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Privacy Notice

This Privacy Notice describes how CBRE Hana Operations, LLC (“CBRE”, “we”, “us”, our”) collects, shares, uses, and otherwise processes your personal data in connection with Hana. It also explains how you can exercise your privacy rights in connection with Hana.

Questions Regarding Our Privacy Practices

If you have any questions about this Privacy Notice, the processing of your personal data, or would like to be directed to a Data Protection Officer (DPO), please contact Privacy.Office@cbre.com. Contact information for our global DPOs is also available in our Global Privacy Policy.

We may update this Privacy Notice from time to time.

Personal Data We Collect and Why

We may collect and process the following categories of personal data for the following purposes in connection with Hana.

Personal data we may collect from you, reuse from your previous interactions with us, or obtain from third parties:

  • Business contact information, such as your name, phone number, email address, company, job title, and country of residence.

  • We use this information to contact you regarding services or offerings in which you have expressed an interest. In the European Economic Area and United Kingdom, we do this based on your affirmative consent.

The data will be retained for the minimum period necessary to fulfill this purpose.

  • Information about your use of our websites, such as the date and time that you visit, your general geographic location (based on IP address), how you reached our site (including search terms used), and which pages you visit.

  • We may share information about how you use our site with third-party vendors to present you with more relevant advertising. For example, your browsing activity on our site may be tracked by our vendors using cookies to show you ads based on your interests when you browse the Web or use social media. Our vendors may also share information about your browsing activity on our Site with us for analytics purposes. In the European Economic Area, we do this based on your affirmative consent. More information on these cookies, including how to provide or revoke your consent, may be found in Cookies below.


The data will be retained for the minimum period necessary to fulfill this purpose.

  • Information about other people.

  • If you are providing information about another person or persons, you confirm that they have appointed you to act for them, that you have informed them of our identity, the information you intend to provide to us and the purposes for which such information will be processed, and that you have provided them with a copy of this Notice before providing us with their information.

How We Share Your Personal Data

Where necessary to fulfill the purposes described in this Privacy Notice, we may disclose your personal data to certain third-parties, vendors and service providers or affiliated employees, contractors and entities as described below.

Vendors and Service Providers

CBRE may share your personal data with companies acting as our authorized agents and service providers. Because CBRE operates globally, we may transfer your information to countries or jurisdictions that do not provide
the same level of data protection as the country in which you reside. If we
make such a transfer we will, or our service providers and vendors will, as
applicable, provide safeguards appropriate to any applicable laws. See
International Data Transfers, below, for more information.

Such third parties may include:

Consultants or Auditors

  • We use this information to consult with a vendor, service provider or other third-party.

Third-Party Legal Counsel

  • We use this information to consult with a vendor, service provider or other
    third-party.

Technology or Equipment Providers

  • We use this information to store data with a third-party provider, to market our services to you, and to perform analytics on visitors to our site.

Regulatory or Other Government Entities

  • We use this information to facilitate compliance with applicable laws, regulations or other requirements.

Merger or Sale

In the event that CBRE shall be or is merged, or in the event of an intended or actual transfer of our assets, Site or operations, CBRE may disclose or transfer your personal information to third parties is connection with such transaction. In the event of a merger or transfer, CBRE will notify you via email or by posting a prominent notice on our Site for 30 days of any such change in ownership of CBRE resulting in a change of control over your personal information.

Legally Compelled Disclosure

We will also disclose your personal information when required to do so by law or as 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 lawful requests by public authorities, including to meet national security or law enforcement 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 or interference with (whether intentionally or unintentionally) our rights or property.

CBRE is committed not to disclose your personal information in response to a court order or a subpoena or other legal obligation unless it is legally compelled to do so. In particular, CBRE, Inc. has assessed and is of the view that it does not qualify as a provider of an 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, and thus US public authorities cannot issue a data disclosure demand under the US Foreign Intelligence Surveillance Act (FISA) upon CBRE, Inc. You can find further information and our transparency report as regards data disclosures received from public authorities in our Global Privacy Policy.

How We Will Secure Your Personal Data

We use appropriate technical and organizational security measures to safeguard the personal data we collect and process about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. These security measures are designed to provide a level of security appropriate to the risk. We also have a process to address and remediate any suspected personal data breach and will notify you and any applicable regulator in the event of a breach where we are legally required to do so.

Cookies

A cookie is a small text file that a website stores on your
computer, smartphone, or other device with information about your navigation on that website A cookie contains the name of the server it came from, an expiration date, and a value—usually a randomly generated unique number. Cookies do not give access to nor damage your computer.

We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage through our preference manager:

  • Required cookies: These cookies are necessary to enable the basic features of this site to function, such as identifying you as a valid user, ensuring that no one else can sign on simultaneously with your account from another computer and helping us serve you better based on your registration preferences. These cookies also allow you to select your cookie preferences. 

  • Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, providing us information about how our site is used and helping us facilitate any promotions or surveys that we provide.

  • Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

Our preference manager allows you to restrict our use of cookies other than Required Cookies. If you use our preference manager on a mobile device, we process your device’s Advertising Identifier. When you access our preference manager, session cookies will be set by the ad networks listed
in our preference manager to honor your preferences if you choose not to
receive interest-based advertising. If you clear your browser cookies, this
will remove all cookies including the opt-out cookies set by the companies. You will need to access our preference manager again to reset your preferences. Our cookie only knows your last set of preferences and does not reflect the current state of cookies on your browser.

International Data Transfers

CBRE is a global business. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed, in countries other than the country in which the information was originally collected, including the United States and elsewhere that may have less stringent data protection laws than the country in which you initially provided the information.

When we transfer your information to countries other than the country in which the information was originally collected, we will protect your information as described in this Notice and will comply with all applicable data protection laws in making such transfers.

If you are located outside the United States, the transfer of personal information is necessary to provide you with the requested information and/or to perform any requested service. To the extent permitted by law, such submission also constitutes your consent for the cross-border transfer.

With respect to transfers originating from the European Economic Area or United Kingdom to the United States and other non-EEA jurisdictions, CBRE has executed EU Standard Contractual Clauses with respect to personal information collected in the European Economic Area and transferred to CBRE in the United States and elsewhere.

Where allowed by applicable law, you may ask for further information on the safeguards that we have put in place to safeguard the transfer of your data to outside of the EEA or UK by contacting us as indicated above.

Your Privacy Rights

The privacy laws in many countries grant you certain rights concerning your personal data. CBRE honors requests to exercise rights granted to you by applicable law.

European Economic Area

If we collect or process your data in the context of our operations within the European Economic Area, you have the following rights under Regulation 2016/679, the General Data Protection Regulation (GDPR):

  • The right to request access to your data

  • The right to request a copy of your data in a portable format

  • The right to request the correction data we hold about you

  • The right to request that we erase your data

  • The right to request restriction of the processing of your data

  • The right to object to our processing of your data

  • Where we process data based on your consent, the right to withdraw that consent at any time

To exercise any of these rights, please submit a request through our Data Subject Rights Portal or contact us at dsr@cbre.com.

You also have the right to file a complaint with the applicable Data Protection Authority. A list of Data Protection Authorities is available from the European Data Protection Board.

California

As a consumer residing in the state of the State of California, you may find information about your rights and how to exercise them online in our California Consumer Privacy Policy.

Elsewhere

You may have rights under applicable law to request to review, access, correct, delete, port or object to us processing your personal information. If so, you may do so by making a request on CBRE’s Data Subject Rights Portal or submitting your request to dsr@cbre.com. If we do not respond
to your satisfaction, you may also have the right to lodge a complaint with a
supervisory authority. Information on privacy laws and supervisory authorities around the world is available from the French Commission Nationale de l'Informatique et des Libertés.

California Residents Privacy Notice

If you are a California resident, the personal information we collect about you, and the business or commercial purposes for which it is used, is detailed above in Personal Data We Collect and Why. For more information on our privacy practices and how to exercise your rights under California law, please see our California Consumer Privacy Policy.







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