This Privacy Policy
was last updated on December 20, 2019:
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 Union or
United Kingdom, Greystar complies with the EU-U.S. Privacy Shield Framework as
set forth by the U.S. Department of Commerce ("Privacy Shield")
regarding the collection, use, and retention of Personal Information from
European Union member countries and the United Kingdom. Greystar has certified
that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability
for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access,
and Recourse, Enforcement and Liability. If there is any conflict between the
policies in this Privacy Policy and the Privacy Shield Principles, the Privacy
Shield Principles shall govern. The Greystar entities that adhere to the
Privacy Shield Principles can be found at www.privacyshield.gov/list.
To learn more about the Privacy Shield program, and to view our certification
page, please visit www.privacyshield.gov.
In compliance with the EU-U.S. Privacy Shield
Principles, Greystar commits to resolve complaints about your privacy and our
collection or use of your Personal Information. European Union and United
Kingdom residents with inquiries or complaints regarding this Privacy Policy
should first contact Greystar. Please use the details in the Contact
Information section to do so.
Greystar has further committed to refer
unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to
BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider
located in the United States and operated by the Council of Better Business
Bureaus. If you do not receive timely acknowledgment of your complaint, or if
your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for
more information and to file a complaint.
Greystar has further committed to cooperate
with the panel established by the EU data protection authorities (DPAs)
regarding unresolved Privacy Shield complaints concerning human resources data
transferred from the EU in the context of the employment relationship.
Please note if your EU originating complaint
is not resolved through these channels, under limited circumstances, a binding
arbitration option may be available before a Privacy Shield Panel. Greystar is
subject to the Federal Trade Commission in respect of its compliance with the
Privacy Shield.
Under certain circumstances, we may remain liable
under the Privacy Shield Principles if our agents process your Personal
Information that we transfer to them in a manner inconsistent with the Privacy
Shield Principles.
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