Copyright © 2023 IWF Campus. All rights reserved.
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.
We receive “Personal Information” in order to provide you with our Services. Personal Information is data that includes a personal identifier, or is any data that identifies, relates to, describes, could be associated with, or could reasonably be linked, directly or indirectly, back to you or a household. Personal Information includes information that you provide to us, that we collect automatically, and that we obtain from third parties.
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 collect personal identifiers associated with your device including your IP address, device type, and cookie ID, and other usage 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.
We may collect and process information relating to you as an individual when you conduct business with C&W as a customer or prospective customer (including when C&W serves as a managing agent on behalf of a building owner), or as a representative 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:
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 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.
We may receive and process information relating to you as an individual when we perform services on behalf of our Customers (including when C&W serves as a managing agent on behalf of a building owner). In this context, we process (e.g., collect, use, and share) your personal information only as a service provider, including as that term is defined under applicable law, and only for purposes of our business relationship with our Customer. Examples of this information include:
We encourage you to review the privacy policy of the building owners / our customers in these contexts for more information on their processing of your 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 fall under the sub-category of “Sensitive Personal Information,” or a similar term, as defined by certain laws. This may include information 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.
We do not use Sensitive Personal Information for any purposes other than to provide the Services contracted.
We may draw inferences from the information above, including personal identifiers, network information, professional or employment-related information, and general location; creating promotional content; offering Services; and business development.
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.
We receive, collect, use, process and store Personal Information to provide our Services. This includes:
Some of this information may be collected using cookies and similar tracking technology, including web beacons.
We make available Personal Information only with your consent or to the following categories of recipients (subject to your prior consent where required under applicable law):
Under applicable data protection law, and based on your jurisdiction, 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 commercial 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.
We use reasonable technical, administrative, and physical controls 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. 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.
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. 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 to fulfil the purposes described above. We use the following criteria to determine how long to retain Personal Information:
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. C&W uses suppliers/sub-processors to provide it with integral IT, administration and business infrastructure support – view the list here.
Depending on the country/region you live in, you may be able to exercise certain rights with respect to your Personal Information:
If you wish to submit a request, please refer to the specific regional information below.
We respond to all requests we receive from individuals wishing to exercise their data protection and privacy rights in accordance with applicable data protection and privacy laws.
We will do our best to respond to your request as quickly as possible, in accordance with applicable law. We confirm receipt of every request we receive. If you are a California resident, we will first acknowledge receipt of your request within 10 business days and provide a substantive response within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing. We may require you to provide us with additional information to complete our verification process or to respond to your request. Depending on the request, we may need you to provide at least two pieces of Personal Information we already have in our possession, such as your email address and proof of home address. 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 fulfil. For instance, we may deny requests
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 our reasons for the refusal.
If you have received an e-mail or e-mails from Cushman & Wakefield that you no longer wish to receive, please contact us at web.manager@cushwake.com.
If you otherwise have any questions or concerns about our use of your Personal Information, you may contact us at:
Chief Privacy Office
Legal, Risk and Compliance
1290 Avenue of the Americas
New York
NY 10104-6178
United States
You may also contact us as follows:
Copyright © 2023 IWF Campus. All rights reserved.