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Privacy Policy

Last update: 9th June 2021
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The Owner is sensitive to the confidentiality of your personal information and has created this Privacy Policy in order to demonstrate its commitment to online privacy.  The Privacy Policy applies to all information you provide through this website.  If you do not agree to the terms and conditions of this Privacy Policy, do not use the website. If the Privacy Policy is amended, changes will be posted on this page and notices may be placed on other pages of the web site, so that you may be aware of the information we collect and how we use it at all times. The Owner reserves, in its sole discretion, the right to revise this Privacy Policy at any time by updating this posting. This Privacy Policy is issued on behalf of CWTC Multi family ICAV (“We”, “Our”, “Us”, the “Owner”) [and any of its affiliates, investors, owners, advisers and agents, as relevant], so when we mention “we”, “our” or “us” we are referring to the relevant company that controls or processes your personal data.

The information we collect and how it is used

Cookies and Google Analytics 
As visitors browse the website, information is collected about the visit.  Cookies are used to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. This is conducted through Google Analytics which ensures that all data sent to them is anonymous. This means that no Personally Identifiable Information (for example, IP addresses, email addresses, names etc..) is shared. You can choose to have your computer warn you each time a cookie is being sent. You can do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
Contact Form and Correspondence 
If you choose to fill out and submit a contact form on our site and / or engage in correspondence with us, we may collect contact information (such as your name, phone number, e-mail address), professional information (such as your job title and name of organisation) and other content you may provide (such as your enquiry, comments and responses to questions). This will help us in answering any queries you may have and ensure that you receive information that is most relevant to you in future. Form entries are forwarded to appropriate internal contacts and stored in the Republic of Ireland.  These representatives may use this information to get in touch with you in connection with your queries and connected topics and issues, and otherwise may be used for the following purposes: 
  • operating, evaluating and improving our business;
  • anonymizing personal information and preparing and furnishing aggregated data reports showing anonymized information;
  • enforcing our Terms of Use or other legal rights;
  • as may be required by applicable laws and regulations or requested by a judicial process or governmental agency having or claiming jurisdiction; or 
  • such other reasons as may be notified to you at the time of collection.
The contact form contains an “opt-in” checkbox in relation to the use of information submitted as part of the form and in connection with all subsequent correspondence and by checking the box you acknowledge and agree to the use of information as set out in this Privacy Policy, and, if you unsubscribe from any direct marketing, a record of this so we ensure your preferences are respected How we obtain your personal data Data you give us voluntarily by visiting the Site, submitting an enquiry, signing up to a mailing list, interacting with us in person, email or telephone.   How we use this information We may use personal data we hold about you in different ways, as described below:
  • send you communications which you have requested and that may be of interest to you. These may include information about offers, promotions, prize draws and competitions; 
  • notify you of changes to our services or policies;
  • seek your views or comments on the services we provide;
  • ensure that content from our sites is presented in the most effective, responsive and compatible manner for you and for your computer or device;
  • respond to your requests for information and other communication or correspondence you may submit to us;
  • carry out our obligations arising from any contracts entered into between you and us;
  • to fulfil our legal and regulatory obligations, including establishing, exercising or defending legal claims or providing information as required by a court order.
  • to protect the safety and security of our Services, staff, systems, property or any person, including to investigate, prevent and minimise the effects of fraud and otherwise to protect our vital interests or the vital interests of others
  • improve our products and services that we provide to you;
  • carry out statistical analysis and market research;
  • allow you to participate in interactive features of our sites, when you choose to do so;
  • investigate any improper use of our products, services or the network; and
  • carry out activities necessary to the running of our business, including systems testing, network monitoring, staff training and quality control.
  • We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant purpose.
  • we may also use the information in other ways for which we provide specific notice at the time of collection.
Legal basis for Processing Personal Data In order to collect, process and share personal data for the purposes described in this Privacy Notice, we rely on a number of separate and overlapping legal bases, including where:
  • consistent with obtained consent, for example, where you have opted-in to receive our marketing information, we may use your information to send you news and newsletters, special offers, and promotions, or information we think may interest you;
  • necessary for the legitimate interests of us or of a third party, provided those interests are not overridden by your interests or rights;
  • necessary to comply with our legal obligations
  • We may process personal data on more than one lawful ground depending on the specific purpose for which we are using that data. We only use personal data for the purposes for which we collected it, unless we believe that we need to use that personal data for another reason that is compatible with the original purpose or as applicable law permits.

How we protect your information

The security and privacy of personal information is treated as an extremely serious matter and priority.  We have put in place various security procedures as set out in this Privacy Policy, which include (by way of example and without limitation) the following appropriate technical and organisational measures: 
  • The website uses an SSL certificate which both verifies our identity and secures the safe transmission of information between your browser and our server.
  • Daily malware scans are conducted to detect any malicious hacking attempts which may compromise the security of our site.
  • The site contains articles and information for your reference only. 
  • We do not ask for any financial (e.g. credit card or account numbers), health or other sensitive information. 
  • Strict internal policies and procedures apply in relation to the storage, access and disclosure of personal information.  

Transfer of information

In connection with one or more of the purposes outlined in this Privacy Policy, we may generally disclose details about you to: affiliates, owners / investors, professional advisors and third parties that provide services to us or any such parties (such as IT systems providers, platform providers, financial advisors, consultants (including lawyers and accountants), providers of HR and recruitment services and other goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them), intermediaries, brokers, and other individuals and entities that partner with us, competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where required to do so by applicable law or regulation at their request), and any central or local government department and other statutory or public bodies. There may be a need to transfer your personal data out of the country in which it was originally collected. For personal data collected in the European Economic Area (“EEA”), this may mean transfers outside the EEA. You should be aware that these countries may not have similar data protection laws to the EEA. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy (for example, without limitation, by putting in place standard contractual clauses, ensuring appropriate encryption or similar protections are in place, and ensuring adequacy of the processes and procedures in place at the data importer(s)). If you object to your personal information being transferred or used in this manner please do not register with or use the site.

How long we keep your personal information

Your personal information will be held on our systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.   

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Updating your details and contacting us

If any of the information that you have provided (through our contact form or otherwise) changes, for example if you change your e-mail address, name or payment details or if you wish to cancel your registration, please let us know the correct details by sending an e-mail to europe.dataprotection@hines.com. We welcome your views about our website and Privacy Policy. If you would like to contact us with any queries or comments please contact us at any of the below details:   Hines Real Estate Ireland Limited Third Floor, Central Quay, Riverside IV, Sir John Rogerson’s Quay, Dublin 2 D02 RR77 +353 1 7999900

Dublin.Information@hines.com

Your legal rights

Individuals within the European Union have additional rights in relation to your personal information. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law. In particular (without limitation), you may: 

  • object to the processing of your personal information;

  • request a copy of personal information we hold about you;

  • ask that we update the personal information we hold about you, or correct anything you think is incorrect or incomplete;

  • ask that we delete personal information that we hold about you, or restrict the way in which we use it; and 

  • withdraw consent to our processing of your personal information (to the extent such processing is based on consent).  

You may exercise any of your rights, or ask questions about our use of your personal information, by e-mailing or writing as provided in this Privacy Policy. You may also use these contact details if you wish to make a complaint to us relating to your privacy. If you are unhappy with the way we handled your personal information or any privacy query or request that you have raised with us, you also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.  Information about how to do this is available on the DPC website at https://www.dataprotection.ie.

Cookies

We use cookies and related technology on the Site. For more information about the cookies we use, please see [LINK TO COOKIES POLICY].

Do Not Track

We honour Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Privacy Policy for Children

This website is not directed to children. We do not knowingly collect information from children under the age of 13 on the site. If you are under the age of 13, please do not provide any personal information to us. If we become aware that we have collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. The latest version of this Privacy Policy is always accessible on our Site. If material changes are made to the Notice, a copy will be made available on request.