This Privacy Notice sets out how Grosvenor Canada Limited (of 1040 West Georgia Street, 20th Floor; Vancouver, B.C. V6E-4H1 Canada) and Grosvenor USA Limited (of 1 California Street, Suite 2500; San Francisco, CA 94111 USA) (‘we’, ‘us’ and ‘our’) obtain, use and disclose personal information relating to its investors’ employees and representatives (‘you’).
What information do we process about you?
We may collect the following personal information about you:
- Prospective Investor intelligence: We collect contact details and preference information about the employees and representatives of corporate investors that may be interested in Grosvenor Americas products. This information may be obtained from word of mouth, events and/or from prospective investor search firms.
- Investor correspondence and documents: If you are an employee or other representative of a corporate investor in Grosvenor Americas products, we may collect information about you in the course of that corporate investor’s business relationship with us. This may include your business details, signature on documents, opinions and preferences and other information you choose to provide when communicating with us (such as leave details).
- Know Your Client checks: If you are or have been connected with an investor in Grosvenor Americas products (such as a director or owner), we may collect information about you when we carry out financial and legal compliance background checks on that investor. This may include:
- Name, date of birth, address, nationality
- Documents necessary to verify your identity (which may include government ID numbers e.g. social security number, passport number).
- Financial background and status
- Legal compliance background, which may include details of any public offices held by you or your close connections, criminal or civil legal proceedings relating to you and any adverse media relating to you.
- Information about you available from public sources, such as government registries, search engines and social media, and from background screening / search firms.
- Investor Portal: If you are an employee or other representative of an investor in Grosvenor Americas products, we may collect information about you when you create an account on our investment portal. This includes your:
- Name, email address, phone number, location and online social accounts.
- Employment details
- History of communications with you
- Investment and other marketing preferences
- Automatically collected information when you use the investor portal or receive communication from us (such as your device and browser information (including cookies) and access details (what you looked at and when).
Why do we process information about you?
We process your personal information for the following purposes:
- managing and administering our investor agreements, including using your contact details to communicate information relating to your organisation’s investments with Grosvenor Americas (including via the investor portal);
- carrying out standard Know Your Client background checks on our investors prior to entering into agreements (including sanctions, anti-money laundering, financial and credit checks);
- providing you with an investor portal to access information about your organisation’s investments with Grosvenor Americas, including verifying your login information, remembering your portal activity and preferences to personalise your experience if you return to the portal from the same computer or mobile device and taking reasonable steps to secure the portal and other users from misuse;
- complying with any applicable present or future law, rule, regulation, guidance or directive, and complying with any applicable industry or professional rules and regulations or any applicable voluntary codes;
- complying with demands or requests made by government and law enforcement authorities, and complying with court orders (or equivalent), or in connection with any litigation; and
- activities connected with any sale, merger, acquisition, disposal, reorganisation or similar change of our business.
Do we share your personal information?
We may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described above:
- other Grosvenor Estate entities so they may inform you about other Grosvenor Estate investments your organisation may be interested in (depending on your marketing preferences);
- our service providers, including third parties providing the investor portal, legal and financial advisors, managing agents, management surveyors, research and analytics providers, insurance brokers, debt recovery agents, hosting service providers and communications and marketing providers;
- government, regulators, law enforcement authorities, courts, tribunals and arbitrators, other judicial committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, financing, reorganisation or similar change to our business (including any potential or actual purchaser or that business and that purchaser’s advisors).
Retention of your personal information
We may hold your personal information for as long as we believe you are an employee or representative of an investor or prospective investor in Grosvenor Americas product. We may continue to hold your personal information for a longer period if required to do for legal, financial or audit purposes.
We (or third party processors on our behalf) may process your personal information in order to generate anonymous statistical information and we may use this for any purpose (including strategic business planning or management decisions).
We also generally allow our third party processors (such as those providing cloud services to us) to process your personal information to generate anonymous statistical information in order to improve their products and services.
Your rights (including under CCPA)
Privacy and data protection laws, including under the CCPA if you are a Californian resident, may provide you with certain rights in respect of our handling of your personal information, including:
- The right to know what personal information has been collected, where it is sourced from, what it is used for, whether it is being disclosed and sold, and to whom.
- The right to request access to, correction and deletion of your personal information (with certain exceptions, such as in order for us to: complete a business transaction with you, detect and protect against fraud or illegal activity, exercise our rights, or comply with our legal obligations).
- The right to “opt out” of the sale of your personal information to a third party or otherwise stop or restrict our processing (including transfers to third parties) of your personal information (particularly where unlawfully used or obtained).
- The right to receive equal service and pricing even if you exercise your rights under privacy and data protection law.
- We confirm that we do not sell your personal information to third parties, and only share aggregated information as described in this Privacy Notice.
If you wish to exercise any of these rights, or if you have a complaint about how we manage your personal information, please contact us using the details in the contact section below.
If you have any questions, comments or requests regarding any aspect of these privacy notices, please contact our Data Protection Officer by email at: dataprotectionGGL@grosvenor.com.