Private Markets Solutions Provider

Hamilton Lane Advisors, L.L.C. and its affiliates (collectively, “Hamilton Lane”) respect your concerns about privacy. This Privacy Notice describes the types of personal information we collect, how we use the information, with whom we may share it and the rights and choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.

This Privacy Notice applies to all products and services offered by Hamilton Lane, including our website, https://www.hamiltonlane.com/en-us, and other websites and mobile apps that link to this Privacy Notice (the “Online Services”), except where the product or service has a separate privacy statement that does not incorporate this Privacy Notice.

Hamilton Lane also provides certain individuals in the United States with supplemental privacy notices, as described below:

U.S. Consumer Privacy Notice: If you are an individual investor who has a financial product or service with Hamilton Lane for personal, family or household purposes, please see our U.S. Consumer Privacy Notice, which federal law requires us to give to certain consumers to explain what we do with their personal information, how we may share it and how the law allows consumers to limit our sharing of the information.
Notice for California Residents: If you are a California resident, please see our California Consumer Privacy Statement.

Information We Obtain

The types of personal information we obtain include:

Contact information, such as name, email, postal address, and phone number;
Account information, such as login information, account preferences and other account details;
Business-related information, such as the name of your employer or the organization you represent and your position;
Demographic information, such as date and country of birth, nationality, and citizenship;
Government-issued identification numbers provided in connection with a subscription to funds, such as Social Security/Insurance number, driver’s license number, passport number, national identification number, and tax identification number;
Professional or employment-related information;
Details regarding investor status (e.g., accredited investor or qualified purchaser), investment experience, expertise and strategy, and risk tolerance;
Financial information, such as information related to your transactions with us or others, bank account details (e.g., account and routing number), financial account history, information concerning the source of funds used for investments, and details regarding your investment history (e.g., types and amounts of investments) assets, income, and financial returns and positions;
Preferences regarding investments and communications (including marketing communications);
Information in connection with background checks, such as any information related to applicable restrictions on your investments (e.g., political exposure);
Other information provided in subscription agreements, related eligibility questionnaires and documentation provided in connection with your subscription to funds (e.g., “know-your-customer” documentation or U.S. tax forms);
Records of calls, electronic communications and other interactions with us and our service providers, including call recordings;
Information you provide in the course of applying for a job with us, such as details about your education, work and military history, legal work eligibility status, and background check information;
Information collected in connection with visits to our offices or events;
Social media information, such as your social media handle;
Other information you choose to provide, such as through investor relations communications, if you are an investor.

Personal information that you provide directly to us will be apparent from the context in which you provide it, for example, if you (1) fill out a form on our Online Services; (2) sign up to receive electronic communications from us; (3) login to and/or register for one of our client portals; (4) submit an account application or enter into a contract (e.g., a subscription or investment advisory agreement) with us; (5) attend one of our events; or (6) otherwise engage in correspondence with us. Please note that if you do not provide us with personal information that we request, we may not be able to provide you with our products or services or process your request.

We also may obtain personal information about you from third-party sources, including (1) the organization you represent (e.g., if you are a representative of an institutional investor); (2) publicly available sources (e.g., bankruptcy registers); (3) governmental authorities (e.g., tax authorities); (4) credit agencies; (5) fraud prevention and detection organizations; (6) transaction counterparties; and (7) social media networks, such as when you communicate with us through a social media website.

Information We Obtain By Automated Means

When you use our Online Services, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your IP address, unique device identifier, web browser and device characteristics and settings, WiFi network identifiers and signal, operating system, battery signal and strength, language preferences, referring URLs and emails, usage statistics, website, clickstream data, actions taken on mobile apps, and dates and times of visits.

We use these automated technologies on our Online Services to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Online Services; (3) tailor the Online Services around your preferences; (4) measure the usability of our Online Services and the effectiveness of our communications; (5) authenticate your identity, protect against fraud and provide our products and Online Services; and (6) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Online Services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

For more information about how we process personal information collected via cookies and other automated technologies, please visit our Cookie Policy.

How We Use The Information We Obtain

We process your personal information as necessary to perform our contractual relationship with you, including to:

Provide you with our products and services;
Establish, manage and administer investment accounts and subscriptions;
Verify your identity and authenticate your access to our products and services;
Process and fulfill transactions;
Facilitate and administer the transfer of funds;

We use the personal information we obtain for the following legitimate interest purposes:

Communicate with you, respond to inquiries, and offer customer support in connection with our products and services;
Establish, manage, and improve our business relationships;
Evaluate, process and fulfill potential or actual investments or other transactions;
Prepare investor disclosure materials;
Manage and organize meetings and events;
Assist our transaction counterparties and lenders with their legal obligations and due diligence;
Operate, evaluate, and improve our products, services and business (including administering our Online Services; developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; analyzing our client base and products and services; performing data analytics; and performing accounting, auditing and other internal functions);
Perform market research and administer surveys;
Inform you about, and advertise and market, our products and services;
Personalize your experience with us and determine the effectiveness of our advertising and marketing;
Manage career opportunities, including conducting recruitment and talent management activities;
Maintain and enhance the safety and security of our products and services and prevent misuse;
Exercise our rights and remedies and defend against legal claims;
Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
Comply with and enforce applicable legal requirements, regulatory obligations, relevant industry standards and Hamilton Lane policies, such as undertaking investor due diligence and background checks, carrying out verification, and reporting to credit bureaus.

In accordance with applicable law, we take reasonable measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we can explain upon request.

Where required by applicable law, we will obtain your consent to process your personal information for the purposes listed above and to send you electronic marketing communications, however, certain exceptions may apply depending on jurisdiction.

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

Third Party Analytics Services

We may use third-party analytics services on our Online Services, such as Google Analytics. The information we obtain through the Online Services may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners. To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Interest-Based Advertising

On our Online Services, we and our third-party advertising partners may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This section of our Privacy Notice provides details and explains how to exercise certain choices.

You may see our ads on other websites and online services because we use third-party ad services. Through these ad services, we can tailor our messaging to individuals considering demographic data, inferred interests and browsing context. These services track information about your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services may collect data about your visits to websites and apps that participate in these services, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Online Services and on third-party websites and apps that participate in these ad services. These ad services use this information to show you ads that may be tailored to your individual interests. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices, www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com. To learn how to opt out of interest-based advertising in the E.U., please visit https://youronlinechoices.eu. For more information about interest-based advertising in Canada, and to understand your options, including how you can opt-out of receiving interest-based ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. Our Online Services are not designed to respond to “Do Not Track” signals from browsers.

How We Share The Information We Obtain

We may share your personal information with our affiliates and subsidiaries for any of the purposes described above. We also may share your personal information with our professional advisors (e.g., auditors, accountants, law firms, and other consultants) and third-party service providers who perform services on our behalf (e.g., data analytics, IT storage and support, marketing, security, and fraud prevention). We do not authorize our service providers to retain, use, or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements.

We (and our third-party service providers, including affiliates) also may disclose personal information (1) if we are required or permitted to do so by law or legal process (such as a court order, subpoena or other legally valid inquiry or order), which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities; (2) in response to requests by government agencies, such as law enforcement authorities; (3) to another organization for the purpose of investigating a breach of an agreement or contravention of law; (4) to establish, exercise or defend our legal rights; (5) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (6) in connection with an investigation of suspected or actual illegal activity; or (7) otherwise with your consent.

We reserve the right to transfer any personal information we have about you in the event of an actual or proposed sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation). If this occurs, we will inform you of the identity and contact information of the receiving party to the extent required by applicable law.

Your Choices and Rights

We offer you certain choices in connection with the personal information we collect from you. You can unsubscribe from our marketing emails by clicking the “Unsubscribe” link in the emails.

If you are a California resident, please see our California Consumer Privacy Statement for more information about your rights with respect to your personal information.

Depending on where you are located and subject to applicable law, you also may have the following rights in connection with the personal information we process about you:

The right to access and obtain a copy of your personal information;
The right to correct, update and rectify inaccuracies in information we have about you;
The right to object to the processing of your personal information on grounds relating to your particular situation;
The right to have your personal information “erased” or to restrict the processing of such information;
Where you have given us your consent, the right to withdraw consent for future processing of your information (subject to reasonable prior notice and applicable legal or contractual restrictions). If you withdraw your consent, we may not be able to provide our products and services to you; or
The right to request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.

If you wish to exercise any of these rights, please email us at privacy@hamiltonlane.com. We will respond to your request in a reasonable time. You may have the right to file a complaint with a data protection authority if you are not satisfied with our response. We may also require specific information from you to help us confirm your identity and process your request.

Data Transfers

We (or our third-party service providers) may transfer, access, store or otherwise process personal information we collect about you to recipients in countries other than the country (or province, if you are located in Canada) in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will comply with applicable legal requirements regarding the transfer of personal information.

If you are located in the EEA, the United Kingdom or Switzerland, we will comply with applicable legal requirements by providing adequate protection for the transfer of your personal information to recipients outside of these regions. To the extent that these data recipients are in countries that have not been recognized by the European Commission or relevant body as providing an adequate level of data protection, we ensure that appropriate safeguards aimed at ensuring such a level of data protection are in place, including by entering into the European Commission’s EU Standard Contractual Clauses (“SCCs”) and, where applicable, the UK Addendum to the EU SCCs, with the data recipients. To obtain a copy of the safeguards we have put in place, please contact us at privacy@hamiltonlane.com.

If you are located in Mainland China, we will comply with applicable legal requirements under the Personal Information Protection Law (“PIPL”) and implementing rules issued by the Cyberspace Administration of China (“CAC”) regarding the transfer of personal information outside of China. Where required by applicable law, we will undergo a data transfer security assessment or execute the CAC’s standard contract for cross-border transfers with the overseas recipient of personal information.

Retention of Personal Information

We will keep your personal information for the time period necessary to achieve the purposes outlined in this Privacy Notice (as applicable), plus a reasonable period to comply with the applicable statute of limitations or if otherwise required under applicable law.

How We Protect Personal Information

We have implemented and maintain administrative, technical and physical safeguards designed to protect personal information in our custody and control against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children’s Personal Information

Our Online Services are designed for a general audience and are not directed to children. In connection with our Online Services, we do not knowingly collect personal information from children under the age of 13 or such other age as may be directed by applicable law. If we become aware that we have inadvertently received personal information from a child under the age of 13, or such other age as may be directed by applicable law, we will delete such information from our records.

Third-Party Services and Features

Our Online Services may provide links to other online services (such as websites or social media platforms), and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Hamilton Lane, we are not responsible for these third parties’ information practices.

Privacy Governance Policies and Practices

We are committed to protecting your personal information and have implemented a set of policies and practices that govern our treatment of personal information, including:

a framework that sets out the roles and responsibilities of our personnel in connection with the handling of personal information in our custody and control;
policies and procedures regarding the protection of personal information, including with respect to the implementation of security safeguards designed to protect personal information against loss or theft and unauthorized access, disclosure, copying, use, and modification;
processes for responding to data subject requests and complaints in a timely and effective manner;
a framework for the retention and disposition of personal information designed to ensure compliance with our legal obligations, including the destruction or anonymization of personal information when it is no longer required.

Updates To This Privacy Notice

We may update this Privacy Notice from time to time and to reflect changes in our personal information practices. We will post a notice on our relevant Online Services to notify you of material changes to the Privacy Notice 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 Notice or the manner in which we, or our service providers on our behalf, treat your personal information, please contact us at privacy@hamiltonlane.com.