I. Overview
Hudson Advisors L.P., Hudson Americas L.P., Hudson Homes Management LLC, Hudson Homes Management (CT) LLC, Hudson Homes Management NJ LLC, Northsight Management LLC, and Northsight Management Solutions LLC(collectively, “Hudson Advisors”) comply with the EU-U.S. Data Privacy Framework (the “EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce (both frameworks collectively referred to in this policy as the “DPF”). Hudson Advisors has certified to the U.S. Department of Commerce that it adheres to the DPF Principles for the processing of personal information related to natural persons from the European Union or the United Kingdom (“Data Subjects”) transferred to the United States. If there is any conflict between the terms in this Data Privacy Framework Privacy Policy (this “Policy”) and the DPF Principles, the DPF Principles shall govern. For more information about the DPF program, and to view Hudson Advisors’ certifications please visit https://www.dataprivacyframework.gov/s/.
Hudson Advisors’ practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply, as appropriate, with the DPF Principles of notice, choice, accountability for onward transfer, access, security, data integrity and purpose limitation, and recourse, enforcement and liability. Hudson Advisors is committed to processing all Personal Data received from the European Union and the United Kingdom in accordance with the DPF program to the DPF Principles.
For the purposes of this policy, “Personal Data” means any information that (i) is transferred to Hudson Advisors in the U.S. from the EU, UK, or Switzerland, (ii) is recorded in any form, and (iii) relates to an identified or identifiable Data Subject.
II. How Hudson Advisors Obtains and Uses Personal Data
In the course of running our business and performing services for our clients, Hudson Advisors obtains and processes certain Personal Data about Data Subjects, including without limitation, names, addresses, assets, liabilities, income, employers, bank account information, family member information, net worth, date of birth, and other information as required to comply with applicable laws or regulations. Hudson Advisors uses this Personal Data to conduct due diligence, asset manage investments made by our clients, and comply with legal and regulatory obligations. Hudson Advisors may share Personal Data with third parties, including our clients; service providers, including but not limited to legal advisors, auditors, and accountants; financial institutions; insurance companies; and judicial, regulatory or governmental authorities, for the purposes indicated in this Policy.
III. Notice
Hudson Advisors complies with the DPF Notice Principle by providing information in this Policy regarding our practices with Personal Data, including the purposes for which we collect and use Personal Data.
IV. Choice
By using the email address provided in the “Questions” section below, Data Subjects may opt out of disclosures of their information by Hudson Advisors either (i) to third parties or (ii) if the information is used for purposes which are materially different from the purposes for which it was originally collected or subsequently authorized by the Data Subject. With respect to sensitive information (as defined in the DPF), Hudson Advisors will obtain Data Subject’s opt-in consent prior to disclosures either (i) to third parties or (ii) if the information is used for purposes which are different from the purposes for which it was originally collected or subsequently authorized by the Data Subject.
V. Accountability for Onward Transfer
If Hudson Advisors shares Personal Data with certain third parties for the purposes set out in the Policy, Hudson Advisors may be liable if those parties process that Personal Data in a manner that is inconsistent with the DPF Principles. Hudson Advisors may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
VI. Access
Data Subjects may (a) access their Personal Data that is retained by Hudson Advisors; and (b) request for Personal Data to be corrected, amended, or deleted where it is inaccurate or used in violation of the DPF Principles. To request access to, or exercise these other rights relating to your Personal Data, please contact us using the information provided in the “Questions” section below. Access may be limited or denied, for example, if it would violate the rights of other individuals. Hudson Advisors may charge a reasonable fee for such access requests, as permitted under the DPF.
VII. Security
Hudson Advisors takes reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. Hudson Advisors complies with the DPF Security Principle through Hudson Advisors’ Information Security Policy.
VIII. Data Integrity and Purpose Limitation
Hudson Advisors complies with the DPF Data Integrity and Purpose Limitation principles by taking reasonable steps to ensure that the Personal Data we process is (i) relevant for the purposes of processing, (ii) reliable for its intended use, and (iii) accurate, complete and current. These steps include relevant provisions of Hudson Advisors’ Record Retention Policy.
IX. Recourse, Enforcement, and Liability
Hudson Advisors commits to comply and cooperate with the DPF Recourse, Enforcement, and Liability Principle. We will take steps to remedy issues arising out of our failure to comply with the DPF Principles. Please contact us using the information provided in the “Questions” section below to address any DPF-Principles based complaints regarding Hudson Advisors’ collection and use of Personal Data in reliance on the DPF. Hudson Advisors has designated JAMS to address unresolved DPF-related complaints and provide appropriate recourse free of charge to the Data Subject. Data Subjects may contact JAMS at https://www.jamsadr.com/dpf-dispute-resolution. In certain circumstances, Data Subjects may be able to invoke binding arbitration with respect to adherence to the DPF. Hudson Advisors is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
X. Contact for Questions
XI. Date Issued
November 2023
