Data Privacy Notice

By logging into ComplianceDesktop® Technology Platform you acknowledge that you have read this Data Privacy Notice and understand the purpose for which the information you provide here is being collected, how it will be used, how to contact the organization that is collecting and using this information, and how to correct and where permitted, amend your information

Purpose of the processing and the legal basis

Hines uses the information collected in ComplianceDesktop® in order to be compliant with legal obligations related to, inter alia, the EU Directive 2015/849, the Luxembourg Law of 13 February 2018 amending, inter alia, the Law of 12 November 2004, the United States Office of Foreign Assets Control and Foreign Corrupt Practices Act, the United Kingdom Bribery Act 2010 and Money Laundering Regulations 2017.

Data processing and sub-processing

We may collect the following personal data from you: name, home address, nationality, copies of ID cards or passports. The data is processed by Red Flag Group Inc, 1230 West Washington Street, Suite 201, Tempe, AZ 85281, USA, (“RFG”) under the responsibility of Hines Interests Limited Partnership. The Hines contract with RFG includes European Commission’s Model Contract Clauses to provide a legitimate mechanism for the transfer of personal data outside of the European Economic Area. RFG has contracted with Amazon Web Services Inc. and its affiliates (“AWS”) to provide cloud hosting services.

Recipient(s) of your personal data

Hines, RFG, AWS and Hines’ external legal counsel (as required) may receive your personal data.

Data protection

Hines is committed to maintaining the confidentiality of your personal information and keeping it secure. Hines will take reasonable precautions to protect it from loss, misuse, alteration and unauthorized access.

Data retention

Data is hosted by AWS facility in Ireland. Data is retained for a period of 5 years after any commercial relationship between Hines and your company has ended; or 5 years after receipt of data if no commercial relationship is established.

Accessing and updating your information

You have the right to request a copy of the information that Hines holds about you and may ask Hines to correct or remove information you think is inaccurate.  If you exercise your right to amend, delete, or change any of the information provided, that could impact our decision whether to commence and/or continue our business relationship. You also have the right to lodge a complaint with a supervisory authority when you think is appropriate.

Completion of the questionnaire in ComplianceDesktop® Technology Platform is voluntary; however, failure to complete the questionnaire may preclude Hines from doing business with you. Throughout “Hines” means Hines Interests Limited Partnership (and affiliates), 2800 Post Oak Blvd, Houston, TX 77056, USA. For further information or questions related to this Data Privacy Notice please contact hines.compliance@hines.com. 

Warning: This system is restricted to authorized users for the ComplianceDesktop® Technology Platform and the relevant applications that have been made available for your use. Unauthorized or improper access and / or improper use of this system is a violation of conditions of use and the law.