PRIVACY POLICY

1. Your Acceptance Through Use

This Global Web Privacy Policy describes how CBRE collects, uses and discloses certain personal information obtained through this Site.  Please note that your use of this Site signifies your understanding and acceptance of the terms of this Global Web Privacy Policy.  This Global Web Privacy Policy is incorporated into, and is part of, the Disclaimer-Terms-of-Use, which govern your use of the Site in general.

This Global Web Privacy Policy will be continuously assessed against new technologies, business practices and our clients’ needs. As we update and diversify our products and services, this Global Web Privacy Policy may evolve. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Global Web Privacy Policy at any time. Visitors are encouraged to review this Global Web Privacy Policy from time to time for updates periodically. We will try to post any changes to this Global Web Privacy Policy before they become effective. If we make any material changes to this Global Web Privacy Policy, we will notify you here, by email or by means of a notice on our Site’s home page. Your continued use of our Site following the posting of changes to these terms means you accept these changes.

 

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2. The Types of Information We Collect

We have several areas in this Site (including links to other CBRE websites) where you can submit personal and other information to us. The types of personal information we may obtain or you may choose to provide include:

• Contact information (such as name, postal or e-mail address, and phone number)
• Your professional information (such as job title, department and name of organization)
• Account information
• Subscription details
• Username and password
• Payment account information
• Content you provide (such as job and education history, comments, responses to questions)
• Mobile device unique identifier
• Geo-location data
• Information about your use of our websites.  For more information, see our Cookies Policy

 

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3. How We Use Your Information

Communications With You – Offerings and Services In Which You Expressed Interest
When you visit or transact business on this Site, you may be required to register with us or be requested to provide us with personal and account information. When you provide us with this information, we may use such information to contact you about the offerings or services in which you have expressed an interest. CBRE has a legitimate business interest to use the personal information we collect from you if you apply for employment or engage in a contractual business relationship with CBRE. Where we have relied on your consent, if you tell us that you do not want us to use this information as a basis for further contact with you (by accessing our opt-out procedure described below), we will respect your wishes.

Communications With You – Newsletters and Marketing Purposes:
In order to keep our users informed about our latest news, products and services, we may, subject to applicable law, send e-mails and marketing communications to the email address that you provided to us while registering on our Site or requesting information from us. Please be aware that we do sometimes send marketing communications that promote a third party’s products and services (for example, those of our business partners) as well as our own. If you elected to opt–in to any of our email lists, newsletters or other promotional offerings and later decide that you no longer wish to receive such newsletters or promotional e-mail from us, you may unsubscribe by following the instructions contained in each email we send to you (or use the opt-out procedure described below).

Other Uses:
We may also use the personal information we obtain about you for the following purposes:

• Creating and managing any accounts you may have with us and respond to your inquiries;
• Evaluating your interest in employment and contacting you regarding possible employment with CBRE;
• Operating, evaluating and improving our business (including developing new products and services; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, and mobile applications and any other digital assets);
• Anonymizing personal information and preparing and furnishing aggregated data reports showing anonymized information;
• Enforcing our Terms and Conditions or other legal rights;
• As may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over CBRE.

We also may use the information in other ways for which we provide specific notice at the time of collection.

 

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4. Information Provided to Us About You By Third Parties

Third-Party Links:
When using our Site, you may click through certain links or promotions that will enable you to purchase products or use services provided by our partners. Some of these partners may share certain information that you provide to them with us. By clicking on and through to a link or promotion on our Site, you agree to allow us to receive and use any information (except for credit card information) that you may provide to our partners, under the same terms and conditions as if you provided your information directly to us. We are not, however, responsible for any other Web site, or their respective privacy policy or how they treat information about their users. We strongly advise you to review their privacy policies to find out how they are treating your personal information.

Third Party Usage:
You may also separately share your information with other Web sites or entities, such as those that create professional marketing lists, to receive special offers and promotions from their affiliates. These Web sites or entities may agree to share your information with us. Whether any third party actually shares your information with us and to what extent they do share your information with us will depend on their agreement with us and their respective privacy policies. CBRE is not responsible for, and will assume no liability if a partner or other Web site or entity collects, uses or shares, any information about you in violation of its own privacy policy, or applicable law.

Marketing Data:
We may purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may also associate this marketing data to the personally identifiable information that you provide to us.
 

 

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5. Personal Information We Share

Vendors:
We may share your personal information with companies acting as our authorized agents in providing our services (e.g., customer/support services) to you, all of which agree to use your information only for such specified purposes. Each vendor must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification or disclosure. Because we operate globally, we may transfer your information to countries or jurisdictions that do not provide the same level of data protection as the country in which you are based. If we make such a transfer, we will, or our vendors will, as applicable, provide for the proper safeguards required by applicable law to ensure that your information is protected. More information onInternational Data Transfers of your personal information is below.

Legally Affiliated Entities:
In the event that CBRE is merged, or in the event of a transfer of our assets, Site or operations, CBRE may disclose or transfer your personal information in connection with such transaction. In the event of such a transfer, CBRE will notify you via email or by posting a prominent notice on our Site for 30 days of any such change in ownership of CBRE resulting in a change of control of your personal information. We may also share your personal information with CBRE affiliates in order to provide or offer services to you.

Legally Compelled Disclosure:
We will also disclose your personal information when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to lawful requests by public authorities, including to meet national security or law enforcement agency's requirements, or in special cases when we have reason to believe that disclosing your personal information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (whether intentionally or unintentionally) our rights or property. 

Bankruptcy:
You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your personal information to be shared or transferred to third parties without your permission.
 

 

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6. International Data Transfers

Consent to Processing In the US and Elsewhere by Registration on This Site 
CBRE is a global business. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed, in countries other than the country in which the information was originally collected, including the United States and elsewhere that may have less stringent data protection laws than the country in which you initially provided the information. By providing any personal information to us, you fully understand and unambiguously consent to the transfer and processing of such personal information in the United States and other countries or territories.
When we transfer your information to countries other than the country in which the information was originally collected, we will protect your information as described in this Global Web Privacy and Cookie Policy or as otherwise disclosed to you at the time the data is collected (e.g. via program specific privacy notice) and will comply with all applicable data protection laws in making such transfers.  In particular, CBRE US affiliates are EU-US and Swiss-US Privacy Shield certified, and CBRE has executed EU Standard Contractual Clauses with respect to personal information collected in the European Economic Area and transferred to CBRE in the United States and elsewhere.
If you object to your personal information being transferred or used in this manner please do not register with or use the Site.

Privacy Shield Certification:
CBRE complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding personal information that is collected by CBRE affiliates or corporate customers located in the European Economic Area and/or Switzerland and transferred to CBRE, Inc. and its wholly owned US-based affiliates, which include CBRE Global Investors LLC, CBRE GCS Inc. (Puerto Rico Employees), CBRE Clarion Securities, LLC, CBRE Security Services, Inc., CBRE Capital Markets of Texas, LP, CBRE HMF, Inc., CBRE Multifamily Capital, Inc., CBRE Capital Markets, Inc., Trammell Crow Company LLC, and CBRE Technical Services, LLC in the United States (“CBRE US”). This Global Web Privacy Policy supplements the data protection notices that Clients and Client contacts may have received.  CBRE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability.  If there is any conflict between the terms in this Global Web Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov. CBRE is subject to investigatory enforcement powers of the Federal Trade Commission as it relates to conformation with Privacy Shield requirements. 
Independent Recourse of Privacy Shield Complaints
In compliance with the EU-US and Swiss-US Privacy Shield Principles, CBRE commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CBRE at: PrivacyAdministrator@cbre.com. 
CBRE has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit www.jamsadr.com for more information or to file a complaint. The services of JAMS are provided at no cost to you.  You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by JAMS.  For additional information on binding arbitration, visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

 

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7. Security

CBRE endeavors to protect the security of your personal information and your choices for its intended use. We use Secure Socket Layers or SSL technology to protect the transmission of sensitive personal information such as your credit card number. We store your personal information on a secure server, and use procedures designed to protect the personal information we collect from unauthorized access, destruction, use, modification or disclosure.
Although we will take (and require our third-party providers to take) commercially reasonable security precautions regarding your personal information collected from and stored on the Site, due to the open nature of the Internet, we cannot guarantee that any of your personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.

 

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8. Your Rights

Marketing Communications:
When you register on this Site, we may ask you to select whether you would like to receive email and electronic communications from us such as offers, news, reports and other promotional communications.  You may withdraw your consent or opt-out of receiving such communications at any time by contacting us as described below.  We are also improving this Site with a privacy preferences page so you can control what communications you want to receive from us.

You may contact us: (a) by telephone, at +1 877 227 3330; (b) by facsimile, at +1 212 6187085; (c) by following the Opt-Out or unsubscribe instruction contained in the body of any marketing e-mail from us; (d) by sending us an e-mail at PrivacyAdministrator@cbre.com, including a copy of the e-mail you have received and by typing “Remove” in the subject line of your e-mail; or (e) by mail, CBRE, Inc., 321 North Clark Street, Suite 3400, Chicago, Illinois 60654, Attention: Global Director, Data Privacy.

If you are located in Europe, the Middle East or Africa, you may also e-mail us at PrivacyAdministratorEMEA@cbre.com, including a copy of the e-mail you have received and by typing “Remove” in the subject line of your e-mail.

If you are located in Asia or the Pacific, you may also e-mail us at PrivacyAdministratorAPAC@cbre.com, including a copy of the e-mail you have received and by typing “Remove” in the subject line of your e-mail.

Your election not to receive newsletters or promotional and marketing correspondence from us will not: (i) preclude us from corresponding with you, by email or otherwise, regarding your existing or past relationship with us, and (ii) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal information in the course of maintaining and improving the Site.

Objecting to or Unsubscribing from Direct Marketing:
You may unsubscribe from or object to receiving direct marketing from us; or request correction or object to our processing your personal information collected by this Site by sending a written request to (a) PrivacyAdministrator@cbre.com or (b)PrivacyAdministratorEMEA@cbre.com if you are located in Europe, the Middle East or Africa, or (c)PrivacyAdministratorAPAC@cbre.com if you are located in Asia Pacific.

Requesting Access to Your Personal Information and Other Rights:
You may also request to review, access, correct, delete, port or object to our processing your personal information processed by us by making a request on CBRE’s data subject rights portal or submitting your request to dsr@cbre.com.  CBRE’s Guidance on Making a GDPR Data Subject Request is available on the DSR Portal.

Independent Recourse for Privacy Shield Complaints:
Information about independent recourse for Privacy Shield complaints can be found above.
Cookie Policy – Automatic Data Collection
By browsing on our Site, you are agreeing to our use of cookies.
What is a Cookie:  A cookie is a small text file that a website stores on your personal computer, telephone or any other device, with information about your navigation on that website. Cookies facilitate browsing and to make it more user-friendly.  A cookie contains the name of the server it came from, the expiry of the cookie, and a value – usually a randomly generated unique number.  Cookies do not give access to nor damage your computer.

 

(1) Cookies Used By Us

How we use Cookies:
When you visit our Site, we use cookies to identify you as a valid user, to ensure that no one else can sign on simultaneously with your account from another computer and to help us serve you better based on your registration preferences. We may also use cookies to help us facilitate any promotions or surveys that we provide.

Cookies Are Not Used to Store Sensitive Data:
The cookies we use do not store sensitive personal information, such as your address, your password, or your credit card data.
Main Cookies we use:
Here's a list of the main cookies we use, and what we use them for:

_ga

This is a Google analytics cookie and is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.

_gat

This is a Google analytics cookie, used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.

exp_csrf_token

This cookie protects against Cross Site Request Forgery (CSRF). A CSRF attack forces a logged-on victim’s browser to send a forged HTTP request, including the victim’s session cookie and any other automatically included authentication information, to a vulnerable web application. This allows the attacker to force the victim’s browser to generate requests the vulnerable application thinks are legitimate requests from the victim.

exp_tracker

Tracks the last 5 pages viewed by the user, and is used primarily for redirection after logging in etc. Affects guests and logged in users.

exp_last_activity

Every time the state is updated (the page reloaded) the last activity is set to the current datetime. Used to determine expiry. This is essential for logged in users, but not for guests - it is set for both.

exp_last_visit

Sets the datetime that the user last visited the site, and is set for both guests and logged in users. If not set, is automatically set to 10 years ago. Affects guests and logged in users.

cookieconsent_dismissed

This cookie is present when the user has accepted the use of cookies through the bottom footer cookie consent panel. Once accepted, the user will no longer see the bottom footer cookie consent panel.

apartmentSearch

This cookie stores your search preferences when using 'Find an apartment' filter search, for example number of bedrooms and floor.

 

(2) Performance Tracking

We sometimes use cookies, as well as tracking technology, such as web beacons, within the promotional emails that we send to our subscribers or advertisements for our Site. These performance tracking devices help us to track whether an e-mail recipient has completed an event, such as signing up for a free trial for example. Such information is non-personally identifying and collected on an aggregate level. We sometimes utilize third party service providers to help us track the activity within our Site. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking but the data would not be tracked in a personally identifiable way. Third parties whose products or services are accessible on our Site may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

 

(3) Avoiding and Disabling Cookies

Avoiding Use of Cookies on this Site: If you prefer to prevent us from using Cookies on your devices, before navigating on this Site, you must first disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this Site.

Disabling and Preventing Further Use of Cookies: You may restrict, block or delete the Cookies from this Site at any time by changing the configuration of your browser. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org.  In addition, while each browser has different settings and configurations, cookies settings can typically be adjusted in the "Preferences" or "Tools" menu. Your browser’s "Help" menu may provide additional information.

 

Contact Us

You are always free to contact us if you have questions or concerns regarding this Global Web Privacy Policy, have a question or problem related to your use of the Site, or wish to exclude your personal information from our direct marketing purposes. Our standard business practice is to retain any communications from our Site visitors to help us to serve each of you better. 

You may contact us by emailing PrivacyAdministrator@cbre.com or by writing to us at 321 North Clark Street, Suite 3400, Chicago, Illinois 60654, Attention: Global Director, Data Privacy. 

Visitors in Europe, the Middle East or Africa:
If you are located in Europe, the Middle East or Africa, you may also e-mail us at PrivacyAdministratorEMEA@cbre.com or write to us at St. Martins Court, 10 Paternoster Row, London EC4M 7HP, United Kingdom, Attention: EMEA Director, Data Privacy.

Visitors in Asia or the Pacific:
If you are located in Asia or the Pacific, you may also e-mail us at PrivacyAdministratorAPAC@cbre.com or write to us at 40/F GT Tower International, 6813 Ayala Ave. cor H.V. Dela Costa Street, Salcedo Village, Makati City, Philippines 1227, Attention: APAC Senior Manager, Data Privacy.

 

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