Privacy statement
WHO WE ARE
LaSalle Investment Management (“LaSalle”) is made up of different legal entities, details of which can be found here: https://www.lasalle.com/company. This Privacy Statement is issued on behalf each company in the LaSalle group, so when we refer to “LaSalle”, “we”, “us” or “our” in this document, we are referring to the relevant company in the LaSalle group of companies responsible for processing your data, as well as on behalf of certain real estate investment funds we sponsor and manage and whose respective websites link to this Privacy Statement. We will endeavour to let you know which entity will be the controller for your data when we collect personal information. LaSalle Investment Management, Inc. is the controller and responsible for this website.
OUR COMMITMENT TO PRIVACY
We take our responsibility to protect the personal information provided to us seriously. This statement explains how we do that. It sets out what we do with the personal information we hold, how we protect it and it explains your privacy rights.
IF WE CHANGE THIS PRIVACY STATEMENT
LaSalle might update this Privacy Statement from time to time. When we do this the revised statement will be posted on this page, and where appropriate, by notification on our homepage. You should check this page from time to time to review any changes we have made.
Equally, it is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
HOW WE COLLECT PERSONAL INFORMATION
We use different methods to collect data from and about you including through:
- Direct interactions: You may give us data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: (i) apply for our products or services; (ii) create an account on our website; (iii) subscribe to our service or publications; (iv) request marketing to be sent to you; (v) you apply for an employment position with us; or (vi) give us feedback or contact us.
- Automated technologies or interactions: As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy at www.lasalle.com/legal/cookies for further details.
- Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources.
OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
We rely upon a number of different legal bases for processing personal information and special category personal information – these include processing personal information where it is in our legitimate interests to do so, where this is necessary for the fulfilment of a contract or where the processing is necessary to carry out our obligations under employment law. Where we rely on our legitimate interests, this means that we use personal information to run our business and to provide the services we have been asked to provide. We only collect information that has been supplied voluntarily; you do not have to provide us with personal information. However, if you do not provide us with information we need by law or require to do work, we may not be able to offer certain products and services.
CATEGORIES OF PERSONAL DATA WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. The categories of personal information we might collect from you include the following:
| Commercial information | Commercial information, including records of personal property, products or services purchased, obtained or considered, real estate interests & preferences. |
| Contact details | Name, address, email, telephone number (including in the capacity as a representative or contact employed by an entity which invests in one of our products or has appointed us to manage or advise in respect of real estate or real estate related securities). |
| Financial information | Including bank account number, credit or debit card number, payment amounts, financial means, credit scores or other financial information. |
| Identification data | Date of birth, proof of residency, government issued ID, driver’s license number, passport number, or other similar identifiers. |
| Location data | Your phone’s GPS location. |
| Network activity data | Internet or other electronic network activity information, such as IP address, browsing history, search history, cookie data, referring/exiting URL, clickstream data, time spent on webpage or advertisement, and other information regarding an individual’s interaction with an internet website, application, email or advertisement. |
| Marketing and communications data | This includes your preferences for receiving marketing from us and your communication preferences. |
| Professional information | An individual’s professional information, for example director positions or past employment. |
| Tenant data | Consumption data of tenants residing in our clients’ properties. |
| Visual and voice recordings | Audio, electronic, visual, such as customer service call recordings, voice commands, photographs, recordings from CCTV cameras. |
| Written signature | An individual’s written signature, such as a signature on a contract or lease document. |
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Other than is required by law (for example, in connection with meeting “know your client” and anti-money laundering rules) or directly in connection with your employment by us, we do not collect any information about criminal convictions and offences.
OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
We will only use your personal information when the law allows us. We rely upon a number of different legal bases for processing personal information and although these may differ between countries, they include the following:
- where it is in our legitimate interests to do so and such basis for processing personal information is not prohibited by law (such as when your interests and fundamental rights override those interests);
- where it is necessary for the fulfilment of a contract;
- where the processing is necessary to carry out our obligations under financial services related licensing and regulatory laws, employment law; or
- where you have given us your consent.
Where we rely on our legitimate interests, this means that we use personal information to run our business and to provide the services we have been asked to provide (and might include for the purpose of enabling the management of contractual arrangements, keep our records up to date, provision of administration and IT services, network security, to better understand how clients use our products/services, to develop our products, to manage our brand awareness, to grow our business or to implement our marketing strategy).
THE PURPOSES FOR WHICH WE USE YOUR INFORMATION
Without limiting the matters outlined above with respect to reliance on our legitimate interests, we use your personal information in compliance with all the relevant laws and may use it in one or more of the following ways:
- We may use the personal information of tenants or other natural persons you have supplied us with to carry out work such as lease management on your behalf.
- We may use your personal information for the establishment, execution or termination of a contract with you.
- We may use the contact information you supply to respond to your requests.
- We may use identification verification documents to meet with regulatory and legal requirements to verify who you are as a condition of providing our services and products.
- We may use personal financial information to assess your eligibility for our products and services.
- Personal information may be used to inform you of services that may be of interest to you from LaSalle. We may assess your interest in our services by logging if you open the links in our marketing emails.
- Personal information is used to make your online experience as smooth as possible – for example by setting cookies and tailoring what you see on the website and to improve the quality, relevance and experience of our Website for our visitors. Visit www.lasalle.com/legal/cookies for more information.
- Personal information may be used to safeguard the security of our premises and those we maintain for third parties – for example through the use of CCTV.
- We may process your personal information for the purposes of internal administration, accounting and controlling.
- We may use your location data and voice recordings to enable you to use our mobile apps.
WHOM WE SHARE PERSONAL INFORMATION WITH
We may share your personal information with:
- LaSalle employees who require it to perform their jobs.
- Other entities of the LaSalle group and our affiliates help us deliver our services.
- Organizations that support the products or services we provide to you.
- Designated service providers that assist LaSalle with advertisement display functions and related analytics.
- Anyone you give us permission to share it with.
- Official bodies to detect and prevent criminal activity e.g. money laundering, theft, fraud, terrorism, cybercrime.
We will never sell your personal information and we take steps to keep your details safe and secure.
WHERE WE KEEP AND PROCESS YOUR INFORMATION
We might transfer and store the information we collect from you outside the country of origin. It may be processed by staff or our suppliers outside the country of origin. When we do this, we aim to make sure the information is secure and properly protected. We do this by means of adequacy decisions or appropriate safeguards (i.e. Privacy Shield/Standard Contractual Clauses).
KEEPING YOUR INFORMATION SAFE
We commit to maintaining the deployment of appropriate security to protect personal information wherever it is located, and whether it is in electronic or manual form. To do this we may use a variety of mechanisms depending on where the information is stored and the relationship between LaSalle and any recipient organizations.
HOW LONG WE KEEP YOUR INFORMATION
We endeavor to keep your information only for as long as we need it for legitimate business or legal reasons. We will then delete it safely and securely.
YOUR RIGHTS
Where applicable you may have the following rights over your personal information:
Request a copy of the information we hold (Right of Access)
You can ask for the personal information we hold about you. To do so please contact us via our online form. In most cases there is no charge for us providing this information to you. You can also ask for information that you have provided to us in an electronic format.
Right to data portability
In some circumstances, you may request that LaSalle transmits your personal information directly to another organization if the processing is based on your consent or a contract. To do so, please contact us via our online form.
Right of erasure (Right to be forgotten)
If for any reason you do not want us to hold your personal information please contact us via our online form. We may need to keep some of your personal information for legal and business reasons, for example to comply with a regulatory requirement. However, for marketing purposes, if requested we will add your name to a suppression list so that you are not contacted in the future for marketing purposes.
Have your information corrected (Right to rectification)
If you think the personal information we hold about you is wrong, please contact your LaSalle contact or our Marketing department at [email protected] and we will check and correct it if necessary. We are committed to holding personal information that is accurate, relevant and current.
Restrict the processing of your personal data
In certain circumstances, for instance, if you contest accuracy of your personal information you may request that we restrict processing of your personal information for the time taken to enable us to verify the accuracy of your personal information.
Object to processing of your personal data
In certain circumstances you can object to the continued use and processing of your personal information. If for any reason you do not want us to use and process your personal information please contact us via our online form. You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.lasalle.com/legal/cookies.
Stopping us contacting you
If you have provided us with consent to supply you with marketing and information, you can withdraw your consent at any time by instructing us to do so at [email protected].
Please note that these rights may be limited in some situations such as where LaSalle can demonstrate that LaSalle has a legal requirement or legitimate interest to process your personal data.
Links
When you visit our websites or open our electronic communication (such as emails), we may collect certain information by automated means (such as cookies). The information we collect in this manner may include your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our websites, and dates and times of website visits. We also may use cookies and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our emails.
Our websites may use cookies as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies.
For more information about the cookies we use, how you manage and change your cookie preferences, please visit www.lasalle.com/legal/cookies.
In addition, our website or material we send you via email may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
CALIFORNIA RESIDENTS ONLY
If you are a California resident as defined in the California Consumer Privacy Act (CCPA) please view our Supplemental Privacy Statement which describes your rights and disclosures about your personal information.
LASALLE SUPPLEMENTAL PRIVACY STATEMENT FOR INDIVIDUALS IN CHINA
If you are a China resident please view our Supplemental Privacy Statement for Individuals in China which describes your rights and disclosures about your personal information.
HOW TO COMPLAIN
If you need to make a complaint about our handling of your personal information, please contact us via our online form.
If you are unhappy with how we deal with your complaint, you can contact your Data Protection Authority or the equivalent in your state or country if applicable. We would, however, appreciate the chance to deal with your concerns before you approach such authority so please contact us in the first instance. Please ensure that you identify your country of residence in your correspondence so that we may efficiently route your complaint to the correct LaSalle team.
HOW ELSE TO CONTACT US
If you have any other questions about your personal information please contact us via our online form.
For all enquiries not relating to your personal information please click on the following link, https://www.lasalle.com/about/locations/, which contains the phone numbers of our regional offices.
as of December 2021