Notices, Policies and Disclaimers
Statements of notices, policies, disclaimers and regulatory disclosures.
Effective Date: April 30, 2021
Harrison Street Real Estate Capital, LLC, and its affiliates, including registered investment advisers, and investment vehicles sponsored or managed by Harrison Street Real Estate Capital, LLC (collectively, “Harrison Street“) provides this Policy in order to describe how we collect, use and protect information that relates to any identified or identifiable person (“personal information”, or “personal data”). This Policy describes your rights in relation to applicable privacy laws including, United States federal and state laws, the UK and EU General Data Protection Regulation (“GDPR”), and the Data Protection Law, 2017 of the Cayman Islands (the “DPL”) as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto.
The “Additional Information under GDPR and DPL” section of this Policy sets out additional information if you are working with our UK office, or are a UK or EEA resident, or if the DPL applies.
For persons outside the UK or EEA, or persons transacting with Harrison Street entities outside the UK or EEA: By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy will be handled in accordance with this Policy.
We are present in the UK through our subsidiary and some of our investment funds. We are present in the Cayman Islands through some of our investment funds.
If the DPL applies, the relevant fund will be characterized under the DPL as a ‘data controller’, while certain of the fund’s service providers, affiliates and delegates may act as ‘data processors’ under the DPL.
If you are a nominee investor or a corporate entity, this notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.
The personal information we collect about you
We collect and use the following personal information:
- Contact information: name, address, and other contact information provided to Harrison Street in the course of its business;
- Business information: data identifying you in relation to transactions with us, in particular as provided in subscription agreements and other investment documents;
- Information necessary to comply with Harrison Street regulatory and reporting obligations: in particular, data necessary to comply with the relevant anti-money laundering laws, sanction screening and regulatory checks related to individual investors and individuals holding at least 10 percent of the equity interest in a legal entity you use to invest with Harrison Street (including name, address, Social Security Number, and date of birth); for a copy of the Harrison Street Anti‐Money Laundering and Counter‐Terrorism Financing Policy, please contact us at the contact information provided below;
- Information in connection with investigations or proceedings: where this is necessary to conduct an investigation or proceeding;
- Attendance records: to record your attendance at our offices for security purposes;
- Supplier data: contact details and other information about you or your company or organization where you provide services to Harrison Street;
- Subscriptions/marketing: when you subscribe to receive information on investment opportunities, our updates or newsletters;
- Events data: attendance at and provision of feedback forms in relation to our events;
- Technical information: when you access this website and our technology services, certain information may be captured, including IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug-in types and versions, the operating system you are using (e.g. Vista, Windows XP, MacOS, etc.), device type, hardware model, unique identifiers and mobile network information;
- Online data: when you access this website and our technology services, information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails; Harrison Street does not collect personal data about your online activities across third party websites or online services;
- Special categories of personal data: such as dietary, disability or similar requirements for events and meetings. If you do not provide this information, we may not be able to respond to your needs or preferences;
- Social media: posts, likes, tweets and other interactions with our social media presence;
- Criminal record data: where permitted by national law and appropriate to do so, such as existence of prior criminal offences (or confirmation of clean criminal record).
The above data will be provided to us by you, your employer, the company or organization who is our client or screening providers who assist us with our legal obligations, in particular to conduct anti−money laundering, sanctions screening and regulatory checks. We may also collect personal data from publicly available sources.
Why we use your personal information; legal bases
We process personal information when we have a specific justification (“legal basis”) for doing so:
- Legal Obligation legal basis – Processing is necessary to comply with UK or EEA legal or regulatory obligations: for example, anti-money laundering, mandatory client screening checks, disclosure to law enforcement, and complying with court orders.
- Contract Performance legal basis – Processing is necessary to perform a contract with you or take pre-contractual steps at your request: forexample, contacting you to confirm payment instructions or providing information about potential investments.
- Legitimate Interests legal basis – Processing is necessary for our legitimate interests or those of a third party provided any interests or rights that you have as an individual do not override our rights.
- Vital Interests legal basis – Processing is necessary to protect the vital interest of an individual.
We use your personal information for the following purposes and legal bases:
- Contract Performance – Everyday business: maintaining your account within a Harrison Street-sponsored fund or with an affiliated registered investment adviser, managing and running transactions with you, your company or an otherwise affiliated entity;
- Contract Performance – Business relationship: managing and administering our relationship with you, your company or organization including keeping records about business contacts, services and payments; enforcing payment and other obligations;
- Legal Obligations – UK Regulatory and compliance: compliance with our UK legal and regulatory obligations as a real estate private equity firm including auditing and reporting requirements, due diligence (under anti−money laundering, sanctions screening and other crime prevention and detection laws and regulatory requirements), which may involve automated screening checks to ensure that clients and contacts are genuine, and to prevent fraud or crime; we may not be able to provide our services if you do not provide the information we need to do these checks; complying with the law, a judicial proceeding, court order, or other legal process; exercising, establishing and defending legal claims;
Where we carry out these activities to comply with US laws and regulations, our legal basis is our Legitimate Interest in protecting our assets and our reputation by conducting our business in compliance with applicable laws.
- Contract Performance – Events: running briefings, roundtables and other events;
- Contract Performance – Managing suppliers: who deliver services to us;
- Legitimate Interest in improving our performance and promoting our business to grow our revenues – Analytics and Marketing; Communications: sending emails, newsletters and other messages to keep you informed of investment opportunities, recent developments, market insights and of our offerings; identifying what our clients want and developing our relationship with you, your company or organization; understanding how visitors use our websites; analyzing and improving our communications, services and offerings; introducing investment opportunities, managing inquiries and feedback; receiving information from other Harrison Street entities; developing relationships with business partners;
- Legitimate Interest in protecting our employees and clients, or Vital Interests where vital interests of clients, staff or other persons are at stake – Site security and emergency management: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings) and to manage emergencies;
- Legitimate Interest in ensuring the effectiveness of our website – Website monitoring: to check the website and our other technology services are being used appropriately and to optimize their functionality;
- Legitimate Interest in protecting our assets – Online security: protecting our information assets and technology platforms from unauthorized access or usage and to monitor for malware and other security threats;
- Legitimate Interest in protecting our assets – Enforcing rights: investigating, preventing, or taking action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved;
- Legitimate Interest in operating our business efficiently – Business Reorganization: sharing data in connection with investments, acquisitions, divestitures and transfers of a business or assets; participating in a bankruptcy or liquidation or similar proceeding;
- Consent – Any other specific purpose: any other specific purpose where you have otherwise consented to the processing of your personal information, such as to receive marketing messages.
We will only use your personal data for the purposes for which we collected it, as set out in this Policy and, if applicable, in Fund documents. If we need to use your personal data for an unrelated purpose, we will contact you.
With whom do we share your personal data?
We share only that personal information that we are permitted by law to share and will only share such information in a manner that complies with applicable law, including GDPR and the DPL, and U.S. data protection laws where applicable.
We share your information with others as follows:
- Harrison Street affiliates: including their management, staff and contractors;
- Suppliers: who support our business including IT and communication suppliers, outsourced business support, advisors and consultants, law firms, and back up suppliers. Our suppliers must meet minimum standards as to information security and they will only be provided data in line with their function and on a “need to know” basis;
- Screening service providers: so that we can comply with legal obligations in relation to the prevention of crime, anti-money laundering, sanctions screening and other required checks;
- Service providers: we disclose the information we collect from you to service providers, contractors or agents who may perform operational or IT functions on our behalf (e.g., cloud storage providers);
- Website users: if you post to our Site, including, without limitation, reviews, comments, and text, your username and content may be available to other users of the Sites and Services.
We also disclose information in the following circumstances:
- Business Transfers: if (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
- In Response to Legal Process: we disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others: we disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved.
- Other Appropriate Parties: in the event of an emergency or to protect the health and safety of our clients, staff and organizations (e.g., first responders, public safety).
To protect your personal information, we maintain physical, electronic and procedural safeguards designed to comply with the applicable laws. We train our employees in the proper handling of personal data.
How long do we keep your data?
We generally keep your information as needed to securely render our business, close transactions and to deal with claims. This will depend on several factors such as whether you or your company or organization are an existing client or have interacted with recent client mailings or bulletins or attended recent events. We will retain your information as necessary to comply with legal, accounting or regulatory requirements. We will not retain your personal information for longer than is necessary for the purposes explained above.
With your consent, when required by applicable law, we may use the information you give us for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of investment opportunities, recent developments, market insights and of our services including events that we think may interest you.
You can opt-out of receiving direct marketing from us at any time. You can do this by contacting us at the contact details provided below or clicking the unsubscribe link in any email we send you.
We do not intend to or knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you may not submit any personal data to us. If we discover that a child under 18 has provided us with personal information, we will delete such information from our systems.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.
Third-Party Ad Networks
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
If you are in Europe and would like to learn more about how advertisers use these cookies or to choose not to receive them, please visit http://www.youronlinechoices.eu.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Application, or by contacting you if we have your contact information.
How to Contact Us
If you would like more information about the way we manage personal data that we hold about you, please contact us:
Harrison Street Real Estate Capital, LLC
444 West Lake Street, Suite 2100
Chicago, IL 60606 USA
For European Union:
Harrison Street Real Estate Capital, Ltd.
20 St. James’s Street
London SW1A 1ES
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us as directed above.
Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at: firstname.lastname@example.org and include in your request a current California address and your attestation that you are a California resident.
Additional Information under GDPR and DPL
If you are working with our UK office or are a UK or EEA resident or if the DPL applies, you may have certain rights in relation to your personal data. The availability of these rights and the ways in which you can use them are set out below in more detail.
Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at the contact details here.
- Information: you are entitled to be informed as to how we collect and use your personal data;
- Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it unless prevented by applicable regulation (e.g., on professional secrecy), or if it would adversely affect rights and freedoms of others (e.g., Intellectual Property, trade secrets);
- Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
- Erasure: you are entitled to ask us to delete or remove personal data in specific circumstances. There are exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law;
- Restriction: under certain conditions you are entitled to ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it;
- Data Portability: when we process your personal data based on contract performance or your consent, you may ask us to transfer certain of your personal data to another party;
- Objection: where we are processing your personal data on the legal basis of our legitimate interest (or those of a third party) you may object on grounds particular to you. However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
- Consent: where we are processing personal data with consent, you have the right to withdraw consent at any time and require us to stop processing or restrict the processing, or not begin the processing, of your personal data, without affecting the lawfulness of processing based on consent before its withdrawal,
If you want to exercise any of these rights, please contact us at DataPrivacy@harrisonst.com or see “How to contact us” above.
You also have a right to lodge a complaint with a data protection supervisory authority in the UK or EEA where you are habitually resident, your place of work, or where an alleged infringement of the GPPR or the applicable local data protection law has taken place. If the DPL applies, you have the right to complain to the Data Protection Ombudsman of the Cayman Islands (you can access their website here: ombudsman.ky).
Please note that if you do not wish to provide us with requested personal information or subsequently withdraw your consent, you may not be able to invest in one of our Funds or remain invested in one of our Funds as it will affect our ability to provide our services to you and manage your investment.
More about cookies
Where will your information be held?
We are present in USA, Europe and Asia and your information may be transferred out of your local jurisdiction or region. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the UK, EEA or certain other jurisdictions. Harrison Street will take steps to protect your information in line with locally applicable data protection requirements. For transfers of data from the UK or EEA jurisdictions Harrison Street has implemented appropriate safeguards where required, notably contractual terms. If you would like copies of the terms applicable to transfers from the UK or EEA, please contact us at: DataPrivacy@harrisonst.com.
Our reasons for using special category data
“Special category data” in the UK and EEA and certain other jurisdictions refers to sensitive personal data such as your racial or ethnic origin, religious beliefs or health data. We may also collect data about criminal convictions. As a general rule, we will not process this data, but in exceptional cases, we may process this data where:
- We have your explicit consent: for processing such information;
- This is necessary to protect your vital interests or those of another person: for example, in medical emergencies;
- You have manifestly made the data public:
- Processing is necessary to deal with legal claims: for example, involving court proceedings;
- Processing is necessary for substantial public interest: for example, to prevent or detect unlawful acts.
The UK and EEA representatives of Harrison Street Real Estate Capital, Ltd. can be reached at: DataPrivacy@harrisonst.com.
Effective Date: April 30, 2021
1. What are cookies and other trackers?
Cookies are text files that are placed on your computer or mobile or handheld device (such as smartphones or tablets) when you visit certain pages on the Internet. They are used to “remember” when your computer or device accesses this Site. Cookies are stored in your browser. A cookie will help the Site, or another website, to recognize your device the next time you visit. Most cookies won’t collect information that directly identifies you as a person, and will instead collect more general information such as how visitors arrive at and use our Site. Cookies may, however, be used to create a profile of the visitor’s activities on the Internet which can be used (for example) to try to predict the visitor’s purchasing and behavioral preferences.
We may also use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also called web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
2. Types of cookies
Session cookies are stored only temporarily during a browsing session and are deleted from the visitor’s device when the browser is closed.
This type of cookie is saved on your device for a fixed pre-defined period of time (usually several months) and is not deleted when the browser is closed. Persistent cookies are used where we need to be able to recognize your device for more than one browsing session. Persistent cookies used on this Site generally have a maximum lifespan of up to 13 months, or exceptionally 2 years; please see below for further details.
First party cookies
First party cookies are set by the website you are visiting and they can only be read by that site.
Third party cookies
Third party cookies are not set by the owner of the website you are visiting, but by a different organization. For example, advertisers and other third parties may use their own cookies when you click on an advertisement or link on our Site, or we might engage a third party analytics company that will set their own cookie to perform this service.
3. Categories of cookies
The different types of cookies set out above can be categorized as follows:
These are cookies that are required for the operation of our Site, such as to ensure security. Other necessary cookies allow us to provide services that you expressly request. These cookies do not require your consent and cannot be switched off (although in some cases you can change your requests). You can set your browser to block or alert you about these cookies, but some parts of our Site may not work if you block these types of cookies.
These allow us to analyze Site usage, namely to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that visitors are finding what they are looking for easily. If you do not consent to these types of cookies we will not be able to improve our Sites based on information from your visit.
These cookies are used to provide certain functionalities to you by recognizing you when you return to our Site so that we can offer you a better experience on this Site. For instance, this enables us to set a cookie to store your preferences regarding the cookies on our Site.
These cookies are used to tailor advertising and content to your interests (“Targeting”), both within and beyond our Sites. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the Targeting displayed on it, and the marketing messages we send to you, more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the Targeting campaign and to monitor from which Targeting source a visitor was directed towards our Site so that we know whether it is worth for us to invest in that particular Targeting source.
These cookies may be set through our Site or by our third party Targeting partners. They may be used by those advertising partners to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and Internet device. If you do not consent to these types of cookies, you will experience less targeted advertising (but not less advertising overall).
The various cookies used by our Site have different lifespans. Session cookies will be deleted once you close your browser. Persistent cookies implemented on our Site will be kept for a period of time that does not exceed 13 months, or exceptionally 2 years. Please refer to the cookies table below to learn about the specific lifespans of the cookies we use.
5. What cookies do we use?
We use different categories of both session and persistent cookies on our Site, which can either be first or third party cookies.
Information on the cookies that we use on our Site (their names and categories, their lifespans and whether third parties have access to the cookies) are set out in the table below.
|Name||Description||Lifespan||First Party / |
|__cfduid||This cookie is set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors to the Site website and minimizes blocking legitimate users. It may be placed on users' devices to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare's security features. |
This cookie is set by HubSpot’s CDN provider because of their rate limiting policies.
The _cfduid cookie collects and anonymizes End User IP addresses using a one-way hash of certain values so they cannot be personally identified.
Learn more about this cookie from Cloudflare.
|Up to 30 days||First Party||Necessary|
|__hs_do_not_track||This cookie can be set to prevent the tracking code from sending any information to HubSpot. It contains the string "yes".||13 months||First Party||Necessary|
|__hs_initial_opt_in||This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode. It contains the string "yes" or "no".||7 days||First Party||Necessary|
|__hs_cookie_cat_pref||This cookie is used to record the categories a visitor consented to. It contains data on the consented categories.||13 months||First Party||Necessary|
|hs_ab_test||This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before. It contains the id of the A/B test page and the id of the variation that was chosen for the visitor.||Session||First Party||Necessary|
|When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page. It contains an encrypted version of the password so future visits to the page will not require the password again.||14 days||First Party||Necessary|
|hs-messages-is-open||This cookie is used to determine and save whether the chat widget is open for future visits. It is set in the visitor's browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity. If a visitor manually closes the chat widget, it will prevent the widget from re-opening on subsequent page loads in that browser session for 30 minutes. It contains a boolean value of True if present.||30 minutes||First Party||Necessary|
|hs-messages-hide-welcome-message||This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed. It contains a boolean value of True or False.||1 day||First Party||Necessary|
|__hsmem||This cookie is set when visitors log in to a HubSpot-hosted site. It contains encrypted data that identifies the membership user when they are currently logged in.||1 year||First Party||Necessary|
|hs-membership-csrf||This cookie is used to ensure that content membership logins cannot be forged. It contains a random string of letters and numbers used to verify that a membership login is authentic.||Session||First Party||Necessary|
|hs_langswitcher_choice||This cookie is used to save the visitor’s selected language choice when viewing pages in multiple languages. It gets set when an end user selects a language from the language switcher and is used as a language preference to redirect them to sites in their chosen language in the future, if they are available. It contains a colon delimited string with the ISO639 language code choice on the left and the top level private domain it applies to on the right. An example will be "EN-US:hubspot.com".||2 years||First Party||Necessary|
|__hstc||The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).||13 months||First Party||Analytics|
|hubspotutk||This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.||13 months||First Party||Analytics|
|__hssc||This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.||30 minutes||First Party||Analytics|
|__hssrc||Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. It contains the value "1" when present.||Session||First Party||Analytics|
|messagesUtk||This cookie is used to recognize visitors who chat via the chatflows tools. If the visitor leaves the Site before they're added as a contact, they will have this cookie associated with their browser. If a visitor chats with the Site and later returns to the Site in the same cookie browser, the chatflows tool will load their conversation history. The cookie is controlled by the Consent to collect chat cookies setting in the chatflow. If this setting is disabled, the cookie is controlled by the Consent to process setting in the chatflow. HubSpot will not drop the messagesUtk cookie cookie for visitors who have been identified through the Visitor Identification API. The analytics cookie banner will not be impacted. This cookie will be specific to a subdomain and will not carry over to other subdomains. For example, the cookie dropped for info.example.com will not apply to the visitor when they visit www.example.com, and vice versa. It contains an opaque GUID to represent the current chat user.||13 months||First Party||Functionality|
|wordpress_cookie_test||The cookie is used to check whether cookies are enabled to provide the proper user experience.||Session||Third Party||Functionality|
|cookie_notice_accepted||Status of cookie banner opt-in||30 days||Third Party||Functionality|
6. Managing cookies and withdrawing consent
We will obtain your opt-in consent to the use of the cookies set out in this Policy when you first access the Site and if we introduce any new cookies to the Site, unless they are necessary cookies, in which case your consent is not required. When you visit the Site, a pop up will appear to inform you about our use of such cookies. You can then consent by clicking on “Accept All”, or you may decline cookies (except necessary cookies) by clicking on “Decline All”. You may alternatively click on the “Cookies Settings” button in the bottom left-hand corner of the website to visit our Cookies Settings tool and decide the categories of cookies that you wish to accept, and the cookies you wish to decline.
If you decline cookies, we will not set those cookies on your device, except necessary cookies and a cookie to remember that you don’t want any cookies set when you visit the Site.
If you have accepted cookies but want to decline them (withdraw your consent) for the future, you can do so by clicking the “Cookie Settings” button in the bottom left-hand corner of the website and clicking on “Decline All”.
You can also disable cookies by changing your Site browser settings to reject cookies. How to do this will depend on the browser you use. All modern browsers allow you to change your cookie settings that will typically be found in the ‘options’ or ‘preferences’ menu of your browser. Use the ‘Help’ option in your browser for more details.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS
If you choose not to use the Cookies Settings tool, but instead control cookies through browsers, please remember to change your settings in each browser and for each of your devices.
Declining all cookies will have a negative impact upon the usability of many websites, including ours. If you decline cookies, you may not be able to use all the features on our Site. You can also delete cookies already stored on your computer. However, deleting cookies might have a negative impact on the usability of many websites, including ours.
7. More about cookies
8. Changes to this policy
9. Contacting Us
Sustainable Finance Disclosure Regulation
Harrison Street Advisors, LLC (the “Firm”) considers the principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impact statement of the Firm for the purposes of regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector.
The principal adverse impacts statement covers the reference period from 1 January 2022 to 31 December 2022 and will be disclosed prior to 30 June 2023.
Since inception in 2005, Harrison Street has sought to combine innovation and process rigor to execute differentiated strategies that improve the lives of its stakeholders. In 2013 Harrison Street began a formal effort to expand its focus and reporting of environmental, social, and governance (ESG) aspects of the business, which included its first submission to GRESB. To date, robust policies and procedures have been implemented to integrate ESG considerations into investment management processes and ownership practices in the belief that these factors can have an impact on financial performance.
These processes include an ESG policy which the Firm first established in 2013, and updates annually. The policy applies across corporate and investment operations and provides a framework for ESG integration. In addition, since 2014 the Firm publishes a Corporate Impact report annually, which presents the Firm’s strategy, goals and performance of the previous year. Stakeholder feedback is critical to the ESG initiative and is collected at least every three years to update the Firm’s priority list of most material ESG issues, including sustainability impacts and indicators.
Description of principal adverse sustainability impacts
Indicators applicable to investments in real estate assets
|Adverse Sustainability Indicator||Metric||Impact |
|Fossil fuels||Exposure to fossil fuels through real estate assets||Share of investments in real estate involved in extraction, storage, transport, or manufacture of fossil fuels||n/a||n/a||No investments in real estate involved in fossil fuels||n/a|
|Energy efficiency||Exposure to energy-inefficient real estate assets||Share of investments in energy-inefficient real estate assets||<25%||<25%||We measure efficient assets as follows, those that have LED lighting, energy efficient appliances, and meet Green Building standards. Based on our methodology and number of properties evaluated in a given year, we consider less than 25% of assets under our control are candidates for energy efficiency upgrades||Do annual reviews of properties for efficiency upgrades|
Other indicators for principal adverse impact
|Adverse Sustainability Impact||Adverse Sustainability Impact |
(qualitative or quantitative)
|Climate and other environment-related indicators|
|Emissions||GHG Emissions||Scope 1 and Scope 2 of GHG emissions generated by real estate assets.|
|Energy consumption||Energy consumption intensity|
|Social and Employee, Respect of Human Rights, Anti-Corruption and Anti-Bribery Matters|
|Human rights||Lack of human rights policy||Share of investments related to entities without human rights policy.|
|Human rights||Lack of processes and measures for preventing trafficking in human beings||Share of investments related to entities without policies against trafficking in human beings.|
This statement does not take into account principal adverse impacts on sustainability factors associated with Harrison Street Core Property Fund B S.C.S., SICAV-RAIF, which are reported at https://lis-aifm.com/esg (.)
Today, the Firm seeks to make an impact, a vision that encompasses not only the discrete impact of assets but also the positive societal and environmental benefit created through the Firms’ investment activities.
ESG is integrated into each investment vehicle. Our annual Corporate Impact Report, found in the Impact section of the Firm’s website, highlights this integration with respect to specific funds.
Description of policies to identify and prioritise principal adverse sustainability impacts
Harrison Street Advisors, LLC established its ESG policy for the first time in 2013, which was last updated December 2022.
The policy applies across corporate and investment operations and provides a framework for ESG integration. The Firm’s approach is defined in two parts, Corporate Operations and Investment Operations. Within Investment Operations, each investment vehicle follows this framework to define a specific approach to ESG integration that aligns with the investment strategy, control, asset class, investment time horizon, and portfolio construction. Execution of the policy resides across the Firm’s various departments. ESG is integrated throughout the Firm. The overall initiative is overseen by the Firm’s Chief Impact Officer and the Sustainability Leadership Team. The team leaders report activities and progress toward meeting ESG objectives quarterly to Harrison Street’s Executive Committee and the Firm at large.
In the Firm’s 2017 materiality assessment, the topics of highest priority were more focused on the individual issues within assets. In 2020, the results show focus is moving toward a more global, collective mindset. Instead of focusing singularly on energy reduction, the Firm will be focusing on net carbon emissions which includes energy reduction but also includes topics like clean energy procurement, on-site renewable energy development, and on-site fuel choices. In addition, the focus on tenant satisfaction will be broadened to encompass a complete picture about the residents and tenants served at assets, encompassing health, wellness, safety, and even affordability.
Sustainability metrics are integrated into due diligence processes, and evaluation criteria include alignment with the Firm governance and ethics standards, presence of certifications, and opportunity for increased efficiency in the future. Internal due diligence policies, procedures, and checklists are defined for specific asset classes and investment vehicles. ESG risks and opportunities are captured in the initial investment underwriting process, the Investment Committee presentation, and during the due diligence period.
The Firm seeks to develop or acquire assets that prioritize high efficiency standards and occupant health attributes. Development partners are engaged in enhancing their sustainable practices in design, construction, and operation. The Firm offers guidance resources and access to expert consultants to evaluate sustainable building strategies and ensure long-term economic benefit and tenant well-being. The Firm collaborates with development partners to integrate viable sustainability strategies into project proforma and design plans on a case-by-case basis, considering location, building type, tenant population, and portfolio goals. Harrison Street’s Asset Management team continues to monitor the property during the development phase and engages third-party vendors to review construction drawings to determine energy optimization and utility expense estimates.
The Firm recognizes that changing climate conditions can impact the operation, performance, and value of real assets. Natural disasters pose a high potential financial loss to assets in key geographic areas, and other societal risks (like geopolitical disruptions or pandemics) influence the operational performance of assets. Therefore, the Firm has implemented resilience and risk management procedures in order to recognize and plan for these events, thus supporting long-term value creation and minimizing risk. These practices are continuously evaluated and enhanced as the global landscape of risks and evaluation processes evolve.
For key environmental indicators, such as energy efficiency, GHG emissions and energy intensity, the Firm uses the energy management platform called Conservice/Goby, which both captures and calculates this information. The social indicators are captured in both initial and ongoing management and company background checks.
Partners, investors, and employees are engaged in and educated about Harrison Street’s ethics policies. Training on ethics, anti-corruption, and specialized topics like foreign corrupt practices and cybersecurity are provided annually, during quarterly certifications, and when new regulations or situations arise. Investment policies and procedures promote compliance with the SEC’s Investment Advisor requirements and assist the Firm in preventing, detecting, and correcting violations. Policies against bribery and corruption are maintained, consistent with the US Foreign Corrupt Practices Act and similar laws in other countries. Anti–money laundering checks are conducted for every new investor and background checks are conducted on all new joint venture partners and employees.
In addition, Harrison Street recognizes that incorporating the feedback of its stakeholders is vital to delivering superior investment strategies and a focused ESG strategy. The Firm regularly engages with employees, investors, third-party operators, joint venture partners, tenants/residents, lenders, and consultants to understand priorities and concerns. Forums for engagement include the annual investor conference and advisory board meetings for each fund, annual operating partner sector-specific conferences, quarterly investor webinars, satisfaction surveys, and a materiality survey conducted at least every three years. Ad hoc feedback from industry conferences, one-on-one calls, industry trade magazines, and webinars is also integrated into materiality assessments.
As mentioned above, stakeholder feedback is critical to the ESG initiative and is collected at least every three years to update the Firm’s priority list of most material ESG issues, including sustainability impacts and indicators. In addition, annually the Firm updates and publishes its ESG policy to reflect changes or enhancements to the ESG policy, if warranted, due to changes in stakeholder demands.
Reference to international standards
The ESG Frameworks the Firm follows include:
- GRESB Real Estate
- GRESB Infrastructure
- TCFD (Task Force on Climate Related Financial Disclosures
- UN PRI (Principles for Responsible Investing)
- GRI Standards (Global Reporting Initiative)
Annually, the Firm submits to GRESB and UN PRI, follows GRI Standards in our Corporate Impact Report, and completes TCFD requirements.
The Firm uses results from reports such as GRESB to identify areas of improvement. The assessments themselves do not predict future performance, but rather are lagging indicators of how one was performing in the previous calendar year. Identifying areas where full points were not awarded, and then setting goals to lessen the gap are how forward-looking scenarios are executed. These goals then roll into the broader ESG strategy.
The Firm follows a pay-for-performance framework that encompasses total compensation, base salary and bonus, such that pay is commensurate with the overall performance of the Firm and individual performance. This includes a balanced assessment of the employee’s annual performance against the Firm’s core values: excellence, integrity, passion, innovation and teamwork. These performance dimensions consider short and long-term priorities that drive sustained shareholder value, while accounting for risk, controls, and conduct objectives.
The Firm’s Performance Management Cycle includes: annual goal setting, manager-employee check-ins, a midyear and annual review. To track performance, a comprehensive online talent management system is utilized, which streamlines all aspects of the Performance Management Cycle. It is the Firm’s intent, that our performance management process provides transparency to all employees with respect to job performance. For select employees involved in ESG related tasks or activities, regard is given to the performance of said strategies. For each of these employees regard is given to the performance of relevant ESG related projects/strategies.
PERE is a leading publication for the world’s private real estate markets. Its annual awards are determined by industry participants through a highly controlled voting system.
Pensions & Investments Best Places to Work award is a two part assessment designed to gather detailed data about each participating company that includes a questionnaire completed by the employer and a satisfaction survey completed by company employees.
The Private Equity Wire awards are based on an online poll of finalist firms pre-selected based on data provided by Bloomberg.
Fitwel is a certification system administered by the Center for Active Design (CfAD) that promotes health and wellness for occupants of real estate assets. CfAD’s annual Best in Building Health awards honor those firms who meet and exceed Fitwel’s certification standards, but also recognizes exceptional leadership and progress in the industry. The distinguished Industry Leadership award is offered at the discretion of CfAD’s senior leadership to honor companies demonstrating exceptional innovation in advancing Fitwel’s commitment to building health for all. As of May 2022, a Harrison Street employee participates on the Fitwel Leadership Advisory Board (Fitwel LAB) of Active Design Advisors, Inc. (“Adai”), which is an affiliate of CfAD. The Fitwel LAB provides industry feedback to Adai regarding its certifications and services. In connection with participation on the Fitwel LAB, Harrison Street made a voluntary donation to CfAD to support its research and the acquisition of CfAD certifications by budget-constrained property owners.
Pensions & Investments largest real estate investment managers is ranked by total worldwide real estate assets, in millions, as of June 30, 2020. Assets are reported net of leverage, including contributions committed or received, but not yet invested; REOCs are included with equity; REIT securities are excluded.
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|HSRE Core Fund GP, LLC|| |
|HSRE Social Infrastructure Fund GP, LLC|| |
|HSRE GP IX, LLC|| |
Harrison Street Real Estate Capital, LLC, acting in its capacity as a delegate of the following General Partners, shall make available the Form 20-2 and Form 21-3 (the “Materials”) to Japan public. Any person that wishes to receive a copy of the Materials, please kindly contact the following e-mail address:
|Name of General Partner operating under the Article 63 Exemption||Name of the Limited Partnership Fund|
|HSRE Core Fund GP, LLC|| |
|HSRE Social Infrastructure Fund GP, LLC|| |
|HSRE GP IX, LLC|| |
The Materials are provided to you for informational purposes only and does not constitute the provision of investment advice. In addition, the information contained in the Materials does not constitute an offer to sell nor a solicitation of any offer to buy and is not intended to be, and should not be construed as, an offer to sell nor a solicitation of an offer to buy any type of securities, financial products or other services offered by Harrison Street and its affiliates to any person in Japan to whom such offer would be unlawful under the applicable laws of Japan.