Please read this policy and if you have any questions contact us.
This site is operated by HFF and may be accessed in the United States of America and abroad. For personal information protection purposes, hfflp.com is the controller and, unless otherwise noted, is also the processor of the personal information. Information collected may be retained as long as it is reasonably required for the purposes it was collected.
The GDPR has two key purposes: (a) to set guidelines for the collection, processing and protection of personal data and (b) to give individuals certain rights in relation to their personal data (such as to access and correct it and object to further processing).
This Privacy Notice is intended to ensure that the client or, where the client is not an individual, the client’s individual directors, officers, employees and/or owners (“you”, or “your”) are aware of how HFF Inc. (“we”, “us” or “our”) may collect, how we collect it, what we use it for and with whom we share it in accordance with the GDPR. Where the client is not an individual please provide a copy of this Privacy Notice to those individual directors, officers, employees and/or owners whose personal data we may process.
“Personal data” means any information relating to you, but does not include data where you can no longer be identified from it such as anonymised aggregated data.
We will be a data controller in respect of your relationship with us as a client. A data controller is responsible for deciding how to hold and use personal data about you. We may process your personal data ourselves or through others acting as data processors on our behalf.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why your personal data is being used. These supplemental notices should be read together with this Privacy Notice.
9 Greenway Plaza, #700
Houston, Texas 77046
Or by email to: email@example.com
To undertake pre-engagement steps, including, but not limited to:
LAWFUL BASIS FOR PROCESSING
In order to take steps prior to the contract between you and us, compliance with applicable legal obligations and our legitimate interests in establishing your preferred investment strategies prior to advice being given.
To undertake business development and marketing activities in relation to making suggestions and recommendations to you about products or services that may be of interest to you. This may include direct electronic marketing.
Our legitimate interests in promoting our products and services and growing our business.
We only send direct electronic marketing where individuals have consented to this or as otherwise permitted by the law. Individuals can opt-out of receiving such messages at any time by using the opt-out mechanisms that may be available in those messages or by contacting firstname.lastname@example.org.
To facilitate the opening of your account, the management and administration of your account on an on-going basis as considered necessary or appropriate for the performance of your contract with us.
The performance of your contract with us
To carry out anti-money laundering checks and related actions considered appropriate to meet any legal obligations relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our anti-money laundering procedures.
Compliance with applicable legal obligations and our legitimate interests in complying with law and regulation applicable to us and our processors
To report tax related information to tax authorities.
Compliance with applicable legal obligations
To disclose information to other third parties such as auditors, administrators, custodians, brokers, legal counsel, technology providers and regulatory authorities to comply with any legal obligation imposed on us or in order to pursue our legitimate business interests.
Compliance with applicable legal obligations.
Our legitimate interests in conducting our business in a proper manner.
To maintain our records and carry out fee calculations.
The performance of your contract with us as a client.
Our legitimate interests in maintaining relations with our clients and in conducting our business in a proper manner.
To provide client relations in respect of your account including provision of investment advice, seeking consents for changes to terms and for other corporate governance purposes.
The performance of your contract with us as a client.
Compliance with applicable legal obligations.
In addition to the uses above, please note that we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process
There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.
We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where:
In some circumstances, if you do not provide us with certain information when requested, we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information means we may not be able to accept you or retain you as a client.
We will only use your personal data for the purposes for which we collected it (as identified above in the ‘Purpose’ column above), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We typically collect personal data about you when you provide information to us or others acting on our behalf when communicating or transacting with us in writing, electronically, or by phone. For instance, requests for property documentation or other forms of literature and your previous transactions.
In addition, we may receive personal information about you from third parties, such as:
In addition to the uses above, please note that we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may share your personal data with a third party where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.
We may need to share your personal data with:
We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may transfer the personal data we collect about you to the United States of America where HFF Inc. is based for the purposes outlined in the table above. The United States of America may not have the same standard of data protection laws as the EEA.
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. In doing this we will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for 5 years following completion of the contract.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
In exercising your rights above, you may be required to terminate your contract with us.
If you want to exercise one of these rights please contact us at email@example.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.
We reserve the right to update this Privacy Notice at any time, and will make an updated copy of such Privacy Notice available to you and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.