1.Information Collection and Use
Domain Real Estate Partners, LLC (“Domain”) recognizes that it is important for you to feel confident in the knowledge that your personal information is secure. We are committed to protecting and safeguarding the confidential data that you have entrusted to us. This Privacy Policy describes how Domain collects, uses, discloses and safeguards personal information relating to our investors and to visitors to our website.
In the ordinary course of business, Domain collects non-public and personally identifiable information regarding our investors. Such information includes, but is not limited to, your name, residential and email addresses, place and date of birth, government-issued identification number, account balances, bank information and representations you made to us regarding your assets, income and sources of funds (collectively, “Confidential Personal Information”).
Domain collects and uses Confidential Personal Information only as reasonably necessary to provide investment management services, to administer investor relationships, to process subscriptions and redemptions, to comply with legal and regulatory obligations (including anti-money laundering and sanctions screening obligations), and for other legitimate business purposes.
Domain obtains access to your Confidential Personal Information primarily through the following sources:
- Subscription forms, investor questionnaires and other information you provide to us, whether in writing, in person, by telephone, electronically or by any other means; and
- Transactions facilitated by Domain, including provision of account balances, subscriptions and redemptions.
2.What Information Domain Will Disclose and to Whom Domain Will Disclose That Information
Domain may disclose your Confidential Personal Information as permitted or required pursuant to applicable laws or regulations. Such circumstances include the following:
- To government entities, in response to subpoenas or information requests, or to comply with applicable laws or regulations;
- When you instruct, or consent to, Domain’s disclosure of Confidential Personal Information;
- To service providers that perform services for Domain, such as external auditors and outside legal counsel, and to service providers that facilitate Domain’s transactions (custodians, broker-dealers, prime brokers, third-party administrators, etc.);
- To Domain affiliates, if the disclosure is deemed necessary for the provision of services to Domain or for compliance with applicable laws or regulations; and
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
Domain does not sell, rent, or trade Confidential Personal Information to unaffiliated third parties.
Domain does not disclose Confidential Personal Information to unaffiliated third parties for their own direct marketing purposes, except as permitted or required by law.
3.Information About Former Investors
To the extent that Domain retains Confidential Personal Information regarding former investors, it will adhere to the privacy policies and procedures set forth herein.
Domain retains Confidential Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to maintain required books and records, comply with applicable legal and regulatory obligations, resolve disputes, enforce agreements, and for legitimate business needs.
4.How Domain Safeguards Information
Domain requires that all employees, affiliates and service providers keep your Confidential Personal Information secure. Domain maintains safeguards that comply with the applicable standards to protect your Confidential Personal Information. It restricts access to your personal and capital account information to those employees who need to know such information in order to fulfill their job responsibilities. Third parties with which Domain shares your information must also adhere to appropriate standards of security and confidentiality.
Domain maintains administrative, technical, and physical safeguards designed to protect Confidential Personal Information against unauthorized access, use, alteration, destruction, or disclosure.
In the event of a security incident involving Confidential Personal Information, Domain will evaluate the incident and take reasonable steps to address and mitigate any potential harm, including providing any notifications required by applicable law.
5.U.S. State Privacy Law Notice
Certain U.S. state privacy laws may provide residents of those states with additional rights regarding their personal information. To the extent such laws apply to Domain and are not otherwise exempted, Domain will comply with applicable requirements.
6.Additional Information for Investors Based in the European Economic Area (“EEA”)
Domain is considered a “data controller” under the EU General Data Protection Regulation (“GDPR”). Certain of its affiliates and third-party service providers may act as “data processors” under GDPR.
Domain may collect, store and use your Confidential Personal Information for lawful purposes, including where necessary for: (i) the performance of its investment management services pursuant to your Subscription Agreement; (ii) compliance with legal or regulatory obligations to which it is subject (such as anti-money laundering obligations or recordkeeping obligations); and/or (iii) the legitimate interest of Domain (including communications regarding Domain, its investment strategies, and investor relationship communications) or a third party, so long as such legitimate interest is not overridden by your interests, fundamental rights or freedoms. Domain may retain your Confidential Personal Information for so long as it is permissible pursuant to items (i), (ii) and/or (iii) above.
Domain may disclose your Confidential Personal Information to recipients (including affiliates of Domain) located in countries outside of the EEA. Such countries, including the United States, may not have data privacy laws equivalent to GDPR. In such circumstances, Domain will take all necessary steps to ensure the safety of your Confidential Personal Information in accordance with GDPR.
Under GDPR, you may have a right to: (i) request access to and rectification or erasure of your Confidential Personal Information; (ii) obtain restriction of processing or to object to the processing of your Confidential Personal Information; and (iii) data portability. If you wish to exercise any of these rights, please contact us using the contact information provided on this website. Additionally, please be advised that you have the right to lodge a complaint regarding the processing of your Confidential Personal Information with your local data protection authority.
Domain will notify you of any data breach affecting your Confidential Personal Information that is likely to result in a high risk to your interests, fundamental rights or freedoms.
If you are an investor, by signing your Subscription Agreement, you acknowledge that we may use your Confidential Personal Information as described herein. You also consent to the transfer of your Confidential Personal Information to Domain and the other recipients described herein, any of which may be located outside of the EEA.
7.Website
Domain’s website may collect limited information automatically when you visit, such as your IP address, browser type, device information, and pages viewed. Domain may use cookies and similar technologies to help the website function properly and to understand website usage. You may disable cookies through your browser settings; however, doing so may affect website functionality. Domain’s website may include links to third-party websites, and Domain is not responsible for the privacy practices of those third parties.
If this Privacy Policy changes in any material way, we will post the updated Privacy Policy on this website and provide any additional notice required by applicable law. If you have questions or comments, please contact us using the contact information provided on this website.