As of November 29, 2021
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).
This Privacy Statement applies to
information we collect:
-
through the Greystar websites operated
by Greystar and its affiliates;
-
through other websites and online
services that we own, operate, or make
available and that link to this Privacy
Statement;
-
when you apply or rent at one of our
properties, or through other offline
interactions (on-site property visits);
-
when you apply for a job with Greystar;
-
through other general inquiries we
receive (including postal mail,
electronic mail, telephone requests,
and in person).
If you are an Investor, please visit our
Investor Portal for more information about
how we handle your Personal Information.
If you are a third-party Vendor/Supplier,
please visit our Supplier Websites for more
information about how we handle your
Personal Information.
Collectively, we refer to the websites,
online services, property visits and
offline interactions as “services.” This
Privacy Statement describes what Personal
Information we gather, how we use it, how
it is shared and how you can access,
delete, correct, change, and limit our use
of it. If you are asked to submit
registration details via this site, you may
be requested to agree to additional terms
regarding our use of your Personal
Information, and those additional terms
will apply in that context. Any additional
terms will be provided for your review at
the time of registration.
Depending on where you are located, there
may be differences in the types of Personal
Information collected, used, and disclosed,
or you may have different rights, For
details specific to your country/region,
please see the Location-Specific
Disclosures section.
The Personal Information We Collect
How and Where We Collect Your
Personal Information
Cookies and Other Tracking
Technologies
Why We Use Your Personal
Information
How and When We Share Your Personal
Information
Your Privacy Preferences and Rights
Other Important Provisions
Location-Specific Disclosures
Contact Information
To provide you services, we collect or you
may choose to provide Personal Information
that may identify you or relate to you as
an individual.
Depending upon the type of relationship you
have with Greystar, we may collect the
Personal Information described in general
terms below.
-
Contact Information such as name,
postal address, email address, date of
birth, picture, and emergency contact
details.
-
Other Personal Identifiers such as
user/account name, social security
number, taxpayer identification number,
driver’s license number, passport
number, identity card or student card,
and resident identification number.
-
Financial and Insurance Information
such as bank account/credit card
number, rent payment details, insurance
policy number, credit history,
sanctions and Politically Exposed
Persons (“PEP”) screening results, and
other financial or tax documentation.
-
Demographic Information such as age,
race, color, ancestry, national origin,
citizenship, marital status, sex,
veteran or military status, in each
case subject to applicable laws. In
certain jurisdictions, you may also
choose to share with us any
disabilities or other health-related
restrictions so that we can provide you
with adequate accommodations.
-
Commercial Information such as records
of products or services purchased,
obtained, or considered, other
purchasing histories or tendencies,
utility bills, insurance claimant name
and contact information, lease
information, rental history, and rent
amount.
-
Internet or other electronic network
activity information through the use of
our websites such as browsing history,
search history, internet protocol
address, cookie identification number,
information regarding consumer’s
interaction with a website, and
internet postings. For more information
please review the Cookies and Other
Tracking Technologies section.
-
Sensory data such as pictures, videos,
and sounds.
-
Employment or other professional
information such as education,
employment history, job title,
university or school attended, diploma,
other CV information, pay history, and
income.
We may collect Personal Information through
the following:
-
Online Services. We collect Personal
Information when you interact with our
Online services which may include, but
are not limited to, searching for an
apartment, communicating with us,
applying for a job, posting to social
media pages, or participating in a
survey.
-
Property Owners. Our residential
properties may be owned by other
investors who share personal
information with us for the purposes of
managing the property and providing you
services.
-
Property Visits and Offline
Interactions. We collect your Personal
Information when you visit our
properties, attend events hosted at our
properties, and/or inquire about
housing directly with our properties.
-
Other Sites and Third Parties. We may
use separate sites for the processing
of applications and agreements and to
assist our residents and service
providers with other tasks which are
required or helpful to them, such as
paying rent online. We also use
separate sites for booking corporate or
flexible stays. We may also receive
information about you from third
parties. For example, if you are on
another website and you opt-in to
receive information from us, that
website will forward us your email
address and other information about you
so that we may contact you as requested
and in accordance with applicable law.
-
Due Diligence. When you provide
services to Greystar as a third-party
vendor/contractor, we will collect
certain information through our
discussions with you, from documents
that you may deliver to us, and in the
ordinary course of our business
relationship.
-
Other Sources. We collect Personal
Information from other sources, such as
public databases or credit agencies.
Where legally required, we will obtain your
consent before collecting or processing
your Personal Information.
We may also collect “Other Data” that
generally does not reveal your specific
identity or does not directly relate to an
individual. To the extent Other Data reveal
your specific identity or relate to an
individual, we will treat Other Data as
Personal Information. Other Data includes:
-
Your browser or device. We collect
certain data through your browser or
automatically through your device, such
as your operating system name and
version, device manufacturer and model,
language, internet browser type and
version, and the name and version of
the online services (such as the apps)
you are using. We use this data to
ensure that the online services
function properly.
-
IP Address. We collect your Internet
Protocol (IP) address which is a number
that is automatically assigned to your
computer whenever you are using the
Internet. Web servers, the main
computers that serve up web pages,
automatically identify your computer by
its IP address. As permitted under
applicable law, Greystar collects IP
addresses for the purposes of system
administration, gathering and analyzing
aggregated information, creating a
better experience for users and
auditing the use of our sites. We do
not normally link IP addresses to
anything personally identifiable, which
means that your session will be logged,
but you remain anonymous to us. We may
seek to link your IP address to your
identity when we feel it is necessary
to protect our sites and other users
from harm and to prevent criminal
misconduct.
-
Aggregated Data. We may aggregate data
that we collect and this aggregated
data will not personally identify you
or any other user.
Cookies, Pixels, and other similar
technologies. We collect certain data from
cookies, pixel tags, web beacons, and other
technologies (“Cookies”) which are pieces
of data stored directly on your device or
browser and may, in certain jurisdictions,
be considered Personal Information. Cookies
may be set by us and called first-party
Cookies. We also use third-party Cookies
for our advertising and marketing efforts,
to measure the success of our marketing
campaigns, and to compile statistics about
usage of the online services. See the
section on PROFILING AND AUTOMATIC
DECISION-MAKING below.
-
Strictly Necessary Cookies are
necessary for the website to function
and cannot be switched off in our
systems. They are usually only set in
response to actions made by you which
amount to a request for services, such
as setting your privacy preferences,
logging in or filling in forms. You can
set your browser to block or alert you
about these Cookies, but some parts of
the site will not work.
-
Performance Cookies allow us to count
visits and traffic sources so we can
measure and improve the performance of
our site. They help us to know which
pages are the most and least popular
and see how visitors move around the
site. All information these Cookies
collect is aggregated and therefore
anonymous. If you do not allow these
cookies we will not know when you have
visited our site and will not be able
to monitor its performance.
-
Functional Cookies enable the website
to provide enhanced functionality and
personalization. They may be set by us
or by third party providers whose
services we have added to our pages. If
you do not allow these Cookies, then
some or all of these services may not
function properly.
-
Targeting Cookies may be set through
our site by our advertising partners.
They may be used by those companies to
build a profile of your interests and
show you relevant adverts on other
sites. These work by uniquely
identifying your browser and internet
device. If you do not allow these
Cookies, you will experience less
targeted advertising.
-
Social Media Cookies are set by a range
of social media services that we have
added to the site to enable you to
share our content with your friends and
networks. They are capable of tracking
your browser across other sites and
building up a profile of your
interests. This may impact the content
and messages you see on other websites
you visit. If you do not allow these
Cookies you may not be able to use or
see these sharing tools.
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 by updating your Cookie
preferences via our cookie banner, where
applicable, when you enter any of our
websites.
|
PURPOSE
|
DESCRIPTION OF ACTIVITIES
|
LEGAL BASIS
|
|
Engage with prospective
residents
|
The activities associated
with this purpose may
include providing property
tours and contacting
prospective residents.
|
Legitimate interests for
leasing an apartment, for
example, communication
regarding your property
preferences
|
|
Applications and Contracts
|
The activities associated
with this purpose may
include collecting and
processing applications or
contracts and communicating
with you regarding your
application or account.
Personal Information will
be used to perform credit
checks, background checks,
or other screenings as
necessary for Greystar’s
know your customer and
anti-money laundering
requirements.
|
Performance of a contract
to initiate a lease or an
employment relationship
Legitimate interests for
ensuring prospective
residents are financially
solvent
Legal obligations, such as
sanctions screenings,
background checks,
anti-money laundering
screenings, and identity
confirmation
|
|
Operations and General
Business
|
The activities associated
with this purpose may
include processing or
communicating with
residents about payments,
performing debt collection,
providing maintenance or
other on-site services, and
managing the property.
Processing this information
also helps us better
understand how we can help
prospective and current
residents.
|
Performance of a contract
to fulfill your lease
Legal obligations relating
to financial transactions,
such as the obligation to
maintain books and records.
|
|
Marketing and Surveys
|
The activities associated
with this purpose may
include communicating with
you about our properties
and promotions and
conducting resident surveys
about your experience.
|
Consent, such as honoring
communication preferences
Legitimate interests, such
as providing advertisements
for our similar products
and services
|
|
Security and Legal
Obligations
|
The activities associated
with this purpose may
include detecting security
incidents, protect against
malicious, deceptive,
fraudulent, or illegal
activity, as well as ensure
the safety of our
residents.
|
Legitimate interests to
protect against malicious
activity
Legal obligations relating
to data protection and to
report illegal activity and
security incidents
|
We may share Personal Information with the
following third parties to provide you
services, following a specific request from
you, or to fulfill our legal obligations.
-
Greystar Affiliates. We disclose your
Personal Information and Other Data
with our affiliated companies as
necessary to communicate with you,
provide you services, fulfill our
contract with you and to accomplish our
business purposes.
-
Service Providers. We disclose Personal
Information and Other Data to third
parties who perform services such as
hosting our websites, processing
payments, conducting research and
analytics, providing on-site services,
providing benefits, conducting
financial, identity and other legal
checks and providing professional
advice.
-
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 legal obligations and are
therefore considered separate data
controllers for multiple processes
during your tenancy journey.
-
Partners. We disclose 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.
We may also use and disclose your Personal
Information as necessary to comply with
applicable laws, respond to requests or
requirements from government authorities,
enforce our terms and conditions, or to
otherwise protect the rights, property, or
safety of Greystar employees, residents and
other persons, including exchanging
information with third parties for fraud
protection and credit risk reduction.
If Greystar goes through a business
transition, such as a merger, being
acquired by another company, or selling all
or part of its assets, Personal Information
may be transferred as part of that
transition. By using our websites and
providing your Personal Information, you
consent to this transfer, provided use of
the Personal Information will remain in
accordance with the Privacy Statement in
place at the time of the transfer. If
required by law, we will separately notify
you of such transfer.
We provide you with options, information,
and choices below to express your
preferences.
Email Consent and Opt-out
Each of our commercial emails contain a
link with instructions on how to remove
yourself from our email list. Please note
that if you are a resident of a Greystar
property and you use this site and your
property site, you will need to opt-out of
your property site separately. You will
also need to opt-out separately from any
third-party sites you have registered with.
Cookies and Other Data
For information on your choices related to
Cookies and Other Data, please see the
Section on Cookies and Other Tracking
Technologies, above.
Access, Change, Delete, Restrict the Use or
Object to the Processing of Your Personal
Information
You may have the right under applicable
privacy laws to request that Greystar
inform you as to whether Personal
Information relating to you is being
processed. Subject to certain exceptions
under applicable privacy laws, you may also
have the right to submit a request to
access, change, delete, restrict the use
of, or object to the processing of your
Personal Information that was previously
provided to us. If you wish to exercise
your rights, please visit our portals and
complete one of the following forms. 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
tenant, please submit your request using
this form
.
If you are a prospective, current or former
employee, 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.
Greystar takes reasonable technical and
organizational measures 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 therefore you must be aware of this
risk.
We limit access to Personal Information to
those individuals and organizations who we
believe reasonably need to receive such
information to provide our services or to
do their jobs, and we take precautions we
deem reasonable to protect the security of
users' Personal Information 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 Information notwithstanding
the actions we take to prevent this.
Because the security of all Personal
Information associated with our users is of
utmost concern to us, we periodically
review and improve our security when new
technology becomes available. This includes
use of software which encrypts (generally
processed at 256 bits) or distorts data
submitted to us relating to an online
rental application or employment
application.
If users have any questions about security,
please contact us using the information in
the "Contact Information" section.
We will retain your Personal Information
for the period we believe reasonable to
fulfill 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 of time before we can delete
them)
-
Whether retention is advisable
considering our legal position (such
as, for statutes of limitations,
litigation or regulatory
investigations)
Our websites are not directed at children.
We do not collect or maintain information
at our sites from those we know are under
16, and we do not permit children under 16
years of age to become registered users of
our sites. By using any of our sites, you
represent that you are not under 16 years
of age. If you are a parent or guardian and
you believe that your child under age 16
may have provided personally identifiable
information through any of our websites,
please contact us using the information in
the "Contact Information" section.
Greystar is a global company and as a
result, we may, subject to law, transfer
Personal Information and Other Data
collected in connection with our services,
to entities in countries where data
protection standards may differ from those
in the country where you reside. If you
provide Personal Information to us, it may
be transferred to and processed in the U.S.
or other countries. Please review the
information provided in the section called
Location-Specific Disclosures to learn more
about data transfers in your jurisdiction.
In certain circumstances and subject to
applicable law, we may use automatic
decision-making to evaluate your credit
against our required criteria.
Credit-checking is a mandatory step in our
application review process.
In certain circumstances and subject to
applicable law, we will use automated means
to conduct sanctions and PEP screenings and
in some cases for background checks. This
processing is in accordance with our legal
obligations and legitimate interests and
has meaningful human intervention before
making final decisions that may impact your
application.
Sanctions screening involves comparing
applicants against public lists maintained
by the US Office of Foreign Asset Control
and other lists maintained by other
Governments. We do this through a secure
online service and the data used to
undertake such searches includes your name,
date of birth, and nationality. For common
names, the system will sometimes return a
result known as a “false positive.” A human
analyst will then use additional data you
provided, such as your address, to make a
final decision about the match.
We may also use third parties to serve
tailored advertisements that may interest
you. To serve these advertisements, those
third parties place a cookie or other
tracking technology on your browser to
profile your access and use of our online
services. For more information about
Greystar’s use of Cookies and how to manage
your cookie preferences, see the section on
Cookies and Other Tracking Technologies,
above. If you would like more information
about this practice, please visit
https://thenai.org/opt-out/
and
https://youradchoices.com/
.
NOTICE TO CALIFORNIA RESIDENTS
Individuals who reside in California and
have provided their Personal Information 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
or by calling 1-877-862-2797.
NOTICE TO RESIDENTS OF CERTAIN US STATES
Some state laws permit residents who
provide us with Personal Information to
request certain information regarding our
disclosure of such information to third
parties for their direct marketing
purposes. We do not, currently, disclose
such information to third parties for their
direct marketing purposes. If we change
this policy, we will update this provision
and provide instructions on how you may
make a request for details.
NOTICE TO EU AND UK DATA SUBJECTS
This section of the Privacy Statement
includes additional provisions for purposes
of the EU and UK General Data Protection
Regulation and related national legislation
(collectively, "GDPR"). For purposes of the
GDPR we have designated Greystar
Netherlands Cooperatief U.A. as our
representative in the EU for services
offered in the EU by non-EU Greystar
entities and Greystar Europe Holdings
Limited as our representative in the UK for
services offered in the UK by non-UK
Greystar entities.
For users residing in the European Union or
United Kingdom, when we transfer your data
outside the EU/UK, including to other
Greystar entities, we ensure your data is
processed only in countries that provide an
adequate level of protection for your data
or where the recipient provides appropriate
safeguards such as Standard Contractual
Clauses or Binding Corporate Rules.
Data Controller Corporate Details
(including contact details):
Austria:
Entity: Greystar Austria GmbH
Location: Wien, Austria
Registered Office: c/o TPA Steuerberatung
GmbH, Wiedner Gürtel 13, 1100 Wien, Austria
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
Germany:
Entity: Greystar Germany GmbH
Location: Frankfurt, Germany
Registered Office: Neue Rothofstrasse
13-19, 60313 Frankfurt am Main, Germany
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
France:
Entity: Greystar France SAS
Location: Paris, France Registered Office:
54 avenue Hoche 75008 Paris
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
Ireland:
Entity: Greystar Ireland Limited
Registered Office: 1st Floor, 118 Lower
Baggot Street, Dublin 2, Ireland
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
Spain:
Entity: Greystar Spain S.L.U.
Location: Madrid, Spain
Registered Office: Paseo de la Castellana
163, 3º Izda. 28046 Madrid
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
The Netherlands:
Entity: Greystar Netherlands Cooperatief
U.A.
Registered Office: New Babylon Gardens,
Anna van Buerenplan 48, 2595 DA, The Hague,
Netherlands
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
United Kingdom:
Entity: Greystar Europe Holdings Limited
Location: London, United Kingdom
Registered Office: Finsbury Circus House,
15 Finsbury Circus, London, EC2M 7EB
Contact Point for Data Protection
Enquiries:
privacy@greystar.com
EU Supervisory Authorities: Should you have
any concerns regarding the processing of
your Personal Information, you may contact
the national data protection authority in
the EU jurisdiction in which you normally
access our sites at
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
.
The Supervisory Authority in the UK is the
Information Commissioner's Office, whose
contact details are available at
ico.org.uk
.
NOTICE TO MAINLAND CHINA DATA SUBJECTS
Individuals in Mainland China can find more
information by reading our
Mainland China Privacy Statement
.
In many instances, Greystar acts as a
separate Controller (as defined in the
GDPR) with property owners, who may also
use the Personal Information we collect.
Owners have the right to use certain
Personal Information for their own purposes
in accordance with your tenant agreement
and in order to comply with their own legal
obligations, including maintaining books
and records. In other instances, Greystar
may be a Processor (as defined in the GDPR)
for certain Personal Information, acting on
behalf of the owner to manage the property
and provide resident services.
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 Policy 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.
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