I. Overview
Hudson Advisors L.P., Hudson Americas L.P. and Hudson Homes Management LLC (collectively, “Hudson Advisors”, “we” or “our”) respect your concerns about privacy. Hudson Advisors has certified that we abide by the EU-U.S. Data Privacy Framework (“EU DPF”) and the UK Extension to the EU DPF (the “UK DPF”, both frameworks collectively referred to in this Policy as the “DPF”) as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of certain Personal Data (as defined below) transferred from the European Union (the “EU”) or the United Kingdom (the “UK”) to the United States. This Policy outlines our general policy and practices for implementing the DPF Principles for the relevant Personal Data. If there is any conflict between the terms in this Policy and the DPF Principles, the Principles shall govern. To learn more about the DPF program, please visit https://www.dataprivacyframework.gov/. Hudson Advisors’ DPF certifications can be found at https://www.dataprivacyframework.gov/s/participant-search.
Hudson Advisors’ practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply, as appropriate, with the DPF Principles of notice, choice, accountability for onward transfer, access, security, data integrity and purpose limitation, and recourse, enforcement and liability.
II. Definitions
For purposes of this policy:
“Employee” means any individual acting in such individual’s capacity as a current, former, or prospective employee, contractor, or consultant of any subsidiary or affiliate of Hudson Advisors who is located in the EU or the UK.
“Personal Data” means any information that (i) is transferred to Hudson Advisors in the U.S. from the EU or UK, (ii) is recorded in any form, and (iii) relates to an identified or identifiable Employee.
III. How Hudson Advisors Obtains and Uses Personal Data
Hudson Advisors obtains and processes certain Personal Data. The Personal Data that Hudson Advisors may obtain includes, without limitation, Employees’ names, addresses, assets, liabilities, income, employer, bank account information, family member information, net worth, dates of birth, and other information as required to comply with applicable laws or regulations.
Hudson Advisors uses Personal Data for the purposes of (i) managing our human resources, including hiring, payroll, benefits, training, and performance reviews; (ii) facilitating internal communications; and (iii) complying with certain legal and regulatory obligations including anti-money laundering, fraud prevention and audit requirements, and other reporting obligations.
IV. Notice
Hudson Advisors complies with the DPF Notice Principle by providing information in this DPF Employee Privacy Policy (“Policy”) regarding our Personal Data practices, including the purposes for which we collect and use Personal Data.
V. Choice
Employees may opt out of disclosures by Hudson Advisors to third parties or for uses that are materially different from those disclosed in this Policy. To exercise this opt-out, please contact us using the information provided in the “Questions” section below. For sensitive information, as defined by the DPF, Hudson Advisors will obtain an Employees’ opt-in consent prior to disclosing such information to certain third parties or using such information for purposes different than the purpose for which it was originally collected or subsequently authorized by the Employee.
VI. Accountability for Onward Transfer
Hudson Advisors may share Personal Data with third parties, including service providers, financial institutions, insurance companies, and judicial, regulatory or governmental authorities for the purposes indicated in the “How Hudson Advisors Obtains and Uses Personal Data” section above. Hudson Advisors complies with the DPF Accountability for Onward Transfer Principle and related rules under the DPF. If Hudson Advisors shares Personal Data with certain third parties, Hudson Advisors may be liable if those parties process that information in a manner that is inconsistent with the DPF Principles.
VII. Access
Employees may (a) access their Personal Data that is retained by Hudson Advisors; and (b) request for Personal Data to be corrected, amended, or deleted where it is inaccurate or used in violation of the DPF Principles. To request access to, or exercise these other rights relating to your Personal Data, please contact us using the information provided in the “Questions” section below. Access may be limited or denied, for example, if it would violate the rights of other individuals, prejudice employee security investigations or grievance proceedings or in connection with employee succession planning and corporate re-organizations. Hudson Advisors may charge a reasonable fee for such access requests, as permitted under the DPF.
VIII. Security
Hudson Advisors takes reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. Hudson Advisors complies with the DPF Security Principle through its Information Security Policy.
IX. Data Integrity and Purpose Limitation
Hudson Advisors complies with the Data Integrity and Purpose Limitation by taking reasonable steps to ensure that the Personal Data we process is (i) relevant for the purposes of processing, (ii) reliable for its intended use, and (iii) accurate, complete and current. These steps include relevant provisions of Hudson Advisors’ Record Retention Policy.
X. Recourse, Enforcement and Liability
Hudson Advisors commits to comply and cooperate with the DPF Recourse, Enforcement and Liability Principle by establishing procedures for periodically verifying implementation of and compliance with the DPF Principles. We conduct an annual self-review or an outside compliance review of our Personal Data practices to verify that the attestations and assertions we make about our privacy practices are true and that our privacy practices have been implemented as represented.
We will take steps to remedy issues arising out of our failure to comply with the DPF Principles. Please contact us using the information provided in the “Questions” section below to address any DPF-Principles based complaints regarding Hudson Advisors’ collection and use of Personal Data in reliance on the DPF.
Hudson Advisors has designated (i) the panel established by data protection authorities (“DPAs“) to address unresolved complaints and provide appropriate recourse free of charge to EU Employees with respect to the EU DPF and (ii) the UK Information Commissioners Office (the “UK ICO”) to address unresolved complaints and provide appropriate recourse free of charge to UK Employees with respect to the UK DPF. Employees may submit inquiries or unresolved complaints concerning human resources data transferred from the EU or the UK in the context of the employment relationship under the EU DPF or UK DPF to their local DPAs or the UK ICO, as appropriate. Hudson Advisors commits to cooperate and comply with the advice of the panel established by the DPAs and the UK ICO.
Hudson Advisors is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In certain circumstances, Employees may be able to invoke binding arbitration with respect to adherence to the DPF.
Hudson Advisors may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
XI. Contact for Questions
privacy@hudson-advisors.com
XII. Date Issued
May 2026
