PROLOGIS PRIVACY POLICY
Effective: January 2024
Thank you for being a valuable member of Prologis' audience. You are important to us, and we respect your privacy.
This privacy policy (“Privacy Policy”) sets out the basis on which we will process any personal data we collect from or about you or that you provide to us. Personal information or data means any information enabling the direct or indirect identification of you or other natural persons (“Personal Data”). Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. This Policy also provides you with information about your privacy rights and how to exercise them.
CONTROLLERS
The Prologis group consists of different legal entities incorporated in Europe and outside of Europe. This Privacy Policy is issued on behalf of the Prologis group in Europe and when we mention “Prologis”, “we”, “us” or “our” we are referring to the relevant Prologis entity that is the controller, in other words, that is responsible for processing your data and determines the means and purposes of such processing. For the list of controllers, please click here.
THE DATA WE COLLECT ABOUT YOU
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, date of birth and gender;
- Contact Data, including your address, email address and telephone and fax numbers;
- Financial Data, including your bank account details and payment related information;
- CCTV/ANPR Data, meaning the close circuit television images or recording of you or your vehicle and the automatic number plate recognition of your vehicle, when you are in our property parks or at our properties;
- KYC Data (Know Your Customer data), or data obtained in the course of screening or due diligence checks, which may include your Identity Data, Contact Data, listings in sanctions or restricted lists, whether or not you are or have been a politically exposed person or connected to such a person, as well as information relating to corruption, crime, regulatory fines and penalties or negative publicity;
- Technical Data, including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Websites;
- Profile Data, which includes your username and password, your preferences, feedback and survey responses;
- Usage Data, which includes information on how you use our products and services, including our Websites.
- Marketing and Communications Data, which includes your preferences in receiving marketing information and materials from us and our third party providers, and your communication preferences;
- Events Data, including your Contact Data, guest and other relevant information and your travel, accommodation and meal preferences, including dietary requirements; your photo or video images taken at events organised by us (to the extent you have given your consent to our use of such photo and video images).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data by law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
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.
HOW WE COLLECT YOUR 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 you:
- enquire about our products or services, including leasing space in our properties or investment opportunities;
- contemplate entering into, or enter into, any contract with us;
- interact with us in the course of our contractual or business relationship;
- are working in, or visiting, any of our properties or property parks;
- use our Websites, for example, by creating an account on any of our Websites or subscribing to our service, our publications, an online tool or our platforms;
- request marketing information or materials to be sent to you;
- register to attend and attend one of our events;
- enter into a competition or promotion;
- give us feedback, by way of a survey or otherwise; or
- apply for a job with us.
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, of any changes to your Personal Data that may be relevant to us.
INFORMATION WE RECEIVE FROM OTHER SOURCES
We may also collect some Personal Data from other sources. For example, if Prologis has a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you, such as your Contact Data or details of your role in the relationship.
Prologis may also collect Personal Data from third party data providers or publicly available sources of information, including collection in order to facilitate our business needs, protect our business and comply with our legal and regulatory obligations. Examples of such data include:
- Technical Data from analytics providers, advertising networks and search information providers (such as Google, Google Analytics or Google Ads);
- Identity and Contact Data from publicly available sources such as trade and company registers;
- 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 (“Third Parties”);
- KYC Data and information for anti-money laundering, background checking and similar purposes from credit check agencies and agencies involved in screening and due diligence checks; and
- CCTV/ANPR Data and access data (as may be applicable) from our third party providers such as security companies for security, safety and statistical purposes, or in the event of a security incident.
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 Websites. For example, we may record how many times you click on a hyperlink, determine whether you visited the Websites from a particular internet link or advertisement, or track your path through the Websites. 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 Website and to better understand the needs of our users, so we can make informed decisions regarding the content and design of the Websites. We may also use this Automatic Data to personalize your experience on the Websites. Additionally, we may share Automatic Data with third parties. If you provide us with Personal Data, we may combine and use the Automatic Data with such Personal Data and such combined data will then be treated as Personal Data.
Some of our online content, such as advertisements, may be provided by third parties that may collect Automatic Data regarding your online activity. 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.
HOW WE USE AND SHARE YOUR PERSONAL DATA
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- to perform the contract we are about to enter or have entered with you;
- when necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests;
- to comply with a legal obligation; or
- in limited circumstances, where we have your consent for the processing of your Personal Data.
PURPOSES OF USE OF PERSONAL DATA
We may process your Personal Data for one or more of the following purposes, depending on our relationship with you:
- to register you as a new customer, investor, service provider or business partner and to establish our contractual or business relationship with you;
- to manage our relationship with you, including (i) providing you with the information and services about our business, products, services and investment opportunities, (ii) providing you access to our properties and property parks, (iii) contacting you in response to your inquiries, comments and suggestions, or contacting you otherwise, when necessary, (iv) receiving goods or services from you, (v) managing payments, fees and charges, and (vi) asking for your participation in surveys;
- to administer and protect our business, including arranging for maintenance and repair of our properties and property parks, reporting incidents, injuries or potential insurance claims, for business continuity purposes, scheduling property viewings and inspections; making decisions about selecting customers, investors, vendors and service providers and associated risk management; deploying and developing our products and services; detecting and preventing fraud or unlawful acts;
- to provide you with marketing information and materials, including notifying you about events organised by Prologis, to make suggestions and recommendations to you about goods or services that may be of interest to you, to enable you to participate in promotional activities such as competitions or sweepstakes and administer the promotions, to deliver relevant Websites content and advertisements to you and to measure or understand the effectiveness of our advertising, in each case in compliance with applicable laws on direct marketing;
- to carry out IT management, including infrastructure management and IT security, to administer and protect our Websites, including (i) troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, (ii) to notify you about updates to the Websites or other services, (iii) to track your use of the Websites for internal market research, and (iv) to improve the Websites and the products and services that Prologis promotes or provides through the Websites;
- to use data analytics to improve our Websites, business processes, products, services, marketing, customer relationships and experiences;
- to identify trends in the real estate sector and to generate aggregate research and statistical studies;
- to publish in articles, stories, collections and other publications in written, multimedia or other formats, with your explicit consent to the extent required;
- to meet all legal and regulatory requirements applicable to our business, or as otherwise required by law or regulation, or requested by competent authorities, or for the protection of persons or property, or to assist us in fraud prevention or investigation, or to enforce the Terms of Use or other Prologis policies; or
- in connection with an acquisition, merger, restructuring, sale or other transfer involving all or any portion of our business.
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. Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have (or are trying to enter into) with you or provide you with the relevant product or service.
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.
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.
DATA RECIPIENTS
We may share your Personal Data, for the purposes detailed above, with:
- Prologis' affiliates which may have a legitimate interest in receiving the relevant information, for our internal business processes;
- the Third Parties (as defined above);
- selected third parties including analytics services and search engine providers, who assist us in the hosting, support, improvement and optimization of the Websites;
- third party IT service and system administration service providers;
- third parties to whom we may sell, merge or transfer (parts of) our business or assets;
- third parties that provide marketing, advertising, communication and related services to Prologis, such as event organizers, marketing and online agencies; and/or
- regulators and other authorities who require reporting of processing activities in certain circumstances.
INTERNATIONAL DATA TRANSFER
Our group companies and third party contractors and consultants operate around the world. This means that we may process personal data outside the European Economic Area (EEA) and the UK. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this notice. These include implementing data transfer clauses with our third party vendors, contractors and consultants and an intragroup agreement for transfers of personal data within our group. You may contact us to request more information about (including a copy of) these arrangements (see the “How to Contact Us” section below).
In relation to the transfer of Personal Data to third parties, Prologis establishes whether any specific data security measures need to be implemented with those third parties beforehand and implements such security measures as required.
An overview of the countries where Prologis is located can be found on www.prologis.com.
DATA RETENTION
Prologis strives to retain Personal Data for no longer than is reasonably necessary for its processing purpose. The applicable retention period depends on the purpose for which Personal Data was obtained and on specific data retention obligations arising from applicable laws that may require the data to be held for a certain period of time.
We may retain Personal Data for a longer period than is necessary for its processing purpose in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. In some circumstances, for research or statistical purposes (including the generation of aggregate statistical studies), we will anonymize your Personal Data, in which case we may use this information indefinitely without further notice to you.
INFORMATION SECURITY
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.
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 legally required to do so.
DATA SUBJECT RIGHTS
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 (data portability) of your Personal Data to another party. However, this right only applies where:
- the processing is based on your consent;
- the processing takes place for the performance of a contract; or
- the processing takes place by automated means.
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.
To exercise your rights please contact us through the information provided below in the “How to Contact Us” section.
TERMS OF USE AND UPDATES TO THE PRIVACY POLICY
Your use of the Websites constitutes your acceptance of the terms and conditions in this Privacy Policy as modified from time to time, including our collection and use of Personal Data, as well as our Terms of Use. Please click here to review our Terms of Use statement in its entirety.
The Privacy Policy may be amended as needed, so you are encouraged to review the Privacy Policy from time to time. The amended Privacy Policy will be effective upon posting on the Websites, and we will note near the top of the first page the date on which any changes are made. Your continued use of the Websites following the posting of changes to the Privacy Policy means that you accept the changes and our use of your Personal Data in accordance with the revised policy. Prologis may, but is under no obligation to, provide you with notice of such modifications to this Privacy Policy via email or other communication.
HOW TO CONTACT US
Should you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected].
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.