Effective Date: January 1, 2023
Last Updated: January 1, 2023
Categories of Personal Information We Process
The type of information that we collect depends on your interaction and relationship with us. We collect, and in the preceding 12 months have collected and processed, the below categories and types of personal information with your consent or as otherwise required or permitted by law.
- Contact Information. We collect full name, email address, current and prior address, telephone number, and business contact information.
- Identifiers. We collect social security number, driver’s license number, employee number signature, passport number, state identification card number, I-9 documentation, internet protocol address, account usernames and passwords, signature, and social media user names.
- Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status and disability information.
- Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, and billing address.
- Commercial Information. We collect records of products or services purchased, obtained, or considered and purchasing histories.
- Professional or Employment Information. We collect job application details, previous work history, salary wage expectation, reference information, background check results, professional memberships and certifications, personnel number, job title role, office location, company entity, compensation and bonus data, benefits data, dependency information, emergency contact information, health insurance information such as your policy number and spouse or dependent information, time tracking, absence and annual leave, travel booking details, business contact details, expense details, performance rating, records of disciplinary action, health and safety related information, workers compensation claims, grievances and complaints, exit interview and comments, and reasons for termination. To the extent permitted and required by applicable laws, we may collect information about your medical and treatment history, diagnosis, dates of service, provider name, and your ability to work.
- Education Information. We collect education history, degrees, transcripts, qualifications and certifications.
- Sensitive Information. We may collect social security number, driver’s license number, passport number, state identification card number, racial or ethnic origin, religious or philosophical beliefs, or union membership, health information, and sexual orientation.
- Inferences. We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.
Sources of Personal Information
We collect, and in the preceding 12 months have collected, personal information in the following ways:
- Directly from you. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, and sensitive information that you provide directly to us, including through our Site.
- From third parties. We may collect contact information, identifiers, personal characteristics or traits, commercial information, professional or employment information, and education information, from third-parties including our vendors, clients, recruiters, suppliers, subcontractors, and service providers.
- From our employees or job applicants. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, and sensitive information from our current or former job applicants, contractors and employees.
Use of Personal Information
We use personal information for the following business and commercial purposes:
- Providing our Portfolio and Services. We use contact information, identifiers, financial information, commercial information, and professional or employment information to allow clients to contract for space at our campuses, provide the services and amenities we have contracted for, and process payments.
- Transactional Purposes. We use contact information, identifiers, financial information, professional or employment information, and commercial information to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, clients, and service providers; and (iv) provide supporting business activities such as billing and collections, procurement, and tax related activities.
- Recruiting and Hiring. We use contact information, identifiers, professional or employment information, education information, financial information, sensitive personal information, and inferences to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process.
- Employment Purposes. We use contact information, identifiers, personal characteristics or traits, financial information, professional or employment information, education information, sensitive information, and inferences to administer all aspects of our employment or contractor relationship with you. For example, we use the information to complete new hire paperwork, enroll you in our human resource management system, conduct background checks, collate company directories and provide communication services, provide you access to our offices and IT systems, set up your personnel file, create benefits packages and provide and administer employee benefits, track your time and attendance and absences and to pay you and reimburse you for professional expenses, provide training, conduct performance and talent management activities, and to evaluate and process time off, sick leave, leaves of absence, or accommodation requests.
- Business Operations. We use contact information, identifiers, personal characteristics or traits, financial information, professional or employment information, education information, sensitive information, and inferences for our day-to-day business operations including maintaining records, planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative and disciplinary purposes and other ethics and compliance reporting tools, and to support our business operations.
- Analytics. We use identifiers, commercial information, and inferences to analyze preferences, trends and statistics.
- Marketing and Promotional Purposes. We use contact information, identifiers, financial information, professional or employment information, and inferences to improve our marketing efforts, conduct market research, prospect for new clients, engage in client relationship management, and to provide you with information about us, including personalized marketing communications.
- Maintenance and Improvement of our Site and Systems. We use contact information and identifiers to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT Service Desk / Help Desk Support.
- Develop and Improve Our Portfolio and Services. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing products and service offerings.
- Security and Fraud Prevention. We use contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information, and inferences to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
- Legal. We use contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
- Other Purposes: We may use contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information, and inferences for other reasons we may describe to you.
Disclosure of Personal Information
We disclose personal information in the following circumstances:
- Service Providers. We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information and inferences to our service providers.
- Clients. We disclose personal information with our clients in connection with their rental of space at our portfolio properties or the services and amenities we provide. In the past 12 months, we have disclosed contact information, identifiers, financial information, professional or employment information, education information and inferences to our clients.
- Affiliates. We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information and inferences to our affiliates.
- Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, education information, sensitive information and inferences to our professional advisors.
- Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us. In the past12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, sensitive information and inferences to government entities.
- Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments. We have not disclosed any personal information to corporate transaction recipients in the last 12 months.
- Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.
We Combine Information
We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party websites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).
How Long We Keep Personal Information
We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods:
- how long the information is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data; and
- what the expectation for retention was at the time the data was provided to us.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not uniform across browsers. Accordingly, our Site is not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/
Links to Other Websites
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
This Website is Not Intended for Children
We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to firstname.lastname@example.org
You can opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at email@example.com
. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.Phone Calls and Text Messages.
If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us. You can also opt-out of telemarketing by contacting us at firstname.lastname@example.org
Processing in the United States
California Privacy Rights / Notice to California Residents
Shine The Light
. If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at email@example.com
. and include “CA Shine the Light” in the subject line of your email.California Consumer Privacy Act.
This section applies to our privacy practices as required under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (together, the “CCPA”). Sale or Sharing of Personal Information
. We do not “sell” or “share” (as those terms are defined in the CCPA), and in the preceding 12 months have not sold or shared, personal information. We do not knowingly sell or share the personal information of minors under the age of 16.Use or Disclosure of Sensitive Personal Information
. In the preceding 12 months, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
- You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information.
- You have the right to request that we provide you with a copy of your personal information.
- You have the right to request that we delete personal information that we have collected from you. We may not delete all of your personal information if one of the exceptions to the CCPA applies.
- You have the right to opt-out of the sale or sharing of your personal information.
- You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA.
- You have the right to correct inaccurate personal information that we hold about you.
- You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain qualifications as part of the recruitment process.
- You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights
. To exercise any of your rights, please use our webform
or call us toll free at 888-467-1716. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at firstname.lastname@example.org
Other Consumer Rights Information. Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:
- Unless otherwise expressly stated, this Site is provided without charge.
- To file a complaint regarding this Site or to receive further information regarding use of this website, please contact us via email at email@example.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.
Removal of Content.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to firstname.lastname@example.org
. Please be aware that such a 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.
If you have any questions about this Policy or our data practices, please email us at email@example.com
. You can also write to us at:
Jay Paul Company
Attn: Privacy Officer
Four Embarcadero Center, Suite3620
San Francisco, CA 94111