Privacy Policy
Last Updated October 29, 2024
Tishman Speyer and its affiliates, subsidiaries, and related companies (“Tishman Speyer”, “we” or “us” or “our”) are committed to protecting the privacy of your personal information and data (collectively, “personal information”). Tishman Speyer has created this Privacy Policy (“Policy”) to inform you how we collect, store, use and protect your personal information, and your rights regarding that information, when you use the ZO Application and the associated services offered by ZO and Studio (the “App”). We may provide a separate privacy policy in connection with certain websites, applications, and services that we offer and, where we do so, such policies will apply to our collection and use of personal information collected through such websites, applications, and services.
Please read this Policy carefully before using the App or submitting personal information to us. This Policy is incorporated into and subject to the Terms of Use. BY ACCESSING OR USING THE APP, OR SUMBITTING PERSONAL INFORMATION TO US BY OTHER MEANS, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. If you do not agree to this Privacy Policy or our Terms of Use, you may not use the App.
We reserve the right to revise this Policy at any time. If we make any material changes, we will update the date noted above. We reserve the right to provide notice of any changes in other ways as well. Your use of the App after such changes constitutes your agreement to the Policy as amended. Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your personal information in accordance with the terms of the Policy in effect at the time of the collection. The Policy and the Terms of Use should be read together with the local Tishman Speyer privacy policies that apply to your region.
1. INFORMATION WE COLLECT ABOUT YOU
In connection with your use of the App, we generally collect the following categories of personal information. We use this information to operate the App, carry out our business, comply with applicable laws, and for other purposes described herein. (Please see the “Why We Collect Your Information” section below for additional information.)
- Identifiers and Contact Information. This category includes names, phone numbers, email addresses, and other similar contact information and identifiers.
- Internet or Other Electronic Network Activity Information. This category includes, without limitation, information regarding which content and features within the App the user interacts with.
- Geolocation Data. This category includes, without limitation, the user’s geolocation when using the App.
- Professional and Employment-Related Information. This category includes, without limitation, current job title, employer, and office location (building and city).
- Consumer Profile. This category includes information drawn from any of the categories above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
2. SOURCES OF INFORMATION WE COLLECT ABOUT YOU
- Information You Provide to Us Directly. You provide us certain information, such as contact and payment information, in connection with your use of the App.
- Information Collected Automatically Through the App. As you interact with the App, we may compile statistical information concerning the usage of the App through analytics services, such as those provided by VTS Activate. To do so, we may collect certain information about your computer or mobile device and in-app activity, including:
- Details of your use of the App, such as traffic data, location data, logs and other communication data, and the content that you interact with on the App, including video content.
- Information about your computer or mobile device and internet connection, including your IP address, operating system, and browser type.
- Information about the time and length of your use of the App.
- Information about your preferences to make your use of the App more productive, collected via the use of cookies and other tracking technologies. For more information, please see the “Cookies and Other Tracking Technologies” section below.
3. COOKIES AND OTHER TRACKING TECHNOLOGIES
We use cookies and other web technologies (“Cookies”) to collect and store certain types of information when you use the App. A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering your user preferences, improving the quality of your visit, recording the website pages you view, remembering the name or address you entered during a visit, or delivering ads that are targeted to your interests and browsing activity.
Types of Cookies
- First and Third Party Cookies: First party Cookies are generally placed on your computer or device by the application you are using. For example, we may use a first party cookie to improve App security. Third party Cookies are placed on your computer or device by a source other than the App in order to enable third-party features such as payment processing.
- Essential or Strictly Necessary Cookies: These Cookies are necessary for the App to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
- Performance and Functionality Cookies: Although these are non-essential Cookies, they help the App perform and function as designed. For example, performance and functionality Cookies help to facilitate payments through the App.
- Analytics Cookies: These Cookies track your usage of the App. The information these Cookies collect can be used for various purposes such as understanding how visitors use the App, content customization, or advertising and marketing.
The App uses essential, functional, and performance Cookies to function and perform as designed and analytics Cookies to understand how you use the App, to improve the App’s functionality, and other related purposes. We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices.
Embedded Content. The App contains embedded content (e.g., videos). Embedded content may place third party Cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these Cookies collect, and you should refer to their website privacy policy for additional information.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because the App is not configured to detect Do Not Track signals from a user’s computer or device, we are unable to respond to Do Not Track requests.
4. WHY WE COLLECT YOUR INFORMATION
In general, we will use the personal information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your personal information in the following ways:
- To Operate the App. We may use your personal information to enable use of and to administer the App;
- To Provide Services. We may use your personal information to provide you with services. For example, to enable you to utilize the amenities, perks, and workspaces offered through the App.
- For Internal Use. We may use your personal information for various internal business purposes, including, without limitation: to review, improve, and monitor your use of the App and overall experience when using the App; to provide customization to meet specific needs; to assess the trends, interests, and demands of users; and to carry out our obligations and enforce our rights, including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To Communicate with You. We may use your personal information to communicate with you, including sending messages about the availability of the App, security, or other service or business transaction-related issues. (You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.) We may also send you administrative or account-related information to keep you updated about your account and the App. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates, tips, or other relevant transaction-related information. App-related communications are not promotional in nature.
- To Provide Customer Support. We may use your personal information to provide customer service and engage in quality control activities concerning our properties and services.
- To Enforce Compliance with Our Terms, Agreements, and Policies. When you access or use the App, you are bound to our Terms of Use and this Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit, or illegal activities on the App. We also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies, and to enforce our agreements with third parties and business partners. We cannot maintain the App in accordance with our terms, agreements, or policies without processing your personal information for such purposes.
- To Ensure the Security of the Services. As noted above, we may process your personal information as necessary or appropriate to protect the rights, property, security, and safety of our business, our employees and clients, our information systems, and the public. Keeping you safe requires us to process your personal information, such as your device information, activity information, and other relevant information. We use such information to combat spam, malware, malicious activities, or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
- To Maintain Legal and Regulatory Compliance. We are subject to certain laws and regulations which may require us to process your personal information. We may also use your personal information to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
- To Engage in Marketing Activities. We may process your contact information, information about your interactions on the App or other information systems, or information we collect from or about you from other sources, to send you marketing communications and keep you updated about the App and our services; provide you with information about events or other materials; and deliver targeted marketing to you.
- Other Purposes. We may use your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
5. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information for the same reasons that we may use it, as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
The following chart describes the categories of personal information we have collected or may collect about you and, for each category, identifies the categories of third parties to whom we may disclose that information.
Categories of Personal Information | Categories of Third Parties to Whom Disclosed & Purposes for Disclosure |
---|---|
Identifiers such as name, phone numbers, email addresses, and other similar contact information | Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including app development and hosting vendors, payment processing vendors, banks, marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. |
Professional information, including job title, employer, and office location (building and city). | Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including app development and hosting vendors, payment processing vendors, banks, marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. |
Internet or other electronic network activity, such as information regarding which content and features within the App the user interacts with | Third parties as directed by you. We may disclose your personal information to third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including app development and hosting vendors, payment processing vendors, banks, marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. |
Geolocation data | Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including app development and hosting vendors, payment processing vendors, banks, marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. |
Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers | Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including app development and hosting vendors, payment processing vendors, banks, marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction. |
6. LINKS TO THIRD PARTIES’ SITES AND THIRD-PARTY INTEGRATIONS
We may provide links to websites or resources outside of the App for your informational purposes only. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with the App to provide you with additional functionality, tools, or services such as maps, sending you requested information, etc.
You acknowledge and agree that we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services, or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or that is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
7. SECURITY
We take precautions to protect data and information under our control from misuse, loss, or alteration. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. However, no system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your personal information from being intercepted, accessed, used, or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information.
Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding the password, security questions and answers, and other authentication information you use to access the App.
8. YOUR CHOICES
We make reasonable efforts to ensure that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You may contact us via the information in the “Contact Us” section below to update personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In responding to your request, we may seek information to verify your identity.
9. RETENTION
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and other legitimate business needs. We will delete, deidentify, or aggregate your personal information when it is no longer reasonably required for the purposes described herein (or compatible purposes), or, where applicable, when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. To determine the appropriate retention period for your personal information, we consider various factors, such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements.
10. CHILDREN’S PRIVACY
The App is not intended to be used by children under 16. Accordingly, we do not knowingly solicit or collect personal information from anyone we know to be under 16 years of age. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove such information from our servers. No information should be submitted to us by users under the age of 16.
11. APPLICABLE LAW
This Policy is governed by the internal substantive laws of New York without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within New York. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
12. INTERNATIONAL TRANSFERS
When you access or use the App, we may transfer your personal information to other countries where we conduct business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the App.
13. CALIFORNIA AND TEXAS RESIDENTS
This section applies only to California and Texas residents. It supplements and amends the information contained in the Policy with respect to such individuals. The other provisions of the Policy continue to apply, except as modified in this section.
Shine the Light [California residents only]. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. Such requests must be submitted to us in accordance with the instructions in the Contact Us section of this Policy. Please mention when contacting us that you are making a “California Shine the Light” inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than in accordance with the instructions specified in this paragraph.
Eraser Law [California residents only]. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information at the end of this Policy. Please be aware that such request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Your Rights.
You may have certain rights related to your personal information, subject to certain exceptions. Specifically:
Right to Know. You have the right to request that we disclose the following to you upon receipt of your verifiable consumer request:
- The categories of personal information we have collected about you
- The categories of sources from which we collected that information
- The business or commercial purposes for collecting, selling, or sharing that information
- The categories of personal information we sold or disclosed for a business purpose
- The categories of third parties to whom we sold or disclosed that information
- The specific pieces of personal information we collected about you
If you previously provided us your personal information, and that information is available in a digital format, you may have the right to obtain a copy of the information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another person without hindrance.
Right to Delete. You have the right to request that we delete your personal information from our records, subject to certain exceptions. Upon receipt of a verifiable consumer request, and as required by applicable law, we will delete and direct any service providers to delete your personal information.
We are not required to comply with deletion requests if we, or our service providers or contractors, need the subject information in order to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information to us.
- Comply with a legal obligation.
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correct. You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by applicable law, we will take appropriate steps to respond to your request.
Opt-Out of the “Sale” or “Sharing” of Personal Information or Use of Such Information for “Targeted Advertising” or “Profiling”. We engage in common marketing and advertising practices to provide more relevant content and ads to users of the App and related services. Certain of these practices may involve the “selling” or “sharing” of personal information, as those terms are defined in the California Consumer Privacy Act, as amended (“CCPA”), or the use of such information for “targeted advertising” or “profiling,” as those terms are defined in the Texas Data Privacy and Security Act (“TDPSA”). We do not sell personal information under the more commonly understood meaning of that word – i.e., providing personal information to third parties in exchange for money. Nor do we have actual knowledge of selling or sharing personal information of minors under the age of 16. To opt-out of the selling or sharing of your personal information, or use of that information for targeted advertising or profiling, please submit your request here, by emailing us at webmaster@tishmanspeyer.com, or by calling us toll-free at (833) 430-2169.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. For example, we generally will not provide you a different level or quality of goods or services if you exercise these rights.
Submitting Consumer Rights Requests
To make a consumer rights request, please submit your request here, by emailing us at webmaster@tishmanspeyer.com, or by calling us toll-free at (833) 430-2169.
Verification. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- a natural person or business entity authorized to act on behalf of a consumer.
To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. Making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond.
Authorized Agents. You may authorize a natural person or business entity to act on your behalf with respect to your rights under this section. Unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission, signed by you, to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Our Response. You may have the right, subject to applicable law, to submit up to two (2) requests per year free of charge. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In the event we deny your request, in whole or in part, we will explain the bases for that denial.
Appeal of Our Response. In the event you believe we have erroneously denied your request, in full or in part, you may, within 60 days of receipt of that denial, submit an appeal here, by emailing us at webmaster@tishmanspeyer.com, or by calling us toll-free at (833) 430-2169. In your appeal submission, please explain why you believe our decision to deny your request was incorrect and please provide any additional information you believe we should consider in connection with your appeal. Within 60 days of receipt of your appeal, we will advise you in writing of any action we have taken, or refrained from taking, in response to your appeal, along with an explanation of why we have taken, or refrained from taking, such action.
14. CONTACT US
For questions relating to this Policy or your personal information, please contact us at webmaster@tishmanspeyer.com.
15. EUROPEAN ECONOMIC AREA and UK RESIDENTS
The following section applies solely to individuals located in the European Economic Area (“EEA”) or United Kingdom (“UK”). This “EEA Section” supplements and amends the information contained in the Privacy Policy. The other provisions of the Privacy Policy continue to apply except as modified by this EEA Section.
Any terms defined within the EU or UK General Data Protection Regulations (“GDPR”) have the same meaning when use in this EEA section.
Tishman Speyer is the data controller for purposes of processing personal data in accordance with this EEA Section, unless otherwise noted.
If you have any questions about this EEA Section, please contact us by email at webmaster@tishmanspeyer.com, call us toll-free at (833) 430-2169, or mail us at the applicable address below:
- Tishman Speyer Properties UK Limited, a company incorporated under the laws of England (registered number: 3556917) whose principal office is at 10 Bressenden Place, London, England, SW1E 5DH, England (the “UK Representative”).
- Tishman Speyer Properties Deutschland GmbH, a company incorporated under the laws of Germany (registered number: HRB 80232) whose principal office is at TaunusTurm Taunustor 1 Frankfurt am Main, 60310, Germany (the “EU Representative”).
A. Collection of Personal Data. We collect the following personal data. In general, you are not required to provide this personal data; however, you may be unable to access or we may be unable to provide services, products, information or content if you choose not to provide certain requested information. We will note when the provision of your personal data is necessary to comply with a legal obligation that applies to us or you, or if the provision of data is a contractual obligation. We will also advise you of the consequences if you choose not to provide your personal data.
We process the following personal data we collect in reliance on the lawful bases and for the purposes set forth below. In general, we may process your personal data for one or more purposes and in reliance on one or more lawful bases such as your affirmative consent, our legitimate interests, to enter or perform a contract with you, or to comply with legal obligations.
Where we rely on legitimate interests to process your personal data, you may object by contacting us at webmaster@tishmanspeyer.com.
i. Identifiers, contact information and similar personal data.
This consists of identity and contact data including username and password; employer; job title; office location; professional data; phone number, address, and similar information. You have the option of submitting a photo for your account profile.
The purposes for processing this information include enabling use of and administering the App; creating your account and account profile; communicating with you; providing requested services and customer support (e.g., to enable you to use the amenities, perks, and workspaces offered through the App); payment processing; for our internal use (e.g., to review, improve, and monitor use of the App and your overall experience; to provide customization; to assess trends, interests, and user demands; to carry out our obligations and enforce our rights, including those arising from any contracts entered into between you and us, including for billing, payment, and collections, for record keeping); to enforce our Terms of Use and this Policy; for security and fraud prevention; to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred; to comply with laws to which we may be subject; to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
We process this data in reliance on the following lawful bases:
- To enter or perform a contract with you.
- For our legitimate interests including data analytics and research; corporate governance, internal audits and reporting, record keeping; marketing; communicating with you; fraud prevention and security; billing; investigating claims or allegations, establishing or defending legal claims; complying with legal obligations to which we are subject.
- For compliance with legal obligations under member state national legislation.
- Based on your affirmative consent.
ii. Marketing and Advertising data:
This information includes your preferences, characteristics, and behaviors; interactions with the App; contact and demographic information; requests for information; and information related to your use of our App, products and services.
The purposes for processing this information include developing marketing and advertising campaigns and programs; sending communications related to our products and services; conducting market research and analytics; record keeping; investigating claims or allegations, establishing or defending legal claims; to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; to comply with laws to which we may be subject; to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
We process this data in reliance on the following lawful bases:
- For our legitimate interests in marketing to potential clients; analytics; research and development; record keeping; corporate governance; and other purposes set forth above.
- Based on your affirmative consent.
iii. Usage and Technical data:
This includes information related to your interaction with the App including without limitation, location data; logs; device identifiers; browser types; information about your preferences and the content that you interact with on the App; IP address and operating system. We may compile statistical information concerning the usage of the App through analytics services, such as those provided by VTS Activate. For additional information, please see our Cookie Policy below.
The purposes for processing this information include authentication, session management, error logging, feature flagging and performance, developing marketing and advertising campaigns and programs; sending communications related to our products and services; conducting market research and analytics; corporate governance; record keeping; fraud prevention and security; ensuring compliance with our website Terms of Use and this Policy; investigating claims or allegations, establishing or defending legal claims; to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; to comply with laws to which we may be subject; to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
We will collect your location at first sign up and thereafter when you use the App. The purpose for processing your location is to help you identify other buildings, amenities (e.g., gyms, parking lots, restaurants) and public events happening in the area. The app does not track your location in the background and you can disable location services for the app in the device settings.
We process this data in reliance on the following lawful bases:
- To enter or perform a contract with you.
- For our legitimate interests in developing and conducting marketing campaigns; data analytics, research and development; record keeping; fraud prevention and security; to ensure compliance with our website terms; investigating claims or allegations, establishing or defending legal claims and other purposes set forth above.
- Based on your affirmative consent.
iv. Financial information.
This includes data related to billing and payment for services.
The purposes for processing this information include providing the App and requested services; payment processing; marketing; corporate governance; record keeping; fraud prevention and security; compliance with legal obligations; investigating claims or allegations, establishing or defending legal claims; to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. to comply with laws to which we may be subject; to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, and for other lawful processes or public safety purposes.
We process this data in reliance on the following lawful bases:
- To enter or perform a contract with you.
- For our legitimate interests in record keeping; fraud prevention and security; investigating claims or allegations, establishing or defending legal claims; compliance with legal obligations and other purposes set forth above.
- Based on your affirmative consent.
B. Cookies and Other Tracking Technologies. We use Cookies to collect and store certain types of information when you use the App. For additional information and to manage your preferences, please see our Cookie Policy below.
C. Sharing Your Personal Data. We share your personal data with the following categories of third parties as required or permitted by law and as necessary to achieve the processing purposes listed above.
- Within Tishman Speyer. We share your data with workforce members or contractors who have a need to know based on job role and responsibilities.
- Related entities and affiliates. For example, we may share your personal data with affiliates that offer services we think may be of interest to you, such as Studio, Exhubrancy, and restaurants located at our properties (e.g., Café Llama, Le Rock, and Naro).
- Your employer.
- Business partners.
- Service providers, vendors, and contractors who provide us with services such as application development and support, IT support; security; cloud storage; marketing, advertising, and data analytics.
- Regulatory authorities, public and judicial bodies, law enforcement and related third parties in connection with investigations, legal proceedings or court orders, legal reporting obligations or as necessary to protect the vital interests of you or others.
- Professional Advisors including lawyers, consultants, and auditors.
- Third parties in relation to evaluating or conducting a merger, acquisition, sale or transfer of our assets.
- Third parties as directed by you.
D. Data Subject Rights. Under the GDPR, you have the following rights, subject to limitations.
These include the right to:
- Obtain confirmation as to whether we are processing your personal data, receive access to the personal data and information about that processing, and obtain a copy of the personal data.
- Request correction of incomplete or inaccurate personal data we hold about you.
- Request a restriction on the processing of your personal data in certain limited circumstances.
- Object to the processing of your personal data carried out in the public interest, based on our legitimate interests of those of a third party, or for purposes of direct marketing.
- Request the erasure or deletion of your personal data.
- Receive your personal data, which you provided to us, in a structured commonly used machine-readable format and to transmit that personal data to another data controller where processing is based on your consent, pursuant to performance of a contract, or where the processing is performed by automated means.
- Not to be subject to a decision based solely on automated processing, including profiling, which produces a legal effect concerning you or similarly significantly affects you.
- Lodge a complaint with the appropriate authority in your jurisdiction.
- Withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us webmaster@tishmanspeyer.com.
E. Retention. Please see section 9, above.
F. Transfers. We or third party service providers may transfer your personal data out of the EEA or UK to third parties or companies affiliated with us for certain purposes listed above, including processing or storage. When we transfer your personal data to a recipient in a third country, we endeavor to ensure it receives a similar degree of protection as provided by the data protection laws of your jurisdiction. For more information on the mechanism we use to transfer your personal data, please contact us at webmaster@tishmanspeyer.com.
16. COOKIE POLICY
We and our partners use Cookies to collect, store, and use certain types of information when you use the App.
This Cookie Policy describes the types of Cookies we or third parties use and how to manage your Cookie preferences. You may accept all Cookies, reject all except essential Cookies, or select the Cookies you wish to allow. You may freely withdraw your consent at any time by following the instructions in the Cookie Chart, below, or deleting them through your Internet browser settings. Please note that if you block certain Cookies, some content, features, and functions of the App may not be available.
For more information on Cookies, visit www.allaboutcookies.org.
We use the following categories of Cookies on the App:
- First and Third-Party Cookies: First party Cookies are generally placed on your computer or device by the website or App you are visiting. For example, we may use a “first party” Cookie to improve App security. “Third-party” Cookies are placed on your computer or device by a source other than the App in order to enable third-party features such as payment processing, advertising, analytics, videos, or interactive content. Third parties may process the Cookie data on our behalf or for purposes determined by that third party. For more information on third parties, please click on the third-party link in the Cookie Chart below.
- Essential or Strictly Necessary Cookies: These Cookies are necessary for the App to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
- Analytics Cookies: These Cookies track your usage of the App. The information these Cookies collect can be used for various purposes such as understanding how visitors use the App, content customization, or advertising and marketing.
The App uses essential Cookies to function and analytics Cookies to understand how you use the App,
We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices. When you use the App, Cookies may be used by our third-party partners or service providers to associate your information and activities with other personal data they or others have about you.
Cookie Chart
The following chart discloses additional information about the Cookies we use on the App.
Cookies | Purpose/Use | Type | Expiry | Third Party |
---|---|---|---|---|
Essential cookies | ||||
adroll_fpc | User authentication and session tracking (Necessary) |
| Persistent | |
_fbc | User authentication and session tracking (Necessary) |
| Persistent | |
_ga_7BGDYC1WQL | User authentication and session tracking (Necessary) |
| Persistent | |
dpi_utmOrigVals | User authentication and session tracking (Necessary) |
| Persistent | |
ajs_anonymous_id | User authentication and session tracking (Necessary) |
| Persistent | |
rm_rk-xQakW3xSXnjZZP8GL | User authentication and session tracking (Necessary) |
| Persistent | |
ajs_group_id | User authentication and session tracking (Necessary) |
| Persistent | |
ajs_user_id | User authentication and session tracking (Necessary) |
| Persistent | |
_mkto_trk | User authentication and session tracking (Necessary) |
| Persistent | |
fs_uid | User authentication and session tracking (Necessary) |
| Persistent | |
_ga | User authentication and session tracking (Necessary) |
| Persistent | |
_dd_s | User authentication and session tracking (Necessary) |
| Persistent | |
_biz_nA | Feature and functionality flagging |
| Persistent | |
_biz_pendingA | Feature and functionality flagging |
| Persistent | |
_biz_uid | Feature and functionality flagging |
| Persistent | |
_ga_31EH4XPW51 | Feature and functionality flagging |
| Persistent | |
@sentry/react-native | Error logging (Necessary) |
| 1 year | |
@sentry/node | Error logging (Necessary) |
| 1 year | |
@sentry/brower | Error logging (Necessary) |
| 1 year | |
AUTH-MECHANISM-COOKIE | Unique session management |
| Expires on session termination | |
CSRF-TOKEN | Unique session management |
| Expires on session termination | |
looker.browser | Unique session management |
| Expires on session termination | |
looker.expires_at | Unique session management |
| Expires on session termination | |
rack.session | Unique session management |
| 30 days | |
looker.session .retention | Unique session management |
| Expires on session termination | |
Last_heartbeat | Unique session management |
| Expires on session termination | |
rack.session | Unique session management |
| Expires on session termination | |
Non-essential cookies | ||||
_hjSessionUser_2879837 | Analytics, engagement metrics |
| 1 year | |
mp__origin_referrer | Analytics, engagement metrics |
| 1 year | |
mp__origin | Analytics, engagement metrics |
| 1 year | |
_rdt_uuid | Analytics, engagement metrics |
| 1 year | |
mp_metrics-1_mixpanel | Analytics, engagement metrics |
| 1 year | |
_uetvid | Analytics, engagement metrics |
| 1 year | |
_fbp | Analytics, engagement metrics |
| 1 year | |
_ga_6NLLN3BJ6F | Analytics, engagement metrics |
| 1 year | |
_gcl_au | Analytics, engagement metrics |
| 1 year | |
_ga | Analytics, engagement metrics |
| 1 year | |
_clck | Analytics, engagement metrics |
| 1 year | |
__stripe_sid | Payment processing |
| 1 year | |
__stripe_mid | Payment processing |
| 1 year |
We or third parties may transfer your personal data out of the EEA or UK to third parties or companies affiliated with us for processing or storage in a third country including the United States. When we transfer your personal data to a recipient in a third country, we endeavor to ensure it receives a similar degree of protection as provided by the data protection laws of your jurisdiction. For more information, please contact us at webmaster@tishmanspeyer.com.
We reserve the right to update this Cookie Policy at any time. Please monitor the “Last Updated” notice for this Cookie Policy since changes to the Policy will be effective upon posting. Your continued use of the App after posting indicates your consent to the updated Cookie Policy.
You may contact us at webmaster@tishmanspeyer.com with any questions relating to this Policy and our use of Cookies.
Our Cookie Policy was last updated: October 29, 2024
To the extent a Tishman Speyer affiliate, subsidiary, or related company is not governed by this Privacy Policy, a different Privacy Policy will be available on the affiliate, subsidiary, or related company’s website or app. The “App” includes by definition, and this Privacy Policy (the “Privacy Policy” or simply the “Policy”) applies to, the App, and any mobile app, web pages, interactive features, other applications, widgets, blogs, social networks, social network “tabs,” or other online or wireless offerings that link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means.