At Dune Real Estate Partners LP, we are committed to protecting and respecting your privacy. This policy explains how we collect and use any personal information (i.e., any information that relates to you and that identifies or can be used to identify you) that you share with us, including how we collect, process, protect and share your personal information.
When you provide us with your personal information, Dune Real Estate Partners LP and its affiliated entities (including, without limitation, any investment funds or vehicles) (collectively, "Dune", "we", "us" and "our") may act as a "data controller". In simple terms, this means that we: (i) "control" the personal information that you provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal information, but only to the extent that we have informed you about the use or are otherwise permitted by law.
- What information do we collect about you?
- How we obtain your personal information
- Why we use your personal information
- Who we share your personal information with
- How we keep your personal information secure
- Our retention of your personal information
- Transfers of your personal information
- Your rights
- Supplemental notice to California residents
- Contact us
- What information do we collect about
The types of personal information we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us. The types of personal information we collect includes contact information (such as name, postal and email address and telephone number) and other personal information you submit to us, such as the information you provide to us when you correspond with us in relation to inquiries.
The personal information collected about you will help us provide you with a better service and facilitate our business relationship.
We do not knowingly collect or solicit personal information from anyone under the age of 16.
- How we obtain your personal
We collect information about you directly when you provide it to us in online correspondence and in conversations (including via email and telephone).
In an offline context, we also collect information about you from the forms and any associated documentation that you complete when subscribing for an investment and/or establishing a relationship with us, including KYC and anti-money laundering information. This will include information about your name, address, date of birth, passport details or other national identifier, driving license, and your national insurance or social security number and/or taxpayer ID.
We also collect personal information about you from third parties during our investment process, both during diligence on entities that we are considering purchasing or investing in and after making such investments, in each case from such potential or actual investment entities, as part of our continuing interest in such investments and compliance with legal obligations in relation to such investments.
We will only collect and process personal information about you where we have lawful bases to do so (please see section 3 below).
We may combine personal information that you provide to us with information that we collect from, or about you from publicly available sources. This will include information collected in an online or offline context.
- Why we use your personal information
We will use the personal information you provide us with for the following purposes, and pursuant to the corresponding legal bases, among others:
Additionally, we will use your personal information to keep you informed of our products and services (e.g. future funds that we are raising), if you have provided your consent to us doing so, or based on our legitimate interest where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the "opt-out" link provided in all our marketing emails.
No automated decision making, including profiling, is used when processing your personal information.
If we require your personal information due to a legal requirement or obligation, or in order to perform a contract with you, we will make you aware of this at the time we collect your personal information and the possible consequences of you failing to provide this personal information (unless we are restricted from doing so under applicable law).
- Who we share your personal
We will share your personal information with third parties as required by law or regulation, such as relevant regulatory authorities and tax authorities.
We make sure any third party that provides a service to or for us generally covenants within a defined standard to:
(i) enters into an agreement with us and meets our standards for data security;
(ii) not to use your personal information for any purpose other than the clearly defined purpose relating to the service that such party is providing;
(iii) not to share your personal information with any organization without our consent (apart from us); and
(iv) hold your personal information securely and retain it only for such period of time as we instruct.
We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.
- How we keep your personal
We are committed to protecting the personal information you entrust to us, and to that end we employ appropriate organizational, physical, technical and procedural safeguards to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
- Our retention of your personal
- Transfers of your personal
To the extent that you reside in the European Union, or EU data privacy legislation applies to you, and we transfer your personal information to countries located outside of the European Economic Area ("EEA"), such transfers are made in compliance with applicable data privacy laws. Similarly, for the purposes of the Data Protection Law, 2017 of the Cayman Islands ("DPL"), where applicable, any transfer of personal information by us or our duly authorized affiliates and/or delegates to countries not having an adequate level of protection shall be in accordance with the requirements of the DPL.
Please contact us for information in relation to the particular safeguards or derogations used in any particular circumstance.
- Your rights
To the extent that you reside in the European Union or Cayman Islands, or EU data privacy legislation or the DPL otherwise applies to you, you have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at firstname.lastname@example.org.
- Access: You have the right to ask for details of the personal information that Dune holds about you free of charge, however we may charge a 'reasonable fee' if we think that your request is excessive, to help us cover the costs of locating the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
- Correction: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.
- Deletion: If you think that we shouldn't be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal information for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. If you do not do so, we may continue to rely upon that previous consent to keep using and processing your personal information in the same way.
- Supplemental notice to California
If you are a resident of California, applicable law permits you to request information regarding the disclosure of any personal information collected by us about you to a third party for third party marketing purposes. To make such a request, please contact us at email@example.com or write us at: Dune Real Estate Partners LP, 640 Fifth Avenue, 17th Floor, NY, NY 10019.
- Contact us
If you reside in the European Union or Cayman Islands, or EU data privacy legislation or the DPL applies to you, and you should you wish to lodge a complaint with regards to how your personal information has been processed by Dune, please contact your local supervisory authority. In the UK, this is the Information Commissioner (https://ico.org.uk/concerns); for the DPL, this is the Cayman Islands Ombudsman.