delet­ing the cook­ies that have already been stored.

If you dis­able the cook­ies that we use, this may impact your expe­ri­ence while on the Unilever web­site, for exam­ple you may not be able to vis­it cer­tain areas of a web­site or you may not receive per­son­al­ized infor­ma­tion when you vis­it a website.

If you use dif­fer­ent devices to view and access the Unilever web­site (e.g., your com­put­er, smart­phone, tablet) you will need to ensure that each brows­er on each device is adjust­ed to suit your cook­ie preferences.

The pro­ce­dures for chang­ing your set­tings and cook­ies dif­fer from brows­er to brows­er. If nec­es­sary, use the help func­tion on your brows­er or click on one of the links below to go direct­ly to the user man­u­al for your browser.

• Inter­net Explorer
• Mozil­la Firefox
• Google Chrome
• Safari
• Opera

There are also soft­ware prod­ucts avail­able that can man­age cook­ies for you.

You can also use www​.ghostery​.com to eval­u­ate the use of cook­ies used on our websites.

To find out more about cook­ies, includ­ing how to see what cook­ies have been set and how to man­age and delete them, vis­it www​.allabout​cook​ies​.org.

Third-Par­ty Linked Sites

Our web­site con­tains links to third-par­ty web­sites, includ­ing social media sites, which may have pri­va­cy poli­cies that dif­fer from our own.

We are not respon­si­ble for the col­lec­tion, use, or dis­clo­sure of infor­ma­tion col­lect­ed through third-par­ty web­sites and express­ly dis­claim any lia­bil­i­ty relat­ed to such data pro­cess­ing. Addi­tion­al­ly, we are not respon­si­ble for the accu­ra­cy, con­tent, or pri­va­cy prac­tices of these third-par­ty sites.

Links to exter­nal web­sites are pro­vid­ed for con­ve­nience only, and your brows­ing, use, and inter­ac­tions with these sites—including those that link to or from our website—are sub­ject to their own rules and poli­cies. We strong­ly encour­age you to review the pri­va­cy pol­i­cy of any web­site you access through our plat­form.

Please note that if you pro­vide per­son­al infor­ma­tion to us through a social media site or inter­act with social media con­tent linked to our web­site, you con­sent to our use of that infor­ma­tion in accor­dance with this Pri­va­cy Pol­i­cy, as if the infor­ma­tion had been sub­mit­ted to us direct­ly via our website.

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.