Privacy Policy
Tishman Speyer and its affiliates, subsidiaries, and related companies ("Tishman Speyer", "we" or "us" or "our") are committed to protecting the privacy of your personal information and data (collectively, "personal information"). Tishman Speyer has created this Privacy Policy ("Policy") to inform you how we collect, store, use and protect your personal information and your rights regarding that information, including when you access this website, Tishmanspeyer.com, or other Tishman Speyer websites, applications, and online services that link to this Policy (collectively, "the Sites"). We may provide a separate privacy policy in connection with certain websites, applications, and services that we offer and, where we do so, such policies will apply to our collection and use of personal information collected through such websites, applications, and services. This Policy also applies to your engagement of Tishman Speyer and the nature of your relationship with us (the "Services"), as well as to your application for or employment with us, and to your business interactions with us.
Please read this Policy carefully before using the Sites or submitting personal information to us. This Policy is incorporated into and subject to the Terms of Use. BY ACCESSING OR USING THE SITES, OR SUMBITTING PERSONAL INFORMATION TO US BY OTHER MEANS, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. If you do not agree to this Privacy Policy or our Terms of Use, you may not use our Sites or our Services.
We reserve the right to revise this Policy at any time. If we make any material changes, we will update the date noted above. We reserve the right to provide notice of any changes in other ways as well. Your use of our Sites after such changes constitutes your agreement to the Policy as amended. Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your personal information in accordance with the terms of the Policy in effect at the time of the collection. The Policy and the Terms of Use should be read together with the local Tishman Speyer privacy policies that apply to your region.
INFORMATION WE COLLECT ABOUT YOU
In connection with your use of Tishman Speyer's Site or Services, your application for or employment with us, or your business interactions with us, we generally collect the following categories of personal information. We use this information to operate our Sites, carry out our business and Services, comply with laws and for other purposes described herein. (Please see the "Why We Collect Your Information" section below for additional information.)
Identifiers and Contact Information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, and other similar contact information and identifiers.
Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.
Commercial Information. This category includes, without limitation, products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education Information. This category includes, without limitation, information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
Internet or Other Electronic Network Activity Information. This category includes, without limitation, browsing history, search history, or a consumer's interactions with a website, application, or advertisement.
Geolocation Data. This category includes, without limitation, location information collected when using one of our apps, devices, or vehicles.
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information. This category includes, without limitation, information collected from voicemail messages, while speaking with one of our service representatives, and/or by video camera.
Biometric Information. This category may include the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes.
Professional and Employment-Related Information. This category includes, without limitation, information regarding job applications, information related to onboarding for payroll and benefits, and information needed for evaluating performance.
Sensitive Personal Information. This category includes:
- social security, driver's license, state identification card, or passport number;
- log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credentials allowing access to an account;
- precise geolocation;
- racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership;
- content of mail, email, and text messages (unless we are the intended recipient of the communication);
- genetic data;
- biometric information;
- health information;
- information from a known child; and
- information regarding sex life or sexual orientation.
Consumer Profile. This category includes information drawn from any of the categories above to create a profile about a consumer reflecting the consumer's preferences, characteristics, and behaviors.
SOURCES OF INFORMATION WE COLLECT ABOUT YOU
• Information You Voluntarily Provide to Us. We collect information you give us voluntarily when you use our Sites or Services, interact with us on social media, in connection with your application for or employment with us, or in connection with your business interactions with us. The information we collect may vary based upon your relationship with us. For example, we may collect the following information from vendors, tenants, visitors, investors, employees, and applicants:
- Vendors: Personal identifiers, such as tax identification information, government issued documents, such as licenses; geolocation data, such as location data based upon security badge usage or visitor access system usage; and beneficial ownership information, such as the names of key people and their addresses;
- Tenants: Personal Identifiers, such as date of birth, tax identification number and/or social security number; financial account information; government issued documents, such as licenses; leasing information; car details for parking registration; geolocation data, such as location data based upon security badge usage or visitor access system usage; and electronic, visual or similar information, such as security cameras at the property;
- Visitors at Our Properties: Government issued documents, such as licenses; car details for parking registration; geolocation data, such as location data based upon security badge usage or visitor access system usage; and electronic, visual or similar information, such as security cameras at the property;
- Investors: Identifiers (date of birth, tax identification number/social security number); financial account information; copy of government issued identification documents; and professional and employment information.
- Employees and Applicants: When you apply for a job with us, you may provide information regarding your educational and professional history. In connection with your employment with us, you may provide financial information needed for payroll processing and government identification numbers needed to verify your identity and work authorization status.
• Information Collected Automatically Through Our Sites. As you navigate through and interact with our Sites, we may compile statistical information concerning the usage of the Sites through analytics services, such as those provided by Google, LinkedIn, Microsoft, Facebook, Vimeo, and HubSpot. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Sites, such as traffic data, location data, logs and other communication data and the resources that you access and use on the Sites, including video content.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our Sites, and the subjects of the ads you click or scroll over.
- Information about your preferences to make your use of the Sites more productive, collected via the use of Cookies and other tracking technologies. For more information, please see the "Cookies" section below.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We use cookies, pixels, session replay, and other web technologies to collect and store certain types of information when you visit the Site. A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering your user preferences, improving the quality of your visit, recording the website pages you view, remembering the name or address you entered during a visit, or delivering ads that are targeted to your interests and browsing activity.
Types of Cookies
First and Third Party Cookies: First party cookies are generally placed on your computer or device by the website you are visiting. For example, we may use a first party cookie to improve website security. Third party cookies are placed on your computer or device by a source other than the website you are visiting in order to enable third-party features such as advertising, analytics, videos, or interactive content.
Essential or Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
Performance and Functionality Cookies: Although these are non-essential cookies, they help the website perform and function as designed. For example, performance and functionality cookies may help the website display videos, enable chat sessions, or recognize whether you visited the website before.
Analytics Cookies: These cookies track your usage of the website. The information these cookies collect can be used for various purposes such as understanding how visitors use the website, site and content customization, or advertising and marketing.
Advertising Cookies: Advertising and marketing cookies perform functions such as helping customize your website experience, personalizing ads based on your online activities and interests, measuring the effectiveness of ads, preventing an ad from reappearing, and serving you targeted advertisements. Information from these cookies may be shared with third parties or third parties may place these cookies on your computer or device. Advertising and marketing cookies may track your online activities.
Our Sites use essential, functional, and performance cookies to function and perform as designed; analytics cookies to understand how you use our Sites, improve our Sites' functionality and other related purposes; and advertising cookies to help us with our advertising and marketing activities including showing you relevant ads when you visit our Sites or other websites. We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices.
Embedded Content and Social Media Widgets. Our Sites contain embedded content (e.g., videos) and Social Media Widgets (e.g., LinkedIn). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. Social Media Widgets allow us to integrate social media functions into our Sites. These widgets may place third party cookies on your device for tracking and advertising purposes. We have no direct control over the information these cookies collect, and you should refer to their website privacy policy for additional information.
Controlling cookies. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Sites may not work. IMPORTANT: BY USING THE SITE, YOU CONSENT TO THE PROCESSING OF ANY PERSONAL INFORMATION FOR THE PURPOSES AND FUNCTIONS DESCRIBED ABOVE.
Do Not Track. "Do Not Track" is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user's computer, we are unable to respond to Do Not Track requests. Cookies set when you visit our Sites may track you over time and across third party websites.
WHY WE COLLECT YOUR INFORMATION
In general, we will use the personal information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your personal information in the following ways:
- To Operate Our Sites. We may use your personal information to enable use of our Sites, and to administer our Sites;
- To Provide Services. We may use your personal information to provide you with Services. For example,
- Vendor information may be collected in connection with the usage of our internet, security badges and/or access control systems, parking registration, and to maintain safety and security.
- Tenant information may be collected in connection with usage of our internet, security badges and/or access control systems, parking registration, to maintain safety and security, and/or for waivers in connection with tenant amenities such as gym access.
- Visitors who access our properties may have their information collected in connection with usage of our internet, security badges and/or access control systems, parking registration, to maintain safety and security, and/or for waivers in connection with tenant amenities such as gym access.
- Investor information may be collected in connection with a subscription agreement, distributions, processing of interests and payments, accounting, auditing, reporting to you and the relevant government authorities, acting in compliance with anti-money laundering checks and/or sanctions checks.
- For Internal Use. We may use your personal information for furthering our business including analyzing your information and other uses; to review, improve, and monitor our website, applications, online services, and overall client experience; to provide customization to meet specific needs; to assess trends, interests, and the demands of clients; to carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections; and in connection with your application for or employment with us.
- To Communicate with You. We may use your personal information to communicate with you including sending messages about the availability of our Sites, security, or other service, employment, or business transaction-related issues. (You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.) We may also send you administrative or account-related information to keep you updated about your account and our Sites. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. Site-related communications are not promotional in nature.
- To Provide Customer Support. We may use your personal information to provide customer service and engage in quality control activities concerning our properties and services.
- To Enforce Compliance with Our Terms and Agreements or Policies. When you access or use our Sites, you are bound to our Terms of Use and this Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Sites. We also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies; and enforce our agreements with third parties and business partners. We cannot maintain our Sites in accordance with our terms, agreements or policies without processing your personal information for such purposes.
- To Ensure the Security of the Services. As noted above, we may process your personal information as necessary or appropriate to protect the rights, property, security, and safety of Tishman Speyer, our employees and clients, our information systems, and the public. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
- To Maintain Legal and Regulatory Compliance. We are subject to certain laws and regulations which may require us to process your personal information. We may also use your personal information to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
- To Engage in Marketing Activities. We may process your contact information, information about your interactions on our Sites or other information systems, or information we collect from or about you from other sources, to send you marketing communications and keep you updated about our Sites; provide you with information about events or other materials; and deliver targeted marketing to you.
- In Connection with Your Application for or Employment with Us. We may collect and process your personal information in connection with evaluating your application for employment, verifying your identity and work eligibility status, managing your work performance and compliance with workplace policies and procedures, administering pay and benefits, and managing requests for accommodations or leaves of absence.
- Other Purposes. We may use your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
The following chart describes the categories of personal information we have collected or may collect about you and, for each category, identifies the categories of third parties to whom we may disclose that information.
Categories of Personal Information Categories of Third Parties to Whom Disclosed & Purposes for Disclosure Address and other identifiers – such as name, postal address, email address, phone number, account name, date of birth, social security number, driver’s license number, photograph, passport number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: social security number, driver’s license number, state identification card number, and/or passport number. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Protected status – such as citizenship, ethnic background, gender, or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial, ethnic, or national origin Third parties as directed by you. We may disclose personal information to those third parties to whom you direct. Our business partners. For example, we might disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Financial information – such as bank account details, credit history, income details or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credential allowing access to an account. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Education or professional information, including veteran status or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: union membership. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement NOTE: The information in this category may include the following elements of Sensitive Personal Information: the contents of mail, email, or text messages, to which the business was not the intended recipient. Third parties as directed by you. We may disclose your personal information to third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Geolocation data NOTE: The information in this category may include the following elements of Sensitive Personal Information: precise geolocation. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Audio, electronic, visual, thermal, olfactory, or similar information. Third parties as directed by you. We may disclose personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Biometric Information NOTE: Biometric information is considered an element of Sensitive Personal Information. Third parties as directed by you. We may disclose your personal information to those third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial or ethnic origin, religious or philosophical beliefs, union membership, health information, genetic information, and/or information regarding an individual’s sex life or sexual orientation. Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including property management, security, and parking service vendors, platform providers, escrow agents, account managers, transfer agents, banks, marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.LINKS TO THIRD PARTIES' SITES AND THIRD-PARTY INTEGRATIONS
We may provide links to websites or resources outside of our Sites for your informational purposes only. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Sites to provide you with additional functionality, tools, or services such as maps, sending you requested information, etc.
You acknowledge and agree that we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or that is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
SECURITY
We take precautions to protect data and information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. However, no system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information.
Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding the password, security questions and answers and other authentication information you use to access our Sites.
YOUR CHOICES
We make reasonable efforts to ensure that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You may contact us via the information in the "Contact Us" section below to update personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In responding to your request, we may seek information to verify your identity.
RETENTION
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and other legitimate business needs. We will delete, deidentify, or aggregate your personal information when it is no longer reasonably required for the purposes described herein (or compatible purposes), or, where applicable, when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. To determine the appropriate retention period for your personal information, we consider various factors, such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements.
CHILDREN'S PRIVACY
Our Sites are not intended to attract children under 16. Accordingly, we do not knowingly solicit or collect personal information from anyone we know to be under 16 years of age. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove such information from our servers. No information should be submitted to us by users under the age of 16.
APPLICABLE LAW
This Policy is governed by the internal substantive laws of New York without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within New York. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
INTERNATIONAL TRANSFERS
When you access or use our Sites, we may transfer your personal information to other countries where we conduct business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Sites.
CALIFORNIA AND TEXAS RESIDENTS
This section applies only to California and Texas residents. It supplements and amends the information contained in the Policy with respect to such individuals. The other provisions of the Policy continue to apply, except as modified in this section.
Shine the Light [California residents only]. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties' direct marketing purposes. Such requests must be submitted to us in accordance with the instructions in the Contact Us section of this Policy. Please mention when contacting us that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than in accordance with the instructions specified in this paragraph.
Eraser Law [California residents only]. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information at the end of this Policy. Please be aware that such request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Your Rights.
You may have certain rights related to your personal information, subject to certain exceptions. Specifically:
Right to Know. You have the right to request that we disclose the following to you upon receipt of your verifiable consumer request:
- The categories of personal information we have collected about you
- The categories of sources from which we collected that information
- The business or commercial purposes for collecting, selling, or sharing that information
- The categories of personal information we sold or disclosed for a business purpose
- The categories of third parties to whom we sold or disclosed that information
- The specific pieces of personal information we collected about you
If you previously provided us your personal information, and that information is available in a digital format, you may have the right to obtain a copy of the information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another person without hindrance.
Right to Delete. You have the right to request that we delete your personal information from our records, subject to certain exceptions. Upon receipt of a verifiable consumer request, and as required by applicable law, we will delete and direct any service providers to delete your personal information.
We are not required to comply with deletion requests if we, or our service providers or contractors, need the subject information in order to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information to us.
- Comply with a legal obligation.
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correct. You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by applicable law, we will take appropriate steps to respond to your request.
Opt-Out of the "Sale" or "Sharing" of Personal Information or Use of Such Information for "Targeted Advertising" or "Profiling". We engage in common marketing and advertising practices to provide more relevant content and ads to users of our websites and services. Certain of these practices may involve the "selling" or "sharing" of personal information, as those terms are defined in the California Consumer Privacy Act, as amended ("CCPA"), or the use of such information for "targeted advertising" or "profiling," as those terms are defined in the Texas Data Privacy and Security Act ("TDPSA"). We do not sell personal information under the more commonly understood meaning of that word – i.e., providing personal information to third parties in exchange for money. Nor do we have actual knowledge of selling or sharing personal information of minors under the age of 16. To opt-out of the selling or sharing of your personal information, or use of that information for targeted advertising or profiling, please submit your request by emailing us at [email protected] or by calling us toll-free at (833) 430-2169. Note: We also treat Global Privacy Control browser signals as opt-out of sale/sharing requests and process these requests in a "frictionless manner" (as defined under the CCPA). To opt-out via the Global Privacy Control, please follow the instructions available here.
Right to Consent to or Limit Use or Disclosure of Sensitive Personal Information. You may have the right, subject to certain exceptions, to consent to or request limitations on the use and disclosure of your sensitive personal information, as that term is defined under applicable law. We do not use sensitive personal information to infer characteristics about data subjects nor for purposes other than those set forth in Section 7027(m) of the CCPA regulations. Upon receipt of a verifiable consumer request, and as required by applicable law, we will take appropriate steps to respond to your request. Additionally, where required by applicable law, we will process your sensitive personal information only with your consent.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. For example, we generally will not provide you a different level or quality of goods or services if you exercise these rights.
Submitting Consumer Rights Requests
To submit a consumer rights request, please submit your request by emailing us at [email protected] or by calling us toll-free at (833) 430-2169.
Verification. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer's minor child, or
- a natural person or business entity authorized to act on behalf of a consumer.
To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. Making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond.
Authorized Agents. You may authorize a natural person or business entity to act on your behalf with respect to your rights under this section. Unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission, signed by you, to act on your behalf and verify the authorized agent's identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
We may not be able to 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.
Our Response. You may have the right, subject to applicable law, to submit up to two (2) requests per year free of charge. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In the event we deny your request, in whole or in part, we will explain the bases for that denial.
Appeal of Our Response. In the event you believe we have erroneously denied your request, in full or in part, you may, within 60 days of receipt of that denial, submit an appeal by emailing us at [email protected] or by calling us toll-free at (833) 430-2169. In your appeal submission, please explain why you believe our decision to deny your request was incorrect and please provide any additional information you believe we should consider in connection with your appeal. Within 60 days of receipt of your appeal, we will advise you in writing of any action we have taken, or refrained from taking, in response to your appeal, along with an explanation of why we have taken, or refrained from taking, such action.
To the extent a Tishman Speyer affiliate, subsidiary, or related company is not governed by this Privacy Policy, a different Privacy Policy will be available on the affiliate, subsidiary, or related company's website. The "Sites" include by definition, and this Privacy Policy (the "Privacy Policy" or simply the "Policy") applies to, the Sites, and any mobile app, web pages, interactive features, other applications, widgets, blogs, social networks, social network "tabs," or other online or wireless offerings that link to this Privacy Policy, whether accessed via computer, mobile device or other technology, manner or means.