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Privacy Policy

Privacy Policy

Global Web Privacy and Cookie Policy

Last updated: 7 May 2021

Please Read Carefully.

CBRE, Inc., together with its subsidiaries (collectively, “CBRE Group”), recognizes the importance of protecting your privacy. This Global Privacy and Cookie Notice (“Notice”) is intended to assist you in understanding CBRE Group’s data collection and handling practices and in making informed decisions and exercising your data privacy rights under applicable law when you:

• Use CBRE Group’s public websites and other services to which this Notice is attached (collectively, the Site) or

• Interact professionally with CBRE Group, including through CBRE Group-operated social media accounts, and are not otherwise provided with a different privacy notice at the point of interaction (collectively, "Professional Interactions” ).

The CBRE websites that comprise the Site may post a local, country-specific privacy and cookie notice alongside this Notice which supplements or modifies this Notice as necessary to comply with applicable law (“Local Notices”).

Table of Contents

  • Summary of Key Information
  • Full Notice

    Global Web Privacy Policy

    Responsible Entity Depending on how and for what reason we collect your personal information through this Site or your Professional Interactions, the CBRE entities responsible for processing your personal information (also known in some jurisdictions as data controller) may differ. Please find information on how to identify your applicable responsible CBRE entity(ies) in Appendix 1. Click here to learn more.
    Acceptance Through Use To the extent permitted by applicable law, your use of this Site or engagement in Professional Interactions with us signifies your understanding and acceptance of the terms of this Notice. Click here to learn more.
    Personal Information We Collect and Sources We collect personal information about your use of the Site and Professional Interactions with CBRE such as Contact Information, Registration Information (such as username/password), Professional Information (such as job title, industry, employer), Business Relationship Information (such as your primary CBRE Group contacts), Social Media Information and Cookie, Device and Web Analytics Information.  We collect this personal information directly from you, from other CBRE employees, and from third parties. Click here to learn more.
    Use and Legal Bases We use your personal information to make the Site accessible to you, to communicate with you, to interact professionally with and provide marketing to you, and to improve our and to fulfill other commercial or business-related purposes. We primarily rely on the overriding business interests of CBRE or your consent (if required by law) to process your personal information. Click here to learn more.
    Data Sharing The CBRE Group is a global firm and the personal information we collect or you provide may be shared and processed as necessary with other CBRE entities, including those better suited to respond to your request and to provide you with access to the Site.  We may also share your personal information with third-parties such as service providers who assist us with IT and data hosting, marketing, and legal and regulatory compliance) and with public authorities.   Click here to learn more.
    International Data Transfers We may share your personal information with other CBRE entities and service providers located outside of your home country. When doing so, we provide appropriate safeguards for international data transfers as required by applicable law.  Click here to learn more.
    Data Security We implement appropriate technical and organizational security measures to safeguard the personal information we collect and process about you against loss and unauthorized alteration or disclosure. Click here to learn more.
    Data Retention We retain the personal information we collect about you for as long as necessary for the purpose for which that information was collected or as otherwise legally required. Click here to learn more.
    Privacy Rights Depending on the legal regulations in your country, you may have certain rights to request access, rectification, deletion, objection, or other actions regarding your personal information.  See details below, including how to exercise any privacy rights you may have under applicable law.  Click here to learn more.
    Changes to this Notice If we make any material changes to this Notice, we will make changes here and, if the changes are significant, we will provide a more prominent notice. Where required, we will obtain your consent. Click here to learn more.
    EU/UK Representative We have appointed a representative for the responsible CBRE entities located outside of the EEA and the UK that process your personal information subject to the EU General Data Protection Regulation and UK data protection law. The contact details are disclosed in this Notice. Click here to learn more.
    Data Protection Officer Where required by law, we have appointed a data protection officer whose contact details are disclosed in this Notice. Click here to learn more.
    California Consumer Privacy Policy Additional disclosures required under California law to be made to individuals who are residents of California, including relating to applicable privacy rights, are provided in CBRE’s California Consumer Privacy Policy. Click her to learn more
    Cookies We use cookies on our Site and our preference manager allows you to restrict our use of cookies other than Required Cookies. Click here to learn more.
    Contact CBRE You are always free to contact us if you have questions or concerns regarding this Notice, have a question or problem related to your use of the Site, our business-related interactions with you, or wish to exercise your rights or to exclude your personal information from our direct marketing purposes. Click here to learn more.

     

    Full Notice

    Depending on the legal regulations in your country and the applicable laws to which you are subject (such as in the EU/EEA and UK), you may have the right to information on  the CBRE entity responsible for processing your personal information (also known in some jurisdictions as data controller), which may differ depending on how and for what reason we collect your personal information through this Site or your professional interactions with the CBRE Group.  Information on how to identify your applicable responsible CBRE entity(ies) in Appendix 1. Each responsible CBRE entity collects your personal information directly from you, directly through your use of the Site or through certain third-party sources as identified in this Notice. The country where the responsible CBRE entity is located, such as the US for CBRE, Inc., may provide a level of data protection which is not equivalent to the level of data protection provided in your home country. More information on International Data Transfers of your personal information is below.

    Whenever this Notice refers to “CBRE”, “we”, “us” or “our”, it refers to the applicable responsible CBRE entity defined in Appendix 1 below.

    Global Privacy Notice

    1. Your Acceptance Through Use

    This Global Privacy Notice describes how CBRE collects, uses and discloses certain personal information obtained through this Site, your interactions with us on social media, and other professional interactions with you. Please note that, to the extent permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of this Global Privacy Notice

    2. Personal Information We Collect and Sources

    Depending on how you interact with CBRE, you may be a data subject as a user of our Site or as a business contact of CBRE having a professional interaction with CBRE, such as a supplier, client, client employee, consultant, or business partner.

     

    a. Data Collection from You

    Depending on your use of the Site and Professional Interactions with CBRE, we may collect and process the following types of personal information from you.  See Consequences of Not Providing Personal Information to Us below for more detail on the consequences of not providing us with your personal information.

                  • Contact Information: such as your name, postal or e-mail address, and phone number

                  • Registration Data:  such as such as newsletter requests, event/seminar registrations, subscriptions, downloads, and username/passwords

                  • Job Applicant Datasuch as employment and educational history, relevant skills, professional certifications and affiliations, compensation history (where allowed by law) and any other information included in curriculum vitaes/resumés, online professional profiles, and job applications, opinions of references you provide, willingness to relocate, and, where allowed by law:  test and assessment results, information about your outside activities or family relationships that may give rise to a conflict of interest and, information about criminal offense, conviction, pending investigations and administrative sanctions.

                  • Employee Onboarding Information:  such as information necessary to form an employment or contractual relationship with the applicant and for legal compliance (such as national ID card, residency permits, and visas demonstrating the Right to Work), to processing payroll and provide employee benefits (such as bank account information, tax withholding elections, and beneficiary information), and disability or other data (where allowed by law) needed to provide workplace accommodations.

                  • Professional Relationship Information: such as business contact information, industry, job title or role, your primary CBRE Group contacts and record of interactions with CBRE Group, information you provide to us which assist us in serving the business relationship, such as the types of investments you are interested in, and information you provide about your personal life (excluding special categories of data)

                  • Marketing Data:  such as your interests and preferences in our products and services.

                  • Social Media Information based on your interactions with CBRE-operated social media sites:  such as your social media username, profile, and content of your interactions with, statements or opinions about CBRE or others in our industry, and aggregated usage reports.

                  • Cookie, Device, and Web Analytics Data:  such as your Computer Internet Protocol (IP) address, geo-location data, browser settings and similar data about the use of the Site,  mobile device advertising identifier, and cookies and other data linked to a device. For more information, see our Cookie Notice.

    b. Data Collection through Third Party Sources

    To the extent permitted by applicable law, we may collect and process the following personal information about you from third party sources:


                  • Contact Information:  such as your name, postal or e-mail address, and phone number. (The third parties who collect and share your Contact Information with us may include your employer, operators of property listing and other websites accessible from links within the Site, and other business partners.  These third parties are independently responsible (also referred to as an independent data controller in some jurisdictions) for the collection and processing of your Contact Information for their own, independent purposes.  We refer you to their privacy notices to understand their privacy practices and how to exercise any rights you may have).

                  • Job Applicant Datasuch as employment and educational history, relevant skills, professional certifications and affiliations, compensation history (where allowed by law) and any other information included in curriculum vitaes/resumés, online professional profiles, and job applications and, where allowed by law:  test and assessment results, and information about criminal offense, conviction, pending investigations and administrative sanctions.

                  • Marketing Data: such as your interest and preference in products and services similar to those offered by CBRE.  (The third parties who collect and share your Marketing Data with us may include companies in the business of compiling and selling marketing data and other business partners to whom you have provided your personal information. The third parties who collect and share your Marketing Data with us are independently responsible (also referred to as an independent data controller in some jurisdictions) for the collecting and processing of your Marketing Data for their own, independent purposes. We refer you to their privacy notices to understand their privacy practices and how to exercise any rights you may have).

                  • Social Media Information based on your interactions with third-party social media sites (including CBRE’s accounts on such third party sites) such as:  your social media username, profile, and content of your interactions with, statements or opinions about CBRE or others in our industry, and aggregated reports about your interactions with CBRE's social media accounts.

                  • Third Party Advertisement Technical Data from advertisements we place on third party websites: such as your IP address, browser type and version, device identifiers, location and time zone setting

                  • Contact Information we collect from third parties such as your employer or other professional referrals:  such as your name, postal or e-mail address, and phone number.

    c. Consequences of Not Providing Personal Information to Us

                  There is no statutory or contractual obligation requiring you to provide your personal information to CBRE. The provision of your personal data is voluntary for you. You may choose not to provide your personal information to us, however, in this case, you may not be able to use our Sites and receive our services and/or to enable interaction with us. Also, the provision of your personal information may be necessary to allow us to perform a contract with you and/or to provide services to you.
                  See the
    Cookie Notice
                  below for more detail on how we use cookies and how to manage your cookie preferences


    3. How We Use Your Information and Legal Bases

    The purposes for which we use your personal information and the legal bases for such processing are as follows:

          • To Manage and Provide You Access to the Site

            We process your Cookie, Device and Web Analytics Data to manage and provide you with access to the Site. We process this personal information where necessary based on the overriding legitimate business interest of CBRE or other third parties to provide you or your employer with access to the Site which we maintain for marketing and other business purposes, or based on your consent (if required by law).

          • To Communicate With You About Your Job Application and Determine Your Qualifications and Suitability for Open Positions

            We process your Cookie, Device and Web Analytics Data to manage and provide you with access to the Site. We process this personal information where necessary based on the overriding legitimate business interest of CBRE or other third parties to provide you or your employer with access to the Site which we maintain for marketing and other business purposes, or based on your consent (if required by law).

          • To Carry Out and Manage the Employee On-Boarding Process

            We process your Employee Onboarding Information to carry out and manage the employee on-boarding process if we offer and you accept employment with us. We use process this personal information where necessary to form an employment or contractual relationship with you and transfer this information to your personnel file for record-keeping purposes. We process your personal information where necessary to comply with CBRE’s legal obligations, including maintaining records, for pre-contractual purposes (e.g., to take steps at your request prior to entering into a potential employment relationship), for other overriding legitimate business interests of CBRE and/or based on your consent (if required by law).

          • To Transact Business and Maintain a Professional Relationship With You

            We process your Contact Information and Professional Relationship Information to transact business and maintain a professional relationship with you or your employer. We process this personal information where necessary to take steps prior to entering into a contract with you (at your request), for the overriding legitimate business interests of CBRE or other third parties, such as to provide such requested services to you or your employer, or based on your consent (if required by law).

          • To Provide Relevant Marketing to You

            We process your Contact Information, Registration Data, Marketing Data, and Third Party Advertisement Technical Data, and Cookie, Device, and Web Analytics Data to contact you about the services, offerings, events and newsletters in which you have expressed an interest or about similar offerings or services (including those of third parties such as business partners) and to better target our advertising and provide pertinent offers in which we think you would be interested. We process this personal information where necessary based on the overriding business interests of CBRE or other third parties (such as your employer or business partners) to keep you and our clients informed about our latest news, products and services and to better target our advertising to you, or based on your consent (if required by law).


          • To Maintain and Manage CBRE’s Brand Reputation – Social Media

            We process your Social Media Information to maintain CBRE’s brand reputation through our presence on CBRE-operated and third party social media sites, including through Professional Interactions with you when you interact with our social-media channels. We process this personal information where necessary based on the overriding business interests of CBRE in maintaining and managing our brand reputation and based on your consent (if required by law).


          • To Operate, Evaluate and Improve Our Business

            We process your Marketing Data, Professional Relationship Information, and Cookie, Device and Web Analytics Data to operate, evaluate and improve 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). We process this personal information where necessary based on the overriding legitimate business interests of CBRE to operate and improve our business and based on your consent (if required by law).


          • To Comply With Legal Obligations And Establish, Exercise or Defend Legal Claims

            To establish, exercise or defend our legal rights, to comply with lawful government requests for disclosure of personal information or otherwise to comply with legal obligations, we use any of the personal information we collect about you where legally permissible to do so. We process this personal information where necessary to comply with CBRE’s legal obligations or based on the overriding legitimate business interests of CBRE to exercise and defend legal claims or based on your consent (if required by law).
            If you object to us using information for these other uses you can email PrivacyAdministrator@CBRE.com.

    4. Sharing of Your Personal Information

    Where we can do so lawfully under applicable law, the personal information we collect may be shared and processed with the following categories of recipients, some of whom may be located in a country that does not provide an adequate level of data privacy and protection rights as your home country, as necessary for the purposes identified above in How We Use Your Information and Legal Bases, above.  CBRE has in place appropriate safeguards regarding internal personal information sharing. See International Data Transfers below for more information.  

        • Internally with Other CBRE Entities

          CBRE Group is a global firm and the personal information CBRE collects or you provide may be shared and processed with CBRE entities as necessary for the purposes identified in How We Use Your Personal Information and Legal Bases, above.  For example, we may share your personal information internally with:

            • another CBRE entity better suited to respond to your request,

            • a decision-maker employed by another CBRE entity, or

            • site administrators employed by another CBRE entity (referred to as data processors in some jurisdictions) who process certain of your personal information to manage your access to, maintain, and improve the functionality of the Site. 

          The potentially relevant CBRE entities are identified in Appendix 1.


        • With Third Parties

          The potentially relevant third parties include:

            • Service Providers who assist us with IT, cyber security, and data hosting providers, marketing, advertising and communications agencies, cookie analytics providers, online advertisers, and providers of website testing / analytics services.

            • Third Party Cookie Providers who may track your browsing activity on our Site using cookies to show you ads based on your interests when you browse the Web or use social media and for analytical purposes. More information on these cookies, including how to provide or revoke your consent, may be found in our in our Cookie Notice below. 

            • Consultants and advisors who assist us with legal, regulatory, and business operations activities, such as legal counsel, compliance consultants and business auditors.

            • Business partners in case of a merger or sale, such as if CBRE is merged with another organization, or in the event of a transfer of our assets or operations.
        • Legally Compelled Disclosure

          It may be necessary disclose your personal information to third parties, such as courts, litigants, governmental agencies, and/or regulatory authorities when required to do so by law or necessary in connection with legal proceedings or similar processes, for example, in response to a court order or a subpoena  or other legal obligation, in response to legally-binding disclosure requests by public authorities, including to meet national security or law enforcement agency 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 or to defend ourselves.
          CBRE is committed not to disclose your personal information in response to a court order or a subpoena or other legal obligation originating outside your home country unless it is legally compelled to do so. In particular, CBRE, Inc. has assessed and is of the view that neither it nor its US subsidiaries are not subject to, and personal information transferred to CBRE US cannot be targeted by, the US Foreign Intelligence Surveillance Act ("FISA") Section 702 since CBRE US does not qualify as a provider of electronic communication service, as defined in 18 U.S.C. § 2510, nor a provider of a remote computing service, as defined in 18 U.S.C. § 2711.  As a result, US intelligence authorities cannot issue a data disclosure demand under FISA upon CBRE, Inc. or its US subsidiaries. In case CBRE receives nevertheless, at some point, data disclosure demands under FISA, we will publish a Transparency Report on cbre.com and our EEA websites (see our Schrems II statement). All personal data transferred by CBRE to the US is encrypted in transit.

    5. International Data Transfers

        • Processing In the US and Elsewhere

          Depending on the CBRE entity that is the responsible CBRE entity (see Appendix 1 below) and the recipients (see Sharing of Personal Information above),  your personal information may be  processed and hosted in countries other than the country in which the information was originally collected, including countries that may have less stringent data protection laws than the country in which you initially provided the information or in which your information was originally collected.

          In case of international data transfers, we will protect your personal information as required by all applicable data protection laws.

          If you are located in a non-US jurisdiction, the transfer of personal information to another country, in particular to CBRE, Inc. in the US, may be necessary to provide you with the requested information and/or to perform any requested service. To the extent permitted by law, your request for information and/or services also constitutes your consent for the cross-border transfer.

        • EEA and UK to Non-EEA Data Transfers

          With respect to international data transfers initiated by CBRE from the European Economic Area ("EEA") or UK to recipients in any non-EEA jurisdictions,


            • some recipients are located in countries which are considered as providing for an adequate level of data protection under EU law (or UK law, as applicable). These transfers do not, therefore, require any additional safeguards under EU (or UK, as applicable) data protection law.

            • other recipients are located in countries not providing an adequate level of data protection under EU or UK law, such as the U.S. and, where required by law, we have implemented appropriate safeguards, such as EU Standard Contractual Clauses, and/or are relying on binding corporate rules of the recipient or an appropriate derogation.  Where applicable, we implement supplementary technical and contractual safeguards. Under applicable law you may have the right to ask for further information on such appropriate safeguards (see Contact Us below).

          As stated above (see Legally Compelled Disclosures), CBRE, Inc. has assessed and is of the view that US public authorities cannot issue a lawful disclosure demand for personal data under FISA 702 upon CBRE, Inc. or its US subsidiaries. All personal data transferred by CBRE to the US is encrypted in transit. 


        • Privacy Shield Certification

          CBRE US (as defined below) are EU-U.S. and Swiss-U.S. Privacy Shield certified for HR and non-HR data. Nonetheless, in accordance with the decision by the Court of Justice of the European Union (C-311/18, also known as "Schrems II"), on July 16, 2020, CBRE US ceased relying on their EU-U.S. and Swiss-U.S. Privacy Shield certifications as a legal basis for international data transfers from the EEA or Switzerland to the U.S. CBRE US will continue to adhere to the EU-US and Swiss-US Privacy Shield principles for all personal information transferred to the US in reliance on such certifications prior to July 16, 2020.

          In addition, as we are still EU-U.S. and Swiss-U.S. Privacy Shield certified, we are obliged to provide you with information as regards the Privacy Shield, which you will find in the remainder of this Notice.

          CBRE US affiliates comply 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 United Kingdom and/or Switzerland and transferred to CBRE, Inc. and its wholly owned US-based affiliates, which include CBRE Global Investors LLC, CBRE GWS Puerto Rico Inc., CBRE Clarion Securities LLC, CBRE Security Services, Inc., CBRE Heery Inc., CBRE HMF, Inc., CBRE Multifamily Capital, Inc., CBRE Capital Markets, Inc., CBRE Technical Services, LLC, CBRE Hana Operations, LLC, Forum Analytics, LLC and Trammell Crow Company LLC in the United States (“CBRE US”). This Notice supplements the data protection notices that Clients and Client contacts may have received. CBRE US 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. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. CBRE US 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-U.S. and Swiss-U.S. Privacy Shield Principles, CBRE US commits to resolve complaints about the collection or use of your personal information. EU, United Kingdom and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CBRE US at: Privacy.Office@cbre.com.
          CBRE US 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 https://www.jamsadr.com/eu-us-privacy-shield 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.


          CBRE US may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and thereby may, as disclosed above in Third Parties with Whom We Share Your Personal Information, transfer personal information onward to third parties. However, as disclosed above in Legal Disclosure and in accordance with CBRE's internal Law Enforcement Response Policy, CBRE is committed not to disclose your personal information in these circumstances unless it is legally compelled to do so. Also note that CBRE, Inc. has assessed and is of the view that US national security authorities may not issue a data disclosure demand under FISA upon CBRE US. See Legally Compelled Disclosure above for more detail.
          In case CBRE US discloses personal information to third party agents/service providers, such as IT support provider, CBRE US remains responsible under the Privacy Shield Principles for third party agents/service providers that process personal information on CBRE’s behalf unless CBRE proves that CBRE is not responsible for the event giving rise to the damage.


          Independent Recourse of Privacy Shield Complaints:


           

          In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, CBRE US commits to resolve complaints about the collection or use of your personal information. EU, United Kingdom and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CBRE US at: Privacy.Office@cbre.com.

          CBRE US 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 https://www.jamsadr.com/eu-us-privacy-shield 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

     


    6. How We Secure Your Personal Information


    We implement appropriate technical and organizational security measures to safeguard the personal information we collect and process about you against loss and unauthorized alteration or disclosure. The information you provide is encrypted in transit and at rest. We utilize role-based access controls to limit access to your personal information on a strict need-to-know basis consistent with the purposes for which we have collected such information. We utilize anti-malware and intrusion detection systems to guard against unauthorized access to our network, and we have an incident response plan in place to quickly respond to any suspected leak or breach of personal information.

    Where we share your personal information with our service providers, we have assessed that their technical and organizational measures provide an appropriate level of security.

    7. How Long We Keep Your Personal Information:


    We will only retain the personal information we collect about you for as long as necessary for the purpose for which that information was collected, and to the extent permitted by applicable laws. We take steps to ensure that when we no longer need to use your personal information, we remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).


    8. Your Privacy Rights

    a. Marketing Communications - Rights to Opt-out and to Object


    When you registe

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