Effective: July 2020
We are pleased that you have elected to visit the website, www.eastdilsecured.com (the “Website” or the “Site”), which is operated by Eastdil Secured LLC (“Eastdil” “us” and “we”). Eastdil is a market-leading commercial real estate brokerage firm that offers its clients guidance and connectivity between the largest and most active real estate owners, operators, investors, and lenders in the world. The Website describes our products, services, markets, and locations.
California Privacy Rights. Under California law, California residents who have provided personally identifiable information to a company may have the right to request the categories of Personal Information and the specific pieces of personal information that the company has collected from you. California residents also may have the right to request a list of all third parties to whom that company has disclosed and/or sold such information for the third parties’ business purposes during the preceding calendar year, along with a list of the categories of Personal Information that has been so disclosed and/or sold.
Eastdil does not at this time collect Personal Information other than internet and electronic activity information such as IP addresses through the Website, and does not use that Personal Information for any marketing or commercial purpose and does not share, sell, or disclose that Personal Information with any third party. Notwithstanding the above, if you are a California resident who would like information on how to exercise your rights concerning third party disclosures under California law, you may call Eastdil at its toll-free number: 888-732-2278. For avoidance of doubt, this provision is made applicable to all users of the Website who want to request information about Eastdil’s use of their Personal Information, whether such user resides in California.
Collection and Use of Information
Personal Information is information that uniquely identifies you, such as your name, address, email address, and telephone number. Eastdil does not currently collect Personal Information other than internet and electronic activity information such as IP addresses through the Website.
Eastdil does not collect any financial information through its Website.
An IP (Internet Protocol) address is a number that is automatically assigned to your computer by your internet service provider when you log on. Your IP address is not linked to your Personal Information but Eastdil does reserve the right to use IP addresses to identify individuals who threaten the Site or other users or visitors. IP addresses may also be used to help diagnose problems with the Site and to gather broad demographic information. The information we collect in this manner is usually anonymized, and we will not identify you from this data, subject to a need to do so to protect the Site and/or other users.
When you access the Website, Eastdil will automatically receive some information about your use of the service. The type of information that is automatically collected by Eastdil includes such things as the date and time of access of the Website, the Internet protocol (IP) address of the computer that you are using, the domain and host from which you access the Internet, your browser software and operating system, the referring website address, and the specific activities you are engaged in while visiting the Site (collectively, “network activity data” or “automatic tracking information”). This aggregate tracking information is used to help Eastdil improve and enhance the website experience for all its visitors. The information we collect in this manner is usually anonymized, and we will not identify you from this data, subject to a need to do so to protect the Site and/or other users.
You must be 18 years of age and a resident of the United States to use this Site. Eastdil does not knowingly collect or maintain any Personal Information from children under the age of 13, and no part of any of the Site is designed with the purpose of attracting such children.
Use of Your Personal Information
We do not use the Personal Information we currently collect for any commercial purpose. To the extent network activity data is used, it is used only as set forth in this Policy.
If you contact Eastdil via direct postal mail and/or by telephone with a request and/or regarding your relationship with Eastdil, we will contact you, if requested, using the contact information you provide at the time. Any contact information provided to Eastdil at that time will be maintained and used only with your consent.
Opting in and opting out of electronic communications. If you receive electronic communications, such as emails, from Eastdil at any time, you can opt-out of receiving future electronic communications by (i) calling us at 888-732-2278 or (ii) clicking on the “opt-out” or “unsubscribe” link in any electronic communication you receive.
Do Not Track Signals. Certain web browsers provide users with an option by which you may have your browser send a “Do Not Track” signal to the website that you are visiting, advising the recipient website that you do not want to have your online activity tracked. However, the way browsers communicate such “Do Not Track” signals are not yet uniform and accordingly, our Site does not take any action in response to such signals. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.
- Necessary: Cookies required to access secure areas of the website and to provide important platform notifications. The site cannot function properly without these cookies.
- Statistics: Cookies are used to track device information anonymously to better understand how visitors interact with the website.
Disclosure of Personal Information to Non-Affiliated Third Parties
We do not collect and do not sell, rent, or market Personal Information collected on this Site to non-affiliated third parties for any purpose. However, we may disclose aggregated statistics about visitors to the Site, along with anonymous information concerning individual users of the Site. We may combine anonymous information and/or aggregate information we collect with additional anonymous and/or aggregate information collected from other sources. We may share anonymous information (including aggregate information) we collect regarding our users with third parties (such as advisors, and/or consultants) for various business purposes including conducting general business analysis and developing website content and services.
Retention of Personal Information
To the extent you provide any Personal Information to Eastdil, such Personal Information is retained to deliver our services, to otherwise fulfill identified or apparent purposes, and for record-keeping. At some point Eastdil may elect to destroy, erase, or anonymize your Personal Information. Once anonymized, Eastdil undertakes not to re-identify the information.
Privacy Choices - Limiting Information Sharing/Accessing Your Information
To the extent any identifiable Personal Information other than network activity data is provided to Eastdil by you, you have the right to access such Personal Information and the right to amend or correct that information, as appropriate, and to receive an account of how it has been used and a list of the organizations to whom it has been disclosed. In some circumstances, you may have the right to object to Eastdil's use of that Personal Information. If you wish to update, amend, or change your Personal Information, or to receive a copy of any such Personal Information, please contact us at 888-732-2278.
Protection and Security of Information
Eastdil maintains reasonable standards of confidentiality and security for the Website and the Personal Information collected from the Website. Physical, technical, electronic, and managerial procedures have been employed to safeguard the security and integrity of Personal Information collected through the Website. Any Personal Information you provide is secured using industry standard security technology. Eastdil also restricts its own employees’ access to Personal Information. However, it is possible that someone may intercept or access communications, transmissions, and/or Personal Information.
In the event that Eastdil determines that there has been a security breach that results in the unauthorized disclosure of Personal Information to a third party, Eastdil will promptly notify consumers whose Personal Information it reasonably believes has been compromised by posting information on the Website and, if email contact is possible, then also by sending an email notification with respect to the situation.
You acknowledge that the security of online transactions you conduct using the Website cannot be guaranteed. To the fullest extent permitted at law, Eastdil shall not accept responsibility for misuse or loss of, or unauthorized access to, your Personal Information.
Links to Other Website and Service
From time to time, the Site may contain links to other websites or social media features (collectively, “other websites”) that are not controlled and/or maintained by Eastdil. Please be aware that these other websites may have different privacy policies which may subject you to different privacy practices. Please review the privacy policies of such other websites for information concerning what information is collected on such websites and how it is used. Eastdil is not responsible for the contents or privacy practices of any linked site or any link on a linked site.
INTERNATIONAL PRIVACY NOTICE
Effective July 2020
Eastdil Secured ("Eastdil") provides this privacy notice ("Notice") as data controller to describe our practices regarding the collection, storage, use, disclosure, and other processing of Personal Data as defined below. If you or your organization share Personal Data with an Eastdil entity in the U.S. a different privacy statement is available regarding that entity's practices and will guide and govern its information collection and processing activities.
1. Types of Personal Data Collected
Eastdil collects different types of personal data. Outside the United States, we primarily have relationships only with corporations and other legal entities. However, we may collect information about individual representatives ("Individuals") of our customer organizations (“Customers”) such as the Individual's:
Work contact details: name, work address, phone number, mobile phone number, email address, and online contact details.
Position description: employer, title, position held, and length of employment.
Authentication data: passport, driver’s license, other governmental identification information, home address and telephone number, documents that verify address, date of birth, country of domicile, documents that verify employment, and signature authorization.
Customer access or use data: username and passwords to log into an Eastdil Secured portal, location data, other website, or product access information.
Financial data: sources of funds, wealth, assets, financial relationships, and financial transactions.
Background check data: background check information including credit and criminal checks and screening, to the extent required or permitted by local law.
Collectively, the above categories of data constitute “Personal Data.” We may collect Personal Data directly from the Individual, Customers, private lists, and publicly available sources. Failure to provide this information may result in Eastdil being unable to provide or continue to provide the requested services to the Customer.
2. Purposes of Collection and Use
The purposes of collection and use of Personal Data are:
To provide the services requested by our Customers, perform obligations under our agreements, and carry out related business functions, including performing data and transaction processing, conducting credit checks, handling Customer inquiries, and managing the Customer relationship, we collect and use work contact details, position description, authentication data, financial data, and background check data.
To comply with legal obligations and regulations applicable to Eastdil and its Affiliated Entities (defined below) in the United States and any relevant jurisdictions, including but not limited to “know your customer” obligations based on applicable anti-money laundering and anti-terrorism requirements, economic and trade sanctions, customer due diligence, suspicious activity reporting, foreign exchange and international trade, tax reporting and other applicable laws, regulations, ordinances, and obligations, we collect and use work contact details, position description, authentication data, financial data, and background check data.
- To confirm a person’s authority as a representative or agent of a Customer with which Eastdil or its Affiliated Entities have entered or intend to enter into various arrangements we collect and use work contact details, position description, and authentication data.
- To conduct record-keeping and otherwise manage the business, we collect and use work contact details, position description, authentication data, financial data, and background check data.
3. Disclosure of Personal Data
Eastdil may disclose Personal Data as follows (in each case to the extent necessary and on a need-to-know basis):
Affiliated Entities. Eastdil has affiliated entities operating in the United States and around the world. Eastdil may disclose Personal Data to our Affiliated Entities on a worldwide basis, and such affiliates may use the data, for the purposes described in Section 2.
Service providers. Eastdil may disclose Personal Data to information technology providers or other service providers around the world that act under our instructions regarding the processing of such data ("Data Processors"). Data Processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the Personal Data, and to process Personal Data only as instructed. Eastdil may also disclose Personal Data to independent external auditors or other service providers around the world that may not be acting as a Data Processor. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such Personal Data.
Legal requirements. Subject to applicable law, Eastdil may disclose Personal Data if required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Eastdil may do business; (b) protect and defend the rights or property of any Eastdil entity; (c) act in urgent circumstances to protect the personal safety of Individuals, Customers, and contractors/employees of any Eastdil entity or others; or (d) protect against any legal liability. In addition, Eastdil may share your Personal Data with U.S. regulators and with other self-regulatory bodies to which we are subject, wherever the Eastdil may do business.
Business transfers, combinations, and related activities. As we develop our business, Eastdil Secured might sell, buy, restructure, or reorganize businesses or assets. In the event of any actual or proposed sale, merger, reorganization, restructuring, dissolution or any similar event involving our business or assets, Personal Data may be shared with the relevant entity or may be part of the transferred assets.
The recipients of Personal Data identified in this Section 3 may be in the United States and other jurisdictions that may not provide the same level of data protection as your home country. As needed, we will take steps to establish appropriate data transfer agreements (including agreements based on the EU Model Contractual Clauses with respect to Personal Data from Europe) or otherwise address cross-border data transfer restrictions.
To the extent that consent is required by applicable law and our collection, use, disclosure, or other processing of Personal Data is not otherwise permitted by applicable law, by providing Personal Data to Eastdil Secured or authorizing our Customer to provide such information to us, you consent to the collection, use, disclosure (including cross-border transfer), and other processing of Personal Data as described in this Notice. You expressly waive the bank secrecy or confidentiality laws and obligations, if any, of the country or countries where you and the accounts are located to the extent permitted by applicable law.
You may revoke consent at any time by notifying us at the address provided in Section 7 of this Notice. Prior uses and disclosures will not be affected (unless required by applicable law), and we may otherwise continue to process Personal Data as permitted or required by law.
5. Information Management and Security Control Measures
The Personal Data will be safely stored in the databases of Eastdil Secured. Appropriate measures are taken so that Personal Data can be kept accurate, and up to date, which will be in accordance with the applicable security requirements. To prevent the loss, misuse, unauthorized access, disclosure, alteration, or destruction of Personal Data, Eastdil will take appropriate legal, organizational, and technical measures to protect Personal Data. We will keep Personal Data no longer than necessary to fulfill the purposes outlined in this Notice and have implemented appropriate record retention policies.
6. Access and Correction, Choice for Marketing Materials, and Other Legal Rights
Access and Correction. Individuals have the right to access and correct any Personal Data held about them. Requests to access or correct any Personal Data held about an Individual must be submitted by the Individual in writing to the address listed in the Customer Inquiries section below. After we have verified the Individual's identity, we will endeavor to provide the information and take the other actions requested as specified by local law, and, where permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. In addition, an overview of all entities involved in the processing of Personal Data, including data processors and the countries where being processed, are available upon request.
Choice for Marketing Materials. If you do not want to receive marketing and sales materials from Eastdil by direct mail, telephone, or email, please follow the “unsubscribe” instructions provided in those communications or submit a written request to the address listed in the Customer Inquiries section below. We will comply with your request within a reasonable period after receiving it.
Other Legal Rights. You may have other rights under the laws applicable to our collection of your Personal Data, such as the deletion of your Personal Data. Contact us in writing with requests to exercise such rights at the address listed in the Customer Inquiries section below and we will honor such rights in accordance with law. The provision of your Personal Data is voluntary. However, if you do not provide your personal data, we will not be able to perform our services.
7. Customer Inquiries
Please direct all requests relating to access, correction, and other legal rights regarding Personal Data, or any questions regarding this Notice to the location below most applicable to your location:
Europe, Middle East, and Africa:
Eastdil Secured International Limited
Your comments are valuable to us and we assure you that we will do our best to address them.
This Notice may be modified due to amendments to the law or regulations or to other reasons. In such case, an amended Notice will be posted on our website at www.eastdilsecured.com. The page providing the Notice shall contain a date as to when the Notice was last updated.