Starwood Capital Group primarily serves as or controls, directly or indirectly, the general partner or managing member of various investment vehicles that it creates, sponsors and advises from time to time and through which various investments are made (the “Starwood Funds”). All investment advice provided to the funds regarding securities is provided by Starwood Capital Group Management, LLC (“SCGM”). SCGM provides investment advice to the funds primarily regarding investments in real property and privately-issued real estate securities. SCGM is registered as an investment adviser with the SEC.
As used on this website, “Starwood Capital Group” or “Starwood Capital” refers to entities that have previously or are currently serving as or controlling, directly or indirectly, the general partner or managing member of the Starwood Funds.
All non-U.S. offices listed are offices of Starwood Capital Group’s affiliates and/or branch/advisory offices of such affiliates.
Mr. Barry Sternlicht, directly or indirectly, controls Starwood Capital Group and SCGM.
Changes to this Policy: We will post any modifications or changes to the Policy on our website www.starwoodcapital.com. We reserve the right to modify the Policy at any time and the “Last Updated” legend above indicates when this Policy was last changed.
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to manage employment relationships and diligence our potential operating partners, investors and business relationships.
We collect information about you in the following ways:
Information You Give Us. This includes:
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
We may collect personal information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Website.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers on our Website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Our Website may use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Website and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Website to remember choices you make when you use our Website. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Website.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Website and how users use our Website. The information gathered does not identify any individual visitor.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Website.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
We may use the information described above for the following purposes to:
We also may use the information in other ways for which we provide specific notice at the time of collection.
We will only process your personal data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
When we collect personal data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect personal data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.
We may share your personal data as follows:
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. Any transfer of your personal data shall take place only in accordance with and as permitted by data protection legislation and we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 11 below.
We intend to keep your personal data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it.
We will retain your information in line with our retention policies or as required by applicable law and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them at this time.
Our website is hosted and operated in the United States. However, we and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries.
Visitors from jurisdictions outside the United States visit us at their own choice and risk.
If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States from which you may access our Sites may not be as stringent as that under privacy standards or the privacy laws of other countries, possibly including your home jurisdiction.
Under California Civil Code Section 1798.83, individuals who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any.
To make such a request, send an email with the subject heading “California Privacy Rights” to [email protected] In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Pursuant to applicable California law, including the California Consumer Privacy Act (CCPA), Starwood makes the following disclosures regarding the personal information it has collected within the last 12 months:
|Category of Personal Information||Category of Source from Which Data is Collected||Purpose of Collection||Category of Third Parties to Whom Data is Disclosed|
|Contact information such as name, postal and email addresses and telephone numbers||Directly from user||To create and manage your account and investments||Service Providers|
|Date of birth, Social Security number, citizenship status||Directly from user||Entity management||Service Providers|
|Automatically-collected information, such as your location; IP address; device type; browser type; operating system or platform; name of Internet Service Provider; referring website; exiting website; pages visited on our website; frequency, time, data, and duration of your visit on our website; whether you open emails from us; links you click on in our emails and on our website, including ads; whether you access our website from multiple devices; other interaction you may have on our website; Device Unique Device Identifier (e.g., Unique Device Identifier (UDID) or International Mobile Equipment Identity (IMEI)); mobile device MAC or IP address; information about your mobile device’s operating system; information about your mobile carrier||Cookies and other tracking technologies||To perform data analyses to improve our business||N/A|
If you are a California resident, pursuant to the CCPA, you have the right to request:
To submit a request, or designate an authorized agent to make a request under the CCPA on your behalf, please contact us at [email protected], 844-979-1459, or complete the web form. To verify your identity when you submit a request, we will match the identifying information you provide us to the personal information we have about you.
However, Starwood will not be required to comply with your request to delete your information if it is necessary for Starwood to maintain your personal information in order to:
Starwood will not discriminate against you in the event you exercise any of the aforementioned rights under CCPA, including, but not limited to, by:
This policy is available to consumers with disabilities. To access this policy in an alternative downloadable format, please click here.
Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on our website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: [email protected]. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We welcome your comments or questions about this Policy. You may contact us in writing at [email protected].