Privacy Notice

Evolution Investment Management LLC (“EIM”, “EvolutionIM”, “we”, “us”, or “our”) is an registered investment advisor and asset manager of real estate private equity investments. This Privacy Policy describes how EIM collects, uses, discloses and otherwise processes personal information from individuals who visit our website (the “Website”), or who obtain information about us or otherwise interact with us, both online and offline.
This Privacy Policy does not address the information we collect from investors in EIM funds or other individuals who receive financial products or services from us, either in their individual capacity or on behalf of a business (“Investors”).
Personal information you may provide:
  • Contact information, such as your name, email address, mailing address, and phone number.

  • Account information, such as your age, occupation, login information, and Social Security number where required by law.

  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.

  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us, including your full name, email address, telephone number and the content of your communications.

Automatic data collection. We and our service providers (such as our investor portal operator) may automatically log information about you, your computer or mobile device, and your interaction over time with our Website, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area.

  • Online activity and usage data: When you access and use the Website, we receive and store information about such interactions such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

How we use your personal information
We use the personal information collected above for the following purposes:
  • Operating the Website, to perform any contract we have with you in accordance with our Terms of Use, including allowing you to create and use an account on the investor portal.
  • To support our online services, and to improve, monitor usage of and protect the Website, in accordance with our legitimate interests, including:
    • responding to your requests, providing customer support, contacting you in case of any issue with your account, and sending you announcements, updates, security alerts, and support and administrative messages;
    • protecting, investigating and deterring fraudulent, harmful, unauthorized or illegal activity in order to keep our Website safe and secure for our users, including conducting authenticating your identity, troubleshooting, testing and research; and
    • improving, monitoring and analyzing trends and use of our Website, including anonymizing or aggregating personal information in a form that does not allows users to be identified.
  • To comply with a legal obligation, for example to keep records of transactions, to verify your identity, or as requested by any judicial process or governmental agency.
  • To send you direct marketing communications, including notifying you of investment opportunities, subject to consent where required.
How we share your personal information
We do not sell personal information. We share personal information with the following categories of recipients:

Affiliates. We share personal information within EIM and with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy. Our affiliates include funds with an Evolution name and any company that is a member of Evolution Investment Partners LLC.

Service providers. We share personal information with third party companies and individuals that provide services on our behalf or help us operate our Website (such as customer support, portal hosting, email delivery, marketing, identity verification, fraud detection, and database management).

Professional advisors. We disclose personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We share personal information for compliance, fraud prevention and safety purposes described above.

Legal. We share personal information with law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of EIM, users, a third party, or the public.

Business transfers. We may share personal information in connection with a corporate transaction (or potential transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your rights and choices

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the “Contact Us” section below.

Children’s privacy

Our Website is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Website from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us using the contact information set out in the “Contact Us” section below.

Retention of personal information

We endeavor to retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our policies and with applicable laws, based on factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and the purposes for which we use personal information.

Security practices
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Notice at any time and we will notify you of any changes when required by applicable law. Please review this Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Cookie Policy

We and our service providers use anonymous identifiers such as cookies and other technologies to collect and store certain types of information about you (e.g., click stream information, browser type, time and date and session ID) whenever you interact with us or third-parties that use our services. Cookies are small files stored directly on the computer or device that you are using that can collect the information described above.
Contact Us

If you have any questions, comments or complaints about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by phone at 512-615-5610, by email at