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Investor Data Privacy Notice

Last updated: September 18, 2026

Why are you seeing this notice?

  • We may process Personal Data as part of your or another’s investment into a fund or other investment vehicle (as applicable, the Fund) managed or advised by investment advisers or management companies that are subsidiaries of Blackstone Inc. or its affiliates (and, where applicable, the general partner of the relevant Fund) (collectively, Blackstone). This notice (the Data Privacy Notice) explains how and why we use, store and otherwise process your Personal Data in such contexts (including under applicable data protection laws). Blackstone also maintains other privacy notices which may also apply to our processing of your Personal Data in other contexts (such as our U.S. Customer Privacy Notice, our website Privacy Notice, or any other privacy notice we make available to you), and a Cookie Notice which describes how and why Blackstone uses cookies and related technologies. Please refer to those notices for further information, including in respect of when they apply.
  • If this notice (the Data Privacy Notice) has been made available to you, you may have certain rights with respect to your Personal Data under applicable data protection laws (including as described in this Data Privacy Notice).
  • “Personal Data” has the meaning given to it under data protection laws that apply to our processing of your personal information, and includes any information relating to an identified or identifiable individual (such as name, address, date of birth, personal identification numbers, sensitive personal information including social security or government ID number, and economic information).
  • We ask that investors promptly provide the information and disclosures contained in this Data Privacy Notice to any individuals whose Personal Data they provide to the Fund or its affiliates in connection with “know your client” / anti-money laundering requests or otherwise.

Please read the information below carefully. It explains how and why Personal Data is processed by us.

Who is providing this notice?

Blackstone is committed to protecting and respecting your privacy. Blackstone is a global financial services firm with offices, branches, operations and entities globally, including as described at this link:

  • For transparency, the Blackstone entities on whose behalf this privacy statement is made are: (i) the Fund; and (ii) where applicable, the Blackstone general partner, manager and/or investment adviser of the relevant Fund, in each case, with which you contract, transact or otherwise share Personal Data (together, the Fund Parties).
  • Where we use the terms “we”, “us” and “our” in this Data Privacy Notice, we are referring to the Fund and the Fund Parties.
  • Please consult your subscription documents, private placement memorandum or other offering documentation provided to you by or on behalf of the Fund Parties which will further specify the entities and contact details of the Fund Parties relevant to our relationship with you.
  • We welcome investors and their representatives to contact us if they have any queries with respect to the Fund Parties (in particular, which Fund Parties are relevant to their relationship with Blackstone). If you have any queries, please see the ‘Contact Us’ section below.

When you provide us with your Personal Data, each Fund Party that decides how and why Personal Data is processed acts as a “data controller”. In simple terms, this means that the Fund Party makes certain decisions on how to use and protect your Personal Data — but only to the extent that we have informed you about the use or are otherwise permitted by law.

Where your Personal Data is processed by an entity controlled by, or under common control with, the Blackstone entity/ies managing a Fund for its own purposes, this entity will also be a data controller.

What personal data do we collect about you?

The types of Personal Data that we collect and share in the context of your investment in a Fund or other investment vehicle depend on the product or service you have with us and the nature of your investment. The Personal Data we collect about you may include:

  • Contact information, such as name, e-mail and postal address, and phone number;
  • Demographic information, such as date and place of birth, gender, place of residence, nationality, and citizenship;
  • Government-issued identification numbers provided in connection with a subscription to Funds, such as Social Security number, driver’s license number, passport number, national identification number, and tax identification number (which is necessary for regulatory compliance, including “know your client”, terrorist financing, sanctions, and anti-money laundering checks, and/or to verify identities to a high degree of accuracy such as to prevent financial fraud or criminal conduct);
  • Professional or employment-related information, such as the name of your employer or the organization you represent and your position, and details of any directorship or other offices you may hold, including your professional profile (including but not limited to public profiles you maintain on third-party social media sites such as LinkedIn);
  • Financial and tax information, such as information related to your transactions with us or others, bank account details (e.g., account and routing number), financial account history, information concerning the source of funds used for investments, and details regarding your investment history (e.g., types and amounts of investments) assets, income, and financial returns and positions, and other information contained in self-certification tax forms;
  • Investment information, including your investment preferences and risk aversion;
  • Information related to background checks (e.g., “know your client”, anti-money laundering and sanctions checks) and any information related to applicable restrictions on your investments, such as political exposure, excuse rights, or sanctions;
  • Information collected in the context of monitoring and surveillance where permitted or required by applicable law, including recordings of telephone and video calls and CCTV;

  • Other information as we may inform you about in other privacy notices or otherwise; and

  • Other information you or the organization you represent choose to provide, such as through eligibility questionnaires and ongoing investor relations communications.

We may also collect, store, and use the following more sensitive types of personal data:

  • Information about your political opinions (such as your status as a politically exposed person);

  • Information about your criminal convictions, allegations, proceedings and offences, including the results of any due diligence checks and any information relating to disqualifying events; and

  • Your biometric information, for example if we apply facial recognition technology to CCTV footage at any premises you visit.

We will only process such sensitive personal data to the extent required or permitted by applicable law.

We may combine Personal Data that you provide to us with Personal Data that we collect from you, or about you from other sources, in some circumstances. This will include Personal Data collected in an online or offline context.

Where do we obtain your personal data?

In the context of your investment in a Fund or other investment vehicle, we collect Personal Data about you from a number of sources, including:

Where do we obtain your personal data?

In the context of your investment in a Fund or other investment vehicle, we collect Personal Data about you from a number of sources, including:
What How
Personal data that you give us
  • From the forms and any associated documentation that you or your authorized representative complete when subscribing for an investment, shares, interests, and/or opening an account with us. This can include information about your name, address, date of birth, passport details or other national identifier, driving license, your national insurance or Social Security number and income, employment information and details about your investment or retirement portfolio(s), and financial-related data (such as returns and financial positions)
  • When you provide it to us in correspondence and conversations, including electronic communications such as e-mail and telephone calls
  • When you make transactions with respect to the Fund
  • When you purchase securities from us and/or tell us where to send money
  • When we need to identify you and/or complete necessary security checks, where you visit one of our buildings or attend meetings. This can include form of ID, and your image for CCTV purposes.
Personal data that we obtain from others We may obtain Personal Data from:

  • Publicly available and accessible directories and sources
  • Bankruptcy registers

  • Service providers
  • Tax authorities, including those that are based outside the territory in which you are located or domiciled, including the Cayman Islands, the United Kingdom (UK) and the European Economic Area (EEA), if you are subject to tax in another jurisdiction
  • Governmental and competent regulatory authorities to whom we may have regulatory obligations

  • Law enforcement
  • Credit agencies
  • Fraud prevention and detection agencies / organizations
  • Transaction counterparties

  • Other investors

Where do we obtain your personal data?

In the context of your investment in a Fund or other investment vehicle, we collect Personal Data about you from a number of sources, including:
What
Personal data that you give us
Personal data that we obtain from others

Why do we process your personal data?

In the context of your investment in a Fund or other investment vehicle, we may process your Personal Data for the following reasons and/or purposes (and further as we may inform you about otherwise):

Why do we process your personal data?

In the context of your investment in a Fund or other investment vehicle, we may process your Personal Data for the following reasons and/or purposes (and further as we may inform you about otherwise):
Why How
Contract It is necessary to perform our contract with you to:

  • Consider and make decisions about your subscriptions to the Fund

  • Admit you to the Fund (including undertaking client and investor due diligence)

  • Administer, manage and set up your investor account(s) to allow you to purchase your holding (of shares or interests) in our Funds

  • To administer and manage your investment, including (i) to contact you to make capital calls; (ii) to report on the performance and governance of the Fund; (iii) to make payments or distributions; (iv) to provide requested investment services and related support services; and (v) to perform any other obligations in or relating to your subscription agreement

  • Meet the resulting contractual obligations we have to you
  • Facilitate the continuation or termination of the contractual relationship between you and the Fund
  • Facilitate the transfer of funds, and administering and facilitating any other transaction, between you and the Fund
  • Enter into, administer or perform any other contract or agreement we have with you
Compliance with law It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject, in order to:

  • Undertake our client and investor due diligence, and onboarding checks

  • Ensure the protection of personal data and other information, property and assets in our possession
  • Carry out verification, “know your client”, terrorist financing, sanctions, and anti-money laundering checks
  • Verify the identity and addresses of our investors (and, if applicable, their beneficial owners)
  • Cooperate with, and comply with requests from, regulatory, governmental, tax and law enforcement authorities, including by undertaking internal investigations, and complying with our reporting, filing and other regulatory obligations
  • Carry out surveillance and investigations
  • Carry out audit checks

  • Comply with our legal and regulatory record-keeping requirements, including to maintain statutory registers
  • Prevent and detect fraud and other unlawful acts
  • Comply with sanctions requirements
  • Comply with any other obligations to which we are subject under applicable rules and laws
Legitimate Interests For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to:

  • Manage and administer your holding in any Funds in which you are invested, and any related accounts on an ongoing basis
  • Provide and improve our services and business offerings
  • Assess and process any applications or requests made by you
  • Provide support and communicate with you
  • Open, maintain or close accounts in connection with your investment in, or withdrawal from, the Fund scheme
  • Send updates, information and notices or otherwise correspond with you in connection with your investment in the Fund scheme
  • Address or investigate any complaints claims, proceedings or disputes
  • Exercise, establish, protect or defend legal rights, property and safety, including to enforce our agreements and policies and to respond to suspected illegal activity and threats to our systems and services
  • Provide you with our investment products and services
  • Send you marketing communications about our investment products and services (including serving you relevant ads online)
  • Monitor and improve our relationships with investors
  • Verify information you have provided and perform appropriate client and investor due diligence
  • Comply with applicable prudential and regulatory obligations, including anti -money laundering, sanctions and “know your client” checks
  • Assist our transaction counterparties to comply with their regulatory and legal obligations (including anti-money laundering, “know your client”, terrorist financing, and sanctions checks)
  • Manage our risk and operations
  • Comply with our accounting and tax-reporting requirements
  • Comply with our audit requirements
  • Assist with internal compliance with our policies and processes
  • Ensure appropriate group management and governance
  • Provide information to a potential purchaser of all or a part of our business
  • Keep our internal records
  • Prepare reports on incidents / accidents
  • Protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law)
  • Analyze and manage commercial, financial and investment risks
  • Seek professional advice, including legal advice
  • To manage insurances, complaints, potential and actual claims
  • Enable any actual or proposed assignee or transferee, participant or sub -participant of the partnership’s or Fund vehicles’ rights or obligations to evaluate proposed transactions
  • Facilitate business asset transactions involving the Fund or Fund-related vehicles or business

  • Carry out surveys

  • Monitor communications to/from us using our systems

  • Protect the security, integrity and business continuity of our information technology systems

  • Protect the security and safety of our buildings and locations where we operate

  • Operate, run and schedule online meetings, webinars and conferences (for example, using Zoom and other online meeting platforms)

  • Manage our financing arrangements with our financiers and financing transaction counterparties, including payment providers, intermediaries, and correspondent / agent banks

  • Monitor the operation of Fund distribution platforms, where these are operated by third parties or service providers


We only rely on these interests where we have considered that, on balance, the legitimate interests are not overridden by your interests, fundamental rights or freedoms.

Why do we process your personal data?

In the context of your investment in a Fund or other investment vehicle, we may process your Personal Data for the following reasons and/or purposes (and further as we may inform you about otherwise):
Why
Contract
Compliance with law
Legitimate Interests

Monitoring as described in ‘Legitimate Interests’ above

We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.

Who we share your personal data with

In the context of your investment in a Fund or other investment vehicle, we may share your Personal Data as follows:

Who we share your personal data with

In the context of your investment in a Fund or other investment vehicle, we may share your Personal Data as follows:
Who Why
Fund Associates We share your Personal Data with our associates, related parties and members of our group. This is:

  • To manage our relationship with you
  • For the legitimate interests of a third party in carrying out anti -money laundering, ‘’know your client’’, and other compliance checks required of them under applicable laws and regulations
  • For the purposes set out in this Data Privacy Notice

  • Delivering the services you require
Fund Managers, Depositories, Administrators, Custodians, Distributors, Investment Advisers
  • Managing your investment
  • Supporting and administering investment-related activities
  • Complying with applicable investment, anti-money laundering and other laws and regulations

  • For the purposes set out in this Data Privacy Notice
Tax Authorities
  • To comply with applicable laws and regulations
  • Where required or requested by tax authorities in the territory in which you are located or domiciled (in particular, Cayman Island or UK/EEA tax authorities) who, in turn, may share your Personal Data with foreign tax authorities
  • Where required or requested by foreign tax authorities, including outside of the territory in which you are located or domiciled (including outside the Cayman Islands or UK/EEA)
Service Providers
  • Delivering and facilitating the services needed to support our business relationship with you (including cloud services)
  • Supporting and administering investment-related activities
  • Where disclosure to the service provider is considered necessary to support Blackstone with the purposes described in this Data Privacy Notice
Financing Counterparties, Lenders, Correspondent and Agent Banks
  • Assisting these transaction counterparties with regulatory checks, such as ‘know your client’, and anti-money laundering procedures
  • Sourcing credit for Fund-related entities in the course of our transactions and fund life cycles
Our Lawyers, Auditors and other Professional Advisers
  • Providing you with investment-related services
  • To comply with applicable legal and regulatory requirements
  • Supporting Blackstone with the purposes described in this Data Privacy Notice
Partners and counterparties in corporate transactions, and their professional advisors
  • In connection with the possible sale or restructuring of all or part of our or Blackstone’s business
Social media providers and digital advertising platforms
  • To serve you digital ads with offers for our products and services
Others, including your representatives, agents, and advisors
  • At your direction

Who we share your personal data with

In the context of your investment in a Fund or other investment vehicle, we may share your Personal Data as follows:
Who
Fund Associates
Fund Managers, Depositories, Administrators, Custodians, Distributors, Investment Advisers
Tax Authorities
Service Providers
Financing Counterparties, Lenders, Correspondent and Agent Banks
Our Lawyers, Auditors and other Professional Advisers
Partners and counterparties in corporate transactions, and their professional advisors
Social media providers and digital advertising platforms
Others, including your representatives, agents, and advisors

In the context of your investment in a Fund or other investment vehicle, we may also share your Personal Data for any other purposes set out in this Data Privacy Notice, as otherwise disclosed to you, or as permitted by applicable law.

In exceptional circumstances, where we are required to do so by law, to enforce our agreements and policies and to respond to suspected illegal activity and threats to our systems and services, or as necessary or advisable to exercise, establish, protect or defend legal rights, property, and safety, we will share your Personal Data with:

  • Competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in a country or region; and
  • Other organizations and agencies.

Do you have to provide us with this personal data?

Where we collect Personal Data from you in the context of your investment in a Fund or other investment vehicle, we will where relevant indicate if:

  • Provision of the Personal Data is necessary for our compliance with a legal obligation; or
  • It is purely voluntary and there are no implications for you if you do not wish to provide us with it.

Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.

Some of the Personal Data that we request is necessary for us to perform our contract with you, and if you do not wish to provide us with this Personal Data, it will affect our ability to provide our services to you and manage your investment.

Sending your personal data internationally

We may transfer your Personal Data between different countries or regions to recipients in countries or regions other than the country in which the information was originally collected (including to our affiliates and group members, members of the Fund’s partnership, transaction counterparties, and third -party service providers). Where you are based in the UK, the EU, or another country or region which imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA”) or that geographical area, to those countries or regions in which our affiliates, group members, service providers and business partners operate. Those countries or regions may not have the same data protection laws as the country or region in which you initially provided the information.

Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of our group, our service providers or another third -party recipient located in a different territory, we will ensure that our arrangements with them are governed by data transfer agreements or other appropriate safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent). Please contact us if you would like to know more about these agreements or receive a copy of them. Please see the ‘Contact Us’ section below for details.

Consent – and your right to withdraw it

Except as may otherwise be required by local law, we do not generally rely on obtaining your consent to process your Personal Data. In particular, we do not generally rely on obtaining your consent where our processing of your Personal Data is subject only to the data protection laws of the UK/EEA (in these circumstances we will usually rely on another legal basis more appropriate in the circumstances, including those set out in “Why do we process your Personal Data?” above). If we do rely on consent for processing of your Personal Data, you have the right to withdraw this consent at any time. Please contact us or send us an e-mail at [email protected] at any time if you wish to do so.

Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes. If you do receive direct marketing communications from us (for example, by post, e -mail, fax or telephone), you may opt out by clicking the link in the relevant communication, completing the forms provided to you (where relevant), or by contacting us (see the ‘Contact Us’ section for details).

Retention and deletion of your personal data

We keep your Personal Data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations or, where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us. We will generally:

  • Retain Personal Data about you throughout the life cycle of any investment you are involved in; and
  • Retain some Personal Data after your relationship with us ends.

As a general principle, we do not retain your Personal Data for longer than we need it. We will usually delete your Personal Data (at the latest) after you cease to be an investor in any fund and there is no longer any legal / regulatory requirement, or business purpose, for retaining your Personal Data.

Rights, Choices, and Complaints

Subject to applicable law, you have the right to request access to, or rectification or erasure of, the personal data we maintain about you, to request the restriction of, or object to, the processing of your personal data, and request we export the personal data we process about you to another company. Where we rely on your consent under applicable law, you may withdraw your consent at any time. Subject to applicable law, the withdrawal of your consent may be subject to legal or contractual restrictions and reasonable notice. Additional rights may be available to you under applicable law.

To submit a rights request, you can use our online form or contact us as indicated below, and we will respond as required by applicable law.

If you have a complaint or grievance regarding the processing of your personal data, including if you believe there has been an infringement of applicable data protection law, you may submit a complaint or grievance by using our online form (for individuals based in the UK only) or by contacting us as indicated below, and we will respond as required by applicable law. In addition, you may have the right to complain to the body regulating data protection in your country, but we recommend that you contact us first so we can try to resolve your issue. Subject to applicable law, you may be required to go through our complaints and grievance procedure before contacting the body regulating data protection in your country.

Please also contact us via any of the contact methods listed below if you have a disability and require an alternative format of this Data Privacy Notice

CCPA Notice

We are providing this supplemental CCPA notice ( “CCPA Notice”) pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively the “CCPA”). This CCPA Notice only applies to Personal Data that is considered “personal information” as defined under CCPA and subject to the CCPA (namely, personal information of California residents who are employees or personnel of our institutional
investors). In particular, the CCPA and this CCPA Notice do not apply to Personal Data which is collected, disclosed, or otherwise processed pursuant to and subject to the Gramm-Leach-Bliley Act (“GLBA”), such as Personal Data of individual investors acting in their personal capacity. Supplemental information regarding our processing of Personal Data subject to the GLBA (including for individual investors acting in their personal capacity) is found in ou r U.S. Investor Data Privacy Notice.

For purposes of this CCPA Notice, the terms “sell”, “share”, and “consumer” shall have the meanings set forth in the CCPA. Please visit our California Consumer Privacy Statement located at  https://www.blackstone.com/privacy/california-consumer-privacy-statement/ for more information, including the rights and choices that may be available to California residents
under the CCPA.

Categories of Personal Data collected. The categories of Personal Data to be collected about you in the context of your employer’s investment in a Fund or other investment vehicle are described in the section above titled “What personal data do we collect about you?” and may include:

  • Identifiers, such as name, e-mail and postal address, and telephone;
  • Information as defined by Cal. Civ. Code § 1798.80 , including state identification card number and financial information;
  • Protected classifications, such as national origin, gender and citizenship status;
  • Biometric information, for example, if we apply facial recognition technology to CCTV footage at a premises you visit;

  • Internet or other electronic network activity information, including your use of our websites and investor platform;
  • Inferences drawn from any of the information identified above, to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities, and aptitude;

  • Professional or employment related information, such as the name of your employer or the organization you represent and your position, and details of any directorship or other offices you may hold, including your professional profile (including but not limited to public profiles you maintain on third party social media sites such as LinkedIn); and

  • Sensitive Personal Data, such as citizenship, social security number, passport number, drivers’ license, or state identification card number.

    Purposes for which the categories of Personal Data are collected and used. The purposes for which the categories of Personal Data are collected and used are provided in the section above titled “Why do we process your personal data?” and may include meeting our contractual obligations with our customers or clients, compliance with applicable laws, and any of the business purposes set forth in Cal. Civ. Code § 1798.140(e).

    Whether we “sell” or “share” Personal Data. In the context of Personal Data we process about you when you represent an institutional investor in a Fund or other investment vehicle, we may disclose your Personal Data to third parties (such as online advertising services) or allow such third parties to collect your Personal Data via automated technologies on our websites and apps, in both cases for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” or “sharing” of your Personal Data. You have the right to opt out of these types of disclosures of your information. We may “sell” or “share” the following categories of Personal Data about you to online advertising services: (i) identifiers; (ii) commercial information; (iii) online activity; and (iv) inferences.

    Retention of Personal Data. We will retain your Personal Data for the time period described in the “Retention and Deletion of your Information” section of the Data Privacy Notice.

    Supervisory Authorities

    The following supervisory authorities may be contacted in applicable jurisdictions:

    Supervisory Authorities

    The following supervisory authorities may be contacted in applicable jurisdictions:
    Location Supervisory Authority
    Cayman Islands Cayman Islands Ombudsman (available at: https://ombudsman.ky)
    European Union A list of the EU data protection authorities and contact details is available by clicking this link.
    United Kingdom Information Commissioner’s Office (available at: https://ico.org.uk/global/contact-us/)

    Supervisory Authorities

    The following supervisory authorities may be contacted in applicable jurisdictions:
    Location
    Cayman Islands
    European Union
    United Kingdom

    Contact Us

    Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.

    Contact us by e-mailing [email protected].

    Contact us in writing using this address:

    Contact Us

    Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.

    Contact us by e-mailing [email protected].

    Contact us in writing using this address:
    Address
    For EU/UK Related Queries 40 Berkeley Square
    London
    W1J 5AL
    United Kingdom
    For All Other Queries 345 Park Avenue
    New York
    NY 10154

    Contact Us

    Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.

    Contact us by e-mailing [email protected].

    Contact us in writing using this address:
    For EU/UK Related Queries
    For All Other Queries

    A list of country or region specific addresses and contacts for locations where we operate is available at www.blackstone.com/privacy/online-privacy-notice/#appendixA.

    Changes to this data privacy notice

    We keep this Data Privacy Notice under regular review. We reserve the right to update this Data Privacy Notice at any time. Please check regularly for any updates on our homepage (www.blackstone.com/privacy/investor-data-privacy-notice/), or at our investor portal (www.bxaccess.com). We may also notify you in other ways from time to time about the processing of your Personal Data.