Privacy Policy

Thank you for visiting the website of Northwood Investors LLC and its affiliates (together, “Northwood,” “we” or “us”). 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 are subject to the following privacy policy (the “Privacy Policy”). By visiting this website or using our Investor Portal, 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 use the Investor Portal. If you do not agree with any provision of the Privacy Policy, you should not use the website or the Investor Portal.

We are committed to protecting the privacy of our website visitors. This Privacy Policy seeks to help you understand how we collect and process information about you when you visit our website and/or use the Investor Portal.

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; we address those practices in separate notices sent to our investors or potential 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, 23rd Floor, New York, NY 10017, Attn. Rich Jones.

HOW WE COLLECT, USE, AND SHARE YOUR PERSONAL INFORMATION

When you enter and browse the website and/or use the Investor Portal, we may collect two different types of information about you: information you provide to us and information we collect through technology. In order to obtain access to certain information or materials provided via the website or Investor Portal, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, postal address and e-mail address. We refer to such information as personal information. Additionally, we may collect and retain a record of all communications with you.

We will collect personal information from you if you voluntarily provide it through our website or Investor Portal, 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.
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; and (v) to comply with applicable laws, regulations, or codes of practice.

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.

We may share your non-personally identifiable information with 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 share your personal information with 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 share your personal information with affiliates and advisors of Northwood. These companies and individuals may have access to the personal information we collect from you through our website, 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 require that these companies and individuals otherwise keep this information confidential. Northwood reserves the right to transfer any and all information that we collect from users, or that we otherwise collect in connection with the website and/or Investor Portal, including, without limitation, to affiliates and third parties, in the event of any liquidation, dissolution, or merger or the sale or transfer of our assets and/or business or any portion of our assets and/or business. We will not otherwise share your personal information, except as required or permitted by law; requested by governmental entity or law enforcement authority, subpoena, court order, or discovery request; or when we otherwise believe in good faith that such disclosure is 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 can disclose any of your information in such circumstances.

PROTECTION OF INFORMATION

The security of your information is important to us. We employ several different technical, administrative, and physical security measures to protect any personal information you provide through our website from unauthorized access or use. 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

Northwood retains your personal information for as long as 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 operate the 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).

YOUR RIGHTS

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, 23rd 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.

INFORMATION REQUESTS

If you are a California resident, you have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

To exercise the rights described above, please submit a request to us by either:

Your request must:

  • Provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
  • Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.

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 share any personal information with third parties for their direct marketing purposes.

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.

Last updated June 2020.