Mainland China Privacy Statement

Updated on 2024.12.10

Effective on 2024.12.10

December 2024 Updates:

This notice is for Mainland China residents as required by the Personal Information Protection Law (PIPL) and is intended to be a supplement to the Greystar Global Privacy Statement. 

For more information about how your information is collected, used, stored and disclosed, please refer to the Global Privacy Statement. 

In accordance with the Personal Information Protection Law of the People's Republic of China, Law of the People's Republic of China on the Protection of Minors and other relevant laws and regulations, this version has been updated. The main revisions focus on the following chapters, ‘How and When We Share Your Personal Information’, ‘Cross-Border Data Transmission’, ‘Children’s Privacy’, etc. This version will inform you more clearly and explicitly of the scenarios, purposes, methods, and scope of our collection of Personal Information, and help you better manage your Personal Information.

This Mainland China Privacy Policy applies to all regions of mainland China (excluding Hong Kong, Macao and Taiwan) in addition to the laws of the People's Republic of China.

Greystar Enterprise Management Consulting (Shanghai) Co., Ltd. and its affiliates located in mainland China (including but not limited to Shanghai Rongbai Xuyu Industrial Co., Ltd., Shanghai Huakang Real Estate Co., Ltd., etc.) ("Greystar", "we", "us" or "our" in this Mainland China Privacy Policy) recognize the importance of protecting the privacy of information that identifies, relates to, describes, could reasonably be associated directly or indirectly with consumers or devices, or could reasonably be directly or indirectly associated with a consumer or device ("Personal Information"), especially for our consumers or users (“you” or “your” in this Mainland China Privacy Policy).

This Mainland China Privacy Policy applies to information we process:

• through the Greystar websites operated by Greystar and its affiliates; such as the Greystar China website - https://www.greystar.cn/, the Greystar project website - https://livn.greystar.cn/, and the Greystar property website - https://livn.greystar.cn/833, etc.;
• through other websites and online services, such as the Greystar LIV’N mobile application (“mobile app”) that we own, operate, or make available and that link to this Mainland China Privacy Policy;
• when you visit, apply or rent at one of our properties, or through other offline interactions (on-site property visits); and
• through other general inquiries we receive (including postal mail, electronic mail, telephone requests, and in person).

Collectively, we refer to these websites, online services, property visits, and offline interactions as “services.” This Mainland China Privacy Policy describes what Personal Information we process, how and where we process it, why we process it, how and when we share it, business transitions, your privacy preferences and rights, how we secure it, retention, children’s privacy, profiling and automated decision-making, location-specific disclosures, personal information processors, updates, and contact information.

Contents

Consent

The Personal Information We Process

How and Where We Process Your Personal Information

Cookies and Other Tracking Technologies

Why We Use Your Personal Information

How and When We Share Your Personal Information

Cross-Border Data Transmission

Business Transitions

Your Privacy Preferences and Rights

Securing Information

Retention

Children’s Privacy

Profiling and Automated Decision-Making

Updates to this Mainland China Privacy Policy

Contact Information

Consent

Please review this privacy policy before providing your Personal Information. In providing such Personal Information, you consent to the collection, use and disclosure of your Personal Information as described in this Mainland China Privacy Policy. We will seek your separate consent where required by law.

THE PERSONAL INFORMATION WE PROCESS

When you use our services, in order to achieve the basic functions of providing you with our services, we need to collect and use your Personal Information, you must authorize us to collect and use the necessary information. If you refuse to provide it, it will result in the relevant service functions not being realized or the results we intend to achieve cannot be achieved.

Depending upon the type of relationship you have with Greystar and subject to applicable laws, we may process the Personal Information described in general terms below.

Contact Information such as name, telephone number, postal address, email address, date of birth, and emergency contact details.

Identification information, such as username/account name, social security number, taxpayer identity number, driver's license number, passport number, ID card or student card number, and resident identification number.

Financial and Insurance Information such as bank account/credit card number, rent payment details, insurance policy number, credit history, and other financial or tax documentation.

Demographic Information such as age, race, color, ancestry, nationality, citizenship, marital status, sex, veteran or military status, in each case subject to applicable laws. You may also choose to share with us any disabilities or other health-related restrictions so that we can provide you with adequate accommodations.

Commercial Information such as records of products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, rent amount, and information related to your rental such as pet and vehicle information (Year, Brand, Model).

App, browser, and device Information such as the device model, software version and other device characteristics, mobile app identifiers (such as Session ID and Customer ID), browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, and internet postings. For more information, please review the Cookies and Other Tracking Technologies section.

Sensory data such as surveillance camera data in public areas, facial recognition information, pictures, videos, and sounds, including photos when submitting a maintenance request, may require you to allow us to access your device's camera if you are using a mobile application.

Employment or other professional information such as education, employment history, job title, university or school attended, diploma, other CV information, pay history, and income.

Environmental, Social, Governance (ESG) such as monitoring and reporting on energy usage both at site levels and within individual tenancies.

Where the Personal Information is considered sensitive or special categories of Personal Information (“Sensitive Personal Information”) under applicable laws, we will follow all applicable requirements with respect to such Sensitive Personal Information.

HOW AND WHERE WE PROCESS YOUR PERSONAL INFORMATION

We may process Personal Information through the following:

Online Services. We process Personal Information when you interact with our online services which may include, but are not limited to, searching for an apartment, communicating with us, applying for a job, posting to social media pages, or participating in a survey.

Mobile Application. We process Personal Information when you use the mobile app which includes creating and updating your account, in providing resident services such as maintenance, and when ensuring the mobile app is performing as expected.

Property Owners. Our residential properties may be owned by other investors who share Personal Information with us for the purposes of managing the property and providing you services.

Property Visits and Offline Interactions. We process your Personal Information when you visit our properties, attend events hosted at our properties, and/or inquire about housing directly with our properties.

Other Sites and Third Parties. We may use separate sites for the processing of rental applications and agreements and to assist our residents and service providers with other tasks which are required or helpful to them, such as paying rent online. We also use separate sites for booking corporate or flexible stays. We may also receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward us your email address and other information about you so that we may contact you as requested and in accordance with applicable law.

Due Diligence. When you provide services to Greystar as a third-party vendor/contractor, we will process certain information through our discussions with you, from documents that you may deliver to us, and in the ordinary course of our business relationship.

Other Sources. We process Personal Information from other sources, such as public databases or credit agencies.

Where legally required, we will obtain your consent before collecting and processing your Personal Information.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may also process “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveals your specific identity or relates to an individual, we will treat Other Data as Personal Information. Other Data includes:

Your browser or device. We process certain data through your browser or automatically through your device, such as your operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the online services (such as the apps) you are using. We use this data to ensure that the online services function properly.

IP Address. We process your Internet Protocol (IP) address which is a number that is automatically assigned to your computer whenever you are using the Internet. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Greystar processes IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our sites. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We may seek to link your IP address to your identity when we feel it is necessary to protect our sites and other users from harm and to prevent criminal misconduct.

Aggregated Data. We may aggregate data that we process, and this aggregated data will not personally identify you or any other user.

Cookies, Pixels, and other similar technologies. We process certain data from cookies, pixel tags, web beacons, and other technologies (“Cookies”) which are pieces of data stored directly on your device or browser and may, in certain jurisdictions, be considered Personal Information. Cookies may be set by us and called first-party cookies. We also use third party cookies for our advertising and marketing efforts, to measure the success of our marketing campaigns, and to compile statistics about usage of the online services. Information about how you interact with our website, including clicks on links, videos, and other features available through our website, may be disclosed to third parties as part of our ordinary course of business. See the section on PROFILING AND AUTOMATED DECISION-MAKING below.

Strictly Necessary Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not work.

Performance Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies process is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Functional Cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Marketing/Targeting Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. These work by uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social Media Cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

Most browsers are set up to accept cookies. If you want to change your cookie preferences, you can do so through your browser settings or by updating your cookie preferences via our cookie banner, where applicable, when you enter any of our websites.

WHY WE USE YOUR PERSONAL INFORMATION

Greystar uses Personal Information collected as described below.

HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.

Greystar Affiliates. We disclose your Personal Information and Other Data to our affiliates outside of mainland China (including the United States, Singapore, etc.) as necessary to communicate with you, provide you services, fulfill our contract with you and to accomplish our business purposes.

Service Providers. We disclose Personal Information and Other Data to third parties who perform services such as hosting our websites, providing our information technology systems, supporting outsourcing arrangements, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice. Some of these service providers may use your Personal Information for their own purposes and legal obligations, and where this is the case, these service providers are therefore considered separate personal information processors. (For details of service provider information, please refer to List of Service Providers).

Property Owners. We disclose Personal Information to the Owners of the properties we manage. Owners may use your Personal Information for their own purposes and legal obligations and are therefore considered separate personal information processor for multiple processes during your tenancy journey.

Property Managers. We disclose your Personal Information to managers who assist us with the management of your property and/or who may take over management responsibilities from us.

Business Partners. We disclose Personal Information and Other Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.

Government and relevant regulatory bodies. We disclose Personal Information and Other Data to government and relevant regulatory authorities in accordance with applicable law.

We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of Greystar employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.

Cross-Border Data Transmission

Personal data collected from individuals in Mainland China will be processed locally (hosted/stored) in Mainland China. However, Greystar team members or service providers located outside of mainland China (including the United States, Singapore, etc.) may transfer or access your Personal Information for maintenance, technical support, or legal and compliance activities. The data protection and privacy laws and principles of these countries may not provide the same level of protection for Personal Information as in Mainland China. In such cases, Greystar will take all necessary steps to ensure that your data is transmitted and protected in a manner that complies with the legal requirements of Mainland China. (For details of overseas data recipients, please refer to List of Overseas Data Recipients) 

BUSINESS TRANSITIONS

If Greystar goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, including an individual property, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Mainland China Privacy Policy in place at the time of the transfer. If required by law, we will separately notify you of such transfer.

YOUR PRIVACY PREFERENCES AND RIGHTS

We provide you with options, information, and choices as required under applicable law to express your preferences.

Email Opt-out
Each of our commercial emails contain a link with instructions on how to remove yourself from our email list. If you opt out of receiving marketing messages, we will continue to send you transactional messages, which may include answers to your questions. If your request has not been duly answered, or you have further doubts, you can contact us via email on: privacy@greystar.com.

Online Services Opt-out

Please note that if you are a resident of a Greystar property and you use this site, your property site, WeChat official accounts, WeChat applets or other online services you will need to opt-out of your property site, WeChat official accounts, WeChat applets or other online services platforms separately.

Cookies and Other Data
For information on your choices related to cookies and Other Data, please see the Section on Cookies and Other Tracking Technologies above.

Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Information
You may have the right under applicable privacy laws to request that Greystar inform you as to whether Personal Information relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, withdraw your consent, change, delete, restrict the use of, or object to the processing of your Personal Information that was previously provided to us. If you are a prospective, current or former resident, a current or former team member, an investor, or a job applicant, please submit your request using this form. If you have any questions, please contact us at privacy@greystar.com or refer to the “Contact Information” section.

Securing information

Greystar takes reasonable technical and organizational measures to safeguard users' Personal Information. While Greystar strives to protect your Personal Information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online and therefore you must be aware of this risk.

We limit access to Personal Information to those individuals and organizations who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take precautions we deem reasonable to protect the security of users' Personal Information in accordance with applicable law. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injurious to the confidentiality of users' Personal Information notwithstanding the actions we take to prevent this. Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security when new technology becomes available.

If users have any questions about security, please contact us using the information in the "Contact Information" section.

RETENTION

We will retain your Personal Information for the period we believe reasonable to fulfill the purposes for which we hold it, as outlined in this Mainland China Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

MINORS’S PRIVACY

We attach great importance to and are committed to protecting the privacy and Personal Information of minors. If you are under the age of 18, you must obtain the consent of your guardian before using any website or online service. If it is proved that anyone under the age of 18 has registered and used our website or online services without the consent of their guardian, we will take appropriate measures for the relevant data as soon as possible in accordance with the law.

We will take reasonable measures to process and store the Personal Information of minors according to the requirements of laws and regulations. The purpose, method and scope of our collection of minors' Personal Information will not exceed those specified in this Privacy Policy.

Particularly, we have established strict rules for the collection and use of children's information to protect the Personal Information of minors under the age of 14. You can find out more information by reading the Children's Privacy Protection Statement.

Guardians or minors may correct or delete Personal Information in accordance with the methods provided in this Mainland China Privacy Policy.

PROFILING AND AUTOMATED DECISION-MAKING

We may also use third parties to serve tailored advertisements that may interest you. To serve these advertisements, those third parties place a cookie or other tracking technology on your browser to profile your access and use of our online services. For more information about Greystar’s use of cookies and how to manage your cookie preferences, see the section on Cookies and Other Tracking Technologies, above.

Updates to this Mainland China Privacy Policy

Any changes we make to this Mainland China Privacy Policy will be effective upon posting. If we change this Mainland China Privacy Policy, we will notify users of such changes through the general instructions at the top of this Mainland China Privacy Policy and may post these details to such other places as we see fit. We may also notify you via email, if permitted by law.

If such updates result in a substantial reduction or material change of your rights under this Policy, we will notify you by prompting or sending you a push message or other means in a conspicuous position before this Policy takes effect, and re-obtain your consent. “Material Changes” include, but are not limited to: (1) material changes to our service model (such as the purpose of processing Personal Information, the types of Personal Information processed, and the way in which Personal Information is used); (2) changes in the main objects of Personal Information sharing, transfer, or public disclosure; (3) significant changes in your rights to participate in the processing of Personal Information and the way in which they are exercised; (4) changes in our team, contact information and complaint channels responsible for handling Personal Information security; and (5) when the Personal Information security impact assessment report indicates that there is a high risk.

CONTACT INFORMATION

Personal Information processor's details (including contact details):
Personal Information processor: Greystar China Rental Management Consulting Co., Ltd.

Location: Shanghai, China

Address: Suite 1704, One Museum Place, 669 Xin Zha Road, Jing An District, Shanghai, China, (Room 1404 on the actual floor).

Zip code: 200041

Contact number: 021-52980900.

E-mail address:privacy@greystar.com.