Privacy Policy

Using information to better serve and administer the client relationship.

HFF is committed to protecting your privacy. This privacy notice details how HFF handles data for various relationships including clients, investors, employment applicants, employees and vendors.  Some of the data collection points outlined in the notice may or may not apply, depending on the nature of your relationship to HFF.  If you have any questions regarding this notice, please contact us here.

By using the site you consent to the collection, use and disclosure of your personal information in accordance with this policy. Holliday Fenoglio Fowler, L.P. (HFF) is committed to protecting your privacy. This privacy policy tells you about our online collection, use and disclosure of personal information. The terms of this policy apply to all personal information collected by HFF on the website hfflp.com.

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.

Privacy Policy

Our Privacy Policy is also in compliance with The General Data Protection Regulation (“GDPR”). GDPR applies to the collection, processing and storage of personal data undertaken by organisations within the European Economic Area (EEA), as well as to organisations outside the EEA that handle personal data relating to the offering of services to individuals in the EEA. 

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. 

You may forward any questions, comments or complaints that you might have about this privacy policy to:

Privacy Policy
HFF
9 Greenway Plaza, #700
Houston, Texas 77046
Or by email to: webinquiry@hfflp.com


PURPOSE

To undertake pre-engagement steps, including, but not limited to;

  • determining your eligibility to become a client of HFF;
  • required due diligence;
  • ascertaining your investment preferences.

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.


PURPOSE

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. 

LAWFUL BASIS FOR PROCESSING

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 jgriffiths@hfflp.com.


PURPOSE

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.

LAWFUL BASIS FOR PROCESSING

The performance of your contract with us.


PURPOSE

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.

LAWFUL BASIS FOR PROCESSING

Compliance with applicable legal obligations and our legitimate interests in complying with law and regulation applicable to us and our processors.


PURPOSE

To report tax related information to tax authorities.

LAWFUL BASIS FOR PROCESSING

Compliance with applicable legal obligations.


PURPOSE

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.

LAWFUL BASIS FOR PROCESSING

Compliance with applicable legal obligations.

Our legitimate interests in conducting our business in a proper mannerOur legitimate interests in conducting our business in a proper manner.


PURPOSE

To maintain our records and carry out fee calculations.

LAWFUL BASIS FOR PROCESSING

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.


PURPOSE

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.

LAWFUL BASIS FOR PROCESSING

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:

  • other entities within our group as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise or for assistance in relation to marketing and business development;
  • professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
  • regulators;
  • tax authorities;
  • parties undertaking anti-money laundering checks; and
  • any of our service providers where such information is relevant to their performance of such services.

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:

  • request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • request rectification of your personal data;
  • request the erasure of your personal data;
  • request the restriction of processing of your personal data;
  • object to the processing of your personal data; and
  • request the transfer of your personal data to another party.

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 jgriffiths@hfflp.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 jgriffiths@hfflp.com. 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.

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data.  If you require any further information, please do not hesitate to contact jgriffiths@hfflp.com.