Last Updated: January 1, 2020
Colony Capital, Inc.: Privacy Notice
We at Colony Capital, Inc., and our affiliated companies (collectively, "we", "us", "our" and "CLNY") respect your concerns about privacy. This Privacy Notice applies to personal information we may obtain through this website (the "Site") and other personal information that we may collect in the course of our business.
This Privacy Notice describes the types of personal information we may obtain, how we may use the information, with whom we may share the information (including where they are located), how long we will retain the information and your choices regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.
Click on one of the links below to view the listed section:
- Who We Are
- Information We Collect
- How We Use The Information We Collect
- Information We Share
- Record Keeping
- Your Choices
- Links To Other Websites
- How We Protect Personal Information
- Updates To Our Privacy Notice
- How To Contact Us
- Notice to California Residents
Who We Are
This privacy notice is published by Colony Capital, Inc., its various affiliated companies and other entities that collect personal information through this Site or otherwise in the course of their businesses.
Information We Collect
Personal Information you provide
We obtain certain personal information (such as name and other contact details) directly from you when you choose to provide it through our Site or in the course of our business relationship – such as when you send us an email. The types of personal information we may obtain include:
- contact information, such as your name, postal address, email address, telephone number, facsimile number, online identifier, IP address, SSN, government identification number and social media handle;
- other personal information such as demographics, location information, online activities, financial information and health/biometric or content you provide on our Site;
- details of your role with an organization that you represent and/or your involvement in our business;
- on our careers pages, you may provide login credentials; address, tax identification number, telephone number, email address, information regarding your work authorization status, work history, references, education history, employment history and professional designations; and other professional information about your qualifications. In addition, where legally permissible, you may provide information regarding your criminal history, gender, race/ethnicity, and your veteran and disability status.
- where required for anti-money laundering purposes, background information such as your date and place of birth, the other details in your passport and information about criminal convictions;
- in connection with our Private Investors Portal found here , you may provide your name, login credentials; telephone number, facsimile number, email address, mailing address, and responses to security questions.
Unless we explain otherwise at the time, providing personal information that we request is optional and any disclosures are made voluntarily.
Personal Information we collect by automated means or from other sources
We collect certain information by automated means when you visit our Site or premises or open our emails – this may include, for example, information as to how many users visit our Site, the pages accessed or images collected by closed circuit television, and whether you opened or clicked the links in our emails.
We collect this information through various means such as "cookies," "web beacons," collection of IP addresses and closed circuit television, as explained below and in our separate Cookies and Tracking Technologies Policy.
Our premises may use closed circuit television (CCTV) systems to monitor and record activity in the public spaces of our premises. The purposes of this monitoring and recording is to provide a safe and secure working environment for staff and visitors and to protect our property. Cameras are only used in public spaces. Should an incident occur, the recordings will be provided as evidence to the police or other law enforcement to assist with their inquires.
If you are involved in a business relationship with us we may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription based services.
How We Use The Information We Collect
We may use the information described above to:
- provide investor services to you, such as email alerts, newsletters and other communications;
- protect the security of our premises;
- create and manage your account;
- respond to and communicate with you about your requests, questions and comments;
- operate, evaluate and improve our business;
- manage your employment application, assess your qualifications and manage your employment with us;
- perform data analyses and other processing;
- protect against identity theft and prevent fraud and other criminal activity (including through anti-money laundering checks), claims and other liabilities;
- manage and develop our relationship with you or the organization that you represent; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we may use information collected online through cookies and other automated means to manage our business. We also may use this information to help diagnose technical and service problems, administer our Site, and identify users of our Site. We may use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Site is not designed to respond to "do not track" signals received from browsers.
In some countries, we need to identify the legal basis upon which we process your personal information. In general, we can process your personal information lawfully because we have a legitimate interest in doing so, to pursue the purposes that we have set out above. We may also occasionally need to process your personal information in order to perform our legal obligations.
Information We Share
We do not sell or otherwise share personal information about you, except as described in this Privacy Notice. We may share personal information with third parties (e.g. service providers) who perform services on our behalf. These third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. We may also share the personal information we obtain with our affiliates or subsidiaries.
We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other corporate event).
The disclosures of personal information referred to above include transfers of personal information which is subject to European Union data protection laws to countries outside the EU, the Cayman Islands Data Protection Law, California Consumer Protection Privacy ("CCPA") and various other worldwide privacy regulations. CLNY is an international group of companies, headquartered in the U.S., and it has affiliates and service providers, and relationships with counterparties and governmental authorities, all over the world. This includes transfers to countries, such as the U.S., which are not regarded by the European Commission as ensuring an adequate level of data protection. Where we transfer personal information to our service providers or affiliated companies in those countries, we do so on the basis of data transfer agreements designed to protect the privacy of your information, in forms approved for this purpose by the European Commission.
The period for which we will keep your personal information varies depending on the information and how we obtained it. Personal information will not be held for longer that it is needed, given the purposes for which it is held. Further information regarding our record-keeping policies is available upon request.
When you give us your contact details through our Site, we offer you certain choices about how we communicate with you and what information we collect from you. You also have the right under data protection law to require us to correct any inaccurate information that we hold about you or to obtain copies of the personal information we hold. You also have rights, in some circumstances, to object to our processing of your personal information and to require us to delete, or restrict our processing of, information we hold about you. You also have right, subject to applicable law, to request us to delete your personal information from our database. To update your online preferences, ask us to remove your information or submit a request, or if you would like a copy of one of the data transfer agreements referred to in Information We Share above, please contact us as indicated in the How To Contact Us section of this Privacy Notice.
You may unsubscribe from our email mailing list at any time by clicking on the unsubscribe link that is included in every promotional email that we send to you.
Links To Other Websites
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with CLNY. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with CLNY, any use of those websites, or the privacy practices of those websites.
How We Protect Personal Information
We take all reasonable precautions in accordance with applicable law, including implementing administrative, technical and physical safeguards, to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Updates To Our Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated.
How To Contact Us
If you have any questions about this Privacy Notice, or if you would like us to update information we have about you or your preferences or exercise the other rights described in this Privacy Notice, please contact us at:
Colony Capital, Inc.
515 South Flower Street, 44th Floor
Los Angeles, CA 90071
Attention: Data Protection Team
Telephone: +1 877-912-6566
Notice to California Residents
Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send an email to firstname.lastname@example.org with "California Shine the Light Privacy Request" in the subject line and in the body of your message.