EU Privacy Policy

Privacy Policy for EU Products and Services

For Privacy Policy for U.S. Products and Service, click here

 

PRIVACY POLICY

This Privacy Policy was last updated: April 10, 2018.

This Privacy Policy applies to the Greystar.com website operated by Greystar® and its subsidiaries (referred to herein as "Greystar", "we", "us", or "our") and applies to information, products and services provided by Greystar in the European Union.

Greystar recognizes the importance of protecting the privacy of individual-specific information ("Personal Information") collected from and about our website users (referred to as "you" or "your" in this Privacy Policy). This Privacy Policy describes what Personal Information we gather, how we use it and how you can correct, change and limit our use of it.  It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information to provide you a valuable service and hopefully to have you as a resident of one of our communities.  In some instances, and in particular, if you are asked to submit registration details through 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 and our website Terms of Use before you send or share Personal Information with us or use our website and to read them again when you return to it.

WHAT PERSONAL INFORMATION DOES GREYSTAR COLLECT?
  
We collect Personal Information from our website in order to provide you with information on the Greystar products and services you have expressed an interest in to provide you with information on other similar Greystar products and services we believe will be of interest to you and to better understand how we can help prospective residents and employees.

The type of Personal Information we collect will depend upon what we will need in order to provide you with the particular product or service you are interested in.  In the case of prospective residents and applicants for employment, the information requested on our registration form includes some or all of the following Personal Information: name and address, age or date of birth, email address, occupation, employment information, telephone number, educational background and Social Security/national insurance number.

Those interested in becoming residents will be asked to include most of the following further information:  the kind of service you are requesting, the apartment/flat size you are looking for, where you want to live, the type of building you prefer, your proposed rent budget, the number of individuals in your household and their ages, and whether or not you have pets.

For those interested in are applying for employment at Greystar, the following additional Personal Information may be requested or obtained:  credit checks, background checks and employment verification.  Where required, we will obtain your consent before undertaking these checks.  Once a candidate accepts a position, the candidate may be asked to provide further details to help us fulfill our duties as an employer.

Our residential communities have their own separate sites and we 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

USAGE TRACKING: USE OF IP ADDRESSES

An IP address is a number that is automatically assigned to your computer whenever you are surfing 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 site.

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 this site 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 record­keeping purposes. Cookies make web surfing easier for you by saving your preferences while you are at our site. 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 the site 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 website and users from potential harm. We never save passwords or credit card information in cookies.

We use persistent tracking cookies on our website 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 site and which sites you may go to if you leave, especially if you access the registered user parts of this site 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 the website, to see how visitors move around the site and the products and services they are interested in when they are using it and to see what other types of products and services they may be interested in. This helps us to improve the way our website works, 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 site.  You may also see advertisements from us if other websites you visit capture through a cookie that you have been on our site.  These ad preference cookies are often used by search engine sites.  Our cookies can be changed, refused or removed 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 the website. You may also limit the information we gain from certain cookies by logging directly into the registered areas of this site 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 website 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?

As a general rule, 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 commercialize or share your Personal Information with third parties, unless:

  • Such information is shared and/or commercialized 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 in order to comply with or in accordance with any applicable law and/or court orders and/or in order 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 in order to help Greystar defend against claims and/or establish or exercise any legal right that Greystar may have;
  • Such information is shared in order 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. 

Greystar may be liable to you for any transfer of your Personal Information by Greystar in violation of applicable laws.

BUSINESS TRANSITIONS

In the event that 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 this website 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 the Greystar website you could be directed to other third party sites that are beyond our control. 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 site. 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 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 employees who we believe reasonably need to receive such information to provide our services or in order to do their jobs, and we take the precautions we deem reasonable to protect the security of users' Personal Information.  We also work very hard to ensure that our employees are aware of the sensitivity of the data submitted to us and that they handle it with care, being careful not to allow any improper access by third parties.  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.

If users have any questions about security, please contact us using the information in the "Contact Information" section.

ENCRYPTION

Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security and this Privacy Policy as necessary when new technology becomes available.  This includes use of software which encrypts (generally processed at 256 bits) or distorts data submitted to us.

EMAIL CONSENT AND OPT-OUT

Your provision of Personal Information on a registration form in the course of our providing a product or service to you 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.  We notify you of this at the time you choose to register, and we will provide you the option not to receive further marketing communications from us at the time you register.  If we do not provide products and services to you, you may fill in a registration form and request that we provide you with commercial information.

You may choose to opt out of receiving future commercial email messages from us as a result of your registrations with 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

We do not collect or maintain information at our site from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our site. No part of our site is structured to attract anyone under 16. By using our site, 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 the Website, please contact us using the information in the "Contact Information" section.

DATA TRANSFERS

Please be aware that if you provide Personal Information to us, it may be transferred to and processed on computers in the U.S. and other countries which are not in the EEA.  Please 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.

We mainly transfer your Personal Information to our affiliate in the United States, Greystar Real Estate Partners.  Greystar Real Estate Partners (“Greystar US”) 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.  Greystar US 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.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. 

In compliance with the EU-U.S. Privacy Shield Principles, Greystar US commits to resolve complaints about your privacy and our collection or use of your Personal Information.  European Union 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 US 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) with regard to 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 concerning Greystar US is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Greystar US is subject to the Federal Trade Commission in respect of its compliance with the Privacy Shield.

CORRECTING AND DEACTIVATING PERSONAL INFORMATION

You have the right, freely and at reasonable intervals, to request that Greystar inform you as to whether Personal Information relating to you is being processed. You have the right to request that Greystar correct, supplement, delete or block your Personal Information in the event that 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 that data from our systems. Due to the nature of our service, some information may not be fully removed due to backups or archived copies; however, such information will only be used for the purpose of performing a contract that the user has entered into with us.

NOTIFICATION OF CHANGES

If we decide to 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.  We may also email you.

CONTACT INFORMATION

If a user's Personal Information changes (such as zip/postal code, phone, email or postal address), or if a user no longer desires to be registered with this site, we provide a way to correct, update or delete/deactivate users' Personal Information. This can usually be done at the Registered User account settings page or by emailing 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 a data protection query and as being time sensitive.

You may also contact us by 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.

GDPR INFORMATION

The EU General Data Protection Regulation ("GDPR") will be in force from 25 May 2018.  This section of the Privacy Policy constitutes a Notice to you as a data subject for purposes of the GDPR and describes our processing of your personal data (as defined in the GDPR). 

                Corporate Details (including contact details):  This website is operated by Greystar Real Estate Holdings Limited (registered number 08741469), a limited company registered in England and Wales with its registered office at 15 Finsbury Circus House, Finsbury Circus, London, England, EC2M 7EB.   Please see the section "Contact Information" for details of how to get in touch with us. 

                Types of Personal Data Processed:  Please see “What Personal Information Does Greystar Collect?" and “Usage Tracking: Use off IP Addresses".

                Purpose and Legal Basis for Processing:  We process Personal Information for our legitimate interest of operating a website to make users aware of our products and services, as more fully described in the section “What Personal Information Does Greystar Collect?"

                Recipients:  We may transfer Personal Information to other Greystar entities, primarily Greystar US and other Greystar entities in the EU and to service providers of Greystar and its affiliates who host and/or provide our IT system.  We may also transfer Personal Information to third-party professional advisors who provide accounting, consultancy and legal services to us. Please also see "What Information Do We Share or Disclose".

                International Transfers:  See "Data Transfers – International Users" above.

                Personal Information Retention: We will generally hold (but are not under an obligation to hold) marketing/registration Personal Information for a period of 7 years from the later of its submission to us or its last active use by you. There are some circumstances when we may be under a requirement to hold your Personal Information for a longer period.

                If you enter into a contract with us, we will provide you with information regarding the retention of your Personal Information for that purpose as part of that process.   Please use the information in the "Contact Information" section if you would like to discuss this further.  

                Data Subject Rights:  See "Email Consent and Opt-Out" and "Correcting and Deactivating Personal Information" above.  In addition to these rights, you may have data portability rights.  Please use the details in the section "Contact Information" section to get in touch with us about any of your rights. 

                Supervisory Body:  You may contact the national data processing authority in the EU jurisdiction in which you normally access this site should you have any concerns regarding the processing of your Personal Information.  The UK Information Commissioner will be our principal GDPR regulator. 

ACCEPTANCE OF THESE TERMS

By using this site, or providing information to us, you acknowledge your awareness of the terms of this Privacy Policy.  If you are not happy with its terms or any amended terms that are made in accordance with this Privacy Policy, you are not authorized by Greystar to use this site.

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