Privacy Policy

PRIVACY POLICY

Effective: 09/01/2001
Last Updated: 02/01/2024

Thanks for visiting our website. Hines Interests Limited Partnership, with headquarters in at Williams Tower, 2800 Post Oak Boulevard, Houston, Texas 77056-6118, USA, hereinafter referred to as “Hines” “we”, “our” or “us” is committed to the protection of your personal data. Our Privacy Policy extends to all personal data you provide you provide to Hines, or Hines obtains from you, or about you. This policy applies to the collection, use, disclosure and/or processing of personal data to which data protection and privacy laws apply.

In accordance with the applicable privacy law, your use of the website signifies your agreement to our Privacy Policy. If you do not agree to the terms of the Privacy Policy, please do not use the website. If you are a resident of California, please see the “California Privacy Rights and Supplemental California Privacy Notice” section further below.

Please be aware that we reserve the right to modify our Privacy Policy periodically. Any changes will be promptly posted on this page, and we may also provide notices on other pages of the Site to ensure you stay informed about the information we collect and how we utilize it at all times.

1. PERSONAL INFORMATION WE COLLECT

When we refer to “Personal Information” or “Personal data” we mean data that could identify you as an individual, whether on its own or in conjunction with other data. This includes all information classified as such under relevant privacy laws.

In some jurisdictions, Personal Information excludes publicly available data, as well as deidentified or pseudonymized information.

As you interact with our website and engage with our services, we may gather and handle the following personal data:

(i) Newsletter Registrations and Marketing Communications: As part of our marketing and communication data collection, we may gather your name, address, telephone number, and email address. Additionally, we’ll note your preferences concerning marketing communications from both our organization and third parties, as well as your favored communication channels. Should you provide explicit consent, we may send you marketing materials via email, mail, or SMS. You’ll always retain the option to unsubscribe from these communications at any time.

(ii) Voluntarily Provided Information: You may provide basic personal details (like name, position, company information, contact details) submitted for specific services, as well as any additional personal data you choose to share on our platform, such as employment and educational background, comments, or responses.

(iii) Contact Us Requests: For inquiries made through our contact channels, we may collect your name, email address, phone number, and service history with us, along with details of your specific requests. Depending on the nature of your inquiry, further personal data may be processed, as we gather pertinent information to ensure we address your needs effectively.

(iv) Cookies and Similar Technologies: 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.

(v) Cloud Security Services: For security purposes, we may process online personal data to prevent, identify, and contain security incidents.

(vi) Site Browsing Information: We may gather statistics on site visits, such as visitor numbers, popular pages, browser types, and referring domains, to optimize our website’s performance and user experience.

2. HOW WE USE YOUR PERSONAL DATA

Your personal data may be stored and processed by us in the following ways and for the following purposes:

(i) Continuous improvement: We use your data to constantly enhance the user-friendliness of our website and to safeguard against potential disruptions or cyber threats.

(ii) Addressing your requests: Your data helps us effectively respond to your inquiries or requests.

(iii) Malicious data analysis: We conduct analyses to detect and understand malicious data, safeguarding your IT systems.

(iv) Statistical monitoring: We monitor and analyze attacks on devices and systems, adapting our solutions to enhance device and system security.

(v) Feedback and support: Your input on Hines Products and Services guides us in providing timely and informative assistance.

(vi) Threat analysis: We conduct in-depth analyses to assess potential threats.

(vii) Understanding your needs: Your data enables us to comprehend your requirements and interests better.

(viii) Anonymization and reporting: We anonymize personal data to create aggregated reports, providing anonymized insights.

(ix) Enforcement and compliance: Your data may be used to enforce our terms and conditions and legal rights, as well as to assess compliance with applicable laws and internal policies.

(x) Compliance with regulations: We may process your data to comply with relevant laws, rules, and regulations, along with internal policies and procedures.

(xi) Marketing communications: With your consent, we may use your data to communicate marketing materials about our Products and Services, ensuring you receive relevant information.

(xii) Database administration: Your data is utilized for the administration and maintenance of databases storing personal information.

When we use personal data we make sure that the usage complies with applicable law. We take steps to make sure only authorized Hines team members and service providers who genuinely need access can see it. And of course, everyone who accesses your data has to keep it confidential.

3. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small pieces of data being placed on the hard drive of your device. With the help of cookies, we can store information for a certain period and identify your device for the purposes mentioned below. These periods may vary depending on the type of cookies. Some cookies will be stored only for the time you are visiting our website (session cookie) and are automatically deleted once you close your browser, others cookies will be stored for a longer period than your session (persistent cookies).

On this website, we also use technologies that function similarly to cookies such as local shared objects. These are small data files that enhance your web-browsing experience, for example, by allowing you to personalize the look of a website that you frequently visit.

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.

(i) Strictly Necessary Cookies: Strictly necessary cookies maintain website security, facilitate network management, ensure site functionality, and enhance accessibility. You have the option to disable strictly necessary cookies in your browser settings, although this may impact your website experience.

(ii) Functional or Preference Cookies: Preference cookies allow us to store specific user selections or preferences, leading to a more personalized website experience. These cookies are activated only with your consent.

(iii) Analytics: Statistical analytics gauge website performance and gather aggregated information on your site usage to optimize your digital experience. This method does not collect individual-level behavioral data.

(iv) Marketing/Tracking/Profiling Cookies: Marketing/tracking/profiling cookies, typically placed by advertising networks, deliver relevant content and assess campaign effectiveness. Information regarding website usage and visits may be shared with third-party organizations such as advertisers. These cookies are activated only with your consent.

(v) Conversational Cookies: Conversational cookies link conversations and interactions to a specific visitor on our website, particularly when engaging with our chatbot. Accepting these cookies is necessary for interacting with the chatbot on our websites.

Regarding your cookie preferences, please note that when you click “accept necessary cookies” on the cookie banner, only Analytics and Strictly Necessary cookies are placed on your device. These cookies don’t gather personal information.

The table below sets out the type of cookie used, what its purpose is, and how long it lasts.

4. SOCIAL MEDIA PLUG-INS

We place various social media buttons on our website in the form of a plug-in. Following are the social media buttons used:

-Facebook
-X
-Instagram

Please be aware that by visiting a website that integrates social media plugins, certain data (your current IP address, visited sites, the date and time the website etc.) is forwarded to these social media services even if you are not registered with these services. If you are already logged into the social media service when you click on the social media button, the social media service may also use this data to identify your username and possibly even your real name. We have no control over the extent, nature, and purpose of such data processing by the social media service. Please note that the social media service is perfectly capable of using this data to create pseudonymized and even individualized user profiles.

You can find further information about data protection regarding social platforms on the privacy policies provided by the social media platforms.

5. THIRD-PARTY LINKED SIDES

Our website contains links to other 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 collection, use or disclosure. We are not responsible for any information or content contained on such sites. Links to other websites are provided solely as a convenience. Your browsing, use and interaction on any other websites, including websites which have a link to the Platform, are subject to that website’s own rules and policies. Please review the privacy policy posted on any website that you may access through, or which links to the Platform.

Please note that if you provide information to us via a social media site or participate in a social media site linked to the Platform, you consent to our use of your information for any reason in accordance with this Privacy Policy as if it were submitted to us directly via the Platform.

6. PERSONAL DATA WE SHARE WITH THIRD PARTIES

In connection with one or more of the purposes outlined in the “How we use your personal data” section above, we could disclose Personal Data to:

(i) Other members of the Hines Group. We will take steps to ensure that access to personal data is restricted to authorized employees who have a lawful basis to access your personal data and only for the purposes described in this Privacy Policy.

(ii) Professional advisors and third parties that provide services to us (such as IT systems providers, platform providers, financial advisors, consultants (including lawyers and accountants), providers of marketing services where we are permitted to disclose your personal data to them, and in all cases such transfers will be under a legal basis as set out in Section 2 of this Privacy Policy and subject to appropriate safeguards including data processing agreements where required;

(iii) competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request); and

(iv) any central or local government department and other statutory or public bodies where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request).

7. INTERNATIONAL DATA TRANSFERS

As a global company, Hines may need to transfer your personal data out of the country or jurisdiction in which it was originally collected. You should be aware that these countries may not have similar data protection laws to the country in which your personal data was originally collected. In such cases, Hines will ensure that there are adequate safeguards in place to protect your personal data with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.

For transfer of personal data outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements, and Hines will take reasonable steps (for example through a contract with the overseas recipient) to ensure that the overseas recipient does not breach the applicable privacy laws in relation to the data.

You can obtain more details of the protection given to your Personal Information by contacting us as described in the Section 16 below.

If you object to your personal data being transferred or used in this manner, please do not register with or use the Site.

8. HOW WE PROTECT YOUR PERSONAL DATA

At Hines, we take your security seriously. We’ve put in place strong measures to keep your information safe and secure. This includes special protections for client files, tailored to the sensitivity of the information they contain. We also have controls in our computer systems to restrict access appropriately.

Only authorized Hines employees have physical access to areas where personal data is stored or processed. We make sure our team members are trained to follow all laws and regulations, especially when it comes to data protection. Access to sensitive information is limited to employees who really need it for their jobs and who are authorized to see it.

If you want more details about how we protect your personal data, just reach out to us as described in Section 14 below. And when you contact us about your file, we may ask for some personal data to make sure that only you or someone you’ve authorized can access your information.

9. HOW LONG WE KEEP YOUR PERSONAL DATA

We will hold your personal data for as long as is necessary to fulfill the purpose for which it was collected or to comply with applicable legal, regulatory or internal policy requirements.

10. MODIFICATION OF YOUR CHOICES AND PREFERENCES

If you don’t want to get marketing messages from us, no problem! You can opt out anytime by unsubscribing, sending us an email, or writing to us at the contact details listed in Section 15 below. If you receive an email from us about marketing stuff, just reply to that email and ask us not to send you any more marketing messages.

11. YOUR RIGHTS

Where applicable and under the conditions set forth under applicable data protection laws, you may have the following rights concerning the processing of your personal information: to access and rectify your personal data, as well as the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling related to such direct marketing, and, in certain cases, to object to the processing based on grounds relating to your particular situation. In addition, you have the right to request the restriction of the processing and the erasure of your personal data (right to be forgotten) as well as the right to data portability. When the processing of personal data is based on your consent, you have the right to withdraw your consent at any time.

You can exercise these rights by contacting us as described in Section15 below.

12. TERMS OF USE

Please take the time to read our Terms of Use. These terms govern our interactions as a legal contract, and we welcome and encourage the time you spend becoming familiar with these legal terms as much as we welcome the time you spend on our Site and your support of Hines.

13. PRIVACY POLICY FOR CHILDREN

This Site is not directed to children. We do not knowingly collect information from children under the age of consent required by applicable law in the jurisdiction you access the Site. If you are under the age required by applicable law, please do not provide any personal data to us. If we become aware that we have collected personal data from a child under the age required by applicable law, we will make commercially reasonable efforts to delete such information from our database.

14. CALIFORNIA PRIVACY RIGHTS AND SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”) requires us to provide additional privacy-related information to residents of California.

(i) CCPA Disclosures

Purpose	Data Categories	Sources of Information	Data Shared with partners for business purposes
Newsletter Registrations and Marketing Communications:	Name  Address Telephone number Email address Marketing communication preferences Consent for marketing materials via email, mail, or SMS	Website; Correspondence with Hines	Affiliated Companies of Hines  Service Providers Business Parties (if you consent) Governmental Authorities
Voluntarily Provided Information:	Basic personal details (name, position, company information, contact details) Additional personal data (employment and educational background, comments, responses)	Website; Correspondence with Hines	Affiliated Companies of Hines Service Providers Governmental Authorities
Contact Us Requests:	Name Email address Phone number Service history Specific request details	Website; Correspondence with Hines	Affiliated Companies of Hines  Service Providers Governmental Authorities
Cookies and Similar Technologies:	Device ID IP address Geolocalization data  Online identifier  Social media data	Website; Correspondence with Hines	Affiliated Companies of Hines  Service Providers Business Parties (if you consent) Governmental Authorities
Cloud Security Services:	IP address (if consented) Device ID Browser types Referring domains  Use of the site	Website; Correspondence with Hines	Affiliated Companies of Hines  Service Providers Governmental Authorities
Site Browsing Information:	IP address (if consented) Device ID Browser types Referring domains Use of the site	Website; Correspondence with Hines	Affiliated Companies of Hines Service Providers Governmental Authorities

We do not use or disclose your sensitive personal information for purposes other than those allowed under the CCPA, including Section 7027, subsection (m).

(ii) Is personal information sold or shared with third parties?
In the preceding 12 months we have not “sold” (as the term “sale” is defined in the CCPA) or “shared” (as the term “share” is defined in the CCPA) Personal Information.

This website is not directed to children. To our actual knowledge, we do not sell or share the Personal Information of consumers under 16 years of age. We do not knowingly collect information from children under the age of 13 on the website. 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 from our database.

(iii) What are your rights concerning your Personal Information?
Under the CCPA, you have the following rights:
• Right to Know. You have the right to know the Personal Information we have collected about you during the previous 12 months, including the categories of Personal Information and the specific pieces of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the purpose for collecting, selling, or sharing personal information, and the categories of third parties to whom we disclose Personal Information.

• Right to Delete. You have the right to delete or have your Personal Information deleted, subject to certain exceptions. If an exception prevents us from deleting your Personal Information, we will inform you at the time you make the request.

• Right to Correct Inaccuracies. You have the right to correct inaccurate Personal Information or request inaccurate Personal Information be corrected.

• Right to No Retaliation. You have the right to exercise the above rights free from retaliation, including we will not deny of goods or services, charge different prices where the difference is not related to the value of the Personal Information, or offer different level of quality of goods or services. Denial of services or change in service level due to exercise of your rights does not constitute retaliation.

To make a request regarding your rights, contact us by telephone at 888.928.6029 or by email at corporate.counsel@hines.com.

In order to verify your identity, we request that you provide your name and other data we may hold associated with your name. We may also request a copy of your driver’s license if we are unable to verify your information. In addition, we request that you provide an email address in order to contact you regarding your request.
We will respond to your request within the 45-day period required by applicable law. In the event we cannot respond to your request, we will notify you of the reasons for the delay and the extended period for response. If we determine that we cannot respond to your request for any reason, we will notify you of the reasons for taking no action and for any instructions as to how to appeal.

You may use an authorized agent to exercise your rights on your behalf. The authorized agent must provide us with proof of your written permission (for example, a power of attorney) that demonstrates authorization to submit a request on your behalf. An authorized agent must follow the process described above to make a request and must verify the agent’s own identity.

Further correspondence regarding questions, comments, or concerns should be made in writing to corporate.counsel@hines.com.

15. CHANGES IN PRIVACY POLICY

Hines reserves, in its sole discretion, the right to revise this Privacy Policy at any time by updating this posting.

16. MORE INFORMATION

If you have any questions about this Privacy Policy or wish to contact Hines in connection with any information contained in this Privacy Policy or to exercise the rights mentioned above, regardless of which country you may be writing from, please write to corporate.counsel@hines.com.