Privacy Policy

Thank you for visiting the website of Northwood Investors LLC and its affiliates (together, “Northwood,” “we” or “us”). We are committed to protecting your privacy. Your visit to this website and use of our investor login portal available via the website (“Investor Portal”) and/or other ways that you may interact with us such as visiting our premises, applying for employment, and other communications with us such as email are subject to the following privacy policy (the “Privacy Policy”).

By visiting this website or our premises, using our Investor Portal, applying for a job with us and/or otherwise providing information to us such as via email, you acknowledge that your personal information will be processed in accordance with this Privacy Policy, which may be updated by us at any time. If we update our Privacy Policy, we will post the updated document here. Any such changes will be effective upon posting. We urge you to review the Privacy Policy each time you visit this website or our premises, use the Investor Portal, apply for a job with us and/or otherwise provide information to us such as via email. If you do not agree with any provision of the Privacy Policy, you should not use the website or the Investor Portal, visit our premises, apply for a job with us or otherwise provide information to us.

For the purposes of EU data protection laws, Northwood Investors LLC is the data controller (i.e., the company responsible for, and which controls the processing of, your personal information). Other than in relation to personal information processed through the Investor Portal, this Privacy Policy does not address our privacy practices concerning any personal information we collect concerning our investors or potential investors with respect to their participation as an investor in investment vehicles that we sponsor or manage or our employees and contractors; we address those practices in separate privacy notices sent to such individuals as required by applicable laws. Where applicable, Northwood complies with regulations adopted pursuant to the Gramm-Leach Bliley Act (“GLBA”), including privacy notice requirements distributed to natural person U.S. investors.

This Privacy Policy also does not apply to any other third-party website, including those that may be linked to in our website. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

If you have any questions or comments about this Privacy Policy, you can e-mail us at privacy@northwoodinvestors.com or write to us at Privacy Matters, Northwood Investors LLC, 575 Fifth Avenue, 40th Floor, New York, NY 10017, Attn. Rich Jones.

HOW WE COLLECT, USE, AND DISCLOSE YOUR PERSONAL INFORMATION

What Information We Collect

When you enter and browse this website, we may collect information from you in two different ways: information you provide to us and information we collect through use of technology. We may collect and process the following personal information about you in connection with your use of this website and the other ways that you may interact with us such as visiting our premises, applying for employment, and other communications with us such as email:

  • Identifiers such as name, postal address, e-mail address, telephone number other governmental identifications and contact information;
  • Internet or other network activity and technical information: for example, browsing or search history, information regarding your interaction with sites and related applications, IP addresses and online identifiers such as cookies;
  • Mailing list data such as marketing and communications preferences and interests;
  • Audio, electronic, visual or similar information, including photographs and CCTV footage;
  • Physical access data relating to details of your visits to our offices;
  • Sensitive personal information, such as social security number, driver’s license, passport and certain health information;
  • Commercial information and financial information;
  • Professional information: for example, employment details, education information, occupational history or business relationships; and
  • Other information you provide, or which may be incidentally processed, when you contact us.

We may also collect personal information from third party sources, which may include publicly available sources of information. Additionally, we may collect and retain a record of all communications with you, in accordance with applicable regulatory statutes.

In addition, in general, we automatically gather certain technical information from our website visitors through our automatic data collection tools, including server logs, which may collect certain standard information that your browser sends to the website such as the number and frequency of your visits. This information may include the URL of the last and next website you visit, your browser and operating system, your Internet Protocol (“IP”) address, how long you spend on our website, and what pages you view here. We may use this information on an aggregate basis to understand better how our visitors use our website; research our visitors’ demographics, interests, and behavior; improve our website; provide visitors with customized services and information; and for other similar purposes.

How Information is Used

We will collect personal information from you if you voluntarily provide it through our website or Investor Portal or otherwise, such as by providing your name, e-mail address, and other personal information to receive further information about us, and will use such personal information for the purpose of processing and responding to your inquiries and requests and to improve our website and offerings. You are under no obligation to provide any such information. However, if you choose to withhold requested information, we may not be able to provide you with certain services, permit you to visit our premises, or apply for employment with us.

The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to contact you and respond to your requests and enquiries; (ii) for business administration, including statistical analysis; (iii) to personalise your visit to the website and to assist you while you use the website; (iv) to improve the website by helping us understand who uses the website; (v) to maintain the security of our website, Investor Portal and premises; (vi) to screen and evaluate candidates for employment; (vii) to send you direct marketing in relation to our services and/or other activities such as events; and (v) to comply with applicable laws, regulations, or codes of practice.

We may disclose your non-personally identifiable information to others, such as investors, for informational or promotional purposes. Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data.

We may disclose your personal information to third-party service providers to facilitate our services and perform functions on our behalf, such as, without limitation, providing technical, analytical, and hosting functions for our website. We may also disclose your personal information to affiliates and advisors of Northwood. These entities and individuals may have access to the personal information we collect from you, as permitted by law and as needed to perform their functions in compliance with the privacy practices and policies of Northwood, but they may not use it for any other purpose. We typically require that these companies and individuals otherwise keep this information confidential. Northwood reserves the right to disclose and/or transfer any and all information that we collect from users, or that we otherwise collect in connection with the website, Investor Portal, job applications, our premises and/or other forms of communication with you, including, without limitation, to affiliates and third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares. We will not otherwise disclose your personal information, except as required or permitted by law; requested by governmental entity, regulatory authority or law enforcement authority, subpoena, court order, or discovery request; or when we otherwise believe in good faith that such disclosure is reasonably necessary or appropriate in connection with any activity that (potentially) violates the law or our internal policies and procedures (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability. We are permitted to disclose any of your personal information in such circumstances.

PROTECTION OF INFORMATION

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. The security of your information is important to us. We employ several different technical, administrative, and physical security measures designed to protect any personal information you provide through our website or otherwise from unauthorized access or use. Additionally, we restrict access to investor personal and account information to employees on a need to know basis. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. We will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with the disclosure of your personal information. You use our website and send us such information at your own risk.

RETENTION OF INFORMATION

For each of the categories of personal information collected, Northwood retains your personal information for as long as reasonably necessary to fulfill the purposes for which such personal information was collected and in compliance with applicable laws. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the website services and otherwise operate our business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual, or other obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes). We keep your personal information in accordance with the retention periods consistent with laws and regulatory obligations that apply to us. If you are an investor, we will usually delete your personal information after you cease to be an investor in our funds and there is no longer any legal/regulatory requirement or business purpose for retaining your personal information.

YOUR RIGHTS

Opt-Out

For Individuals in the EEA/UK: Your Right to Object – Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest.

Individuals in the EEA (“European Economic Area”)/UK have certain data subject rights that may be subject to other limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their personal information; (ii) obtain restriction of processing or to object to processing of their personal information; and (iii) data portability. Individuals in the EEA/UK also have the right to lodge a complaint about the processing of their personal information with their data protection authority.

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes concerning any personal information you provide us through this website, or if you are based in the EEA/UK and would like to exercise your data subject rights, you can e-mail us at privacy@northwoodinvestors.com or write to us at Privacy Matters, Northwood Investors LLC, 575 Fifth Avenue, 40th Floor, New York, NY 10017.

COOKIES

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently, as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our website, we may place a “cookie” or other online tracking device (e.g., Web beacons) in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and delivering content specific to your interests. The cookies we place may also collect information about your IP address or click stream data within our website (i.e., the actions taken in connection with the website). This information helps us improve the functionality of the website.

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies, and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.

We do not control any cookies, web beacons, or other similar devices that may be placed on our website by third parties.

Consent – Except where cookies are necessary for the operation of our website, we will obtain your consent before setting cookies (such as Google Analytics; please see below). You can give or withdraw your consent to our use of these cookies at any time by using the cookie banner preference centre on our website.

GOOGLE ANALYTICS

We use Google Analytics to collect information about your use of the website. Google Analytics collects information such as how often users visit the website, what pages users visit, and what other sites they visited prior to or after coming to the website. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. We use the information we get from Google Analytics only to improve the website.

DO NOT TRACK

We do not track visitors of our website over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

INTERNATIONAL USE

You are solely responsible for complying with all local laws, rules, and regulations regarding online conduct and website access. When you are located in the EEA/UK, personal information collected from you, including via the website and the Investor Portal, will be transferred to recipients (including Northwood) who are located in countries located outside the EEA/UK (including the United States, where this website is hosted) that do not provide a similar level of protection to that provided by countries in the EEA/UK. You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, that are located outside the EEA/UK. You can withdraw your consent at any time.

GOVERNING LAW AND FORUM

The laws of the State of New York govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the website or the Investor Portal shall be resolved solely in the state or federal courts located in New York City. You agree to waive trial by jury in any such action.

CALIFORNIA PRIVACY POLICY

This California Privacy Policy supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and all implementing regulations thereto (collectively, 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 in the Privacy Policy.

What does this California Privacy Policy apply to?

This California Privacy Policy applies solely to your interactions with us through our website, Investor Portal, visits to our premises, applying for a job with us and electronic communications. If you provide personal information to us through another means (e.g., as an employee or as an investor), you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we may have collected over the last twelve (12) months include the following:

  • Identifiers, such as name, contact details and address (including physical address, email address and IP address) or other government identifications;
  • Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including bank account numbers and other financial information;
  • Other customer records, such as telephone number and personal information provided;
  • Commercial information;
  • Professional or employment-related information;
  • Education information;
  • Sensitive personal information, such as social security number, driver’s license, passport and certain health information;n and
  • Internet or other electronic network activity information, such as information regarding your use of our website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.

For additional details about the personal information we may collect, please refer to the section titled “What Information We Collect” above.

We do not knowingly collect personal information from anyone under the age of 18.

How do we obtain your personal information?

We may collect and maintain your personal information from the following sources:

  • information from your communications with us in connection with this website, Investor Portal, your job application and/or otherwise provided by you, including information provided through online forms;
  • information from your visits to our premises; and
  • information captured on our website, Investor Portal or via your job application, including information captured electronically as a result of your use of same.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This may include information collected in an online or offline context.

How long do we retain your personal information?

For each of the categories of personal information that we collect (listed above), we retain such personal information only for as long as reasonably necessary to fulfill the purposes we collected it for, including for purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless a longer retention period is otherwise required by law.

How do we use your personal information?

We will use your personal information for one or more of the business purposes described in the section titled “How Information is Used” above.

We do not use any of your sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

To whom do we disclose your personal information?

We do not “sell” or “share” (as such terms are defined by the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we may have disclosed each of the categories of personal information we have collected to affiliates and service providers and as described in the section titled “What Information We Collect” above.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Correction Rights: You have the right to request that we correct inaccurate personal information about you.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use 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;
  • the categories of third parties to whom we disclose 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.

Non-Discrimination: 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 to you) a different level or quality of service.

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 on your behalf using any of the methods set forth in the “Contact us” section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

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 (e.g., the risk of responding to fraudulent or malicious requests), we may request further information or your Investor Portal access credentials, if applicable, to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf if 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, but in certain cases, additional time might be required (up to 90 days). If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

CALIFORNIA’S SHINE THE LIGHT LAW

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.

Please contact privacy@northwoodinvestors.com with any questions about our privacy policies.

Last updated May 10, 2024.