Greystar Living Privacy Statement
Last Updated October 17, 2023
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 Data”), 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.
Greystar takes a layered approach to its Privacy Statements. For general information about how your Personal Data is processed as a resident of a Greystar community, please visit our Privacy Hub to 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. 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.
This Privacy Statement does not apply to the third-party online/mobile store from which you install the Application, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.
Depending on where you are located, there may be differences in the types of Personal Data collected, used, and disclosed, or you may have different rights, for details specific to your region, please see the Location-Specific Disclosures section.
PERSONAL DATA WE PROCESS
The data we may collect or process within the Application may include the following:
Contact Information
We will 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
While the App does not currently collect or process payments, 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 can also view your insurance information such as insurance provider, policy number, coverage amount, deductible, and start and end dates.
Mobile Device and Event Data
We may collect the following information generated from a users mobile device: device model, IP address, OS version, and country/region. We collect information, such as user interactions and analytics events, to helps us understand how the App is used, which features are most used, and overall performance. We collect Session IDs and Customer IDs, which are tied to the events that could be used to uniquely identify an individual; however, we do not explicitly track and identify particular users.
Mobile Device Access
We request access or permission to your mobile device’s camera for taking pictures or to your photos when submitting a maintenance request.
Other Data
You may use the App to submit and manage your requests. In doing so, you may provide a description, location, photos, and additional details required to fulfil the request or provide the services.
USE OF YOUR INFORMATION
The information collected or processed via the Resident Application is used to facilitate the following functions:
Account Management and Settings
The activities associated with this purpose may include updating your account settings, name, or other information within your profile. You may also view certain documents, such as your lease agreement, insurance policy information, or community policies.
Resident Services
The activities associated with this purpose include 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
The activities associated with this purpose may include capturing events and other metrics to track the use of the App. We use the App event data logs to, among other things, analyze the use of the App, determine the popularity of certain content, and better understand online activity. By accessing the App, you consent to and understand that you information is collected and captured by us.
Security, Legal Obligations, and Enforcement of Terms
The activities associated with this purpose 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.
DISCLOSURE OF YOUR INFORMATION
HOW AND WHEN WE SHARE YOUR PERSONAL DATA
We may share information we have collected about you in certain situations. Your Personal Data collected in the App may be disclosed to certain parties as described below.
Greystar Affiliates
We disclose your Personal Data and Other Data 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 Data to the owners of the properties we manage. Owners may use your Personal Data for their own legal purposes and to fulfil their legal obligations. Therefore, property owners and Greystar are considered separate data controllers for the processing of your Personal Data.
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.
By Law or to Protect Rights
If we believe the release of information about you 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 others, 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 reorganizes or sells all or a portion of our assets, undergoes a merger, or is acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline to honor commitments we made in this Privacy Statement.
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 below to express your preferences.
Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Data
You may have the right under applicable privacy laws to request that Greystar inform you as to whether Personal Data relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, change, delete, restrict the use of, or object to the processing of your Personal Data that was previously provided to us. If you wish to exercise your rights, please visit our portal and complete the form. For your protection, we will verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.
If you are a prospective, current or former resident, a current or former team member, an investor, or a job applicant, please submit your request using this form or by calling 1-844-795-2806.
If you would like to exercise your right to opt out of the selling or sharing of your information, please submit your request using this form.
For all other inquiries, or if you have any questions about the forms or our process, feel free to contact us at privacy@greystar.com or see the Contact Information section below.
Security of Your Information
Greystar takes reasonable technical and organizational measures to safeguard users’ Personal Data. Though we have taken reasonable steps to secure the Personal Data you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security when you provide Personal Data.
We limit access to Personal Data to those individuals and organizations who we believe reasonably need to receive such information to provide the services or to do their jobs, and we take precautions we deem reasonable to protect the security of users’ Personal Data in accordance with applicable law. 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 Data notwithstanding the actions we take to prevent this.
If users have any questions about security, please contact us using the information in the “Contact Information” section.
RETENTION
We will retain your Personal Data for the period we believe reasonable to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
· The length of time we have an ongoing relationship with you and provide the services to you.
· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them).
· Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation, or regulatory investigations).
POLICY FOR CHILDREN
Our App is not directed at children. We do not collect or maintain information in our App from individuals under 16, and we do not permit children under 16 years of age to become registered users of our App. By using our App, 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 our App, please contact us using the information in the “Contact Information” section.
LOCATION-SPECIFIC DISCLOSURES
Notice to California Residents
Individuals who reside in California and have provided their Personal Data to us may exercise their rights under the California Consumer Privacy Act (“CCPA”). California residents can find more information on exercising their rights under the CCPA by reading our California Consumer Privacy Statement.
Notice to Residents of Certain US States
Some state laws permit residents who provide us with Personal Data to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes; however, currently we do not disclose Personal Data to third parties for their direct marketing purposes. If we change this Statement, we will update this provision and provide instructions on how you may make a request for details.
UPDATES TO THIS PRIVACY STATEMENT
Any changes we make to this Privacy Statement will become effective upon posting. If we change our Privacy Statement, we will advise users of those changes through a general description at the top of this Privacy Statement and may also post these details to other places we deem appropriate. If we are legally permitted to do so, we may also email you.
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