Cal­i­for­nia Pri­va­cy Notice

Pur­suant to the Cal­i­for­nia Con­sumer Pri­va­cy Act of 2018, as amend­ed by the Cal­i­for­nia Pri­va­cy Rights Act of 2020 (col­lec­tive­ly, the ​“CCPA”), Hines Pri­vate Wealth Solu­tions LLC (“Hines Pri­vate Wealth Solu­tions,” ​“we,” or ​“us”) is pro­vid­ing the fol­low­ing details regard­ing the cat­e­gories of Per­son­al Infor­ma­tion that we col­lect, use, and dis­close about Cal­i­for­nia res­i­dents. We are pro­vid­ing this Notice in addi­tion to the infor­ma­tion con­tained in our gen­er­al Pri­va­cy Pol­i­cy.

This Notice does not apply to our job appli­cants, employ­ees, con­trac­tors, own­ers, direc­tors, or offi­cers where the Per­son­al Infor­ma­tion we col­lect about those indi­vid­u­als relates to their cur­rent, for­mer, or poten­tial role at Hines Pri­vate Wealth Solu­tions. Under the CCPA, ​“Per­son­al Infor­ma­tion” is infor­ma­tion that iden­ti­fies, relates to, or could rea­son­ably be linked with a par­tic­u­lar Cal­i­for­nia res­i­dent or household. 

SOURCES OF PERSONAL INFORMATION

We col­lect this Per­son­al Infor­ma­tion from you, such as when you vis­it our web­site, reg­is­ter for an account, or under­take a trans­ac­tion with us, and from oth­er cat­e­gories of sources: enti­ties with which we do busi­ness that have a pre-exist­ing rela­tion­ship with you, joint mar­ket­ing part­ners, pub­lic data­bas­es, and social media platforms.

CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED

The fol­low­ing chart details which cat­e­gories of Per­son­al Infor­ma­tion about Cal­i­for­nia res­i­dents we col­lect, as well as which cat­e­gories of Per­son­al Infor­ma­tion we have col­lect­ed and dis­closed for our oper­a­tional busi­ness pur­pos­es in the pre­ced­ing 12 months.

USE OF PERSONAL INFORMATION 

We use this Per­son­al Infor­ma­tion to oper­ate, man­age, and main­tain our busi­ness, to pro­vide our prod­ucts and ser­vices, and to accom­plish our busi­ness pur­pos­es and objec­tives, includ­ing, for exam­ple, to: devel­op, improve, repair, and main­tain our prod­ucts and ser­vices; per­son­al­ize, adver­tise, and mar­ket our prod­ucts and ser­vices; con­duct research, ana­lyt­ics, and data analy­sis; main­tain our facil­i­ties and infra­struc­ture; under­take qual­i­ty and safe­ty assur­ance mea­sures; con­duct risk and secu­ri­ty con­trol and mon­i­tor­ing; detect and pre­vent fraud; per­form iden­ti­ty ver­i­fi­ca­tion; per­form account­ing, audit, and oth­er inter­nal func­tions, such as inter­nal inves­ti­ga­tions; com­ply with law, legal process, and inter­nal poli­cies; main­tain records; car­ry out cor­po­rate trans­ac­tions, such as merg­ers, joint ven­tures or acqui­si­tions; and exer­cise and defend legal claims.

We do not ​“sell” Per­son­al Infor­ma­tion (includ­ing Sen­si­tive Per­son­al Infor­ma­tion), and we do not ​“share” Per­son­al Infor­ma­tion (includ­ing Sen­si­tive Per­son­al Infor­ma­tion) for pur­pos­es of cross-con­text behav­ioral adver­tis­ing, as defined under the CCPA. We have not engaged in such activ­i­ties in the 12 months pre­ced­ing the date this Notice was last updat­ed. With­out lim­it­ing the fore­go­ing, we do not sell or share Per­son­al Infor­ma­tion (includ­ing Sen­si­tive Per­son­al Infor­ma­tion) of minors under 16 years of age.

PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

We col­lect, use, and dis­close Sen­si­tive Per­son­al Infor­ma­tion only as per­mit­ted under applic­a­ble law, for pur­pos­es of per­form­ing ser­vices for our busi­ness, pro­vid­ing goods or ser­vices as request­ed by you, ensur­ing secu­ri­ty and integri­ty, short term tran­sient use such as dis­play­ing first par­ty, non-per­son­al­ized adver­tis­ing, order pro­cess­ing and ful­fill­ment, ser­vic­ing accounts, pro­vid­ing cus­tomer ser­vice, ver­i­fy­ing cus­tomer infor­ma­tion, pro­cess­ing pay­ments, pro­vid­ing financ­ing, and activ­i­ties relat­ing to qual­i­ty and safe­ty con­trol or prod­uct improvement.

RETENTION PERIOD

We retain Per­son­al Infor­ma­tion for as long as need­ed or per­mit­ted to ful­fill the purpose(s) for which it was obtained, includ­ing to sat­is­fy any legal, com­pli­ance, account­ing, or report­ing require­ments, 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 prod­ucts and ser­vices to you, for exam­ple, for as long as you con­tin­ue to use our Web­site or oth­er services;
• Whether there is a legal oblig­a­tion to which we are sub­ject, for exam­ple, to keep records of your trans­ac­tions for a cer­tain peri­od of time; or
• Whether reten­tion is advis­able in light of our legal posi­tion, such as in regard to applic­a­ble statutes of lim­i­ta­tions, lit­i­ga­tion, or reg­u­la­to­ry investigations.

INDIVIDUAL RIGHTS AND REQUESTS

If you are a Cal­i­for­nia res­i­dent, you may request that we:

1. Dis­close to you the fol­low­ing information: 
   1. The cat­e­gories of Per­son­al Infor­ma­tion we col­lect­ed about you and the cat­e­gories of sources from which we col­lect­ed such Per­son­al Information; 
   2. The spe­cif­ic pieces of Per­son­al Infor­ma­tion we col­lect­ed about you; 
   3. The busi­ness or com­mer­cial pur­pose for col­lect­ing Per­son­al Infor­ma­tion about you; and 
   4. The cat­e­gories of Per­son­al Infor­ma­tion about you that we dis­closed, and the cat­e­gories of third par­ties to which we dis­closed such Per­son­al Information. 
2. Cor­rect inac­cu­ra­cies in your Per­son­al Information.
3. Delete Per­son­al Infor­ma­tion we col­lect­ed from you. 

To make a request for the dis­clo­sures, cor­rec­tion or dele­tion described above, please con­tact us at 888−220−6121 or privacypolicy@​hines.​com. We will ver­i­fy and respond to your request con­sis­tent with applic­a­ble law, tak­ing into account the type and sen­si­tiv­i­ty of the Per­son­al Infor­ma­tion sub­ject to the request. We may need to request addi­tion­al Per­son­al Infor­ma­tion from you, such as the last four dig­its of your Social Secu­ri­ty num­ber and your Hines account num­ber, in order to ver­i­fy your iden­ti­ty and pro­tect against fraud­u­lent requests. If you main­tain a pass­word-pro­tect­ed account with us, we may ver­i­fy your iden­ti­ty through our exist­ing authen­ti­ca­tion prac­tices for your account and require you to re-authen­ti­cate your­self before dis­clos­ing or delet­ing your Per­son­al Infor­ma­tion. If you make a dele­tion request, we may ask you to ver­i­fy your request before we delete your Per­son­al Information.

You have the right to be free from unlaw­ful dis­crim­i­na­tion for exer­cis­ing your rights under the CCPA.

AUTHORIZED AGENTS

If an agent would like to make a request on your behalf as per­mit­ted under applic­a­ble law, the agent may use the sub­mis­sion meth­ods not­ed in the sec­tion enti­tled ​“Indi­vid­ual Rights and Requests.” As part of our ver­i­fi­ca­tion process, we may request that the agent pro­vide, as applic­a­ble, proof con­cern­ing his or her sta­tus as an autho­rized agent. In addi­tion, we may require that you ver­i­fy your iden­ti­ty as described in the sec­tion enti­tled ​“Indi­vid­ual Rights and Requests” or con­firm that you pro­vid­ed the agent per­mis­sion to sub­mit the request.

CHANGES TO THIS NOTICE

We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new ​“Last Updat­ed” date.

CONTACT US

If you have any ques­tions regard­ing this Notice, please con­tact us at privacypolicy@​hines.​com.