Rev. June 1, 2021
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.
In the conduct of our business, we may obtain personal information about you in connection with JLL Funds, including without limitation your name, date of birth, address and other contact details, social security number, tax or other identification number, identity documents and information about your income, assets and other financial information. This information may come from subscription agreements, investor questionnaires or other forms that you 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.
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 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.
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 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).
We take seriously the obligation to safeguard your non-public personal information. We maintain 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.
You 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 to: (i) check whether we hold personal information about you and to access such data; (ii) request the correction of personal information about you that is inaccurate; (iii) have a copy of the personal information we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal information; (v) request the restriction of processing concerning you; (vi) 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); and (vii) 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.
Please email JLLAccounting@jllpartners.com 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.