Last Updated: September 13, 2023
We at DigitalBridge Group, Inc and our affiliated companies (collectively, “we”, “us”, “our” and “DBRG”) respect your 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 DBRG; you are an individual employee or other representative of an investor or potential investor; you visit our website (including our Private Investors Portal); or in other situations when you otherwise interact or communicate with us, for example, when you visit our offices.
This Privacy Policy describes the types of personal information we may obtain, how we collect and use the information, with whom we may share the information (including where they are located), how long we will retain the information and your rights in relation to the information we use. 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
- Information We Collect
- How We Use The Information We Collect
- Information We Share
- How Long We Keep Your Information
- Your Rights
- How We Protect Personal Information
- How To Contact Us
- Updates To Our Privacy Notice
Who We Are
This privacy notice is published by DigitalBridge Group, Inc. and its various affiliated companies and other entities that are involved in the management of funds. For further information about particular DBRG entities that may collect and process your personal information in relation to a particular fund, please speak to your regular DBRG 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, or interact with us by visiting our website or our offices. The types of personal information we obtain may include:
- basic personal details such as your full name and contact information, including your postal address, email address, and telephone number;
- social security number, other government identification numbers and financial information;
- identity information such as your passport details, including your date and place of birth, and other identity numbers and documentation;
- details of your occupation, job title and 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 or proposed investment;
- information regarding your work authorization status, employment history, education history, employment or educational references, professional designations and other personal information about your qualifications;
- where legally required and permissible, you may provide information regarding your criminal history, political affiliations, gender, race/ethnicity, health, your veteran and disability status;
- other personal information such as your signature, marital status, demographics, location information, family information, beneficiaries;
- online activities such as online identifiers, IP address, device IDs, browser information, social media handle;
- information if you visit one of our offices such as video footage or visual images collected by closed circuit television CCTV located at different points on our premises (our usual practice is to automatically overwrite CCTV footage after a period of 30 days); and
- in connection with our Private Investors Portal, you may provide your name, login credentials; telephone number, facsimile number, email address, mailing address, and responses to security questions.
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 and to invite you to participate in events;
- manage your (or the organization that you represent) investment in a DBRG fund;
- respond to and communicate with you about your requests and questions;
- operate, evaluate, improve and protect our business;
- perform data analyses and other processing;
- protect against identify theft and prevent fraud and other criminal activity (including through anti-money laundering and other due diligence checks), claims and other liabilities;
- identify and prevent physical security-related issues, such as identifying and deterring unauthorized entry into our facilities and restricted zones;
- 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 process your personal information to enter into or to perform a subscription contract with you; to comply with our legal obligations; or because we have a legitimate interest in doing so, in order to pursue one or more of the purposes that we have set out above.
Please read the our separate Cookies and Tracking Technologies Policy for information about how we use cookies on our website.
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 and with whom we have written agreements in place. 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).
DBRG is an international group of companies, headquartered in the U.S., and it has funds, affiliates and service providers, and relationships with counterparties and governmental authorities, all over the world. This means that we may transfer your personal information to locations outside of your local country. Where we transfer personal information subject to UK, European Union, Singapore or any other international privacy laws to our service providers, other organizations involved in the management of the relevant fund or our affiliated companies in those countries, we do so on the basis of data transfer agreements or other appropriate safeguards designed to protect the privacy of your information, in line with applicable legal requirements.
We do not sell your personal information to any third parties or share your personal information with third parties for cross-context behavioral advertising or to use for their own marketing or other purposes.
How Long We Keep Your Information
The period for which we will keep your personal information will vary depending on the information and the purpose for which we are using it. We will process your personal information for as long as is necessary the purposes for which it was originally collected or to comply with our legal and regulatory obligations.
Your Rights
In certain circumstances and where permitted by applicable data protection laws and regulations you may have the right to:
- Access: Access the personal information we hold about you, including obtaining a copy of such information and certain details about its processing;
- Correction: Update or correct any inaccurate or incomplete information that we hold about you. If you identify any inaccuracies in your personal information please contact us so that we may promptly update our records;
- Objection: Object to our processing of your personal information or asking us to stop processing it in some circumstances, for example, if we are using it for a legitimate business interest, direct marketing or targeted advertising purposes;
- Erasure: Delete your personal information from our records if it is no longer needed to meet the purposes mentioned above and we do not have a legal obligation or valid reason to continue to use or retain it;
- Restriction: Restrict our processing of information we hold about you where you have contested its accuracy, for a period of time allowing us to verify such accuracy;
- Portability: Transfer your personal information to other organizations in a commonly used electronic format (where this is possible);
To submit a request related to your rights please contact us as indicated in the How To Contact Us section of this Privacy Policy. We may request certain information from you in order to verify your identity and confirm that you have the right to access the personal information you are requesting, or exercise any of the other rights mentioned above.
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.
How To Contact Us
If you have any questions about this Privacy Policy, or if you would like to exercise your privacy rights as described in this Privacy Policy, please contact us at:
DigitalBridge Investment Management, LLC
750 Park of Commerce Drive, Suite 210
Boca Raton, FL 33487
Attention: Data Protection Team
Email: dataprotectionteam@digitalbridge.com
Telephone: +1 561-570-4644
Updates To Our Privacy Notice
This Privacy Policy may be updated periodically to reflect changes in our personal information practices. We will notify you of any significant changes to this Privacy Policy via the channel we typically use to communicate with you or 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.