Last Updated: May 18, 2018
Instagram® is a registered trademark of Facebook, Inc. (“Facebook”). LinkedIn® is a registered trademark of LinkedIn Corporation (“LinkedIn”). Vimeo® is a registered trademark of Vimeo, Inc. (“Vimeo”). Please be advised that GFPRE™ is not in any way affiliated with Facebook, LinkedIn or Vimeo, nor are the Site Offerings endorsed, administered or sponsored by any of the foregoing entities.
Your California Privacy Rights
GFPRE™ will never share, sell, rent, exchange or barter your Personal Data to or with any third-party for financial gain or marketing purposes. Nevertheless, we may, in certain limited instances, share your Personal Data with third parties who perform administrative functions on our behalf. If you are a resident of the State of California and would like to learn how your “Personal Data” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of Personal Data/personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: firstname.lastname@example.org; call us at: (212) 609-8000; or send us mail to: GFP Real Estate, LLC, Attn: Anny Rose Pahl, 125 Park Avenue, 14th Floor, New York, NY 10017.
Personal Data Collected
Where a User attempts to utilize the Contact Services, that User may be required to submit, and GFPRE™ may collect, some or all of the following information: (a) the User’s e-mail address; and (b) any other information collected via the Contact Services form.
In addition, where a User attempts to use one (1) or more of the Third-Party Portals made available on the Site, that User may be required to submit information (such as payment information, information about the User’s unit at an applicable Property and/or employment-related information where GFPRE™ Employees are using the Employee-designated Third-Party Portal) to the Third-Party Service Provider that operates the Third-Party Portal (collectively, “Portal Data”). Your submission of Portal Data shall be governed by the privacy policies of the applicable Third-Party Service Provider(s) who operate the subject Third-Party Portal(s). We encourage you to review the privacy policies and settings of the Third-Party Service Provider(s) and associated Third-Party Portal(s) with which you interact to help you understand the respective privacy practices of the Third-Party Service Provider(s). If you have questions about the security and privacy settings of any Third-Party Service Provider and/or Third-Party Portal that you use, please refer to the applicable Third-Party Service Provider’s privacy notices or policies.
Further, when using the Listing Share feature, you must input the email address of the individual that you wish to provide a Listing to (each, a “Listing Share E-mail Address”). Please be advised that GFPRE™ will not access and/or use any Listing Share E-mail Address for any purpose other than facilitating the Listing Share communication.
Use of Personal Data
GFPRE™ will never share, sell, rent, exchange or barter your Personal Data to or with any third party for financial gain or marketing purposes. By making that Personal Data available to GFPRE™, you grant GFPRE™ the right, subject to applicable law, to use that Personal Data to contact you by email regarding your request for Contact Services and other use(s) of the Site Offerings. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such e-mail message or see the “Opt-Out/Unsubscribe” section below.
We will also use your Personal Data for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you when necessary in connection with your use of the Site Offerings. We may also use your Personal Data for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings.
We may also employ other companies and individuals to perform certain functions on our behalf. Examples include the Third-Party Service Providers that operate the Third-Party Portals. The entities performing these limited functions on our behalf shall have access to our Users’ Personal Data solely as needed to perform these functions for us, but we do not permit them to use User Personal Data for other purposes.
At times, we may want to contact you via telephone regarding your use of the Site Offerings. To enable us to contact you by telephone regarding your use of the Site Offerings, you agree that by submitting your Personal Data by and through the Site Offerings, such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
We reserve the right to release current or past Personal Data: (i) in the event that we believe that the Site Offerings are being or have been used in material violation of the Terms and Conditions or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any Personal Data pursuant to a subpoena; (iii) to comply with a legal obligation, including sharing your name/e-mail address with third-parties to assist you with your opt out requests in compliance with applicable law, including the GDPR and the CAN-SPAM Act of 2003, as amended from time-to-time; (iv) to protect and defend the rights or property of the Company and/or its other Users; (v) to act in urgent circumstances to protect the personal safety of Users or the public; or (vi) if we are sold, merge with a third party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if GFPRE™ is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Data, as well as any choices that you may have regarding your Personal Data.
Non-Personal Data Collection and Use
IP Addresses/Browser Type
We may collect certain non-personally identifiable information about your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.
Cross Device Tracking
GFPRE™ does not track Users’ use of the Site Offerings across multiple devices, including personal computers and mobile devices.
GFPRE™ reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing Personal Data, or linking any personally identifiable information.
Social Media Websites
If you engage in any interaction with GFPRE™, other Users or any third party on any Social Media Pages, you should be aware that: (a) the Personal Data that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where GFPRE™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of GFPRE’s™ social media accounts.
We are not responsible for the Personal Data that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from GFPRE™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.
Third-Party Websites/Web Venues
This Site may contain links to third-party owned and/or operated websites, web venues and other web-based properties including, without limitation, the Third-Party Portals and Social Media Websites. GFPRE™ is not responsible for the privacy practices or the content of such websites/web venues. These third-party websites/web venues have separate privacy and data collection practices and GFPRE™ has no responsibility or liability relating to them.
We endeavor to safeguard and protect our Users’ Personal Data. When Users make Personal Data available to us, their Personal Data is protected both online and offline (to the extent that we maintain any Personal Data offline). If we ever store and/or transmit sensitive information (such as credit card or bank account information), that sensitive information shall be encrypted with advanced TLS (Transport Layer Security).
Access to your Personal Data is strictly limited, and we take reasonable measures to ensure that your Personal Data is not accessible to the public. All of our Users’ Personal Data is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User Personal Data to perform a specific job are granted access to User Personal Data. Our employees are dedicated to ensuring the security and privacy of all User Personal Data. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User Personal Data on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of Personal Data under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your Personal Data, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personal Data; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your Personal Data will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable law, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Data. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Visitors under eighteen (18) years of age are not permitted to use and/or submit their Personal Data at the Site. GFPRE™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age. GFPRE™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: email@example.com.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from GFPRE™, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to GFPRE™, as applicable.
Deleting, Modifying and Updating Your Information
We will only maintain your Personal Data for as long as needed for the purpose collected, including providing you with access to the Site Offerings that you have requested. At your request, we will: (a) inform you of what Personal Data we have on file for you; (b) amend the Personal Data that we have on file for you; and/or (c) remove Personal Data that you have provided to us, or that we have collected, from our servers/databases and the servers/databases of any third party that we have provided your Personal Data to. You may do so by e-mailing us at: firstname.lastname@example.org. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your Personal Data may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the Personal Data that we have on file for you.
Please be further advised that, after you delete your Personal Data, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Transfer of Personal Data Internationally