Effective: March 2022
Customer means any tenant of Prologis.
Services means any facility management or other property related services and any other requests for services made by the Customers or by Prologis through the CRC Platform.
Users means the users of the Platform including Customers and Prologis personnel.
Prologis Platforms means the CRC Platform, the FM Platform. Essentials and the Knowledge Center.
Vendor means the professional provider of the Services.
We may collect, store or otherwise process different kinds of your Personal Data depending on how we interact with you. Categories of Personal Data that we collect include:
- Identity Data, such as your first name, last name, username or similar identifier, title;
- Contact Data, including your business address, email address and telephone and fax numbers;
- Technical Data, including your internet protocol (IP) address, your login data, browser type and version, time zone setting, locations, browser plug-in types and versions, operating system and CRC Platform, and other technology on the devices you use to access the CRC Platform;
- Profile Data, which includes your username (email address), feedback and survey responses;
- Usage Data, which includes information on how you use the CRC Platform.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We hereby explicitly ask you not to provide us with any special categories of Personal Data.
The type of Personal Data that we collect about you will depend on our relationship with you, as further described below.
Information that you give to us
You may provide us with your Personal Data by filling in your information in a form (either online or in hard copy) or by corresponding with us (by post, phone, email or otherwise), for example, when:
- your user account is created on the CRC Platform;
- you are placing an order, opening a ticket or making a request through the CRC Platform, or responding to such order, ticket or request;
- interact with us in the course of our business relationship in relation to the CRC Platform;
- interact with us and other Users through the public discussion board (“Public Forum”) available on the CRC Platform. You and other Users may post content such as stories, comments, photos, reviews, Contact Data ("Public Postings"). Public Postings will be made available on the Public Forum and therefore to the Users having access to Prologis Platforms.
- give us feedback, by way of a survey or otherwise.
It is important that the Personal Data you provide to us is accurate and current. Please keep us informed, through the “How to Contact Us” section or your account settings, of any changes to your Personal Data that may be relevant to us.
Prologis may also receive Personal Data from third party data providers such as:
- Technical Data from analytics providers, advertising networks and search information providers (such as Google, Google Analytics or Google Ads);
- Identity and Contact Data from (i) third party service providers we deal with in the course of our business, including brokers, agents, consultants, valuers, building contractors, asset and property managers, facility managers, security companies, cleaning and maintenance providers, third party lenders, bankers, valuers and insurers, (ii) professional advisors such as lawyers, notaries, auditors, accountants and tax advisors, (iii) our business partners, such as our joint venture partners or investors, and/or (iv) our counterparties, for example, in the course of an acquisition or a disposition of assets, and, for any of the above, where applicable, their subcontractors.
Automatic Data, cookies and other tracking devices
We record information about your computer or device and/or track your activity while you are using the CRC Platform. This information is collected via cookies or similar technologies. A cookie is a small piece of data that is stored on your computer or device. For example, we may record how many times you click on a hyperlink, determine whether you visited the CRC Platform from a particular internet link or advertisement, or track your path through the CRC Platform. This automatic data collection may include but is not limited to Technical Data and information collected by cookies, IP addresses, log data, browser data, and transparent GIFs ("Automatic Data").
We use Automatic Data to report aggregated activity on the CRC Platform and to better understand the needs of our Users, so we can make informed decisions regarding the content and design of the CRC Platform. We may also use this Automatic Data to personalise your experience on the CRC Platform. Additionally, we may share Automatic Data with third parties.
Some of our online content, such as advertisements, may be provided by third parties that may collect Automatic Data regarding your online activity. They may collect information about your online activities over time and across different websites and online services. These third parties include, by way of example only, Google Ads and Burst Media. Information collected by third parties is subject to their own privacy policies and Prologis is not responsible for their privacy policies, practices or content.
We may process your Personal Data for one or more of the following purposes:
- Service desk: to answer any questions or resolve any issues you notify us about in relation to the CRC Platform via our service desk.
- Liaising with you: to manage our relationship with you in the context of the CRC Platform by email, phone or text depending on the information you shared with us, including (i) asking for your participation in surveys or events or to provide us with a review or a rating about the CRC Platform, the Services and the Users, (ii) notifying you about updates to the CRC Platform and (iii) sending you other administrative messages, which can include security alerts.
- Protecting the security of the CRC Platform and providing you with a safe service: to administer and protect the CRC Platform (or person and property where relevant and possible), including using Personal Data to report incidents, injuries, detect and prevent frauds or unlawful or unwanted acts, for business continuity purposes.
- Marketing activities: to the extent permitted by applicable law, to provide you with marketing information and materials, including notifying you about events organised by Prologis or sending you news about the CRC Platform or Services, to make suggestions and recommendations to Customers about Services that may be of interest to them, to enable you to participate in promotional activities such as competitions or sweepstakes and administer the promotions, to deliver relevant CRC Platform content (including individualised offers, including on third party websites or apps) and advertisements to you and to measure or understand the effectiveness of our advertising. However, we will not use your Personal Data to send you marketing materials if you have requested not to receive them. If you no longer wish to receive marketing communications from us, you can let us know by adjusting your preferences in the forms and links included for that purpose in our electronic marketing communications or by contacting us as specified in the “How to Contact Us” section below.
- Improving the CRC Platform and our property management services: to use data for analytical purposes so as to improve the CRC Platform (including its functionality and quality, in particular, via troubleshooting, data analysis, testing, system maintenance and support), improving our business processes, linked services, marketing, property management services, Customer and Vendor relationships and experiences. We may also, for this purpose and more specifically for internal market research purposes, study how you use the CRC Platform.
- Research and statistics: to identify trends in the real estate sector and to generate aggregate research and statistical studies.
- Postings and Surveys: you may be invited to post feedback or complete a survey.
- Publications: to publish in articles, stories, collections and other publications in written, multimedia or other formats.
We may from time to time review Personal Data held in our systems, including the contents of and other information related to your email and other communications with us, for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations.
To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to competent authorities and litigation counterparties.
Your emails and other communications may also occasionally be accessed by persons other than the staff member with whom such communications were initially conducted for regular business management purposes (for example, when a staff member is out of the office or has left Prologis).
We will only process your Personal Data as necessary to pursue the purposes described above. Providing your Personal Data is voluntary. However, depending on the service you wish to use, some of the Personal Data is required. If you do not want to provide (part of) your Personal Data, you may not be able to use all or part of the CRC Platform.
If you wish to obtain further information on the purposes for which we use your Personal Data, please contact us as specified in the “How to Contact Us” section below.
The use of the Personal Data is necessary, with respect to each of the above purposes mentioned above:
- to perform the contract, we are about to enter or have entered with you;
- to respond to Prologis' legitimate interests (or those of a third party), in respect of the establishment, maintenance and improvement of the CRC Platform, our property management services and the prevention of fraud, when your interests and fundamental rights do not override those interests;
- to comply with a legal obligation; or
- in limited circumstances and to the extent required, where we have your consent for the processing of your Personal Data.
We may share your Personal Data, for the purposes detailed above, with:
- Prologis' affiliates which may (i) have a legitimate interest in receiving the information gathered via the CRC Platform, for example, for product development purposes, improvement of the CRC Platform or property management services, or regulatory and compliance purposes, or (ii) conduct data quality checks or provide IT services;
- Customers as applicable, in order for you to liaise with Users;
- selected third party providers including analytics services and search engine or IT providers, who assist us in the hosting, support, improvement and optimization of the CRC Platform, as well as in the fraud detection and prevention services;
- third parties to whom we may sell, merge or transfer (parts of) our business or assets, or in the context of any other corporate reorganization in which Prologis participates;
- selected third parties that provide marketing, advertising, communication and related services to Prologis, such as event organisers, marketing and online agencies; and/or
- government agencies, regulators and other competent authorities, where required by law or court order or in order to protect our legal rights.
We transfer Personal Data within and between Prologis' various worldwide locations, for the purposes described above. This means that your Personal Data may be transferred to countries outside of your jurisdiction and such countries may not be considered to have the same level of data protection as in your jurisdiction. As and to the extent required by applicable law, we have established certain safeguards and contractual arrangements regarding the transfer of Personal Data. International transfers of Personal Data from the European to the US parts of the Prologis group are based on Standard Contractual Clauses issued by the European Commission as referred to in article 46 of the General Data Protection Regulation. Any transfers of data from the UK establishments to the US establishments of the Prologis group and from the European Economic Area to the UK establishments of the Prologis group will be based on Standard Contractual Clauses issued by the European Commission as referred to in article 46 of the General Data Protection Regulation. You may contact us to request more information about (including a copy of) these arrangements (see the “How to Contact Us” section below).
An overview of the countries where Prologis is located can be found on www.prologis.com.
We also transfer Personal Data to third parties such as technology service providers which may be located outside the EEA in countries not considered to have the same level of data protection as in the EEA. Prologis has put in place, as and to the extent required by applicable law, appropriate safeguards to ensure such data transfers comply with applicable legal requirements (such as implementing appropriate contractual clauses).
Prologis strives to retain Personal Data for no longer than is reasonably necessary for the purposes the Personal Data is collected and processed. We shall retain your Personal Data for as long as you hold a profile or an account and may retain it after your account or profile has been deactivated or after your last interaction with the CRC Platform, subject to any relevant provisions of applicable law and the relevant applicable retention periods. In some circumstances, for research or statistical purposes (including the generation of aggregate statistical studies), we will anonymise the Personal Data in which case we may use this information indefinitely without further notice to you.
We take appropriate technical and organisational measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Prologis is committed to ensure that Personal Data can only be accessed on a "need to know" basis.
You should keep in mind that no internet transmission is 100% secure or error-free, so please consider carefully what type of information you provide to us using the internet. Concerning your profile or user account, we use both logins and passwords to authenticate you. You are responsible for maintaining the security of your login credentials.
We have procedures in place to deal with any suspected or actual Personal Data breaches and will notify you and the relevant regulator of the occurrence of such a breach if we are required to do so by applicable law.
If a child has provided us with Personal Data, a parent or guardian of that child (or another individual who has such rights based on the applicable local law) may contact us to have the information deleted from our records. To do so, please contact Prologis through the information provided below in the “How to Contact Us” section. If we become aware that a child has provided us with Personal Information without parental consent, we will take steps to remove such information.
As an individual you have a number of rights you can exercise in relation to the Personal Data, we hold about you. In particular, you have the right to:
- Request access to your Personal Data. This enables you to request a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to request that any incomplete or inaccurate information we hold about you is corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue processing it.
- Object to the processing of your Personal Data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
Note that under certain conditions, we may not be able to or permitted to satisfy your request, for example if we are under a legal obligation to retain or process certain Personal Data, we hold about you. If that is the case, we will let you know as soon as possible. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights, or to ask you any other relevant information as permitted by applicable law.
To exercise your rights please contact us through the information provided below in the “How to Contact Us” section.
When the Personal Data processing is based on your consent, you have the right to withdraw your consent concerning such data processing at any time.
You also have the right to lodge a complaint with your local data protection authority. A list of EU data protection authorities is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We would, however, appreciate the chance to deal with your concerns before you approach such authority so, please do not hesitate to contact us in the first instance.