Privacy Policy

Privacy
Policy

Privacy Policy

Last Updated: October 21, 2022

We at NorthStar Healthcare Income, Inc. and our affiliated companies (collectively, "we", "us", "our" and "NHI") respect your concerns about privacy. This Privacy Policy applies to personal information we may obtain about you if you are an investor (or a potential investor) in a fund managed by NHI, or an individual employee or other representative of an investor or potential investor.

This Privacy Policy describes the types of personal information we may obtain, how we may use the information, with whom we may share the information (including where they are located), how long we will retain the information and your choices regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

Below is a list of the sections included in this notice:

Who We Are

This privacy notice is published by NorthStar Healthcare Income, Inc. and its various affiliated companies and other entities that are involved in the management of funds. For further information about particular NHI entities that may collect and process your personal information in relation to a particular fund, please speak to your regular NHI contact or contact us as indicated in the How To Contact Us section of this Privacy Policy.

Information We Collect

Personal Information you provide

We obtain certain personal information (such as name and other contact details) directly from you when you fill in forms relating to your involvement in a fund, send us an email or otherwise communicate with us. The types of personal information we may obtain include:

  • contact information, such as your name, postal address, email address, telephone number, facsimile number, online identifier, IP address, SSN, government identification number, social media handle;
  • other personal information such as demographics, location information, online activities, financial information and health/biometric;
  • details of your role with an organization that you represent and/or your involvement in a fund (including, if you are an investor (or potential investor), details of your investment of proposed investment);
  • telephone number, email address, tax identification number, information regarding your work authorization status, work history, references, education history, employment history and professional designations; and other personal information about your qualifications. In addition, where legally permissible, you may provide information regarding your criminal history, gender, race/ethnicity, and your veteran and disability status; and
  • where required for anti-money laundering purposes, background information such as your date and place of birth, the other details in your passport and information about criminal convictions.

Unless we explain otherwise at the time, providing personal information that we request is optional and any disclosures are made voluntarily.

Personal Information we collect from other sources

We may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription based services.

How We Use The Information We Collect

We may use the information described above to:

  • provide investor services to you, such as email alerts, newsletters and other communications;
  • manage your (or the organization that you represent) investment;
  • respond to and communicate with you about your requests, questions and comments;
  • operate, evaluate and improve our business;
  • perform data analyses and other processing;
  • protect against identify theft and prevent fraud and other criminal activity (including through anti-money laundering checks), claims and other liabilities;
  • manage and develop our relationship with you or the organization that you represent; and
  • comply with and enforce applicable legal requirements, relevant industry standards and our policies.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

In some countries, we need to identify the legal basis upon which we process your personal information. In general, we can process your personal information lawfully because we have a legitimate interest in doing so, to pursue the purposes that we have set out above. We may also need to process your personal information in order to perform our legal obligations.

Information We Share

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We may share personal information with third parties (e.g., service providers) who perform services on our behalf. These third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. We may also share the personal information we obtain with other organizations involved in the management of the relevant fund and with our affiliates or subsidiaries.

We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other corporate event).

The disclosures of personal information referred to above include transfers of personal information which is subject to UK or European Union data protection laws to countries outside the UK, EU, the Cayman Islands Data Protection Law, California Consumer Protection Privacy (“CCPA”) and various other worldwide privacy regulations. This includes transfers to countries, such as the U.S., which are not regarded by the European Commission as ensuring an adequate level of data protection. Where we transfer personal information subject to UK or European Union data protection laws to our service providers, other organizations involved in the management of the relevant fund or affiliated companies in those countries, we do so on the basis of data transfer agreements designed to protect the privacy of your information, in forms approved for this purpose by the European Commission.

Record-Keeping

The period for which we will keep your personal information varies depending on the information and how we obtained it. Personal information will not be held for longer that it is needed, given the purposes for which it is held. Further information regarding our record-keeping policies is available upon request.

Your Choices

You have the right under data protection law to require us to correct any inaccurate information that we hold about you or to obtain copies of the personal information we hold. You also have rights, in some circumstances, to object to our processing of your personal information and to require us to delete, or restrict our processing of, information we hold about you. You also have right, subject to applicable law, to request us to delete your personal information from our database. To ask us to remove your information or submit a request, or if you would like a copy of one of the data transfer agreements referred to in Information We Share above, please contact us as indicated in the How To Contact Us section of this Privacy Policy.

How We Protect Personal Information

We take all reasonable precautions in accordance with applicable law, including implementing administrative, technical and physical safeguards, to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Updates To Our Privacy Notice

This Privacy Policy may be updated periodically to reflect changes in our personal information practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions about this Privacy Policy, or if you would like us to update information we have about you or your preferences or exercise the other rights described in this Privacy Policy, please write to us at:

NorthStar Healthcare Income, Inc.
16 E. 34th Street
18th Floor
New York, NY 10016

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