Greystar Living Supplemental Privacy Statement
Last Updated August 9, 2024
Greystar Global Enterprise, LLC and its affiliates (referred to herein as “Greystar”, “we”, “us”, or “our”), recognize the importance of protecting the privacy of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“Personal Information”), particularly our consumers or users (referred to as “you” or “your” in this Privacy Statement). Please read this Privacy Statement carefully. If you do not agree with the terms of this Privacy Statement, please uninstall and do not use the application.
This Privacy Statement applies to information we collect and process through the Greystar Living mobile application (referred to herein as “App” or “Application”) operated by Greystar and supplements the Greystar’s Global Privacy Statement. In the event of a conflict between this Privacy Statement and the Gloval Privacy Statement, the Global Privacy Statement shall take precedent, except where such terms are specific to the App. For more information about how your Personal Information is processed as a resident of a Greystar community and the rights you may have, please refer to our Greystar Global Privacy Statement.
We reserve the right to make changes to this Privacy Statement at any time and for any reason without notice; however, we will notify you if there are material changes to this Privacy Statement and will make you aware of other changes by updating the Last Updated date at the top of this Privacy Statement and may also post these changes to other places we deem appropriate. If we are legally permitted to do so, we may also email you regarding changes. You are encouraged to periodically review this Privacy Statement to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Statement by your continued use of the Application after the date such revised Privacy Statement is posted.
PERSONAL INFORMATION WE PROCESS
To provide you services, we collect or process, or you may choose to provide, Personal Information that may identify you or relate to you as an individual.
The information we may collect or process within the App may include the Personal Information described in general terms below:
Contact Information: We collect your name, email address, phone number, and date of birth to verify and activate your profile within the App. Within the App, you’ll also have access to view and/or update your account settings, such as managing your preferences or maintaining your pet and vehicle information (year, make, and model).
Insurance and Financial Information: The App does not currently collect or process payments, however, you may view a summary of your previous rental payments and transactions, outstanding balance, and a read-only version of your lease agreement. To submit payments, the App will redirect you to the resident portal where the Greystar Global Privacy Statement will apply. You may also view your insurance information such as insurance provider, policy number, coverage amount, deductible, and start and end dates.
Derivative and Events Data: We automatically collect information when users access the App, such as user interactions. This information helps us track how residents are using the App, which features are most used, and overall performance. While we are not explicitly tracking this by individual user, there are Session IDs and User IDs tied to the events which could be used to uniquely identify an individual. Our servers automatically collect information such as analytic events, UI interactions, etc. using Microsoft App Center. We are not explicitly tracking individual users; however, Microsoft App Center must be tracking these devices using established mechanisms. While Microsoft App Center assigns a Session ID and User ID to events, we only know what events go together and not the specific user which triggered the events.
Mobile Device Access: We may request access or permission to your mobile device’s camera for taking pictures or to your photos when submitting a maintenance request.
Mobile Device Data: The Microsoft App Center may capture the following user generated information from your device: device model, IP address, OS version, and country/region.
Other Data: We may collect information related to communications, location, and additional details required to fulfil your request or provide the services.
We may aggregate data that we process, and this aggregated data will not personally identify you or any other user.
USE OF YOUR INFORMATION
The information collected or processed via the Resident Application is used to facilitate the following functions:
Account Management and Settings: We process Personal Information when you update your account settings, name, or other information within your profile. We also process Personal Information when you view certain documents, such as your lease agreement, insurance policy information, or community policies.
Resident Services: We process Personal Information when we provide services such as communicating with residents about a submitted service request or collecting information about an issue or request. We may also ask for your consent for maintenance professionals to enter the unit or community management will communicate with you directly to coordinate.
App Performance: We process Personal Information when ensuring the App is performing as expected, which may include capturing events and other metrics to track the use of the App. We use session replay tools, which record your interactions with our App, such as how you move throughout our App and engage with our features, which helps us identify and fix technical issues and improve our App. We use the App event data logs to, among other things, analyze use of the App, determine how users are engaging with the features, and better understand user activity.
Security, Legal Obligations, and Enforcement of Terms: We process Personal Information when we protect our legitimate interests and comply with legal obligations, which may include ensuring the safety of our residents, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, preventing and responding to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our App or websites.
HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION
We may share information we have collected about you in certain situations. Your Personal Information collected in the App may be disclosed to certain parties as described below.
Greystar Affiliates: We disclose your Personal Information and Other Information with our affiliated companies as necessary to communicate with you, provide you services, fulfil our contract with you and to accomplish our business purposes.
Property Owners: We disclose Personal Information to the owners of the properties we manage. Owners may use your Personal Information for their own purposes and to fulfil their legal obligations. Therefore, property owners and Greystar are considered separate data controllers for multiple processes during your tenancy journey.
Property Managers: We disclose your Personal Information to managers who assist us with the management of your property and/or who may take over management responsibilities from us.
Partners: We disclose your Personal Information and other data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.
Third-Party Service Providers: Greystar may share your information with third parties that perform services for us or on our behalf, including maintenance requests, hosting services, customer service, and other community assistance. Some of these service providers may use your Personal Information for their own purposes and legal obligations, and where this is the case, these service providers are therefore considered separate data controllers.
Government Authorities, By Law, or to Protect Rights: If we believe the use and disclosure of your Personal Information is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of Greystar employees, residents and other persons, we may share your information as permitted or required by any applicable laws, rules, or regulations. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Business Transitions, Sale, or Bankruptcy: If Greystar goes through a business transition, reorganizes or sells all or a portion of our assets, including an individual property, undergoes a merger, or is acquired by another entity, we may transfer your Personal Information to the successor entity. If we go out of business or enter bankruptcy, your Personal Information would be an asset transferred or acquired by a third party. By using the App and providing your Personal Information, you consent to such transfer, provided use of the Personal Information will remain in accordance with this Privacy Statement in place at the time of transfer. If required by law, we will separately notify you of such transfer.
THIRD-PARTY OR OTHER WEBSITES
Our App may contain links to other websites and applications of interest or as necessary to provide you with our services. Once you have used these links to leave the App, any information you provide to those websites or apps will not be covered by this Privacy Statement. Before visiting and providing any information to other websites or apps, you should inform yourself of the applicable privacy policies governing that service.
YOUR PRIVACY PREFERENCES AND RIGHTS
We provide you with options, information, and choices as required under applicable law to express your preferences, please visit Greystar Global Privacy Statement.
CHILDREN’S PRIVACY
Our App is not directed at children. We do not collect or maintain information in our App from those who are considered children in the jurisdiction in which they reside, and we do not permit children under 16 years of age (or such higher age specified by applicable law) to become registered users of our App. By using our App, you represent that you are not under 16 years of age (or such higher age specified by applicable law). If we detect that you do not meet these age requirements, we may block and/or delete the Personal Information that you provided. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable information through our App, please contact us using the information below.
CONTACT INFORMATION
If you have any questions about this Privacy Statement, please contact us at privacy@greystar.com.
You may also contact us by postal mail at the following address:
Greystar
Attn.: Data Privacy
465 Meeting St., #500
Charleston, SC 29403