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* © 2022 Starwood Capital Group
* Disclaimer and Legal Notices
Disclaimer
DISCLAIMER
Starwood Capital Group primarily serves as or controls, directly or indirectly,
the general partner or managing member of various investment vehicles that it
creates, sponsors and advises from time to time and through which various
investments are made (the “Starwood Funds”). All investment advice provided to
the funds regarding securities is provided by Starwood Capital Group Management,
LLC (“SCGM”). SCGM provides investment advice to the funds primarily regarding
investments in real property and privately-issued real estate securities. SCGM
is registered as an investment adviser with the SEC.
As used on this website, “Starwood Capital Group” or “Starwood Capital” refers
to entities that have previously or are currently serving as or controlling,
directly or indirectly, the general partner or managing member of the Starwood
Funds.
All non-U.S. offices listed are offices of Starwood Capital Group’s affiliates
and/or branch/advisory offices of such affiliates.
Mr. Barry Sternlicht, directly or indirectly, controls Starwood Capital Group
and SCGM.
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LEGAL/PRIVACY
Thank you for visiting Starwood Capital Group website. By using this website,
you agree to abide by the following terms and conditions. If you do not accept
these conditions, do not use this website. Starwood Capital Group may change
this Privacy Policy and User Agreement (Agreement) from time to time, based upon
any changes to our website and our users’ experience on it.
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STARWOOD CAPITAL GROUP PRIVACY AND COOKIE POLICY
INTRODUCTION
This privacy and cookie policy (“Policy”) describes how Starwood Capital Group
entities including our relevant local entities (“Company,” “we,” and “our”)
collects, uses and shares personal data. Please read the following information
carefully to understand our views and practices regarding your personal data and
how we will treat it.
Changes to this Policy: We will post any modifications or changes to the Policy
on our website www.starwoodcapital.com. We reserve the right to modify the
Policy at any time and the “Last Updated” legend above indicates when this
Policy was last changed.
1. PURPOSES OF PROCESSING
WHAT IS PERSONAL DATA?
We collect information about you in a range of forms, including personal data.
As used in this Policy, “personal data” is as defined in the European Data
Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any
successor legislation, this includes any information which, either alone or in
combination with other information we hold about you, identifies you as an
individual, including, for example, your name, postal address, email address and
telephone number.
WHY DO WE NEED YOUR PERSONAL DATA?
We will only process your personal data in accordance with applicable data
protection and privacy laws. We need certain personal data in order to manage
employment relationships and diligence our potential operating partners,
investors and business relationships.
2. COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Information You Give Us. This includes:
* Business and personal contact information (such as name, postal and email
addresses and telephone numbers); and
* Other information you submit to us (such as filling in forms or in general
correspondence with us).
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making.
However, we may do so in order to fulfil obligations imposed by law, in which
case we will inform you of any such processing and provide you with an
opportunity to object.
3. COOKIES
WHAT ARE COOKIES?
We may collect personal information using “cookies.” Cookies are small data
files stored on the hard drive of your computer or mobile device by a website.
We may use both session cookies (which expire once you close your web browser)
and persistent cookies (which stay on your computer or mobile device until you
delete them) to provide you with a more personal and interactive experience on
our Website.
We use two broad categories of cookies: (1) first party cookies, served directly
by us to your computer or mobile device, which are used only by us to recognize
your computer or mobile device when it revisits our Website; and (2) third party
cookies, which are served by service providers on our Website, and can be used
by such service providers to recognize your computer or mobile device when it
visits other websites.
COOKIES WE USE
Our Website may use the following types of cookies for the purposes set out
below:
Type of cookie Purpose Essential Cookies These cookies are essential to provide
you with services available through our Website and to enable you to use some of
its features. Without these cookies, the services that you have asked for cannot
be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our Website to remember choices you
make when you use our Website. The purpose of these cookies is to provide you
with a more personal experience and to avoid you having to re-enter your
preferences every time you visit our Website. Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Website and
how users use our Website. The information gathered does not identify any
individual visitor.
We use Google Analytics for this purpose. Google Analytics uses its own cookies.
It is only used to improve how our Website works. You can find out more
information about Google Analytics cookies
here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data
here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Website
by downloading and installing the browser plugin available via this
link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
DISABLING COOKIES
You can typically remove or reject cookies via your browser settings. In order
to do this, follow the instructions provided by your browser (usually located
within the “settings,” “help” “tools” or “edit” facility). Many browsers are
set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been
set on your computer or mobile device and how to manage and delete them,
visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your
use of our Website.
Some Internet browsers may be configured to send “Do Not Track” signals to the
online services that you visit. We currently do not respond to do not track
signals. To find out more about “Do Not Track,” please
visit http://www.allaboutdnt.com.
4. USING YOUR PERSONAL DATA
We may use the information described above for the following purposes to:
* operate, evaluate and improve our business (including developing new products
and services; enhancing, improving and analysing our products and services;
managing our communications; and performing accounting, auditing and other
internal functions);
* create and manage your account;
* manage your investments;
* comply with and enforce applicable legal requirements, relevant industry
standards and our policies;
* protect against, identify and prevent fraud and other unlawful activity;
* in some cases, in order to operate, administer and improve the user’s
experience of the Website;
* with your consent, to send you promotional materials, newsletters and
communicate with you about, and administer your participation in, special
events, programs, promotions, offers, surveys and market research. You may
opt-out of receiving such information at any time: such marketing emails tell
you how to “opt-out.” Please note, even if you opt out of receiving marketing
emails, we may still send you non-marketing emails. Non-marketing emails
include emails about your account with us (if you have one) and our business
dealings with you;
* provide our products and services to you, such as market commentary and email
alerts;
* respond to your inquiries;
* verify your information; and
* perform data analyses (including market and consumer research, demographic
analyses and anonymization and aggregation of information).
We also may use the information in other ways for which we provide specific
notice at the time of collection.
We will only process your personal data as necessary so that we can pursue the
purposes described above. Where we process your Personal Data for our legitimate
interests as a business, we do so only where we have concluded that our
processing does not prejudice you or your privacy in a way that would override
our legitimate interest in pursuing those purposes.
When we collect personal data from you, unless indicated otherwise, you should
assume that, if we ask you for information, we need it for our business or
compliance purposes. In limited circumstances, we are required to collect
personal data to comply with a legal obligation and/or might ask you to provide
information which is purely voluntary; in either case, this will be indicated to
you.
5. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
* Third Parties Designated by You. We may share your personal data with third
parties where you have provided your consent to do so.
* Our Third Party Service Providers. We may share your personal data with our
third party service providers who provide services such as data analysis,
information technology and related infrastructure provision, customer service
and email delivery, auditing and other similar services.
* Affiliates. We may share some or all of your personal data with our
affiliates, in which case we will require our affiliates to comply with this
Policy. In particular, you may let us share personal data with our affiliates
where you wish to receive marketing communications from them.
* Other Disclosures. We may share personal data as we believe necessary or
appropriate: (a) to comply with applicable laws; (b) in the event that we are
subject to mergers, acquisitions, joint ventures, sales of assets,
reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or
other types of business transactions; (c) to comply with lawful requests and
legal process, including to respond to requests from public and government
authorities to meet national security or law enforcement requirements; (d) to
enforce our Policy; and (e) to protect our rights, privacy, safety or
property, and/or that of you or others.
6. INTERNATIONAL DATA TRANSFERS
Your information, including personal data that we collect from you, may be
transferred to, stored at and processed by us and our affiliates and other third
parties outside the country in which you reside, including, but not limited to
the United States, where data protection and privacy regulations may not offer
the same level of protection as in other parts of the world. Any transfer of
your personal data shall take place only in accordance with and as permitted by
data protection legislation and we will take all steps reasonably necessary to
ensure that your data is treated securely and in accordance with this Policy.
7. SECURITY
We seek to use reasonable organizational, technical and administrative measures
to protect personal data within our organization. Unfortunately, no transmission
or storage system can be guaranteed to be completely secure, and transmission of
information via the internet is not completely secure. If you have reason to
believe that your interaction with us is no longer secure (for example, if you
feel that the security of any account you might have with us has been
compromised), please immediately notify us of the problem by contacting us using
the details in Section 11 below.
8. RETENTION
We intend to keep your personal data accurate and up-to-date. We will delete the
information that we hold about you when we no longer need it.
We will retain your information in line with our retention policies or as
required by applicable law and, in any event, for no longer than is necessary
given the purpose for which it was collected, after which it will be deleted or
anonymized.
9. DO NOT TRACK
Because there currently is not an industry or legal standard for recognizing or
honoring Do Not Track (“DNT”) signals, we do not respond to them at this time.
10. LOCATION OF OUR SITE
Our website is hosted and operated in the United States. However, we and our
service providers may store information about individuals in the United States,
or we may transfer it to, and store it within, other countries.
Visitors from jurisdictions outside the United States visit us at their own
choice and risk.
If you are not a resident of the United States, you acknowledge and agree that
we may collect and use your personal information outside your home jurisdiction,
and that we may store your personal information in the United States or
elsewhere. Please note that the level of legal protection provided in the United
States from which you may access our Sites may not be as stringent as that under
privacy standards or the privacy laws of other countries, possibly including
your home jurisdiction.
11. YOUR CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, individuals who reside in
California and who have an existing business relationship with us may request
information about our disclosure of certain categories of personal information
to third parties for the third parties’ direct marketing purposes, if any.
To make such a request, send an email with the subject heading “California
Privacy Rights” to dataprivacy@starwood.com. In your request, please attest to
the fact that you are a California resident and provide a current California
address for our response. Please be aware that not all information sharing is
covered by these California privacy rights requirements and only information on
covered sharing will be included in our response. This request may be made no
more than once per calendar year.
Pursuant to applicable California law, including the California Consumer Privacy
Act (CCPA), Starwood makes the following disclosures regarding the personal
information it has collected within the last 12 months:
Category of Personal Information Category of Source from Which Data is Collected
Purpose of Collection Category of Third Parties to Whom Data is Disclosed
Contact information such as name, postal and email addresses and telephone
numbers Directly from user To create and manage your account and investments
Service Providers Date of birth, Social Security number, citizenship status
Directly from user Entity management Service Providers Automatically-collected
information, such as your location; IP address; device type; browser type;
operating system or platform; name of Internet Service Provider; referring
website; exiting website; pages visited on our website; frequency, time, data,
and duration of your visit on our website; whether you open emails from us;
links you click on in our emails and on our website, including ads; whether you
access our website from multiple devices; other interaction you may have on our
website; Device Unique Device Identifier (e.g., Unique Device Identifier (UDID)
or International Mobile Equipment Identity (IMEI)); mobile device MAC or IP
address; information about your mobile device’s operating system; information
about your mobile carrier Cookies and other tracking technologies To perform
data analyses to improve our business N/A
Starwood has not sold consumers’ personal information in the twelve (12) months
preceding the Effective Date of this Privacy Policy.
If you are a California resident, pursuant to the CCPA, you have the right to
request:
* the categories of personal information Starwood has collected about you;
* the categories of sources from which your personal information is collected;
* the business or commercial purpose of collecting or selling your personal
information;
* the categories of third parties with whom Starwood shares your personal
information;
* the specific pieces of personal information Starwood has collected about you;
* the categories of personal information that Starwood has sold about you and
the categories of third parties to whom the personal information was sold, if
applicable;
* deletion of your personal information; and
* an opt out of having your personal information disclosed or sold to third
parties.
To submit a request, or designate an authorized agent to make a request under
the CCPA on your behalf, please contact us at dataprivacy@starwood.com,
844-979-1459, or complete the web form. To verify your identity when you submit
a request, we will match the identifying information you provide us to the
personal information we have about you.
However, Starwood will not be required to comply with your request to delete
your information if it is necessary for Starwood to maintain your personal
information in order to:
* complete the transaction for which the personal information was collected,
provide a good or service requested by you, or reasonably anticipated within
the context of Starwood’s ongoing business relationship with you, or
otherwise perform a contract between you and Starwood;
* detect security incidents, protect against malicious, deceptive, fraudulent,
or illegal activity; or prosecute those responsible for that activity;
* debug to identify and repair errors that impair existing intended
functionality;
* exercise free speech, ensure the right of another consumer to exercise his or
her right of free speech, or exercise another right provided for by law;
* comply with the California Electronic Communications Privacy Act pursuant to
Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal
Code;
* engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics
and privacy laws, when Starwood’s deletion of the information is likely to
render impossible or seriously impair the achievement of such research, if
you have provided informed consent;
* to enable solely internal uses that are reasonably aligned with your
expectations based on your relationship with the Starwood;
* comply with a legal obligation; or
* otherwise use your personal information, internally, in a lawful manner that
is compatible with the context in which you provided the information.
Starwood will not discriminate against you in the event you exercise any of the
aforementioned rights under CCPA, including, but not limited to, by:
* denying goods or services to you;
* charging different prices or rates for goods or services, including through
the use of discounts or other benefits or imposing penalties;
* providing a different level or quality of goods or services to you; or
* suggesting that you will receive a different price or rate for goods or
services or a different level or quality of goods or services.
This policy is available to consumers with disabilities. To access this policy
in an alternative downloadable format, please click here.
12. CHILDREN
Our website is not intended for children under 13 years of age. No one under age
13 may provide any information to or on our website. We do not knowingly collect
personal information from children under 13. If you are under 13, do not use or
provide any information on our website or on or through any of its features. If
we learn we have collected or received personal information from a child under
13 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 13, please
contact us at dataprivacy@starwood.com.
13. COMPLAINTS
We are committed to resolve any complaints about our collection or use of your
personal data. If you would like to make a complaint regarding this Policy or
our practices in relation to your personal data, please contact us
at: dataprivacy@starwood.com. We will reply to your complaint as soon as we can
and in any event, within 45 days. We hope to resolve any complaint brought to
our attention, however if you feel that your complaint has not been adequately
resolved, you reserve the right to contact your local data protection
supervisory authority, which for the UK, is the Information Commissioner’s
Office.
14. CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us in
writing at dataprivacy@starwood.com.
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CCPA REQUEST FOR INFORMATION
* Name*
First Last
* Email*
Enter Email Confirm Email
* State of Residence*
California
* Type of Request*
AccessDeletion
* Attachment
Max. file size: 2 MB.
* Authorization*
* I affirm that I am making this request with respect to my own information.
* I affirm that I am making this request on behalf of another individual,
and that I have obtained that individual’s legal authorization to make
this request.
* Acknowledgement*
* I understand that additional information may be required to process the
request, including information to verify identity or to clarify the
request, and that failure to provide this information may result in our
inability to fulfill the request.
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