EMEA AND CALIFORNIA PRIVACY NOTICE
Last updated: 20 December 2019
Previous version: 17 May 2018
This website (the "Website") is operated by Cushman & Wakefield Debenham Tie Leung Limited on behalf of ourselves, our group companies, international partnerships and affiliated organisations ("C&W", "we", "our" or "us").
We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
This applies to personal information that we collect though the Website or when engaging in our relationship or potential relationship with you (or your organisation) as a supplier, customer or business partner.
What do we do?
Cushman & Wakefield is a leading global real estate services firm with 51,000 employees in more than 70 countries helping occupiers and investors optimize the value of their real estate. Cushman & Wakefield is among the largest commercial real estate services firms providing core services of agency leasing, asset services, capital markets, facility services (C&W Services), global occupier services, investment & asset management (DTZ Investors), project & development services, tenant representation, and valuation & advisory. For more information about us, please see the About Us section of our Website.
What information do we collect?
In the past 12 months, we have collected personal information about consumers that broadly falls into the categories listed below. Depending on your relationship with C&W, we may continue to collect your personal information in these same categories. When we collect your personal information we will treat it securely, lawfully and fairly.
We have collected and may continue to collect personal identifiers including name, mailing address, online identifier, Internet Protocol address, email address, telephone number and other similar identifiers.
In some situations we may ask you to voluntarily provide us with some personal identifiers. For example, we may ask you for this type of information when you visit our website. This might be if you are interested in signing up to receive emails from us, or reading some research, or attending an event, or participating in any online forum provided by us from time to time, or if you register for any online account made available by us, or contact us via the Website (in which cases we will collect information such as name, email address, organisation, country, zip code/postal code, job title, telephone number(s), details of your comment or query and username/password).
When you visit our Website, we may automatically collect personal identifiers associated with your device including your IP address, device type, and cookie ID. In some countries, including countries in the European Economic Area and the United States, this information may be considered personal information under applicable data protection laws.
Internet and network activity information
We have and may continue to automatically collect information about how user devices interact with our Website, including the pages accessed and links clicked. We may also collect browser-type information.
Biometric information: CCTV images/Building access control
We have and may continue to deploy CCTV and/or building access control procedures at C&W premises (which involve the processing of CCTV images of visitors and/or personal information such as name, organization represented and time of access) for security and law enforcement purposes, to exercise establish or defend our legal rights or to protect the vital interests of any person.
We have and may continue to collect broad geolocation information (e.g., country or city-level location) when users visit our website.
Professional or employment-related information
We have and may continue to collect information users may elect to provide about their employment status or employer.
Information about job candidates
When you contact us in relation to employment opportunities at C&W, we collect certain information as part of the recruitment process (and if successful, your employment). You can learn more about this in our separate Candidate Privacy Notice.
Information that we collect when you do business with us
We may collect and process information relating to you as an individual (whether as a Website user or otherwise) when you conduct business with C&W as, or on behalf of, a customer or prospective customer, or as, or on behalf of, a vendor, supplier, consultant, professional adviser or other third party ("Customer, Vendor or Business Partner Data"). Examples of Customer Vendor or Business Partner Data include:
- contact details of a point of contact for C&W Customer, Vendor or Business Partners (such as name, business phone numbers, business address, photograph) including for the purposes of attendance at or participation in any promotional or other C&W event or competition;
- role-related information about Customer, Vendor or Business Partners or their representatives (such as job title, responsibilities, department, work history, qualifications and experience);
- financial information (such as financial account information about individuals connected to a particular business) or property ownership information relating to such individuals if needed to take payment or fulfill contractual obligations or for due diligence or related purposes.
Information that we obtain from third party sources
In order to comply with various regulations, or to conduct background checks in accordance with our internal requirements (where permissible and in accordance with applicable law), sometimes we may receive personal information about you from third party sources such as credit check databases, politically exposed persons databases, government denied parties, sanctions and watch lists, your employer, other parties in the real estate sector such as real estate agents, purchasers, vendors, borrowers, lenders, architects, engineers, surveyors, developers, landlords, tenants and financial institutions, as well as online sources databases and public registries.
We will only obtain this information where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of information we collect from third parties include, for example, information about whether you have been subject to any particular regulatory action or legal proceedings. We use the information we receive to maintain and improve the accuracy of the records we hold about you and assess any risks arising from any relationship or prospective relationship with you and/or your organisation.
Sensitive personal information
Some of the information you provide or that we obtain from third party sources (where permitted by, and in accordance with, applicable law) in connection with conducting due diligence on you or your organisation may be sensitive, such as any criminal convictions you have received or details of your political activities or religious affiliations (e.g. in the context of establishing whether you are a politically exposed person). We need this information for the purposes of conducting "know your counterparty" checks and to otherwise assess risk in accordance with applicable law in the context of engaging with you/your organisation as a prospective customer or supplier.
You may also provide us with information about a health condition to facilitate us making adjustments to ensure accessibility to premises and/or events.
Inferences drawn from the above information
We may draw inferences from the information above, including personal identifiers, network information, professional or employment-related information, geolocation, and biometric information to create a profile about our consumers for the purpose of tailoring advertising; creating promotional content; offering services; business development.
Information you provide about others
If you provide us with information about another person, you confirm that they have appointed you to act for them, that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their information will be processed and that you have obtained any necessary consents to the processing of their personal information. When we first contact them, we may tell them where we got the information from.
How do we use your personal information?
We use each category of personal information that we have collected in the past 12 months for the following purposes (or otherwise described at the point of collection). We will continue to use your personal information that we collect for these same purposes:
We use personal identifiers such as your name, contact information, and online identifiers:
- to create and administer records about your online account (if any), to provide online services to you, including facilitating your participation in any discussion forum, and for Website and system administration;
- to improve our Website(s) and our products and services;
- for due diligence purposes, in accordance with applicable law, to assess financial, reputational, credit or insurance risks arising from any relationship or prospective relationship with you/your organisation and/or to carry out any necessary anti-money laundering checks;
- to provide you/your organisation with information or products and services that you have requested and deal with invoicing and payment;
- to send you service-related communications, to deal with communications you send us and request feedback;
- to facilitate your participation in events or competitions for which you have registered/which you have entered;
- to contact you directly or via our agents by mail, telephone, fax, email, SMS or other electronic messaging service with offers of goods and services or information that may be of interest to you (including information about other organisations' goods and services). If you do not wish to receive marketing information from us, please indicate this if requested on the registration or contact form or contact us (EMEA; California). We will obtain your consent to the provision of direct marketing material to you, if required to do so by law.
Internet activity information and geolocation
We use your internet activity information and geolocation, including how your device has interacted with our Website, the pages you have accessed and links you have clicked, and browser-related information for internal analytics and to improve the Website experience for our users. As with the personal identifiers that we collect, some of this information has been and may continue to be collected using cookies, web beacons, or similar technology.
Biometric information (CCTV images)
We use CCTV-captured facial imaging for security and law enforcement purposes, to exercise, establish or defend our legal rights or to protect the vital interests of any person.
Inferences drawn from the information that we collect
We may draw inferences from the information we collect, including personal identifiers, network information, professional or employment-related information, geolocation, and biometric information to create a profile about our consumers for the purpose of tailoring advertising; creating promotional content; offering services and business development.
Who do we share your personal information with and why?
We have disclosed in the past 12 months, and may continue to disclose, personal information to the following categories of recipients:
- to our group companies or affiliated entities, third party services providers and partners:
- who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or other IT infrastructure, to assist us with carrying out due diligence checks, to carry out marketing, analytics or research on our behalf or to support the delivery of services to our clients in general or pursuant to a particular engagement);
- with whom we arrange joint promotional events (for the purposes of ensuring that you do not receive direct marketing information about the event from multiple sources); or
- in the case of group companies or affiliated entities, who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. Further information about our group companies, affiliated entities and the third party service providers that may process your personal information (including their location) can be provided on request by contacting us using the details in the How to contact us heading below.
- to our clients and bid participants, in relation to bids and transactions with which you are involved.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
We have disclosed the following categories of information for a business purpose within the past 12 months:
- Personal identifiers;
- Internet activity information;
- Biometric information;
- Geolocation information;
- Inferences drawn from information in these categories.
Legal basis for processing personal information
Under European Union data protection law, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we process your sensitive personal information, we do so: (i) in the context of know-your-counterparty checks as required by applicable law; (ii) on the basis that the processing is necessary for reasons of substantial public interest; (iii) on the basis of your explicit consent; or (iv) to establish, exercise or defend legal claims.
You can choose not to provide personal information to us. However, unless otherwise indicated, the information that we request is necessary for the purposes of entering into and performing a contract with you or your organisation and/or providing services to you or your organisation and failure to provide it will impede the contracting process and/or the provision of the relevant services.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be: to provide our services to you, respond to your queries, improve our Website(s), undertake marketing, or for the purposes of detecting or preventing illegal activities.
Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards that we take to protect your personal information (including as outlined under the How do we protect your information heading below), our legitimate interests are not outweighed by any prejudice to your individual rights and freedoms. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the How to contact us heading below.
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who provide services to us or otherwise have a legitimate purpose for accessing it (see under the Who do we share your personal information with? heading above). Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Privacy Notice and that the security and confidentiality of the information is maintained.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Website servers are located in the United States, and our group companies, affiliated companies and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries. For example, we use a third party customer relationship management platform that entails the processing of personal information in the US.
However, we take steps to safeguard your personal information in accordance with this Privacy Notice. These include, for example, reliance on a third party service provider registration with EU-US Privacy Shield (pursuant to Article 45 of the General Data Protection Regulation). Further details about the protection given to your personal information can be provided upon request by contacting us using the details in the How to contact us heading below.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. If you are a client or vendor (or a representative of a client or vendor) then the information will be retained for a period of time to allow us to provide our services, to comply with applicable legal, tax or accounting requirements and, if necessary, for the establishment, exercise or defence of legal claims.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Cushman & Wakefield uses suppliers/sub-processors to provide it with integral IT, administration and business infrastructure support – view the list here.
European data protection rights
If European data protection laws apply, you have the following rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the How to contact us heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the How to contact us heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or email us at firstname.lastname@example.org. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the How to contact us heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
California Consumer Privacy Act (CCPA) Rights
If you are a California resident and the CCPA applies, you have the following rights:
- You have the right to request disclosure of your personal information that we have collected, used, disclosed, or sold within the past 12 months. If we collect personal information about you, you have the right to request disclosure of:
- The categories and specific pieces of personal information we have collected about you;
- The categories of sources from which we collected that information;
- The business or commercial purpose for collecting your personal information; and
- The categories of third parties with whom we share your personal information.
- If we sell your personal information or disclose it for a business purpose, you have the right to request disclosure of:
- The categories of personal information that we collect about you;
- The categories of your personal information that we have sold or disclosed for a business purpose;
- The categories of third parties to whom we have sold or disclosed your information;
- If we collect personal information directly from you, you have the right to request that we delete your personal information that we collect or maintain.
- If we sell information about you, you have the right to request that we stop selling your information (an “opt-out request”).
- You have the right not to be discriminated against for exercising any of your CCPA rights. As provided by the CCPA, we reserve the right to provide services that are reasonably related to information that you may choose to provide to us.
How to submit CCPA requests
If you wish to submit a request, you have three options. You may complete and submit the appropriate online request form in our online request portal. Use the following links to access the online request portal:
We do not sell your personal information.
You may also submit requests by calling this toll-free number: +1-844-339-8836.
You may submit a request yourself or through an authorized agent. If you choose to have an authorized agent submit a request for you, you will need to complete the Agent Authorization Form. The authorized agent will then need to submit a request using one of the methods listed above.
How we respond to CCPA requests
We respond to all requests we receive from individuals wishing to exercise their consumer privacy rights in accordance with applicable consumer privacy laws. We will do our best to respond to your request as quickly as possible. If your request is subject to the CCPA, within 10 days of receiving your request, we will confirm that we received it and explain to you how we will process it, including any further information we may need.
When you submit a disclosure or deletion request, we will need to verify your identity. We will also need to verify your identity if you use an agent to submit a request on your behalf. To verify your identity, we will match information that you provide us with information in our records.
We may require you to provide us with additional information to complete our verification or to respond to your request. We will use this information only for purposes of verifying your identity and responding to your request, where we are required to do so. We will delete information that you provide us to verify your identity after we process your request, unless we are required by law to maintain a record of it. Any information that we maintain will be securely protected consistent with our general information security practices.
There may be requests that we are unable to fulfill. For instance, we may deny requests when required by law, when we are unable to verify your identity, when complying with your request would interfere with the rights of others, or when necessary to exercise or defend legal claims. This is not a comprehensive list and we reserve the right to refuse your request in other circumstances. If we refuse your request, we will explain to you our reasons for the refusal.
Links to other websites
We link to other websites. We are not responsible for the content or privacy policies of these websites for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers nor are we authorized to make representations on their behalf. In any event, you should explore the privacy practices of those third parties.
In order to bring you more personalized services, we may ask you to establish one or more passwords to gain access to certain services or sections on our Website. You are solely responsible for the control and use of each password you create and we recommend not reusing an old password and creating a strong one.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments, or to comply with our legal requirements. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.
If you have received an e-mail or e-mails from Cushman & Wakefield that you no longer wish to receive, please contact us at email@example.com. If you otherwise have any questions or concerns about our use of your personal information, please contact us at at firstname.lastname@example.org if you are in California and at email@example.com if you are in EMEA. If you are in Germany, you can contact C&W's German-based Data Protection Officer (DPO).
The data controller of your personal information is the Cushman & Wakefield group entity (i) with which you or your organisation is engaged as a supplier or customer; (ii) which is considering entering into a relationship with you or your organisation; and/or (iii) with which you are engaged as user of a particular Cushman & Wakefield website.
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