Privacy Policy - JLL Partners

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.

Supplemental California Privacy Notice

Effective as of: May 9, 2023.

This privacy notice for California residents (this “CA Privacy Notice”) is provided in addition to any other privacy notice provided by JLL Partners, LLC and JLL Partners FCH, Inc. (together, “JLL”, “us” or “we”), including the JLL Website Privacy Policy, and explains JLL’s online and offline collection, use, and disclosure of Personal Information relating to residents of the State of California (“consumers”, “you” or “your”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, together with any applicable regulations (all together, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice.

This CA Privacy Notice is available in alternative formats upon request. Please contact IR@jllpartners.com or (212) 210-9390 to request this CA Privacy Notice in an alternative format.

This CA Privacy Notice is only relevant to you if you are a resident of California as defined under the CCPA. If you are an individual investor, our privacy practices with respect to your information are described in the JLL Investor Privacy Notice provided above.

1. OUR COLLECTION, USE, RETENTION, AND DISCLOSURE OF PERSONAL INFORMATION

a. Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising purposes.

b. Collection, Sources and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “lasted updated’ date of this CA Privacy Notice:

*Categories of Personal Information*	*Sources*	*Business Purposes*
“Identifiers,” including name, contact details (including address, telephone number, email address and Internet Protocol address), cookies, beacons, pixel tags, mobile ad identifiers and similar technology), and other online identifiers.
“Other records,” including signature, physical characteristics or description; bank account number, other financial information (including accounts and transactions with other institutions); driver’s license or other state ID card number, or passport number; medical information and health insurance information; and verification documentation (including social security number, tax status, income and assets).	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.
“Protected classifications” under California or federal law, including race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status.	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.
“Commercial information,” including your investment information, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies.	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.
“Online activity,” including your Internet and other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with websites, applications or advertisements).	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.
“Employment Information,” including your professional or employment-related information.	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.
“Other information” you create or provide to us, including the content of your communications with us.	Directly from you; from automated tracking technology and monitoring tools; from within JLL and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources.	Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction.

We do not knowingly collect or solicit any categories of Personal Information from any individual under the age of eighteen (18). We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, JLL will maintain and use such data without attempting to re-identify the data.

c. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. 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.

d. Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, or passport numbers; account credentials (including certain bank account information); precise geolocation; racial or ethnic origin; religious beliefs; biometric data; personal information concerning a consumer’s health or sex life or sexual orientation; as well as contents of a consumer’s mail, email and text messages. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business (i.e. customer service); (vii) to verify and maintain the quality and safety of product or services owned, manufactured, or controlled by JLL; and (viii) generally for purposes that do not infer characteristics about you.

e. Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “last updated’ date of this CA Privacy Notice:

*Business Purposes*	*Categories of Recipients*	*Categories of Personal Information*
Performing and providing the services that we offer.	Service providers, contractors, advisors and others who provide services to us or on our behalf (together, “service providers and contractors”); professional services organizations, such as auditors, tax advisors and law firms (together, “professional advisors”); prospective lenders to or creditors of an entity in which we have or are considering investing.	Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information.
Auditing and verifications, including but not limited to, verifying the quality and effectiveness of services and compliance.	Service providers and contractors; professional advisors; prospective lenders to or creditors of an entity in which we have or are considering investing.	Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information.
Short-term, transient uses.	Service providers and contractors.	Identifiers; Other records; Protected classifications; Commercial information; and Online activity.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.	Service providers and contractors; government entities, including regulatory agencies and law enforcement (together, “government entities”); and professional advisors.	Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information.
Debugging to identify and repair errors that impair existing intended functionality.	Service providers and contractors.	Identifiers; Other records; Online activity; Employment information; and Other information.
To comply with legal obligations such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations.	Government entities; counterparties and intermediaries; and professional advisors.	Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information.

In addition, JLL may disclose anonymous or aggregated data in order to facilitate our business operations.

2. YOUR CALIFORNIA PRIVACY RIGHTS

a. Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.

Know: You have the right to request, twice in a 12-month period, that we provide certain information about the (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting your Personal Information; and (iv) the categories of third parties with whom we have shared your Personal Information; and (v) that we disclose to you the specific pieces of Personal Information we have collected, used, and disclosed about you during the past 12 months.
Deletion: You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If JLL collects any sensitive personal information, it will use it only for purposes listed above in Section 1(d). As such, any sensitive personal data that we collect does not come within this right to limit use.
Opt-out: You have the right to request that we opt-out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes.
Non-Discrimination: You have the right to not to experience discriminatory treatment and we will not discriminate against you because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

b. How to Submit a Request. You may submit a request by using one of the following methods.

Call: 212-210-9390

Write to us: JLL Partners LLC, 300 Park Avenue, 18^th Floor, New York NY 10022

Attn: Johanna Doherty

Email us: IR@jllpartners.com

c. Verifying Your Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

Consumer Verification. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information to confirm your identity: contact information, such as telephone number, email, physical address and any other identifiable financial information, such as bank details and/or last capital call/distribution amounts. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.

Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (2) verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the request.

d. Additional California Privacy Disclosures

Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
Shine the Light Notice. California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.