Online Privacy Policy

Effective date: May 23, 2018

This Online Privacy Policy is issued on behalf of Principal Real Estate Limited (Principal Real Estate).

The Online Privacy Policy applies to our website. By using our website you are consenting to the practices described in this Online Privacy Policy, including the use of cookies as described below.

Please note: Depending on the nature of our relationship with you (e.g., you are a client, investor, potential investor, business partner or business contact), we may collect and use information that we receive directly from you or from sources other than through the website — to review how we collect and use this information, click here.

Information we collect about you through the website.

  • Information you provide to us.

We collect information that you volunteer to us through our website forms, such as name and email address.

  • Information we collect through cookies (“Cookie Policy”).

We allow third-party companies, including Google Analytics and others, to use cookies to collect certain usage information when you visit our website. This usage information helps us analyze visitor activity on our website. Usage information may include, for example, such things as your IP address, browser type, device type, operating system, application version, time zone setting, and the preceding page views.

Cookies are used to store information on your computer and are a way to have your web browser “remember” specific bits of information about your previous visits to our website. They are designed to help you have a better user experience within our website, and we use the information to improve our site content and site functionality.

We use two types of cookies, “session” and “persistent”. Session cookies are temporary and expire when you leave our website or are inactive for a specified length of time. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently. Persistent cookies store your preferences for a website, are stored on your computer, and are read by your browser each time you visit the website. They therefore enable the website to “recognize” you on your return, remember your preferences, and tailor services to you.

During some visits to our website we may collect session information, including page response times, download errors, what time you visited our website, how long you were on our website, if you’ve been to the website before, what web pages you visited, page interaction such as scrolling, clicks, and mouse overs, what type of browser you used to access our website and methods to browse away from the page. This information helps us identify ways to modify and improve our website.

Principal Real Estate considers the information collected through our website valuable. At this time, Principal Real Estate does not respond to do-not-track signals or similar technologies sent by a browser setting. However, visitors will continue to have the ability to control cookie settings for Principal Real Estate’s website. The information we receive from your web browser and device may or may not be personally identifiable.

The information we collect may depend on your web browser settings. Most browsers (Chrome, Safari, Firefox, Internet Explorer, etc.) automatically accept cookies, but you can usually alter the setting of your browser to prevent that; however, doing so may limit your access to certain sections of our website.

If you do not wish to receive cookies, please refer to the help section of your browser to learn how to either block all cookies or receive a warning before a cookie is stored on your computer. In addition to altering the cookie settings on your browser, you can also install the Google Analytics Opt-out Add-on, which prevents Google Analytics from collecting information about your website visits.

Use of information collected through the website.

We use your information when you consent or when it is necessary for our legitimate interests, and your interests and your fundamental rights do not override those interests.

The information that we collect may be used by us in the following ways:

  • To provide you information and services that you request, such as our newsletter;
  • To provide you marketing materials and other information about us or about services that may be of interest to you;
  • To comply with our legal and regulatory obligations;
  • To administer the website and for internal operations, including troubleshooting, system and security updates, data analysis, testing, research, statistical and survey purposes;
  • To improve the website to ensure that content is presented in the most effective manner for you and for your computer; and
  • As part of our efforts to keep the website safe and secure.

We will only use your personal information for the uses and purposes set out above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original uses and purposes. If we need to use your personal information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.

Disclosure of information collected through the website.

We may share the information we collect with the following categories of recipient:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • Analytics and search engine providers that assist us in the improvement and optimisation of the website;
  • Third party support services, such as website developers and data hosting centers; and
  • Regulators, law enforcement authorities, or as otherwise required to comply with a legal obligation.

How we protect and retain your information.

We understand the importance of appropriately safeguarding information we collect. It is our practice to protect the confidentiality of this information, limit access to this information to those with a business need, and not disclose this information unless required or permitted by law.

We have security practices and procedures in place to protect data entrusted to us. These procedures and related standards include limiting access to data and regularly testing and auditing our security practices and technologies.

All employees are required to complete privacy, security, ethics and compliance training. We also offer a wide variety of other training to all employees and temporary workers to help us achieve our goal of protecting your information.

We retain your information for as long as your information is necessary for the purposes for which it was collected. To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process the data, whether we can achieve those purposes through other means, and the applicable legal requirements.

Children’s privacy.

Our website is not directed toward children. We do not knowingly collect, use or post personal information from children under the age of 13. If we determine upon collection that a user is under this age, we will not use or maintain his or her personal information without parent or guardian consent. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

Your rights.

Under certain circumstances, you have rights under EU data protection laws in relation to your personal information:

  • The right to be informed about the collection and use of your personal information;
  • The right of access to your information;
  • The right to request that inaccurate or incomplete information about you is rectified;
  • The right to request the deletion or removal of your information where there is no further reason for us to use it;
  • The right to restrict the use of your information;
  • The right to obtain and reuse the information that we have about you for your own purposes;
  • The right to object to certain uses (such as for marketing purposes); and
  • The right not to be subject to a decision that has a legal effect on you that has been based on an automated decision.

You have the right to make a complaint to the relevant data protection supervisory authority in the EU member state in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority. Our contact information is listed below.

Changes to our Online Privacy Policy.

Any changes we make to our Online Privacy Policy in the future will be posted on this page and reflected by an updated Effective Date. Please check back frequently to see any updates or changes.

Contact us.

If you have any questions about this Online Privacy Policy or if you would like to exercise any rights you may have in relation to your personal information, please contact us using the following contact details: CorpPrivacy@exchange.principal.com or Compliance Director PGIE, 1 Wood Street, London, EC2V 7JB or contact by phone in the UK at 44-20-7710-0225.

This website, the distribution of information on it and the offer or placement of interests in any fund managed by Principal Real Estate Limited (“Principal Real Estate”) or any of its affiliates (a “Fund”) may be restricted by law or regulation in certain jurisdictions. This website and the information on it is only directed at persons, and interests in any Fund will only be available for investment, to the extent that it is lawful under all applicable law and regulation to do so in any relevant jurisdiction. This website and the information on it are not addressed to any person resident in any jurisdiction where such distribution would be contrary to local law or regulation. Accordingly, visitors to this website should inform themselves about, and observe, local laws in their own jurisdiction which may restrict their ability to engage the services of Principal Real Estate or any of its affiliates, or to invest in any Fund.

In particular for investors in the European Economic Area (“EEA”), this website and the information on it is only directed at persons who are professional investors for the purposes of the Alternative Investment Fund Managers Directive (2011/61/EU) (“AIFMD”), professional clients or eligible counterparties for the purposes of the Markets in Financial Instruments Directive (Directive 2014/65/EU) (“MiFID II”) or as otherwise defined under applicable local law and regulation and at whom this website and the information on it may lawfully be directed in any relevant jurisdiction (“Eligible Persons”). In relation to each member state of the EEA (“Member State”) which has implemented AIFMD (and for which transitional arrangements are not/ no longer available), this website may only be accessed and interests in Funds may only be offered or placed in a Member State to the extent that: (i) the relevant Fund is permitted to be marketed to professional investors in the relevant Member State in accordance with AIFMD (as implemented into the local law/regulation of the relevant Member State); or (ii) this website and its information may otherwise be lawfully distributed and the interests in Funds may otherwise be lawfully offered or placed in that Member State (including at the initiative of the investor). In relation to each Member State of the EEA which, at the date of accessing this website, has not implemented AIFMD, this information may only be distributed and interests in Funds may only be offered or placed to the extent that this information may be lawfully distributed and the interests in Funds may lawfully be offered or placed in that Member State (including at the initiative of the investor).

In addition in the United Kingdom, this website and the information on it is intended only for, and is directed only at, persons who both (i) are capable of being treated by Principal Real Estate as professional clients or eligible counterparties, as each term is defined in the rules of the FCA, and (ii) fall within an exemption from Section 21 (or, in relation to communications by Principal Real Estate concerning collective investment schemes, Section 238) of the Financial Services and Markets Act 2000 (“FSMA”) in accordance with (a) Article 19 of the FSMA (Financial Promotion) Order 2005 (“FPO”) or Article 14 FSMA 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (“CIS Order”), being investment professionals having experience in relation to investments including unregulated funds, (b) Article 49 FPO or Article 22 CIS Order, being certain high net worth companies, trusts and unincorporated associations etc., or (c) being any other class(es) of person in or outside the United Kingdom to whom this website and its contents may otherwise lawfully be communicated. This website and the information on it and the opportunity to invest in the Funds is only available to such persons in the United Kingdom and this website and the information therein must not be relied or acted upon by any other persons. This website is not directed at or intended for U.S. persons and by accessing this website you represent to Principal Real Estate and its affiliates that you are not a U.S. person as defined in Regulation S under the United States Securities Act of 1933, as amended and are not acting on behalf of a U.S. person, nor purchasing with a view to re-sale in the US or to or for the account or benefit of a U.S. person.

Persons who are not Eligible Persons, including but not limited to those individuals or other persons who fall within the FCA’s definition of ‘retail clients’, should not use or rely upon this website or the information contained therein and may not engage the services of Principal Real Estate or any of its affiliates, or invest in any Fund. Potential investors are advised that all or most of the protections provided by the UK regulatory system will not apply and that the UK Financial Services Compensation Scheme may not be available in relation to an investment in a Fund or separate account.

When using this website and clicking accept below, you agree you will comply with all applicable local, national and international laws and regulations, including but not limited to those laws and regulations relating to data privacy, international communications and exportation of technical or personal data. In certain jurisdictions it may be illegal to access, view or download the information contained on the website and Principal Real Estate and its affiliates hereby disclaim all responsibility and liability if you access or download any information from this website which is in breach of any law or regulation of the jurisdiction in which you are a citizen, resident or domiciled.

This website and the information contained therein is not intended to provide the basis of any investment decision relating to Funds, products or services and any potential investor accessing this website should not solely rely on this website in evaluating the virtues of investing in any investments in such Funds, products or services referred to on this website. Any decision by a person to purchase interests in Funds, products or services must only be made following such person having thoroughly read all of the related materials to such investment including the relevant prospectus or offering memorandum for the relevant Fund and any supplements or appendices thereto, which must be received and reviewed prior to a person making any such investment decision. The relevant prospectus or offering memorandum for the relevant Fund may contain different information to the information and opinions contained on this website at any point in time. Any person purchasing an interest in a Fund, product or service referred to on this website must be able to bear the risks involved and must satisfy the relevant suitability requirements relating to such purchase of an interest in a Fund, product or service. Furthermore, some or all investment programs included on the website may not be suitable for certain investors.
The contents of this website have not been verified or approved by any competent regulatory or supervisory authority. No liability, whether in negligence or otherwise, arising directly or indirectly from the use of the information or any part of it on this website is accepted and no representation, warranty or undertaking, whether express or implied, is or will be made at any time by Principal Real Estate or its affiliates or any of their respective advisers, directors, officers, employees, representatives or other agents (“Principal Agents”) for any information or any of the opinions contained herein or for any errors, omissions or misstatements. None of Principal Real Estate or its affiliates or any Principal Agents makes or has been authorised to make any representation or warranties, whether express or implied, in relation to Principal Real Estate or regarding the truth, accuracy or completeness of any of the information contained on this website at any time. No representation or warranty is given by Principal Real Estate, its affiliates or the Principal Agents as to the achievement or reasonableness of, and no reliance should be placed on any projections, targets, estimates or forecasts contained in the information on this website. Furthermore nothing contained on this website is or should be relied on as a promise or representation as to the future. No reliance may be placed by any person for any purpose whatsoever on the information or opinions contained on this website or on its completeness, accuracy or fairness at any time.

Before accessing this website please confirm that you have understood and agree to the above and that you understand yourself to be, or be representing, an Eligible Person.