This Privacy Policy was last updated on 13th October 2020. Updates made to information
on Section "DATA TRANSFERS – INTERNATIONAL USERS"
This
Privacy Policy applies to information we collect through: (1) the
Greystar websites operated by Greystar Worldwide, LLC and its affiliates
(referred to herein as "Greystar", "we", "us", or "our"),; (2) other
websites and online services that we own, operate, or make available and
that
link to the Privacy Policy and (3) to all other general
enquiries we receive (including postal mail, electronic mail, telephone
requests and in person).
Greystar recognizes the importance of
protecting the privacy of individual-specific information that
identifies, relates to, describes, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer or device (“Personal Information”)
particularly our consumer users (referred to as "you" or "your" in this
Privacy Policy). This Privacy Policy describes what Personal Information
we gather, how we use it, how it
is shared and how you can correct,
change and limit our use of it. if you are asked to submit registration
details via this site, you may be requested to agree to additional terms
regarding our use of your Personal Information, and those additional
terms will apply in that context. Any additional terms will be provided
for your review at the time of registration. We encourage you to read
this Privacy Policy before you send or share Personal Information
with us or use our websites. We also encourage you to read it again when you return to our websites.
WHAT PERSONAL INFORMATION DOES GREYSTAR COLLECT?
We
collect the Personal Information described in general terms below. For
greater detail, we have set out in Annex 1 details of the categories of
Personal Information we have processed over the last twelve (12) months.
The
type of Personal Information we collect will depend upon what we will
need to provide you with the product or service you are interested in.
Prospective
residents may be asked to provide the following information: first and
last name, primary phone number, email address, the apartment size you
are looking for (number of bedrooms, number of bathrooms), where you
want to live (e.g., city and state or community name), the type of
building you prefer, your proposed rent budget, move-in date, desired
lease term, and whether or not you have pets (if so, what type), and any
additional comments you wish
to provide.
Current residents of
one of our residential communities may be asked to provide an apartment
number, first and last name, phone number, email address, reason for
contacting us, and any additional comments.
Our residential
communities may have their own separate sites and we may use separate
sites for the processing of rental applications and agreements and to
assist our residents with other tasks which are required or helpful to
them, such as paying rent online. You will move away from this site when
engaging in those activities and those sites will have their own
privacy policies, and so please review that privacy policy before using
those separate sites. See also Third-Party
Site Links below.
For
those interested in booking corporate housing stays, you can view
available listings on our Greystar general websites. We use separate
sites for booking corporate stays and you will be redirected to those
websites, which have their own privacy policy.
For
those interested in applying for employment at Greystar, the following
Personal Information may be requested or obtained: name and address, age
or date of birth, email address, occupation, employment information,
telephone number, educational background and Social Security/national
insurance number, credit checks, background checks and employment
verification. Where legally required, we will obtain your consent before
undertaking these checks.
Once a candidate accepts a position,
the candidate may be asked to complete further online details. This may
include an invitation to self-identify ethnicity or race. This
information is only collected in relation to positions in some
jurisdictions and we do this to meet government reporting requirements.
Provision of this information by candidates is voluntary and it is not
collected where it would be unlawful for us to do so.
We may
receive information about you, including Personal Information, from
third parties. For example, if you are on another website and you opt-in
to receive information from us, that website will forward to us your
email address and other information about you so that we may contact you
as requested.
USAGE TRACKING: USE OF IP ADDRESSES
An
IP address is a number that is automatically assigned to your computer
whenever you are using the Internet. Web servers, the main computers
that serve up web pages, automatically identify your computer by its IP
address. As permitted under applicable law, Greystar collects IP
addresses for the purposes of system administration, gathering and
analyzing aggregated information, creating a better experience for users
and auditing the use of our sites. We do not normally link IP addresses
to anything personally identifiable, which means that your session will
be logged, but you remain anonymous to us. We will seek to link your IP
address when we feel it is necessary to protect our sites and other
users from harm and to prevent criminal misconduct. Please see the section on Use of "Cookies."
USE OF "COOKIES"
Cookies
are pieces of information that a website transfers to an individual for
record-keeping purposes. Cookies make web use easier for you by saving
your preferences while you are at our sites. The use of cookies is an
industry standard, and as such, you will find them at most major
websites. By showing how and when users use a site, cookies help us see
which areas are popular and which are not. Many improvements and updates
to our sites are based on such data as total number of visitors and
pages viewed. This information is most easily tracked with cookies. We
use the information from cookies only to provide services better
tailored to your needs and for the protection of our websites and users
from potential harm. We never save passwords or credit card information
in cookies.
We use persistent tracking cookies on our websites
which are cookies that stay in your web browser between visits. These
cookies can also be used to show us which sites you have visited before
entering our sites and which sites you may go to if you leave,
especially if you access the registered user parts of our sites by using
your social media log-in credentials. We use these to capture
analytical information about our visitors that helps us to improve the
performance of our
website and create a better experience. These
cookies allow us to recognize and count the number of visitors, to
provide content related to a prior visit to our websites, to see how
visitors move around the sites and the products and services they are
interested in when they are using them and to see what other types of
products and services they may be interested in. This helps us to
improve the way our websites work, for example by making sure users are
finding what
they need easily.
We may also use cookies which
allow us or third parties to advertise our products and services on
websites that you access after you have visited our sites. You may also
see advertisements from us if other websites you visit capture through a
cookie that you have been on our sites.
These ad preference cookies
are often used by search engine sites. Our cookies can be disabled as
indicated below. To prevent this advertising, you may also need to
review the cookies disabling information on the other sites you visit.
Most
browsers are set up to accept cookies. If you want to change your
cookie preferences, you can do so through your browser settings or
refuse the cookies when you enter any of our websites. You may also
limit the information we gain from certain cookies by logging directly
into the registered areas of our sites rather than by logging in by
using your social media log-in credentials. Please remember that our
cookies are often used to give you certain functionality and without
them you may not be able to use some of our websites e.g. save
properties from our listings.
You can also remove cookies that have already been set in your browser via your browser settings.
WHAT INFORMATION DO WE SHARE OR DISCLOSE?
Generally,
Greystar will not disclose Personal Information except when we have
your permission or under special circumstances, such as when we believe,
in good faith, that the law requires our disclosure. We may also
disclose Personal Information for business operations as described
below.
We do not share your Personal Information with third parties, unless:
- Such information is shared following receipt of a specific request and/or permission from users;
- Such
information is shared with affiliated companies and/or potential
investors (in any form of business transaction, including purchase or
merger) pursuant to an agreement which contains reasonable
confidentiality arrangements;
- Such information is shared with
contractors who work with us pursuant to an agreement which contains
reasonable confidentiality arrangements;
- Such information is
shared to comply with or in accordance with any applicable law and/or
court orders and/or to prevent suspected illegal acts, frauds,situations
involving potential threats to the safety of any person, or as
otherwise required by law. This includes responding to lawful requests
by public authorities, including to meet national security or law
enforcement requirements;
- Such information is shared to help
Greystar defend against claims and/or establish or exercise any legal
right that Greystar may have;
- Such information is shared to help
Greystar prevent violations of the Greystar Terms of Use and this
Privacy Policy or to otherwise protect the rights, property, or safety
of Greystar employees, residents and other persons others, including
exchanging information with third parties for fraud protection and
credit risk reduction.
BUSINESS TRANSITIONS
If
Greystar goes through a business transition, such as a merger, being
acquired by another company, or selling all or part of its assets,
users' Personal Information will, in most instances, be part of the
assets transferred. By using our websites and providing your Personal
Information, you consent to this transfer, provided use of the Personal
Information will remain in accordance with the Privacy Policy in place
at the time of the transfer.
THIRD-PARTY SITE LINKS
You
should be aware that when you are on a Greystar website you could be
directed to other third-party sites that are beyond our control,
including, without limitation, to the websites of residential
communities. There are links to other sites from Greystar, which take
you outside our service. For example, if you "click" on a banner, an
advertisement or a search result, the "click" may take you off the
Greystar sites. These other sites may include sites of other
advertisers, sponsors and partners that may use their logo with ours as
part of a co-branding agreement.
These other sites may send their
own cookies to visitors to collect data or solicit information.
Greystar does not control these sites and therefore is not responsible
for their content. The inclusion of hyperlinks to any other sites by
Greystar does not imply any endorsement of the material on such sites,
nor any association with their operators.
Greystar policies do
not extend to anything that is inherent in the operation of the
Internet, which is beyond our control. Remember that whenever you give
out Personal Information online, that information may be collected and
used by people you do not know.
SECURING INFORMATION
Greystar
takes reasonable technical and organizational measures in accordance
with applicable laws to safeguard users' Personal Information. While
Greystar strives to protect your Personal information and therein your
privacy, we cannot guarantee the security of any Personal Information
you disclose online, and you therefore disclose such Personal
Information at your own risk.
We limit access to Personal
Information to those individuals and organizations who we believe
reasonably need to receive such information to provide our services or
to do their jobs, and we take the precautions we deem reasonable to
protect the security of users' Personal Information.
However, as in
many computer systems, internet applications and software programs,
unauthorized use, failure of hardware or software, etc. may be injurious
to the confidentiality of users' Personal Information.
Because
the security of all Personal Information associated with our users is of
utmost concern to us, we periodically review and improve our security
when new technology becomes available. This includes use of software
which encrypts (generally processed at 256 bits) or distorts data
submitted to us relating to an online Rental Application or employment
application. If users have any questions about security, please contact us using the information in the "Contact Information" section.
EMAIL CONSENT AND OPT-OUT
Your
provision of Personal Information through any of our registration forms
on our sites constitutes your affirmative consent that we may contact
you by email to provide you with information and notices relating to the
property where you reside, on various similar services available to you
at or through that property and on various other properties that may be
available and of interest to you in the future. It also means we may
email you regarding updates to this Privacy Policy.
You may
choose to opt out of receiving future commercial email messages from us.
Each mass commercial email sent by us contains a link with instructions
on how to remove yourself from our email list. Please note that if you
are a resident of a Greystar community and you use this site and your
community site, you will need to opt-out of your community site
separately. You will also need to opt-out separately from any
third-party sites you have registered with. Please see the section on Third-Party Site Links.
CHILDREN'S PRIVACY
Our
websites are not directed at children. We do not collect or maintain
information at our sites from those we know are under 16, and we do not
permit children under 16 years of age to become registered users of our
sites. By using any of our sites, you represent that you are not under
16 years of age. If you are a parent or guardian and you believe that
your child under age 16 may have provided personally identifiable
information through any of our websites, please
contact us using the information in the "Contact Information" section
DATA TRANSFERS – INTERNATIONAL USERS
If
you provide Personal Information to us, it may be transferred to and
processed on computers in the U.S. and other countries. Do not provide
your Personal Information to us if you do not want this information to
be transferred outside of your country, or if the laws in your country
restrict
these types of transfers.
For
users residing in the European Economic Area or the United Kingdom,
Greystar relies on the European Commission approved Standard Contractual
Clauses (controller-to-controller) (2004/915//EC) to govern the
transfer of Personal Information from these countries to countries
outside of the European Economic Area and/or the United Kingdom.
CORRECTING AND DEACTIVATING PERSONAL INFORMATION
You
may have the right under applicable privacy laws to request that
Greystar inform you as to whether Personal Information relating to you
is being processed. Subject to certain exceptions under applicable
privacy laws, you may also have the right to request that Greystar
correct, supplement, delete or block your Personal Information if the
data are factually inaccurate, incomplete or irrelevant to the purposes
of the processing activities or if the Personal Information is being
processed in any other way which infringes a legal provision. If you
wish to exercise your rights or if you have any questions or suggestions
regarding the use, collection, or security of your Personal
Information, please contact us using the contact details in the "Contact
Information" section.
When
a request for user deletion is received, we will make all reasonable
efforts to purge said data from our systems. Due to the nature of our
services, some information may not be fully removed (e.g., backups or
archived copies. Following a deletion request, any Personal Information
about you that was not deleted from our systems due an exception under
applicable privacy laws will only be used for the purposes provided for
by the applicable exceptions (e.g., to
continue performing a contract that you have with us).
NOTICE TO CALIFORNIA RESIDENTS
The
California Consumer Privacy Act (“CCPA”) provides California residents
with certain rights regarding their Personal Information. These rights
and the methods for exercising them are described in more detail below.
Please note that this section applies only to and the rights described
in it can only be exercised by residents of California.
Description of Rights
- Right to Opt-Out of Sale
- Greystar does not sell your information to third parties.
- Right to Know
- You
have the right to request that we disclose that Personal Information
about you that Greystar collects, uses, discloses, and sells (if any at
all). Once we receive and confirm your verifiable consumer request, we
will disclose to you:
- The categories of information we have collected about you.
- The categories of sources for the Personal Information we have collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- If
we sold or disclosed your Personal Information, we will let you know
and list the categories of Personal Information that were disclosed or
sold to third parties for a business or commercial purpose.
- Whether or not we sell the Personal Information of minors under 16 years of age without affirmative consent.
- Greystar’s
response to requests to know (either the categories or specific pieces
of Personal Information) will only cover the 12-month period preceding
the request.
- Right to Delete
- You
have the right to request that Greystar delete any Personal Information
that we collected from you and retained, subject to certain exceptions.
Once we receive and confirm your verifiable consumer request, we will
delete (and direct service providers to delete) your Personal
Information from our records. Greystar may deny your deletion request if
retaining the information is necessary for us or our service providers
to:
- Complete the transaction for
which the Personal Information was collected, provide a good or service
already requested by the consumer or reasonably anticipated to be
requested, taking into account our ongoing relationship with the
consumer, or to otherwise perform a contract between us and the
consumer.
- Detect security incidents, protect against malicious,
deceptive, fraudulent, or illegal activity; or to prosecute those
responsible for that activity.
- Debug to identify and repair errors that impair existing functionality.
- Exercise
free speech, ensure the right of another consumer to exercise his or
her free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act.
- Engage
in public or peer-reviewed scientific, historical, or statistical
research in the public interest, if the deletion of the information is
likely to render impossible or seriously impair the achievement of such
research, if the consumer has provided informed consent.
- Enable
solely uses that are reasonably aligned with the expectations of the
consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise
use the consumer’s Personal Information, internally, in a manner that
is compatible with the context in which the consumer provider the
information.
- Right to Non-Discrimination
- Greystar
will not discriminate against a consumer for exercising any of their
privacy rights under the CCPA by doing any of the following:
- Denying goods or services.
- Charging different prices or rates for goods or services, including applying discounts or imposing penalties.
- Providing a different level or quality of goods or service.
- Suggesting
that a consumer will receive a different price or rate for goods or
services or a different level or quality of goods and services.
Exercising Your Rights
- How to Exercise Your Rights
- To exercise any of your rights described above, please submit a request to Greystar by either:
- Calling us at 1-877-862-2797
- Following this link to our online request portal.
- Only
you, or a person registered with the California Secretary of State that
you have authorized to act on your behalf, may make a verifiable
consumer request related to your Personal Information. You may, however,
make a verifiable consumer request on behalf of your child.
- Greystar
cannot respond to your request or provide you with Personal Information
if we cannot verify your identity or authority to make the request and
confirm the Personal Information relates to you. All requests must:
- Provide
enough information for us to reasonably verify you are the person about
whom we collected Personal Information or an authorized representative.
The amount of information necessary will depend on the request but we
will only use Personal Information provided with a request to verify
your identity and authority to make the request.
- If you
have any questions or concerns regarding the exercise of your rights or
Greystar’s privacy policies and practices, please let us know. You can
contact us by using the "Contact Information" details below.
- Exercising Rights for Someone Else
- Only
you, or a person registered with the California Secretary of State that
you have authorized to act on your behalf, may make a verifiable
consumer request related to your Personal Information. You may, however,
make a verifiable consumer request on behalf of your child.
- Response Timing and Format
- We
will make our best effort to respond to a verifiable consumer request
within 45 days of its receipt. Within ten (10) days of receiving the
request, Greystar will confirm receipt and provide information about its
verification and processing of the request. If we require more time, we
will inform you of the reason and an extension period in writing. For
requests that seek the disclosure of specific pieces of information
about the consumer, we will select a format that is readily useable and
should allow consumers to transmit the information from one entity to
another entity without hindrance. We do not charge a free to process
requests, unless they are manifestly unfounded or excessive. Greystar
will maintain records of consumer requests made pursuant to CCPA as well
as our response to said requests for a period of at least twenty-four
(24) months.
NOTICE TO RESIDENTS OF CERTAIN STATES
Some
state laws permit residents who provide us with Personal Information to
request certain information regarding our disclosure of such
information to third parties for their direct marketing purposes. We do
not, currently, disclose such information to third parties for their
direct marketing purposes. If we change this policy, we will update this
provision and provide instructions on how you may make a request for
details.
DO-NOT-TRACK DISCLOSURES; THIRD-PARTY TRACKING
Certain
mechanisms may allow you to send web browser signals, known as “Do Not
Track” (“DNT”) signals, indicating your choice to disable tracking on
websites. We do not respond to browser do not track signals currently.
We may not be aware of or able to honor and respond to every such
mechanism. More information about “do not track” is available at www.allaboutdnt.org concerning such information.
Third
parties, other than our service providers, do not have authorization
from us to track which websites, apps, or other online services you
visit prior to and after visiting our websites. Please note, however,
that we cannot control third-party tracking and there may be some
third-party
tracking that occurs without our consent or knowledge.
NOTIFICATION OF CHANGES
Any
changes we make to this Privacy Policy will become effective upon
posting. If we change our Privacy Policy, we will advise users of those
changes through a general description at the top of this Privacy Policy
and may also post these details to other places we deem appropriate, so
our users are aware of what information we collect, how we use it, and
under what circumstances, if any, we disclose it. If we are legally
permitted to do so, we may also email you
CONTACT INFORMATION
If
your Personal Information changes (such as zip/postal code, phone,
email or postal address), we provide a way to update your Personal
Information. This can usually be done at the Registered User account
settings page or by emailing our Data Privacy Department through privacy@greystar.com.
You
may use this email to get in touch with us for any other reason
relating to this Privacy Policy. If you send us an e-mail, our
communication should clearly be marked as data protection query and as
being time sensitive.
You may also contact us by postal mail at
Greystar, Attn.: Data Privacy, 600 E. Las Colinas Blvd., Suite 2100,
Irving, Texas, 75039. If you contact us by mail, your communication
should clearly be marked as a data protection query and as being time
sensitive.
APPENDIX 1
Category of Personal Information | Sources from which the Information was Collected | Business & Commercial Purpose for the Collection |
Identifiers | - Consumers
- Job applicants and employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Personal Information categories listed in California Civil Code § 1798.80(e) | - Consumers
- Job applicants and employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Protected classification characteristics under California or federal law | - Consumers
- Job applicants and employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Commercial Information | - Consumers
- Job applicants and employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Internet or other electronic network activity information | - Consumers
- Employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Sensory data | - Consumers
- Employees
- Vendors, third parties, and service providers
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Employment or other professional information | - Consumers
- Job applicants and employees
- Vendors, third parties, and service providers.
| - Fulfilling our obligations
- Advertising and marketing
- Service performance
- Security and legal obligations
|
Personal Information Categories
- Identifiers: name,
user/account name, postal address, email address, contact information,
internet protocol address, internet cookie identification number, social
security number, taxpayer identification number, bank account/credit
card number, driver’s license number, passport number, date of birth,
picture, resident identification number, device identification number,
emergency contact details
- Personal Information categories listed in California Civil Code § 1798.80(e):
name, signature, social security number, address, telephone number,
passport number, insurance policy number, education, employment,
employment history, financial information, medical or health insurance
information.
- Protected classification characteristics under California or federal law: age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status
- Commercial Information:
records of products or services purchased, obtained, or considered,
other purchasing histories or tendencies, utility bills, insurance
claimant name and contact information, credit history, lease
information, rental history, rent amount.
- Internet or other electronic network activity information:
browsing history, search history, internet protocol address, cookie
identification number, information regarding consumer’s interaction with
a website, internet postings.
- Sensory data: pictures, videos, and sounds.
- Employment or other professional information:
current job and past job history, job title, and, in the case of
prospective and current residents or tenants, pay history, income.
Purposes
- Fulfilling Our Obligations:
We process Personal Information to fulfill or meet the reason you
provided the information to us, such as contracting with us as a tenant
or applying for a position with us.
- Advertising and Marketing:
We process Personal Information to communicate with you about the
Greystar products and services you have expressed an interest in and to
provide you with information on other similar Greystar products and
services we believe will be of interest to you.
- Service Performance:
We process Personal Information for the performance of services and to
better understand how we can help prospective residents, current
residents and employees
- Security and Legal Obligations:
We process Personal Information to detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity We also
process Personal Information in accordance with our legal rights and
obligations under applicable laws.
Third Parties with Whom We Share Personal Information
- Contracted
service providers who provide IT, system administration and hosting,
payment processing, research and analytics, marketing and data
enrichment for the purposes set forth above.
- Our affiliates
where required based on the affiliate’s relationship with you or where
sharing of data is necessary to fulfill a request you have submitted.
- Sponsors of events, contests and promotions in which you have expressed interest or for which you have registered.
- Third-party advertising networks and websites so that Greystar can market and advertise on third party platforms and sites.
- Professional advisors such as lawyers, bankers, auditors and insurers.
- Third
parties who are part of a business transition such as a merger,
reorganization or the sale of all or a part of our business