Effective Date: January 1, 2020.
Kingsley Associates (“Kingsley”, “we”, or “us”) understands that your privacy is important to you. Protecting your personal information is our priority. This Privacy Statement describes how we handle and protect the personal information that we collect or use in connection with our business activities and customer services, and on websites, applications, and communications that post a link to this Privacy Statement. As used in this Privacy Statement, “personal information” shall be any information that is capable of identifying you as an individual person.
- How We Collect Your Personal Information
- How We Use Your Personal Information
- How We Protect Your Personal Information
- How Long We Retain Your Personal Information
- How We Share Your Personal Information
- How We Transfer Personal Information Across International Borders
- Links To Third Party Websites
- How We Respect Your Privacy in Marketing
- Your California Privacy Rights
- How To Contact Us
- Children Under Thirteen
- Changes To This Privacy Statement
How We Collect Your Personal Information
We collect information about you from the following sources:
- Directly from you
- From technology when you visit our website, applications or other digital properties
- From our clients when they hire us to conduct surveys or benchmarking on their behalf
What Personal Information We Collect
Kingsley may collect some or all of the following personal information:
- Identifiers, such as your name, email address, mailing address, telephone number, and birthdate
- Demographic information
- Commercial information, including records of personal property, products or services, purchase, obtained, considered or leased, or other purchasing or consuming histories or tendencies, provided that for individual survey respondents, we do not receive financial information about your lease
- Identifiers and internet or other online network activity information, such as IP address, device identifier, web browser, and browsing and use information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”)
- Professional or employment-related information
- Inferences drawn from any of the information identified above
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the websites.
How We Use Your Personal Information
We collect and use your personal information to:
- manage stakeholder feedback programs on behalf of our customers (e.g., tenant satisfaction surveys, resident satisfaction surveys, employee surveys, broker perception surveys)
- provide products and services to our customers such as benchmarking and consulting
- analyze the performance and functioning of our websites, manage our websites and collect analytics about how our websites are used
We may keep any of your personal information on file and use it to contact you if your owner or management company requests additional services from us.
If you are a business client, we use the personal information that we have collected from you to market to you. If you are individual survey respondent, we do not use the personal information that we have collected on behalf of our customers to market to you.
We also use de-identified or anonymized information for other purposes.
How We Protect Your Personal Information
We have implemented reasonable security procedures and technical and organizational measures to protect personal information against accidental or unlawful destruction, loss, disclosure or use. Only authorized Kingsley personnel and third party service providers are provided access to personal information, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
How Long We Retain Your Personal Information
We may retain your personal information for a period of time consistent with the original purpose for collection. For example, we keep your personal information for no longer than reasonably necessary for use of our products and services and for a reasonable period of time afterward. We also may retain your personal information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
When personal information is no longer needed for the purpose it was collected or processed or to comply with a legal obligation, we securely destroy it.
How We Share Your Personal Information
We do not sell, rent or lease our customer lists to third parties. We do not sell or otherwise disclose personal information that we collect over our websites or as otherwise collected in connection with our services, except as described herein.
We may disclose information about you to the following categories of third parties or in the following circumstances:
- With third party service providers who perform services and functions on our behalf to support our interactions with you, such as conducting statistical analyses, sending you emails or postal mail, and providing you with customer support. Additionally, personal information collected on our websites may be shared and transferred to our third party service providers that service or host our websites;
- With our customers, for examples, we share the information collected in response to our surveys or benchmarking efforts with the customer that hired us to conduct the survey or benchmarking;
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- 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;
- If disclosure is necessary to protect the vital interests of a person;
- To protect our property, services and legal rights;
- To prevent fraud against Kingsley, our subsidiaries, affiliates and/or business partners;
- To support auditing, compliance, and corporate governance functions;
- To comply with any and all applicable laws; or
- To complete a corporate transaction such as a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal information that is processed by Kingsley’s third party service providers, including the transfer of your personal information to countries other than the one in which you reside. By using any of the websites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.
How We Transfer Personal Information Across International Borders
Kingsley participates in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) administered by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Our participation in the Privacy Shield subjects it to the investigatory and enforcement power of the Federal Trade Commission. You can view a complete list of all Privacy Shield participants, including Kingsley Associates at https://www.privacyshield.gov/list.
As a Privacy Shield participant, we are committed to and has certified that we adhere to the Privacy Shield Principles for all personal information received from the European Union and Switzerland in reliance on the Privacy Shield. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
- We may share personal information that is subject to the Privacy Shield Principles with service providers who collect and host personal information in cloud-based environments and who provide services that support the business activities that we conduct on behalf of our customers. We may be liable under the Privacy Shield if service providers process such personal information in a manner inconsistent with the Privacy Shield and we are responsible for the event giving rise to the damage.
- We may disclose personal information received in reliance on the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- European Union or Swiss individuals have the right to request access to personal information received by us in reliance on the Privacy Shield, to request the ability to correct, amend or delete inaccurate personal information, and to exercise choice in limiting our use and disclosure of such information. European Union or Swiss individuals who are interested in exercising their right and choice, please contact us at the address, phone number or email address below.
229 Peachtree St NE, Suite 1100
Atlanta, Georgia 30303
Attn: AJ Rao
We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU–privacyshield/for–eu–consumers for more information, including information about how to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Link to Third Party Websites
How We Respect Your Privacy in Marketing
We use various means of communication and tools to market our products and services. We use commercial marketing email as permitted under applicable law. If you prefer not to receive future communications from us, you may unsubscribe by using the “Unsubscribe” or “Opt-out” link in the commercial email or by contacting us at email@example.com or calling us at (770) 908-1220.
We collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access the website, the pages you have accessed while visiting the website, and the Internet address from which you accessed the website. We use these technologies to remember user preferences, analyze and maximize the performance of our website, applications and services, measure the effectiveness of our email campaigns and to customize online content.
You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
Our websites do not track you by collecting personal information about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
Your California Privacy Rights
We are considered a “data processor”/“service provider” for our customers where we process personal information to provide our services to our customers. When we act as a data processor/service provider, we process personal information in accordance with the instructions of the “data controller”/ “business” (i.e., our customer).
If you are a California consumer seeking to exercise your rights under the California Consumer Privacy Act (CCPA) with respect to information we hold on behalf of our customers, please reach out directly to that organization responsible for determining the purposes and means of processing your personal information, generally your owner or management company.
We do not and will not sell your personal information.
We do not share your personal information with third parties for those third parties’ direct marketing use.
How To Contact Us
If you have any questions or comments about our Privacy Statement, please contact us at:
229 Peachtree Street NE, Suite 1100
Atlanta, Georgia 30303
Children Under Sixteen
We do not knowingly collect, use, share or sell personal information from children under the age of 16. If you believe we have done so in error, please contact us at the address or email above and we will delete the information.
Changes To This Privacy Statement
We reserve the right to make changes to this Privacy Statement from time to time. We will alert you to any such changes by updating this Privacy Statement. If we make material changes to this Privacy Statement that increase our rights to use personal information that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our website.