Contributing to the alleviation of homelessness in the UK, whilst targeting inflation protected income and capital returns, by investing in a diversified portfolio of assets across the UK which will provide good quality accommodation to the homeless.

Data protection policy

Home REIT plc (the "Company"), its subsidiaries and any third party service providers, functionaries, or agents appointed by the Company and acting on its behalf (together, the "Fund", "we", "us", "our") are committed to protecting your personal data and are required, by Data Protection Legislation (as defined below), to provide individuals with certain information about how we use your personal information.

This privacy policy ("Privacy Policy") explains what personal information we collect from you or you provide to us, how we use it and with whom we share that information. This Privacy Policy also sets out your rights and who you can contact for more information.

In this Privacy Policy:

For the purposes of Data Protection Legislation the data controller is the Company.

1 What information we collect about you

The Fund may collect, record and use information that personally identifies you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we, collect and process may include:

(A) Information that you provide to us

This is information that personally identifies you that you provide to us. Such information may typically include:
(B) Information that we collect or generate about you
This may include:
(C) Information we obtain from other sources

This may include information from publicly available sources, including third party agencies such as credit reference agencies, public databases, registers and records such as Companies House and the FCA Register and information obtained from sanction checking and background screening providers.

In certain circumstances, we also collect and process what are known as 'special categories' of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in the Company obtaining information about actual or alleged criminal convictions and offences.

You are not obliged to provide us with your personal data where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with the Company if you do not do so.

2 How we collect your information

The personal information we collect comes from:
3 How we use your information

Our primary purpose in collecting your personal information is to facilitate and record your holding of shares in the Company, the management and administration of your holding in the Company and any related administration on an on-going basis.

Additionally, on an ongoing basis during your relationship with us, we may use your information for the following specific purposes:
We will only use your personal information for the purposes for which it was collected unless we reasonably consider that it is necessary to use it for another reason and that reason is compatible with the original purpose.

4 Legal grounds for using your personal information

Data Protection Legislation permits us to process your personal data in the way that we do because such processing is:
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

5 Providing your information to third parties

We may share your personal information with the following categories of recipients who may receive it and process it for the purposes outlined in this Privacy Policy:
The Fund does not undertake marketing activities for third parties, nor does it provideinformation to third parties for their own marketing purposes.

6 Transferring data outside of the UK and EEA

We may transfer your personal data to locations outside your country. As such, your personal data may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") and the UK, to the extent that it is not a member of the EEA. Some of these destinations may not have data protection laws that are similar to those in the UK and EEA and may not be regarded by the relevant supervisory authorities as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information outside the UK and EEA, we will aim to ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.

7 Automated processing

We do not carry out automated decision-making or profiling based on your personal data.

8 Your rights

In the circumstances where we collect, use or store your personal information, as outlined in this Privacy Policy, you may have the following rights and, in most cases, you can exercise them free of charge:

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information of which we are made aware and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change. Failure to provide accurate information or to update changed information may have a detrimental impact on your investment in the Company.

9 How long we keep your information

We will only keep the information we collect about you for as long as required for the purposes set out in this Privacy Policy or as long as required for us to comply with any legal obligations to which we are subject being the longest of the following periods:
This will involve us regularly reviewing our files to check that information is accurate, up-to- date and still required.

10 How we protect your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal information from unauthorised access.

11 Changes to Privacy Policy

This Privacy Policy may be amended from time to time without notice, in which case the date of this Privacy Policy will be revised.

If our Privacy Policy changes in any way, we will place an updated version on our website. Regularly reviewing the Privacy Policy ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

12 Other

This Privacy Policy is for your information and should not be used as the basis for any decision to purchase or sell investments in the Company. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.

13 Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to the Company Secretary at

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

Version: 22 September 2020