Privacy statement for California consumers
Effective Date: January 2023
Why?
The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information LaSalle Investment Management, Inc. (“owner”), together with its subsidiaries and affiliates, collects and uses about them, including whether it is being sold or disclosed to third parties. Owner does not sell or disclose personal information to third parties without a business agreement. The CCPA also grants certain rights to California residents, including the right to delete their personal information (subject to certain exceptions) and the right to prevent owner from selling their personal information. Companies are also prohibited from retaliating or discriminating against consumers for exercising their rights under the CCPA.
All companies need to collect and share consumers’ personal information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons. This privacy statement for California consumers (“privacy statement”) provides the information required under the CCPA and applies to both owner’s online and offline activities.
What?
Please view the charts below to learn about the categories of personal information we have collected about consumers in the preceding 12 months, along with the categories of sources from which the personal information is collected, the purpose for collecting or selling (if applicable) the personal information, and the categories of third parties with whom we share the personal information for a business or commercial purpose.
In addition to the purposes for collecting and sharing personal information described below, owner collects and discloses any and all personal information (regardless of your relationship or interaction with us) as necessary or appropriate to: comply with laws and regulations; monitor, investigate, and enforce compliance with and potential breaches of owner policies and procedures and legal and regulatory requirements; comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and exercise or defend the legal rights of owner and its employees, affiliates, customers, contractors, and agents.
Personal information
In this privacy statement, “personal information” (or “PI”) means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly.
Your rights
If you are a California resident, you have the following rights under the CCPA with respect to your personal information:
- Right to notice. Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it. This Privacy Statement is intended to satisfy this requirement.
You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of personal information disclosed or sold, and the categories of third parties with whom we shared or sold the personal information. - Right of access. You have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
- Right to deletion. You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
- Right to opt-out of the sale of personal information. Owner does not sell your personal information as the term is defined based on our understanding of the CCPA. We have not sold any personal information to third parties for business or commercial purposes in the 12 months prior to the effective date of this Privacy Statement.
- Right to limit the use of sensitive personal Information. We do not collect or process ‘Sensitive Personal Information’ (as defined by applicable California law) for the purpose of inferring characteristics about consumers. We do not use or disclose Sensitive Personal Information for purposes other than those specified in the California Consumer Privacy Act Regulations. Such permitted purposes include the performance of services reasonably expected by an average consumer who requests those services; to prevent, detect and investigate security incidents; to resist malicious, deceptive, fraudulent or illegal actions directed at us; to ensure the physical safety of natural persons; short-term, transient uses such as nonpersonalized context-based advertising; to performing services on behalf of the business, which includes maintenance or servicing of user accounts, providing customer service, processing orders and fulfilling transactions, verifying customer information, processing payments, providing financing, analytic services, storage, or similar services on behalf of the business; to verify, maintain or improve the quality of a service; and purposes that do not infer characteristics about the consumer.
- Right not to be subject to discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.
You can exercise your rights by calling the owner toll-free at 833-906-2120 or by contacting the owner via our online form.
Verification
We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully.
- Along with your request, we ask that you provide us with a scanned copy of your government-issued ID, driver’s license or utility bill (from the last 3 months) for verification purposes.
- When all of your household members jointly submit a request, we ask that each of you provide us with a scanned copy of your government-issued ID, driver’s license or utility bill (from the last 3 months) for verification purposes.
You may also authorize someone else to submit these requests on your behalf. To do so, you may designate directly with us another person who may act on your behalf by providing us with a notarized copy of power of attorney, or by having your authorized agent (lawyer) provide us with a copy of your written and signed permission and a scanned copy of their own government-issued ID.
| CATEGORIES OF PERSONAL INFORMATION | CATEGORIES OF SOURCES | PURPOSES FOR COLLECTING |
| Owner has collected the following categories of personal information in the preceding 12 months: | The personal information has been collected from the following categories of sources: | Owner collects the personal information for the following business or commercial purposes: |
| Commercial information, including records of personal property, products or services purchased, obtained or considered, real estate interests & preferences. | You (directly from consumer). | Determine product and service eligibility and coverage. |
| Contact details, such as name, address, email, telephone number. | Public records. | Provide our products and services to you. |
| Financial information, including bank account number, credit or debit card number, payment amounts, financial means or other financial information. | Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID. | Administer, manage, analyze, and improve our products and services. |
| Identification data, including date of birth, proof of residency, government issued ID, driver’s license number, passport number, or other similar identifiers. | Authorized/legal representatives. | Issue invoices and collect payments. |
| Location data, including your phones’ GPS location. | Payment processors and other financial institutions. | Fulfill payment obligations. |
| Network activity data, including Internet or other electronic network activity information, such as 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. | Third parties who assist with fraud prevention, detection, and mitigation. | Communicate with you regarding our products and services. |
| Professional information, such as an individual’s professional information (e.g., director positions). | Consumer reporting agencies and other third parties who verify the information you provide. | Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations. |
| Tenant data, including consumption data of tenant and tenant’s household members. | Third parties that provide access to information you make publicly available, such as social media platforms. | Analyze and better understand your needs, preferences, and interests. |
| Visual and voice recordings, including audio, electronic, visual, such as customer service call recordings, voice commands, photographs, recordings from CCTV cameras. | Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms. | Conduct internal business analysis and market research. |
| Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, behavior, and attitudes. | Cookies, web beacons, and similar technologies (automatically) when you visit our websites or third-party websites. | Advertising and product promotion, including to contact you regarding products, services, and topics that may be of interest to you. |
| Written signature – an individual’s written signature, such as a signature on a contract or lease document. | Third party advertising partners and other third parties who provide digital marketing services. | Engage in joint marketing initiatives. |
| Third parties who provide website and online security services. | Comply with legal and regulatory obligations. | |
| When you contact or visit us (automatically), such as when we record calls to our call center or use CCTV cameras. | Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices. | |
| Your mobile devices and other internet-connected devices and applications (automatically). | Provide access to, monitor, and secure our facilities, equipment, and other property. | |
| We draw inferences from the information we collect from and about you, such as your preferences. | Detect security incidents and other fraudulent activity. | |
| Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements. | ||
| To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with products, services, and advertisements for such purposes. |
CATEGORIES OF PERSONAL INFORMATION DISCLOSED TO THIRD PARTIES
CATEGORIES OF THIRD PARTY RECIPIENTS
Commercial information
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties with whom we have joint marketing and similar arrangements.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Third parties who deliver our communications, such as the postal service and couriers.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
- Third party network advertising partners.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Contact details
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties with whom we have joint marketing and similar arrangements.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Third parties who deliver our communications, such as the postal service and couriers.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
- Third party network advertising partners.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Financial information
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Identification data
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Location data
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Network activity data
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives
- Third parties with whom we have joint marketing and similar arrangements.
- Third parties who provide product fulfillment services in connection with our products and services.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
- Third party network advertising partners.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Professional information
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Third parties who deliver our communications, such as the postal service and couriers.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Tenant data
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Third parties who deliver our communications, such as the postal service and couriers.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Visual and voice recordings
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Inferences
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties with whom we have joint marketing and similar arrangements.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Third parties who deliver our communications, such as the postal service and couriers.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
- Third party network advertising partners.
- Third parties who assist with our information technology and security programs.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
Written signature
- Owner employees who require it to perform their jobs.
- Authorized/legal representatives.
- Third parties who provide product fulfillment services in connection with our products and services.
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- Other third parties as necessary to complete transactions and provide our products/services.
- Third parties who assist with fraud prevention, detection, and mitigation.
- Consumer reporting agencies.
- Our lawyers, auditors, and consultants.
- Legal and regulatory bodies and other third parties as required by law.
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 in accordance with the applicable records retention policies/schedules. We calculate retention periods for your personal information in accordance with the following criteria, the length of time necessary to fulfil the purposes we collected it, for the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations, any limitation periods within which claims might be made, any retention periods prescribed by law or recommended by regulators, professional bodies or associations, the existence of any relevant proceedings. We will then delete it safely and securely.
Contact us
Please use our online form for privacy-related concerns or call toll-free 833-906-2120 to contact us with questions regarding this supplemental statement. California residents who are unable to review or access this supplemental privacy statement due to a disability may call toll-free 833-906-2120 to access this supplemental privacy statement in an alternative format.