Privacy Policy

1. Who We Are

Barrow Street Advisors ("we," "our," or "us") is a commercial real estate capital advisory firm. We are the data controller for the personal data described in this policy.

For privacy questions, data protection requests, or anything else covered by this policy, contact us at privacy@barrowstreetadvisors.com. We aim to acknowledge within five business days and to complete formal rights requests within one month.

Information Commissioner's Office (ICO) registration: registration in progress. Our registration number will be published in this section once it is issued.

2. Scope

This policy covers personal data we process through this website and through general business contact. Personal data we process in the course of a signed advisory engagement is governed additionally by the engagement letter and any data processing terms agreed with the client, which take precedence where they are more specific.

3. Information We Collect

Information you give us:

Information we collect automatically when you visit this site:

We record this visit information in our own customer relationship system so that we can see which organizations are researching our services and how the site is used. We do not try to identify individual visitors from it, and we do not enrich it using data brokers or third party lead identification services.

Information we obtain from public and commercial sources for business development:

We use this information to contact companies, in a strictly business capacity, about commercial real estate financing that appears relevant to them. It is limited to business contact details and information about the company itself, we rely on our legitimate interests in business development as the legal basis, and every such message identifies us and includes a working way to opt out. If you opt out, we add your address to a permanent suppression list and do not contact you again.

4. How We Use It, and Our Legal Basis

Under the UK GDPR and the EU GDPR we rely on the following legal bases:

• Legitimate interests: responding to enquiries, providing advisory services, understanding how the site is used, protecting the site against fraud and abuse, and business development in a commercial context. You may object at any time.
• Performance of a contract: delivering services under a signed engagement and administering that relationship.
• Consent: sending market commentary to subscribers, and sending SMS messages where you have given a mobile number for that purpose. You may withdraw consent at any time.
• Legal obligation: meeting record keeping, tax, anti money laundering, and other regulatory requirements that apply to us.

5. Cookies and Analytics

We keep tracking on this site deliberately minimal. We use privacy oriented traffic and performance analytics provided by our hosting platform, which measures page views and site performance without advertising cookies and without cross site profiling. We do not run advertising networks, retargeting pixels, or social media tracking pixels here, and we do not sell or share data for advertising.

You can block or delete cookies through your browser settings. Doing so will not stop you using this site.

6. Who We Share It With

We do not sell, rent, or trade personal data. We share it only as set out below, and only with providers bound by written data processing agreements that hold them to our documented instructions.

• Cloud hosting and content delivery providers, which serve this website and store its data
• Business email and productivity providers, through which enquiries reach us and correspondence is held
• Customer relationship and business development systems, which hold our contact records and the site visit information described above
• Document processing and analysis providers, used to extract and structure figures from transaction documents during an engagement
• Electronic signature and secure file transfer providers, used to exchange and execute documents
• Professional advisors such as lawyers and accountants, where they need the information to advise us
• Capital providers and their advisors, but only the transaction information a client has instructed us to share in order to arrange financing
• Law enforcement, regulators, or courts, where we are legally required to disclose
• A counterparty to a corporate transaction such as a merger or acquisition, subject to equivalent protections

We keep a current list of the providers we use and will supply it on request to clients and to anyone exercising a data protection right.

7. Where We Process It

We operate across the United States and the United Kingdom, so personal data may be processed in either. For individuals in the United Kingdom or the EEA, and for transaction documents originating there, our standing commitment is that processing takes place within the United Kingdom and the EEA, and that transaction content does not leave that boundary without an appropriate safeguard in place.

Where a transfer outside the United Kingdom or the EEA is necessary, we rely on one or more of the following: an adequacy decision or adequacy regulations covering the destination; the UK International Data Transfer Addendum to the EU Standard Contractual Clauses; or the EU Standard Contractual Clauses. Copies of the relevant safeguards are available on request.

We do not permit personal data or client transaction content to be handled by providers domiciled in jurisdictions we have assessed as unacceptable for client confidentiality. That restriction is enforced in our systems, not only in policy.

8. Automated Analysis of Transaction Documents

During an engagement we use automated systems to read transaction documents such as rent rolls, operating statements, and leases, and to structure the figures they contain. These documents can carry personal data about tenants and guarantors.

• We configure these providers so that the content we send them is not retained, and the terms we contract on prohibit using it to train their models.
• No document content is used to train any model, ours or anyone else’s.
• Automated extraction is a drafting aid, not a decision maker. Every figure is reviewed by a person before it reaches a lender or a client, and no financing decision about an individual is made by automated means alone.

9. How Long We Keep It

• Website enquiries that do not become an engagement: up to 24 months from your last contact with us.
• Market commentary subscribers: we keep your email address for as long as you remain subscribed, and we act on any unsubscribe request as soon as we receive it.
• Client and engagement records: for the life of the relationship and then seven years, to meet legal, tax, and professional record keeping requirements.
• Site visit records: up to 24 months.
• Transaction documents supplied by a client: for the term agreed in the engagement, then returned or deleted on request, subject to any retention we are legally required to apply.

10. Security

We apply technical and organizational measures appropriate to the sensitivity of what we handle, including encryption in transit and at rest, access limited to those who need it, multi factor authentication on business systems, system access logging, and written processing terms with our providers. No system is completely secure. Where a breach requires it, we will notify the affected individuals and the relevant supervisory authority.

11. Your Rights

If you are in the United Kingdom or the EEA, you have the right to:

• Access the personal data we hold about you, and receive a copy
• Have inaccurate data corrected
• Have your data erased, in the circumstances the law provides for
• Restrict how we process your data
• Object to processing carried out on the basis of legitimate interests
• Receive your data in a portable format, where processing is automated and based on consent or contract
• Withdraw consent at any time, without affecting processing carried out before you withdrew it

To exercise any of these, email privacy@barrowstreetadvisors.com. There is no charge, and we will not treat you differently for asking.

You also have the right to complain to a supervisory authority. In the United Kingdom that is the Information Commissioner's Office (ico.org.uk, helpline 0303 123 1113). We would ask you to raise it with us first so we have the chance to put it right. Residents of California and other US states with comprehensive privacy laws have equivalent rights of access, correction, and deletion, which we honor through the same contact route.

12. SMS and Mobile Communications

If you provide your phone number through our deal submission form, you may receive SMS messages from Barrow Street Advisors regarding your inquiry, including application updates, document requests, and appointment confirmations. Message frequency varies. Message and data rates may apply. Consent to receive SMS is not a condition of service. You may opt out at any time by replying STOP to any message. Reply HELP for assistance.

Your mobile information will not be sold or shared with third parties for promotional or marketing purposes.

13. Children

Our services are provided to businesses and professional investors. This site is not directed at children, and we do not knowingly collect personal data from anyone under 18.

14. Changes to This Policy

We may update this policy from time to time. The date at the top of this page shows when it last changed. Where a change materially affects how we use your personal data, we will tell you directly if we hold contact details for you.

15. Contact Us

Questions about this policy, or about how we handle personal data, should go to privacy@barrowstreetadvisors.com.