HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION
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, providing our information technology systems, supporting outsourcing arrangements, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice. 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.
- 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.
- 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 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.
- Government Authorities. We disclose Personal Information and Other Data to government authorities in accordance with applicable laws.
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.
BUSINESS TRANSITIONS
If Greystar goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, including an individual property, 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 Global Privacy Policy in place at the time of the transfer. If required by law, we will separately notify you of such transfer.
YOUR PRIVACY PREFERENCES AND RIGHTS
We provide you with options, information, and choices as required under applicable law 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. If you opt out of receiving marketing messages, we will continue to send you transactional messages. These include answers to your questions. If your request has not been duly answered, or you have further doubts, you can contact us via email on: privacy@greystar.com.
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, withdraw your consent, 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 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.
SECURING INFORMATION
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.
RETENTION
We will retain your Personal Information for the period we believe reasonable to fulfill the purposes for which we hold it, as outlined in this Global Privacy Policy 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); and
- whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
CHILDREN'S PRIVACY
Our websites are not directed at children. We do not process or maintain information at our sites from those who are considered children in the jurisdiction in which they reside. We do not permit children under 16 years of age (or such higher age specified by applicable law) to become registered users of our sites. By using any of our sites, 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 does not meet these age requirements, please contact us using the information in the "Contact Information" section.
DATA TRANSFERS – INTERNATIONAL USERS
Greystar is a global company and as a result, we may, subject to law, transfer Personal Information and Other Data processed 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. and in other countries, such as India. These transfers will comply with the data transfer requirements of applicable laws. Please review the information provided in the section called Location-Specific Disclosures to learn more about data transfers in your jurisdiction.
PROFILING AND AUTOMATED DECISION-MAKING
In certain circumstances and subject to applicable law, we may use automatic decision-making to evaluate your credit against our required criteria. Except as set out in the section called Location-Specific Disclosures, credit-checking is a mandatory step in our application review process.
In certain circumstances and subject to applicable law, we or our third party service providers 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/.
AI TOOLS
Our website and/or the websites of the properties we manage may offer certain AI tools, which includes any AI chatbots that use Microsoft’s generative pre-trained transformer language models known as GPTs. The AI chatbot does not collect personal information unless you voluntarily input such information. We may use the prompts submitted by users to improve the quality of the AI chatbot responses; however, the prompts used for quality improvement purposes do not identify an individual, unless user voluntarily provided their personal information. Prompts are shared with Microsoft solely to provide the AI chatbot service. The AI chatbot is not used for the purpose of automated decision making.
LOCATION-SPECIFIC DISCLOSURES
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.
Some state laws, such as the California Consumer Privacy Act (“CCPA”), permit residents to exercise certain rights regarding their Personal Information. Residents of these states can find more information on exercising their rights under these state laws by reading our US State Law Privacy Notice.
NOTICE TO RESIDENTS OF CANADA
Any transfers of personal information outside your province will comply with applicable privacy legislation including the requirement to use data transfer agreements to provide your information with appropriate protection.
In addition to the rights of access, change, and consent withdrawal described above in “Your Privacy Preferences and Rights” section, Canadian residents have the right to lodge a complaint with the applicable data protection authority if they believe that their privacy rights have been violated.
Under certain circumstances, Quebec residents may also have the right to request that we: (i) cease disseminating their personal information; (ii) de-index or re-index a hyperlink attached to their name that provides access to personal information by a technological means; or (iii) that computerized personal information collected from them be communicated to them in a commonly used technological format as well as to any person or body authorized by law to collect such information.
Those seeking additional information on Greystar’s processing of Personal Information are invited to contact:
Canada:
Entity: Greystar Canada Property Management Services Ltd.
Location: Charleston, SC
Registered Office: 465 Meeting Street, Suite 500, Charleston, SC 29403 USA
Contact Point for Data Protection Enquiries: privacy@greystar.com
NOTICE TO BRAZILIAN DATA SUBJECTS
When Personal Information is transferred outside Brazil, including to other Greystar entities, we ensure your Personal Information is processed only in countries that provide an adequate level of protection or where the recipient provides appropriate safeguards for such processing. In addition, we guarantee that all the guidelines and standard clauses published by the national authorities will be applicable and duly respected when handling your Personal Information.
Data Controller Corporate Details (including contact details):
Brazil:
Entity: Greystar Brasil Consultoria Imobiliária Ltda.
Location: São Paulo, Brazil
Registered Office: Rua São Bento, 470, 10th floor, São Paulo, Brazil
Contact Point for Data Protection Enquiries: privacy@greystar.com
NOTICE TO EU AND UK DATA SUBJECTS
This section of the Global Privacy Policy 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: Grosse Gallusstrasse 16-18 Frankfurt, 60311 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 https://ec.europa.eu/newsroom/article29/items/612080.
The Supervisory Authority in the UK is the Information Commissioner's Office, whose contact details are available at ico.org.uk.
NOTICE TO RESIDENTS OF INDIA
In accordance with the provisions of the Indian Information Technology Act, 2000, residents of India may request the name and address of any external third parties who may have access to or are retaining Personal Information by making a request to Greystar for such details.
India:
Entity: Greystar India Services Private Limited
Location: Mohali, India
Registered Office: Unit A-711, Tower A, Bestech Business Towers, Sector 66, Mohali - 160059
Contact Point for Data Protection Enquiries: privacy@greystar.com
NOTICE TO MAINLAND CHINA DATA SUBJECTS
Individuals in Mainland China can find more information by reading our Mainland China Privacy Statement.
NOTICE TO INDIVIDUALS LOCATED IN AUSTRALIA
This section of the Privacy Statement includes additional provisions for the purposes of the Privacy Act 1988 (Cth) and Australian Privacy Principles (“APPs”).
“Personal Information” means information or opinion about an identified individual or an individual who is reasonably identifiable.
In addition to the purposes set out above, we may also use or disclose your personal information for any purposes permitted by applicable law.
In the course of our ordinary business operations, we commonly disclose personal information to third parties located in the following countries:
- United States of America
- United Kingdom
In addition to the “Securing Information” section, we store your personal information electronically, and the steps we take to secure personal information include encryption measures and access controls. Hard copies containing personal information are retained only when deemed essential and are stored in secure environments.
Credit-checking is not a mandatory step in our application review process.
If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Privacy Act, please contact us as set out below. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
Data Privacy Officer
privacy@greystar.com
465 Meeting St., #500
Charleston, SC 29403
If you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing
Director of Compliance
Office of the Australian
Information Commissioner
GPO Box 5288
Sydney NSW 2001
www.oaic.gov.au
For a Phone Enquiry: 1300 363 992
CONTROLLER AND DATA PROCESSOR
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 process, and this may also be the case when we work with another property manager, or another property manager succeeds us. 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.
UPDATES TO THIS GLOBAL PRIVACY POLICY
Any changes we make to this Global Privacy Policy will become effective upon posting. If we change our Global 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. If we are legally permitted to do so, we may also email you.
CONTACT INFORMATION
If you have any questions about this Global Privacy Policy or have complaints about the processing of the Personal Information, 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