Privacy Policy

Last Updated: 1/1/2023

BY USING OR ACCESSING OUR WEBSITES OR BY PROVIDING PERSONAL INFORMATION TO US ON OR THROUGH THESE WEBSITES, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF THAT INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

General

This Privacy Policy sets forth the privacy practices and policies of Shorenstein Realty Services, L.P. (“Shorenstein,” “us,” or “we”). Shorenstein is committed to respecting and protecting your privacy and helping you make the most of your time on the Internet within a trusted environment. This Shorenstein Privacy Policy (“Privacy Policy”) governs our data collection, usage and services and applies to Shorenstein’s websites and our properties’ websites that link to this policy (the “Websites”). This Privacy Policy discloses how we collect, protect, use and share information gathered about you on our Websites. If you use the Websites you explicitly agree to the terms and conditions of the Privacy Policy in effect at the time of your use. We hope that this disclosure will help increase your confidence in our Websites and enhance your experience on the Internet. Please read our Privacy Policy to understand:

Information We Collect

To receive certain benefits of using the Websites, you may be required to voluntarily provide your personally identifiable information, including name, email address, physical address, phone number, job titles, and other employment and background information (“Personal Information”). If you do not agree with the collection of this Personal Information, you should not provide it. The following describes the types of personal and other information we may collect about you, and how we use and maintain that information:

Site Use Information

Our web servers may collect the IP address of visitors to our Websites. This information may be aggregated to measure the number of visits, average time spent on the Websites, pages viewed, etc. Such information is not considered Personal Information under this Privacy Policy. We may use this information to measure the use of our Websites and to improve the content we offer. We may share with third parties this experiential information or other data on an aggregated basis without the use of any information that personally identifies you.

Use of Cookies

Like most websites, we employ “cookies” or similar technologies on certain pages of our Websites. Cookies make the use of the Websites easier by, among other things, saving your preferences. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Websites to Personal Information that you previously submitted. The information that we collect with cookies allows us to statistically analyze usage of our Websites, and to improve and customize our content and other offerings. However, we only disclose information collected with cookies to third parties on an aggregated basis without the use of Personal Information. Cookies are not considered Personal Information under this Privacy Policy. We may share statistical or demographic information in aggregate form with third parties for marketing or research purposes.

The cookies we use on our Websites may include:

  • Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content.
  • Persistent cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the Websites for our users. For example, we may use a persistent cookie to associate you with your user account or to remember your choices on the Websites.

We recognize “do-not-track” signals from your web browser.

Your use of our Websites will be deemed to be your consent to the placement of cookies on your computer or other devices. If you prefer not to receive cookies through our Websites, you can set your browser to either reject all cookies, to allow only “trusted” websites to set them, or to accept only those cookies from those sites you are currently on. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you log on to our Websites and use them. If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, then your use of the Websites may not be as efficient or as enjoyable as it would be if the cookie were enabled, and some parts of the Websites may not work at all.

Information You Provide to Us

By providing Personal Information through our Websites you explicitly agree to our collection and use of that information as described in this Privacy Policy. If you choose to interact with the Websites in ways including but not limited to creating an account to apply for career opportunities, we will retain the information you submit to consider your application. Where we collect Personal Information from you through our Site, our goal is to provide a means of contacting us should you need to update or correct that information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections to the email or phone number listed below under Contact. We will make reasonable efforts to incorporate the changes in your Personal Information that we hold as soon as practicable.

You also agree that we may use any information that you provide for our general purposes and may share it with our affiliates and third parties, only as described in this Privacy Policy.

Personal information may be used, for example, for identification purposes, to communicate with you regarding career opportunities or to facilitate the functioning of our Websites. If you provide us with a telephone number and/or email address, you expressly agree that we, or our authorized agents, can use that number and/or email address to contact you about career opportunities.

We may keep any information that you provide to us indefinitely.

LinkedIn

Our Websites include the ability for you and other users to import your resume through LinkedIn. As a result, we receive information about you, including but not limited to your basic profile including your name, photo, headline, and current positions and the primary email associated with your LinkedIn account. We may keep all of this information indefinitely.

Disclosing Information to Third Parties

We will not share, rent, sell or otherwise disclose any Personal Information that we collect about you through our Websites, except in any of the following situations:

  • You request or authorize the release of your Personal Information.
  • We may use the Personal Information we collect from you to fulfill your requests, manage the Websites, and communicate with you about career opportunities.
  • We may disclose Personal Information that we collect about you to our third-party contractors who perform services for us in connection with the Websites. We may also disclose Personal Information to service providers or suppliers if the disclosure will enable that party to perform business, professional or technical support for us.
  • We may provide your Personal Information to our affiliates, so as to provide access to benefits and communicate important information about them. We may also provide such Personal Information to other select third parties approved by Shorenstein as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by Shorenstein.
  • We may disclose Personal Information about you as part of a merger, acquisition or other sale or transfer of the assets or business of Shorenstein. We do not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this Privacy Policy.
  • We may disclose Personal Information about you to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
  • We may share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose the number of visitors to our Websites or the number of people who have downloaded a particular document.

Security

To help protect the privacy of data you transmit through our Websites, where Personal Information is requested, we use technology designed to encrypt the information that you input before it is sent to us. In addition, we take steps to protect the user data we collect against unauthorized access. However, you should keep in mind that the Websites are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.

Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure.

While we take steps to protect your Personal Information and keep it secure, you also play a role in protecting your information. You can help to maintain the security of your online activities by not sharing your account information and password with anyone. Shorenstein cannot guarantee the security of any information you transmit to us or from our Websites, and therefore you use our Websites at your own risk.

Links to Other Websites

Our Websites contain links to other websites, however this Privacy Policy only addresses Shorenstein’s use and disclosure of your information collected on our Websites, if any. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

Child Privacy

If you are under the age of 18, please do not use or access the Websites in any way. We will not knowingly collect or use any Personal Information from any child under the age of 18. It is not our intention to collect Personal Information from anyone under 18 years of age. If we become aware that we have collected any Personal Information from children under the age of 18, we will promptly delete such information from our databases.

Notice to California Residents

Your California Privacy Rights (Shine the Light Act)

Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of Personal Information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. California residents who have an established relationship with Shorenstein may tell us not to share their Personal Information with third parties for marketing purposes. To opt out, you may contact us at any time as described below under Contact.

California Privacy Rights Act Notice

The California Privacy Rights Act (“CPRA”) provides verified California residents with the right to receive disclosure of our information collection and disclosure practices, the specific information collected about them, to request that we correct information we hold, to make requests that we do not sell information or do not share personal information for cross-context or behavioral marketing purposes, to request that we limit processing of sensitive personal information to the purposes for which it was originally provided, or that we delete information subject to certain exceptions.  This Notice explains these rights and how to exercise them and provides information about the categories of information we collect, the information sources, our purposes for collecting it and how we may disclose it.  We will not discriminate against you as a result of your exercise of any of your CPRA rights.

For purposes of the CPRA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Our California employees (current or former) will receive a separate notice about their CPRA rights; applicants can learn about our information collection and disclosure practices and how to exercise their CPRA rights by referring to our Candidate Privacy Policy on the Careers page.

CPRA Rights

Verified California residents have the following rights:

Information Access Rights

As a California resident you have the right to request that we disclose certain information upon request about our information collection and disclosure practices information. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period.  Once we receive and confirm your verifiable request, we will disclose to you:

  • The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold.
  • The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information.
  • The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since January 1, 2022. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

Information Deletion Rights

California residents have the right to request that we delete any personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You may make deletion requests at any time. For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations.

Information Correction Rights

California residents have the right to request that we correct information that we hold which is inaccurate.  We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections.  In some cases, for instance if you have an account with us, you can update your information by logging into your account.  You can make information correction requests at any time.

Opt-Out Rights

  • Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
  • Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with others for cross-context behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us that we may use to select advertisements to show you.

We do not share your personal information with third parties for cross-context behavioral advertising purposes.

  • Limit Processing of Sensitive Personal Information. You have the right to tell us to limit processing of Sensitive Personal Information to the purposes for which it was originally collected.

We only process Sensitive Personal Information for the purpose for which we originally collected it.

 

Exercising Your CPRA Rights

Making CPRA Requests and Our Responses

  • Access, Correction and Deletion. To exercise the access, correction, and deletion rights California residents may contact us by calling us toll-free at 844-823-2386 or visiting our disclosure request page here ethicspoint.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that we expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

 

  • Opt-Out Rights. If you are a California resident over the age of 16 and would like to instruct us not to sell your personal information, not to share your information for cross-context behavioral marketing purposes, or to limit processing of your Sensitive Personal Information please visit our Do-Not-Sell web page here ethicspoint.com or call us toll free at 844-823-2386. We will comply with your request within 15 days.
  • You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting third party, analytics, or advertising partner cookies on your browser. This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code.  If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated.

 

Selling Information. We do not sell your information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CPRA. During the past 12 months we disclosed Identifiers, Commercial Information and Electronic Network Activity with third parties for a business purpose which falls within the definition of a ‘sale’. We do not sell personal information of individuals we actually know are less than 16 years of age. If you request that we not sell your information we will honor your request within 15 days, will notify those who received your information in the 90 days before your request to not further sell your information and will notify you when this has been completed. Once we receive your Do-Not-Sell request we will wait at least 12 months before asking you to reauthorize personal information sales.

Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Information Collected, Sources, and Business Purpose for Collection

During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from tenants or other individuals.

Category of Information collected Source Business purposes* for use Categories of third parties receiving information
A. Identifiers (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver’s license number, passport number, unique personal identifier, IP address) Individuals submitting information to us;

information we automatically collect from site visitors;

information we may receive from third-party marketing and data partners.

 Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

government regulators;

law enforcement (if lawfully requested);

strategically aligned businesses.

 
B. Protected Information (name with financial account, medical, health, and health insurance information, user name and password) Individuals submitting information;

employment applications;

employees.

 Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

government regulators;

law enforcement (if lawfully requested);

strategically aligned businesses.
C. Protected classification information (race, gender, ethnicity, religion) Individuals submitting information. Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

vendor and employee selection, retention, and administration;

legal compliance;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

government regulators;

strategically aligned businesses;
D. Commercial information (transaction history, products/services purchased, obtained or considered, product preference) Individuals submitting information;

information we may receive from third-party marketing or data partners.

 Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

ad customization;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners),

affiliated companies,

government regulators,

law enforcement,

strategically aligned businesses.

 
E. Electronic network activity (browsing or search history, website interactions, advertisement interactions) Information automatically collected from site visitors. Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

ad customization;

performing services for you;

internal research and development;

 

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

law enforcement (if lawfully requested);

strategically aligned businesses.

 
F. Audio, video or similar information (customer service calls, security monitoring) Individuals submitting information;

information we collect for security purposes.

 Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

law enforcement (if lawfully requested);

strategically aligned businesses.

 
G. Geolocation Information we automatically collect from site visitors. Auditing relating to transactions;

security detection, protection and enforcement;

functionality debugging/error repair;

performing services for you;

quality control.

 

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

law enforcement (if lawfully requested);

strategically aligned businesses.

 
H. Professional, educational or employment related information Information submitted by individuals;

information received from third parties in connection with vendor or employment status or applications;

information we observe in connection with vendor or employment oversight.

 Auditing relating to transactions;

security detection, protection and enforcement;

Vendor and employee selection, retention, legal compliance, and administration

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

government regulators;

law enforcement (if lawfully requested);

strategically aligned businesses.
I. Sensitive Personal Information (social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.) Information submitted by individuals;

information received from third parties in connection with vendor or employment status or applications;

information we observe in connection with vendor or employment oversight.

 Identity verification;

 

employment and benefits administration;

 

vendor oversight;

 

security detection, protection and enforcement;

 

compliance with law.

 Service providers (such as payroll processors, employee benefits partners, professional advisors);

 

government regulators;

 

law enforcement (if lawfully requested).
J. Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.) Internal analytics Auditing relating to transactions;

performing services for you;

internal research and development;

quality control.

 Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

affiliated companies;

strategically aligned businesses.

 

*More specifically, the business purposes include:

  1. Performing services for you:
  • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
  • To assist you in completing a transaction or order;
  • To allow tracking of shipments;
  • To prepare and process invoices;
  • To respond to queries or requests and to provide services and support;
  • To provide aftersales customer relationship management;
  • To create and manage our customer accounts;
  • To notify you about changes to our services and products;
  • To administer any promotion, contest, survey, or competition;
  • To provide you information regarding our products and services,
  • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.
  1. Advertising customization:
  • For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
  1. Auditing relating to transactions, internal research and development:
  • To provide for internal business administration and operations, including troubleshooting, Website customization, enhancement or development, testing, research, administration and operation of our Websites and data analytics;
  • To create products or services that may meet your needs;
  • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.
  1. Security detection, protection and enforcement; functionality debugging, error repair:
  • As part of our efforts to keep our Websites safe and secure;
  • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Websites, for example, by requesting verification information in order to reset your account password (if applicable);
  • To ensure the physical security of our premises through the monitoring of surveillance images;
  • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.
  1. Quality control:
  • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
  • To develop and improve our products and services, for example, by reviewing visits to the Websites and various subpages, demand for specific products and services and user comments.

Processing Sensitive Personal Information

We collect and process Sensitive Personal Information for the purposes disclosed above or at the time we collect this information.  We do not process this information for purposes other than the purpose for which it was originally collected unless required by law.  We use and process Sensitive Personal Information collected from California employees, job applicants or vendors (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to comply with laws including anti-discrimination laws and disability accommodation laws. We use Sensitive Personal Information from other consumers (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to provide disability accommodations.

Sharing Personal Information for Cross-context Behavioral Marketing. 

“Sharing” your personal information means making it available to a third party so that they can use it to display cross-context behavioral advertisement to you. Cross-context behavioral advertising means that an advertisement is displayed to you that is selected based on personal information about you obtained or inferred over time from your activities across other companies’ websites, applications or online services that is used to predict your preferences or interests.  Cross-context behavioral advertising does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share personal information for cross-context behavioral advertising purposes.

Notice to Residents of Colorado, Connecticut, Virginia and Utah

We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly.

Notice to Residents of Nevada

We do not sell personal information of Nevada residents for monetary consideration.  You have the right to tell us not to sell your information in the future by emailing us at [email protected] with “Nevada Do Not Sell” in the subject line.  Please include your name, residence address and telephone number in the email.

Access from Outside the United States

If you access the Websites from outside of the United States, information that we collect about you will be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of your country of origin. By allowing us to collect information about you, you consent to such transfer and processing of your data.

Governing Law

By choosing to visit our Websites or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreement that we have with you.

Changes to this Privacy Policy

We may occasionally amend this Privacy Policy to reflect Shorenstein and user feedback and we reserve the right to make changes to this Privacy Policy at any time. The use of your information is subject to the Privacy Policy and Terms of Use in effect at the time of use. The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices with respect to our Websites. Please check the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. We encourage you to check frequently to see the current Privacy Policy to be informed of how Shorenstein is committed to protecting your information and providing you with improved content on our Websites in order to enhance your experience.

Contact

If you have any questions or comments regarding our Privacy Policy or our Websites, please contact us at [email protected] or by phone at (415) 772-7000.