AEW Privacy Statement

Last Updated: June 30, 2023

AEW is committed to maintaining the confidentiality, integrity, and security of personal data in our control. This Privacy Statement describes the personal identifiable information we collect, why, and how we collect that information. Additionally, this statement describes what AEW does to keep personal identifiable information private and secure. Please direct any personal identifiable information requests or question regarding this Privacy Statement to DataPrivacy@aew.com or 1-844-612-7994.

In some cases, we may provide you with additional or supplemental privacy statements with additional details about our privacy practices. These additional statements will control to the extent there is a conflict with this Privacy Statement, with respect to your personal information that is subject to that additional notice. For example, this Privacy Statement does not apply to the personal information that we collect that is subject to the Gramm-Leach-Bliley Act, and we will provide you with a separate statement to the extent we collect such personal information from you.

If you are a resident of California, Singapore, the European Economic Union, or the United Kingdom, please also refer to the Additional Privacy Information for Certain Jurisdictions section below, which includes additional information about privacy rights for residents of certain jurisdictions.

Personal Identifiable Information

Personal identifiable information (PII), also referred to as "personal data," means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data Collected

In the ordinary course of business, we may collect and use personal data with respect to our relationship(s) involving our clients, prospective clients, and other third parties. AEW only collects personal data that is relevant for our business purposes.

We collect data from the following sources:

Client Intake Process - Data we receive from clients (or third parties authorized by the client to provide information) in investment management agreements, subscription agreements or other forms, which may include the client’s name and address, social security or tax identification number, total assets and other information.
Website Analytics - application which provides high level website traffic data and your browsing information, such as cookies and pixel tags.
Direct Data - data received directly from the individual, such as their name, email, telephone number, etc.
Client History - Data about client transactions with AEW including transactional activity and balances in accounts with us.

How We Use Your Personal Data and Why

We treat personal data in a confidential manner. Generally, we collect, use, disclose and otherwise process the personal data we collect for the following purposes:

Services and support. To evaluate a request for products or services, administer such products or services, process transactions on behalf of clients, communicate with you about your use of the products and services, provide troubleshooting and technical support, fulfill your orders and requests, and for similar service and support purposes.
Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes
Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events.
Research and surveys. To administer surveys and questionnaires, such as for market research or client satisfaction purposes.
Security and protection of rights. To protect the Services, our products and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
General business and operational support. To consider and implement business transactions such as financings, and other operations related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

Disclosures of Personal Data

AEW does not sell personal data to any third parties. AEW will not share your information with third parties for marketing purposes. Consistent with the foregoing, AEW may disclose personal data when we believe it necessary to conduct our business, when directed by the client to do so, where disclosure is required by law, and as follows:

Vendors and service providers. Personal data may be disclosed to others to enable them to provide business services for us such as, performing general administrative activities for us and assisting us in processing a transaction on behalf of a client. Personal data may also be disclosed for audit or research purposes. AEW requires that vendors and service providers who have access to personal data treat that information as confidential and not use it for any purpose other than to carry out the services they have been contracted to perform on behalf of AEW.
Affiliates. We may disclose personal data we collect to our affiliates who will use and disclose this personal data in accordance with the principles of this Privacy Statement.
In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a acquisition or disposition of assets or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal data as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.
Compliance and legal obligations. We may also disclose personal data to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws.
Security and protection of rights. We may disclose personal data where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of our services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Use. We may also disclose information, including personal data, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

Cookies and Analytics

We and our third-party service providers use cookies and analytics to automatically collect information through our website. We use this information to, for example, analyze and understand how users access, use and interact with our website, as well to identify and resolve bugs and errors on our website and to assess secure, protect, optimize and improve the performance of our website and Services. You have certain choices about our use of cookies, as described in this section.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others are used to enable a faster log-in process, support the security and performance of the website and services, or allow us to track activity and usage data within the website.

Analytics. Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) from our website in order to provide us with reports and metrics that help us to evaluate usage of our website and services and to improve performance and user experiences. You can learn more about how Google uses data at www.google.com/policies/privacy/partners/ in the section titled, "How Google uses data when you use our partners' sites or apps.”

Managing Your Preferences. We make available certain ways for you to manage your preferences regarding cookies on our website. Such preferences are browser and device specific, which means that you need to set the preference for each browser and device you use to access our website; in addition, if you delete or block cookies, you may need to reapply these preferences.

Cookie preference manager. You can review or change your preferences for nonessential cookies and tags on our websites by adjusting your cookie settings preferences by clearing your browsing history and relaunching our website; you will be offered an option to “accept” or “deny” all but necessary cookies. These settings are browser and device specific. We do not collect targeting cookies on our website.
Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our website who disable cookies will be able to browse the website, but some features may not function.

Children/Minors

Our Services are not designated for children/minors and we do not knowingly collect personal data from children under 18 years old. If we discover that a child under 18 years old has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us at DataPrivacy@aew.com or 1-844-612-7994.

How We Protect Your Personal Data

AEW employees are required to protect the confidentiality of personal data. We maintain physical, electronic and procedural safeguards, as appropriate, to protect personal data. Please be aware that despite our efforts, no data security measures can guarantee security.

How You Can Access and Update Your Personal Data

The accuracy of your information is important. Please direct any personal identifiable information requests or question regarding this Privacy Statement to DataPrivacy@aew.com or 1-844-612-7994

Keeping You Informed

If you have any questions regarding AEW’s policies and procedures involving personal data, please feel free to contact your client relationship manager, DataPrivacy@aew.com or 1-844-612-7994 .

Changes to this Privacy Statement

This Privacy Statement is current as of the Effective Date set forth above. We may change this Privacy Statement from time to time, so please be sure to check back periodically. We will post any updates to Privacy Statement on this site www.aew.com/privacy.

Additional Privacy Information for Certain Jurisdictions

Privacy Notice and Policy for California Residents→

Privacy Statement - Singapore Addendum →

Privacy Statement - EEA and UK Addendum →