Privacy Policy

Rev. March 28, 2023

Privacy Notice

This notice (“Notice”) is provided by JLL Partners, LLC and JLL Partners FCH, Inc. (together “JLL”, “us” or “we”). This Notice is addressed to any natural person who is any of the following: an investor in any fund managed or advised by JLL (a “JLL Fund”), a member, partner, shareholder, beneficial owner, officer, director, or employee of JLL, including any prospective investor whose personal information JLL collects and controls in the conduct of its business.

This Notice gives information regarding our collection and use of your personal information and describes the basis on which we process your personal information, for what purposes, your privacy rights under applicable privacy laws including, where applicable, under the General Data Protection Regulation (“GDPR”) and other United Kingdom (UK) and European data privacy laws and applicable US privacy laws, (the “Privacy Laws”) and how we protect your personal information. For purpose of this Notice, “personal information” means any information that relates to you as an individual or that is otherwise defined as “personal information” or any similar term (e.g., “personal data,” “nonpublic personal information,” etc.) under the Privacy Laws. Maintaining your privacy is important to us and we hold ourselves to the highest standards in its safekeeping and use. We have developed policies designed to protect confidentiality, while allowing the needs of our investors to be served. For the purposes of the GDPR, JLL Partners, LLC will be the controller.

1. Personal Information We Collect

In the conduct of our business, we may obtain personal information about you in connection with JLL Funds, including without limitation your name, telephone number, gender, nationality, citizenship, date of birth, address and other contact details, social security number, tax or other identification number, identity documents, information provided by you in the context of carrying out background checks, and information about your income, assets and other financial and/or banking information. This information may come from subscription agreements, investor questionnaires or other forms that you (or your third party intermediary acting on your behalf) may submit to us, including information obtained from meetings and telephone conversations, as well as financial information relating to any such person’s investment in a JLL Fund or any portfolio investments, such as capital account balance, contributions, income allocations and distributions. We may also collect personal information from public sources, as well as via our website.

2. How We Use Your Personal Information

We collect and process your personal information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of JLL and/or third parties (such legitimate interests include those set out in this Notice) and for other purposes for which JLL has a lawful basis under the Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing; (ii) to verify the status and / or eligibility of JLL Funds; (iii) for compliance with tax reporting requirements; (iv) for purposes of reporting to or communicating with you in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Customer” requirements; and (v) in connection with litigation, investigations, regulatory or governmental enquiries, to establish, exercise or defend our rights, or for other legal or regulatory purposes involving JLL or JLL Funds.  We also collect and process your personal information when we have your consent to do so. Where we collect your personal information pursuant to a legal or contractual requirement, your failure to provide such information may impact our ability to fulfill our obligations. To the extent you provide us with your telephone number or otherwise communicate with us by telephone and/or via text messages, we may retain your telephone number and the content of such text messages, including any personal information contained therein, in order to comply our legal or regulatory obligations. We do not currently send marketing or promotional text messages and, to extent required, will endeavor to do so in compliance with applicable laws. We may use your telephone number to communicate purely administrative messages (e.g., support updates, technical notices, security alerts, and messages about changes to this Notice).

3. Disclosure of Your Personal Information

JLL and JLL Funds do not sell personal information to third parties or target advertising to individuals based on their personal information obtained from their online activity on nonaffiliated websites or applications (“cross-context behavioral advertising”).

Financial companies choose how they share nonpublic personal information, and federal law gives consumers the right to limit some but not all sharing.  Where necessary, we may share the categories of personal information described above with third parties including:

• Our affiliates (i.e., companies related to us by common ownership or control)
• Service providers. As is common in the industry, non-affiliated third party service providers (e.g., attorneys, auditors, accountants, tax advisers, custodians, depositaries, distribution managers and brokerage firms, event organizers or other agent, adviser or service provider of any JLL Fund) may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, account statements and other information, organizing events, conducting research on client satisfaction and gathering shareholder proxies. These third parties may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

• Other third parties including regulatory bodies and authorities, if required by law or regulation (including tax reporting requirements) or to exercise or defend legal rights.

We do not disclose personal information to third parties for joint marketing purposes. When you are no longer our customer, we may continue to share your information as described in this Notice. Where your personal information is transferred from the UK or European Economic Area (EEA) to be processed by third parties outside the UK and EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).

4. Safeguarding Your Personal Information

We take seriously the obligation to safeguard your non-public personal information. We maintain commercially reasonable and appropriate physical, electronic, and procedural safeguards to protect against unauthorized access to your information.  We endeavor to restrict access to personal information about you to those members, officers, employees and other workers of JLL and service providers who need access to that information. All of our employees and service providers are required to maintain the confidentiality of all personal information. Additional measures which we use include various computer safeguards, secured files, and access to our building.

5. Your Rights

To the extent provided by the law of your jurisdiction, you may have certain rights relating to the personal information we hold in accordance with and subject to the conditions and limitations set out in Privacy Laws, including to:

• refuse to provide any personal information and the right to object at any time to the processing of your personal information (please note that such refusal or objection may prevent us from providing services to you);
• confirm whether we process your personal information and obtain information regarding the processing of your personal information;
• access the personal information that we hold about you;
• request the correction of personal information about you that is inaccurate or incomplete;
• have a copy of the personal information we hold about you provided to you in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where technically feasible;
• request the deletion of your personal information;
• request the restriction of processing concerning you;
• withdraw your consent to processing your personal information if the processing is based on consent (though note that such withdrawal will not affect the lawfulness of the processing based on consent prior to the withdrawal);
• the right to limit our use of your Sensitive Personal Information to those uses which are necessary to perform our services or provide goods as reasonably expected (note that we already limit our use of your Sensitive Personal Information to such uses);
• non-discrimination against you for exercising your legal rights in relation to your personal information;
• lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed; and
• object to automated decision making and profiling and/or direct marketing.

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Notice and in accordance with applicable legal and regulatory requirements.

6. Contact Information

Please email IR@jllpartners.com  or call (212) 210-9390 if you have any questions about our Notice or wish to exercise any of the rights mentioned above in which case we shall consider such requests in accordance with Privacy Laws. You may also make a complaint, in accordance with applicable Privacy Laws to a supervisory authority in your jurisdiction. For example in the UK, the supervisory authority is the Information Commissioner’s Office.