Online Privacy Notice
June 30, 2020
The Lightstone Group and our affiliates (collectively, “Lightstone”, “we,” or “us”) respect your concerns about privacy. This Online Privacy Notice describes how we process the Personal Data:
- That we collect on lightstonegroup.com, lightstonecapitalmarkets.com that are accessible through lightstonegroup.com, and other websites or applications that may link to this Online Privacy Notice (the “Sites”);
- When you visit our premises;
- Where you are a contact at one of our suppliers or other business partners; and
- Through other data collection points or notices that reference this Online Privacy Notice.
We provide information on the types of Personal Data we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. “Personal Data” is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information.
Information We Obtain
Information that you give us
The types of information we collect concerning individuals includes:
- Business and personal contact information (such as name, postal and email addresses, and telephone number); and
- Other information you provide to us (such as information provided by registering for email alerts or filling in forms).
In connection with a job inquiry or application on our careers pages, you may provide: login credentials; information regarding your work authorization status, education history, current or past job/employment history and professional designations; performance evaluations; and other information about your background and qualifications. In addition, where legally permissible, you may provide information regarding your gender, race/ethnicity, and your veteran and disability status. Lightstone will not consider either this information or your choice to decline to provide it in evaluating your qualifications for employment with us. This information will be used only for Equal Employment Opportunity reporting and other legal and compliance purposes.
In connection with our Investor Portal at lightstonecapitalmarkets.com, you may provide: login credentials; financial information (such as banking information and an account number); taxpayer ID number; jurisdiction of tax residence; date of birth; and certain investment-related information. Please see our separate Investor Data Privacy Notice for detailed information as to how we use your Personal Data.
Depending on the nature of our relationship with you, in the past 12 months we may have collected Personal Data concerning you in the following categories:
- Identifiers such as real name, postal address, email address, government ID, financial information;
- Sensitive/protected characteristic information such as age, race, citizenship, gender;
- Commercial information such as products or services purchased, obtained, or considered, personal information disclosed in a sale or acquisition process;
- Internet or other network activity such as browsing or search history, information regarding interaction with an internet website, application, or advertisement;
- Geolocation data such as physical location;
- Professional or employment-related information such as job history, performance evaluations;
- Non-public education information such as education records; and
- Inferences drawn from other personal information such as profiles reflecting preferences and trends.
In connection with electronic interactions you have with us or our service providers (including by email, phone or other forms of electronic communication), we may record and monitor details of those interactions, including their content, to the extent permitted or required by applicable law.
We may also collect some information from other sources, including:
- If we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship; and
- Information from third party data providers or publicly available sources for anti-money laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
Information We Obtain By Automated Means
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plugins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
How We Use the Information We Obtain
We may use, disclose or otherwise handle the information described in this Online Privacy Notice for the following purposes to:
- Operate, evaluate, develop, promote, and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; managing our premises; and performing accounting, auditing and other internal functions);
- Create and manage your account;
- Manage your investments;
- Comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
- Protect against, identify and prevent fraud, money-laundering, breach of confidence, cyber-attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
- In some cases, in order to operate, administer and improve the user’s experience of the Sites;
- Provide our products and services to you, such as market commentary and email alerts;
- Send you (or produce) promotional materials, newsletters and other communications, including in visual and audio form (such as videos, podcasts and online seminars);
- Communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
- Respond to your inquiries;
- Manage your employment application, assess your qualifications and manage your employment with us – please see our Career Page Privacy Notice for full information about how and why we use your Personal Data in this context;
- Verify your information; and
- Perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information).
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (a) customizing our users’ visits to our Sites, (b) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (c) managing our Sites and other aspects of our business.
We may also use the information in other ways for which we provide specific notice at the time of collection.
We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
When we collect Personal Data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information that is purely voluntary; in either case, this will be indicated to you.
If you are a former employee, worker, or contractor of Lightstone, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and/or our legal compliance purposes and/or for the establishment or defense of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g. to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).
Online Tracking and Interest-Based Advertising
We and third parties acting on our behalf (such as Facebook, Twitter and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/.
Information We Disclose to Others
We do not disclose Personal Data we obtain about you through the Sites or other channels covered by this Online Privacy Notice, except as described in this Online Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf, our financial and transaction counterparties, our professional advisors, and your agents and representatives. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.
We also may disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities, regulators, or other government entities or other competent authorities based on a lawful disclosure request, or (3) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
In addition, we may share anonymous/aggregated information with third parties, such as service providers, in order to facilitate our business operations.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Lightstone is not responsible for those providers’ information practices.
For California Residents, in the preceding 12 months, we may have disclosed Personal Data listed in any of the categories in the “Information We Obtain” section above for business purposes (in particular, as described in this section).
We have not sold Personal Data in the 12 months preceding the date of this Online Privacy Notice.
We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information was originally collected. If you are based in the UK, the EU, or another country that imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA”) or that geographical area, including to those countries in which our affiliates, group members, service providers and business partners operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of Lightstone or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent).
Retention and Deletion of your Information
We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
Your Rights and Choices
We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
These rights, subject to certain limitations, may include:
Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source (the “category information”). You may also have the right to require any inaccurate Personal Data to be corrected or deleted.
Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your Personal Data to you or a third party, in a data portable format.
California residents may also request certain information about our disclosure of Personal Data during the prior year, including category information (as defined above).
We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles.
If you wish to exercise any of these rights, please contact us as set out below.
Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
How We Protect Personal Data
We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Links to Other Websites
Updates to Our Online Privacy Notice
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.
How to Contact Us
If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at firstname.lastname@example.org.
You also may write to:
The Lightstone Group Inc.
Attn: General Counsel
1985 Cedar Bridge Avenue, Suite 1
Lakewood, NJ 08701