Who we are
LaSalle Investment Management (“LaSalle”) is made up of different legal entities, details of which can be found here: https://www.lasalle.com/company. This Privacy Statement is issued on behalf each company in the LaSalle group, so when we refer to “LaSalle”, “we”, “us” or “our” in this document, we are referring to the relevant company in the LaSalle group of companies responsible for processing your data, as well as on behalf of certain real estate investment funds we sponsor and manage and whose respective websites link to this Privacy Statement . We will endeavour to let you know which entity will be the controller for your data when we collect personal information. LaSalle Investment Management, Inc. is the controller and responsible for this website.
Our commitment to privacy
We are sensitive to the privacy concerns of our individual limited partners and clients. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.
Sources of Non-Public Information
In connection with (i) forming and operating our private investment funds (or “funds”) for our limited partners, and (ii) managing our separate account mandates (“clients”, and collectively with limited partners “investors”), we collect and maintain non-public personal information from the following sources:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
- Information about your transactions with us or others;
- Public records;
- Third parties who assist with fraud prevention, detection, and mitigation;
- Third parties that provide access to information you make publicly available, such as social media platforms; and
- Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies when you visit or interact with our websites.”
Disclosure of Information
We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, third parties that assist with fraud prevention, detection and mitigation, third parties as necessary to complete transactions and provide our product and services, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We do not sell any of the personal information we collect about you to third parties.
We maintain non-public personal information of our former investors and apply the same policies that apply to current investors.
We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non-public personal information in our possession or under our control.
We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you.
PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the United States Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
Categories of Personal Information We Collect
We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
- Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number);
- Other customer records, such as telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets);
- Protected classification characteristics under California or federal law, such as date of birth, citizenship and birthplace;
- Commercial information, such as account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s);
- Internet or other electronic network activity information, such as information regarding your use of and time spent on our website, fund data room and investor reporting portal (e.g., cookies, browsing history referring/exiting URL and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries and other information regarding an individual’s interaction with an internet website, application, email or advertisement; and
- An individual’s written signature, such as a signature on a contract or lease document.
- Within the last twelve (12) months, we have shared each of the categories of personal information collected with affiliates and third-party service providers as set forth in “Disclosure of Information” in the Privacy Notice above, and we collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above.
Purposes for Collecting Personal Information
We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:
- determine product and service eligibility and coverage;
- providing services to you, including but not limited to, the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
- monitor, investigate and enforce compliance with our policies, product/service terms and conditions;
- advertising and product promotion, including to contact you regarding products, services, and topics that may be of interest to you; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
We do not sell any of the personal information we collect about you to third parties.
You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights
We may share your personal information with:
You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties with whom we share the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights
To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request using any of the methods set forth below.
Call us using the following toll-free number: 833-906-2120.
Email us at the following email address: email@example.com.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact Rochelle McAllister, Chief Compliance Officer of LaSalle Investment Management, Inc., at the email address above with any questions about this Privacy Notice.]
EU PRIVACY NOTICE
This Privacy Notice applies to the extent that EU Data Protection Legislation applies to the processing of personal data by an Authorized Entity (as defined below) or to the extent that a data subject is a resident of the UK, the European Union (“EU”) or the European Economic Area (“EEA”). If this Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below.
For this Privacy Notice, “EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including (without limitation): the Data Protection Directive (95/46/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, or any other legislation which implements any other current or future legal act of the European Union concerning the protection and processing of personal data (including Regulation (EU) 2016/679 (the General Data Protection Regulation) and any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing. The terms “data controller”, “data processor”, “data subject”, “personal data” and “processing” in this Privacy Notice shall be interpreted in accordance with the applicable EU Data Protection Legislation.
Please contact Rochelle McAllister, Chief Compliance Officer of LaSalle Investment Management, Inc., at Rochelle.firstname.lastname@example.org with any queries arising out of this Privacy Notice. Categories of personal data collected and lawful bases for processing
Categories of personal data collected and lawful bases for processing
In connection with (A) commencing and managing separate account mandates or (B) offering, forming and operating private investment funds for potential investors, the applicable fund, its general partner, the applicable Advisor, their affiliates and, in each case, their administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data either relating to potential investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects from the following sources (and all references to “potential investor(s)” in this Privacy Notice shall be to such potential investor(s) and, as applicable, any of these other persons as relate to such potential investor(s)):
- information received from you in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
- information about transactions with any Authorized Entity or others;
- information captured on any Authorized Entity’s website, fund data room and/or investor reporting portal (as applicable) including registration information and any information provided through online forms and any information captured via “cookies”; and
- information from available public sources, including from:
- publicly available and accessible directories and sources;
- bankruptcy registers;
- tax authorities, including those that are based outside the UK and the EEA if you are subject to tax in another jurisdiction;
- governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
- credit agencies; and
- fraud prevention and detection agencies and organizations.
Any Authorized Entity may process the following categories of personal data:
- name, date of birth and birthplace;
- contact details and professional addresses (including physical address, email address and telephone number);
- account data and other information contained in any document provided by potential investors to the Authorized Entities (whether directly or indirectly);
- information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history)
- risk tolerance, transaction history, investment experience and investment activity;
- information regarding a potential investor’s status under various laws and regulations, including their social security number, tax status, income and assets;
- accounts and transactions with other institutions;
- information regarding a potential investor’s interest in the applicable fund(s), including ownership percentage, capital investment, income and losses;
- information regarding a potential investor’s citizenship and location of residence;
- source of funds used to make the investment in the applicable fund(s); and
- anti-money laundering, identification (including passport and drivers’ license) and verification documentation.
Any Authorized Entity may, in certain circumstances, combine personal data it receives from a potential investor with information that it collects from, or about such potential investor. This will include information collected in an online or offline context.
One or more of the Authorized Entities are “data controllers” of personal data collected in connection with the applicable fund(s). In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from potential investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.
There is a need to process personal data for the purposes set out in this Privacy Notice as a matter of contractual necessity under or in connection with the applicable agreement of limited partnership or other governing agreement (the “Fund Agreement”) and associated documentation for the fund(s) in which the data subject has or may invest, and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest.
A failure to provide the personal data requested to fulfill the purposes described in this Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the terms of the Fund Agreement and/or the subscription agreement for such fund (the “Subscription Agreement”).
Purpose of processing
The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d) and (f), in the legitimate interests of the Authorized Entities):
a) The performance of obligations under the Partnership Agreement and/or the Subscription Agreement (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund.
b) The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the applicable fund.
c) Ongoing communication with potential investors, their representatives, advisors and agents, (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the applicable fund.
d) The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the applicable fund in accordance with the Partnership Agreement and other applicable documentation between the parties.
e) Any legal or regulatory requirement.
f) Keeping investors informed about the business of the general partner of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund.
g) Any other purpose that has been notified, or has been agreed, in writing. The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect their respective businesses and the security of their respective systems.
The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect their respective businesses and the security of their respective systems.
Sharing and transfers of personal data
In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by EU Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisers (where necessary or required by law).
Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Partnership Agreement, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact Rochelle McAllister, Chief Compliance Officer of LaSalle Investment Management, Inc., at Rochelle.email@example.com. For the purposes of this Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the European Economic Area; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU Data Protection Legislation to ensure an adequate level of protection for personal data.
Retention and security of personal data
The Advisors consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.
Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in a fund managed by an Advisor. However, some personal data will be retained after a data subject ceases to be an investor in such fund.
Data Subject Rights
It is acknowledged that, subject to applicable EU Data Protection Legislation, the data subjects to which personal data relates, have certain rights under EU Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this Privacy Notice, may result in the inability to provide the services required pursuant to the Subscription Agreement and the Partnership Agreement.
In case the data subject to whom personal data relate disagrees with the way in which their personal data is being processed in relation to the Subscription Agreement or the Partnership Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.
The data subject may raise any request relating to the processing of his or her personal data with Rochelle McAllister, Chief Compliance Officer of LaSalle Investment Management, Inc., at Rochelle.firstname.lastname@example.org.