Notices, Policies and Disclaimers
Statements of notices, policies, disclaimers and regulatory disclosures.
Updated Date: September 19, 2023
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
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.
- 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.
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.
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.
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.
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
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.
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:
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
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
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,
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.
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
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.
- 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.
- 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.
- 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.
- 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.
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Harrison Street Real Estate Capital, LLC
444 West Lake Street, Suite 2100
Chicago, IL 60606 USA
Sustainable Finance Disclosure Regulation
Harrison Street Advisors, LLC (the “Firm”) considers the principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impact statement of the Firm for the purposes of regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector.
The principal adverse impacts statement covers the reference period from 1 January 2022 to 31 December 2022 and will be disclosed prior to 30 June 2023.
Since inception in 2005, Harrison Street has sought to combine innovation and process rigor to execute differentiated strategies that improve the lives of its stakeholders. In 2013 Harrison Street began a formal effort to expand its focus and reporting of environmental, social, and governance (ESG) aspects of the business, which included its first submission to GRESB. To date, robust policies and procedures have been implemented to integrate ESG considerations into investment management processes and ownership practices in the belief that these factors can have an impact on financial performance.
These processes include an ESG policy which the Firm first established in 2013, and updates annually. The policy applies across corporate and investment operations and provides a framework for ESG integration. In addition, since 2014 the Firm publishes a Corporate Impact report annually, which presents the Firm’s strategy, goals and performance of the previous year. Stakeholder feedback is critical to the ESG initiative and is collected at least every three years to update the Firm’s priority list of most material ESG issues, including sustainability impacts and indicators.
Description of principal adverse sustainability impacts
Indicators applicable to investments in real estate assets
|Adverse Sustainability Indicator||Metric||Impact |
|Fossil fuels||Exposure to fossil fuels through real estate assets||Share of investments in real estate involved in extraction, storage, transport, or manufacture of fossil fuels||n/a||n/a||No investments in real estate involved in fossil fuels||n/a|
|Energy efficiency||Exposure to energy-inefficient real estate assets||Share of investments in energy-inefficient real estate assets||<25%||<25%||The Firm measures efficient assets as follows, those that have LED lighting, energy efficient appliances, and meet Green Building standards. Based on the Firm’s methodology and number of properties evaluated in a given year, it considers less than 25% of assets under its control are candidates for energy efficiency upgrades||Do annual reviews of properties for efficiency upgrades|
Other indicators for principal adverse impact
|Adverse Sustainability Impact||Adverse Sustainability Impact |
(qualitative or quantitative)
|Climate and other environment-related indicators|
|Emissions||GHG Emissions||Scope 1 and Scope 2 of GHG emissions generated by real estate assets.|
|Energy consumption||Energy consumption intensity|
|Social and Employee, Respect of Human Rights, Anti-Corruption and Anti-Bribery Matters|
|Human rights||Lack of human rights policy||Share of investments related to entities without human rights policy.|
|Human rights||Lack of processes and measures for preventing trafficking in human beings||Share of investments related to entities without policies against trafficking in human beings.|
This statement does not take into account principal adverse impacts on sustainability factors associated with Harrison Street Core Property Fund B S.C.S., SICAV-RAIF, which are reported at https://lis-aifm.com/esg (.)
Today, the Firm seeks to make an impact, a vision that encompasses not only the discrete impact of assets but also the positive societal and environmental benefit created through the Firms’ investment activities.
ESG is integrated into each investment vehicle. Our annual Corporate Impact Report, found in the Impact section of the Firm’s website, highlights this integration with respect to specific funds.
Description of policies to identify and prioritise principal adverse sustainability impacts
Harrison Street Advisors, LLC established its ESG policy for the first time in 2013, which was last updated December 2022.
The policy applies across corporate and investment operations and provides a framework for ESG integration. The Firm’s approach is defined in two parts, Corporate Operations and Investment Operations. Within Investment Operations, each investment vehicle follows this framework to define a specific approach to ESG integration that aligns with the investment strategy, control, asset class, investment time horizon, and portfolio construction. Execution of the policy resides across the Firm’s various departments. ESG is integrated throughout the Firm. The overall initiative is overseen by the Firm’s Chief Impact Officer and the Sustainability Leadership Team. The team leaders report activities and progress toward meeting ESG objectives quarterly to Harrison Street’s Executive Committee and the Firm at large.
In the Firm’s 2017 materiality assessment, the topics of highest priority were more focused on the individual issues within assets. In 2020, the results show focus is moving toward a more global, collective mindset. Instead of focusing singularly on energy reduction, the Firm will be focusing on net carbon emissions which includes energy reduction but also includes topics like clean energy procurement, on-site renewable energy development, and on-site fuel choices. In addition, the focus on tenant satisfaction will be broadened to encompass a complete picture about the residents and tenants served at assets, encompassing health, wellness, safety, and even affordability.
Sustainability metrics are integrated into due diligence processes, and evaluation criteria include alignment with the Firm governance and ethics standards, presence of certifications, and opportunity for increased efficiency in the future. Internal due diligence policies, procedures, and checklists are defined for specific asset classes and investment vehicles. ESG risks and opportunities are captured in the initial investment underwriting process, the Investment Committee presentation, and during the due diligence period.
The Firm seeks to develop or acquire assets that prioritize high efficiency standards and occupant health attributes. Development partners are engaged in enhancing their sustainable practices in design, construction, and operation. The Firm offers guidance resources and access to expert consultants to evaluate sustainable building strategies and ensure long-term economic benefit and tenant well-being. The Firm collaborates with development partners to integrate viable sustainability strategies into project proforma and design plans on a case-by-case basis, considering location, building type, tenant population, and portfolio goals. Harrison Street’s Asset Management team continues to monitor the property during the development phase and engages third-party vendors to review construction drawings to determine energy optimization and utility expense estimates.
The Firm recognizes that changing climate conditions can impact the operation, performance, and value of real assets. Natural disasters pose a high potential financial loss to assets in key geographic areas, and other societal risks (like geopolitical disruptions or pandemics) influence the operational performance of assets. Therefore, the Firm has implemented resilience and risk management procedures in order to recognize and plan for these events, thus supporting long-term value creation and minimizing risk. These practices are continuously evaluated and enhanced as the global landscape of risks and evaluation processes evolve.
For key environmental indicators, such as energy efficiency, GHG emissions and energy intensity, the Firm uses the energy management platform called Conservice/Goby, which both captures and calculates this information. The social indicators are captured in both initial and ongoing management and company background checks.
Partners, investors, and employees are engaged in and educated about Harrison Street’s ethics policies. Training on ethics, anti-corruption, and specialized topics like foreign corrupt practices and cybersecurity are provided annually, during quarterly certifications, and when new regulations or situations arise. Investment policies and procedures promote compliance with the SEC’s Investment Advisor requirements and assist the Firm in preventing, detecting, and correcting violations. Policies against bribery and corruption are maintained, consistent with the US Foreign Corrupt Practices Act and similar laws in other countries. Anti–money laundering checks are conducted for every new investor and background checks are conducted on all new joint venture partners and employees.
In addition, Harrison Street recognizes that incorporating the feedback of its stakeholders is vital to delivering superior investment strategies and a focused ESG strategy. The Firm regularly engages with employees, investors, third-party operators, joint venture partners, tenants/residents, lenders, and consultants to understand priorities and concerns. Forums for engagement include the annual investor conference and advisory board meetings for each fund, annual operating partner sector-specific conferences, quarterly investor webinars, satisfaction surveys, and a materiality survey conducted at least every three years. Ad hoc feedback from industry conferences, one-on-one calls, industry trade magazines, and webinars is also integrated into materiality assessments.
As mentioned above, stakeholder feedback is critical to the ESG initiative and is collected at least every three years to update the Firm’s priority list of most material ESG issues, including sustainability impacts and indicators. In addition, annually the Firm updates and publishes its ESG policy to reflect changes or enhancements to the ESG policy, if warranted, due to changes in stakeholder demands.
Reference to international standards
The ESG Frameworks the Firm follows include:
- GRESB Real Estate
- GRESB Infrastructure
- TCFD (Task Force on Climate Related Financial Disclosures
- UN PRI (Principles for Responsible Investing)
- GRI Standards (Global Reporting Initiative)
Annually, the Firm submits to GRESB and UN PRI, follows GRI Standards in our Corporate Impact Report, and completes TCFD requirements.
The Firm uses results from reports such as GRESB to identify areas of improvement. The assessments themselves do not predict future performance, but rather are lagging indicators of how one was performing in the previous calendar year. Identifying areas where full points were not awarded, and then setting goals to lessen the gap are how forward-looking scenarios are executed. These goals then roll into the broader ESG strategy.
The Firm follows a pay-for-performance framework that encompasses total compensation, base salary and bonus, such that pay is commensurate with the overall performance of the Firm and individual performance. This includes a balanced assessment of the employee’s annual performance against the Firm’s core values: excellence, integrity, passion, innovation and teamwork. These performance dimensions consider short and long-term priorities that drive sustained shareholder value, while accounting for risk, controls, and conduct objectives.
The Firm’s Performance Management Cycle includes: annual goal setting, manager-employee check-ins, a midyear and annual review. To track performance, a comprehensive online talent management system is utilized, which streamlines all aspects of the Performance Management Cycle. It is the Firm’s intent, that our performance management process provides transparency to all employees with respect to job performance. For select employees involved in ESG related tasks or activities, regard is given to the performance of said strategies. For each of these employees regard is given to the performance of relevant ESG related projects/strategies.
Harrison Street Real Estate Capital Ltd
MIFIDPRU 8 Disclosure
The Financial Conduct Authority (the “FCA”) in the Prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Harrison Street Real Estate Capital Ltd (“HSUK”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which HSUK must comply, further to those prudential requirements.
HSUK is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, HSUK is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.
The purpose of these disclosures is to give stakeholders and market participants an insight into HSUK’s culture and to assist stakeholders in making more informed decisions about their relationship with HSUK.
This document has been prepared by HSUK in accordance with the requirements of MIFIDPRU 8 and is verified by the Board. Unless otherwise stated, all figures are as at HSUK’s 31 December financial year-end.
Remuneration Policy and Practices
As an SNI MIFIDPRU Investment Firm, HSUK is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to:
- Promote effective risk management in the long-term interests of HSUK and its clients;
- Ensure alignment between risk and individual reward;
- Support positive behaviours and healthy firm cultures; and
- Discourage behaviours that can lead to misconduct and poor customer outcomes.
The objective of HSUK’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of HSUK and the services that it provides to its clients.
In addition, HSUK recognises that remuneration is a key component in how HSUK attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity, and results. As such, HSUK’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.
HSUK is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude, and results.
Characteristics of HSUK’s Remuneration Policy and Practices
Remuneration at HSUK is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the firm’s financial performance, and the financial and non-financial performance of the individual in contributing to HSUK’s success. All staff members are eligible to receive variable remuneration.
Compensation is based upon a balance of financial and non-financial measures, with all staff compensated based upon the performance of their role, function and the business as a whole. HSUK ensures proper goals and rewards are clear and transparent to the employees, and the general review criteria that are applicable to all employees are based on the firm’s Cultural Core Values (Teamwork, Innovation, Passion, Integrity and Excellence).
The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which HSUK may do where HSUK’s profitability performance is constrained, or where there is a risk that HSUK may not be able to meet its capital or liquidity regulatory requirements.
Governance and Oversight
Harrison Street Real Estate Capital LLC’s (the “Parent”) remuneration committee (“Remuneration Committee”) has discretion to pay bonuses to all staff, based on the performance of the Group as a whole, and the performance of the individual in contributing to the success of HSUK. As such the Remuneration Committee is responsible for setting and overseeing the implementation of HSUK’s remuneration policy and practices. In order to fulfil its responsibilities, the Remuneration Committee:
- Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital, and liquidity;
- Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of HSUK;
- Ensures that HSUK’s remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors, and other stakeholders in HSUK; and
- Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of HSUK and of its clients.
HSUK’s remuneration policy and practices are reviewed on at least an annual basis.
Quantitative Remuneration Disclosure
For the financial year 1 January to 31 December 2022, the total amount of remuneration awarded to all HSUK staff was £9,814,288 of which £4,452,053 comprised the fixed component of remuneration, and £5,362,235 comprised the variable component.
PERE is a leading publication for the world’s private real estate markets. Its annual awards are determined by industry participants through a highly controlled voting system.
Pensions & Investments Best Places to Work award is a two part assessment designed to gather detailed data about each participating company that includes a questionnaire completed by the employer and a satisfaction survey completed by company employees.
The Private Equity Wire awards are based on an online poll of finalist firms pre-selected based on data provided by Bloomberg.
Fitwel is a certification system administered by the Center for Active Design (CfAD) that promotes health and wellness for occupants of real estate assets. CfAD’s annual Best in Building Health awards honor those firms who meet and exceed Fitwel’s certification standards, but also recognizes exceptional leadership and progress in the industry. The distinguished Industry Leadership award is offered at the discretion of CfAD’s senior leadership to honor companies demonstrating exceptional innovation in advancing Fitwel’s commitment to building health for all. As of May 2022, a Harrison Street employee participates on the Fitwel Leadership Advisory Board (Fitwel LAB) of Active Design Advisors, Inc. (“Adai”), which is an affiliate of CfAD. The Fitwel LAB provides industry feedback to Adai regarding its certifications and services. In connection with participation on the Fitwel LAB, Harrison Street made a voluntary donation to CfAD to support its research and the acquisition of CfAD certifications by budget-constrained property owners.
Pensions & Investments largest real estate investment managers is ranked by total worldwide real estate assets, in millions, as of June 30, 2020. Assets are reported net of leverage, including contributions committed or received, but not yet invested; REOCs are included with equity; REIT securities are excluded.
Harrison Street Real Estate Capital, LLCは、下記ジェネラル・パートナーからの委託を受けて、別紙様式第20号の2及び第21号の3に該当する資料（以下、「当該資料」といいます。）を公衆の縦覧に供するための手続きを行います。ご希望の方は下記アドレスまでご連絡ください。
|HSRE Core Fund GP, LLC|| |
|HSRE Social Infrastructure Fund GP, LLC|| |
|HSRE GP IX, LLC|| |
Harrison Street Real Estate Capital, LLC, acting in its capacity as a delegate of the following General Partners, shall make available the Form 20-2 and Form 21-3 (the “Materials”) to Japan public. Any person that wishes to receive a copy of the Materials, please kindly contact the following e-mail address:
|Name of General Partner operating under the Article 63 Exemption||Name of the Limited Partnership Fund|
|HSRE Core Fund GP, LLC|| |
|HSRE Social Infrastructure Fund GP, LLC|| |
|HSRE GP IX, LLC|| |
The Materials are provided to you for informational purposes only and does not constitute the provision of investment advice. In addition, the information contained in the Materials does not constitute an offer to sell nor a solicitation of any offer to buy and is not intended to be, and should not be construed as, an offer to sell nor a solicitation of an offer to buy any type of securities, financial products or other services offered by Harrison Street and its affiliates to any person in Japan to whom such offer would be unlawful under the applicable laws of Japan.