Privacy Policy

Trammell Crow Residential (collectively “we,” “us,” or “our”) is committed to keeping the personal data collected from individuals confidential and secure. The proper handling of such personal data is a high priority. Please read this policy carefully to understand how we collect, use, share, and protect your personal data. In this policy, “you” and “your” refers to the individual to whom such personal data relates.

Data We Collect

We collect personal data about you (such as your name, address, email address, phone number, tax identification number, bank account information) that you voluntarily provide us in our discussions with you and from other documents and information you may deliver to us. Your submission of personal data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide the necessary personal data.

If you visit our website, we may also collect other technical data, including information about your device and usage such as your operating system, browser, geographical location, IP address, and page views and clicks. Our website may use cookies to obtain certain types of data when you visit our website. Cookies are files that we transfer to your computer’s hard drive through your web browser to enable our system to recognize your browser, to provide various types of functionality, to better understand how you interact with our website, to monitor aggregate usage, and to optimize web traffic routing on our website. You can typically adjust browser settings to accept or reject cookies automatically or ask you for permission before cookies are placed. Certain areas or features of the website may not be available or fully-functional if you choose to disable cookies.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate entity (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Use of Personal Data

The legal basis for our processing of your personal data generally includes one of the following: (a) you have consented to our processing of your personal data; (b) processing is needed to fulfill a request made by you; (c) processing is required to comply with a legal or regulatory obligation; or (d) processing is necessary for reasons that are in our legitimate interest as a company, such as to protect our business. For example, we may use personal data:

  • for the purposes for which you provided it to us;
  • to respond to your inquiries and communications to us; and
  • to fulfill our obligations under our customer contracts.

Sharing of Personal Data

We do not sell your personal data to any third parties. We may share your personal data as needed to fulfill the purposes described in the “Use of Personal Data” section above, including:

  • with nonaffiliated persons and entities that perform services for us, such as attorneys, brokers, administrators, accountants, auditors and custodians;
  • to third party companies or individuals that contract with us to perform servicing functions such as record-keeping, accounting, management, administrative services and computer-related services;
  • as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements; or
  • as requested or approved by you (including to your advisors, which can include, among others, accountants, investment advisors, and/or attorneys).

Companies we hire to provide services are not authorized to use your personal data for their own purposes and are obligated to maintain confidentiality of such data. We do not provide your personal data to mailing list vendors or solicitors for any purpose.

In the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets which would generally be transferred is the data we have collected. We will advise a successor or successors in interest of the terms of this privacy notice and our expectation that the successor(s) in interest will comply with the terms hereof.

Opt Out Options

To opt out, please contact us in writing or by email as set out at the end of this policy. Please be specific about the purposes you wish to opt out from, so we can efficiently process your request.

Employee Access to Data

We restrict access to nonpublic personal data to those employees with a legitimate business reason to have access to such personal data. These employees are educated on the importance of maintaining the confidentiality and security of this data. They are required to abide by our data handling practices.

Protection of Data; Email

We maintain commercially reasonable administrative, physical, and technical security standards designed to protect your personal data, whether written, spoken or electronic.

Should you send us your questions and comments via email, we will share your correspondence with those employees or agents most capable of addressing your questions and concerns. We will retain your communication until we have attempted to provide you with a complete and satisfactory response. Ultimately, we will either discard your communication or archive it according to the requirements under applicable securities laws, legal obligations and record retention policies. Please note that, unless we expressly advise you otherwise, our email facilities do not provide a means for completely secure and private communications between us and yourself.

Although we will attempt to keep your data confidential, from a technical standpoint, there is still a risk. For that reason, please do not use email to communicate data to us that you consider to be confidential. If you wish, you may contact us instead via telephone or by facsimile.

Data Retention, Access, and Correction

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

You may access and correct your personal data that we process, except where the burden of providing you such access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. You may also request erasure of your personal data in certain circumstances (and subject to any applicable legally required or permitted retention standards). To request access to, correction of, or erasure of your personal data, please contact us as set forth at the end of this privacy notice.

Our goal is to maintain accurate, up-to-date personal records in accordance with industry standards. When you or any other individual provides us with updated personal data, we will endeavor to update our records as soon as possible. We do not, however, have a duty to inquire as to changes in the data you provide to us.

Cross-border Transfers of Personal Data

We are based in the United States, and personal data collected by us and our affiliates worldwide (including within the EU and Switzerland) may be transferred to the United States for processing. By using our services or submitting personal data to us or our affiliates, you consent to the transmission of your data outside your own country. We are generally the “data controller” as that term is used under applicable laws. We may be liable in cases of onward transfers of your personal data to third parties.

Where it is applicable, we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal data. European Union and Swiss individuals with inquiries or complaints regarding our privacy notice should first contact us as set forth at the end hereof. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an independent alternative dispute resolution provider located in the United States. If a complaint is not resolved by other resource and enforcement mechanisms, then individuals may request binding arbitration. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact JAMS or visit their website (https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim) for more information. The services of JAMS are provided at no cost to you.

The Privacy Shield Frameworks apply to transfers of personal data from within the EU or Switzerland to the United States. If you are a EU or Swiss resident and have a question or complaint about the processing of your personal data within the EU or Switzerland, you have rights separate from those arising under the Privacy Shield Frameworks.

If you have any questions or complaints about data processing activities, please contact us at the email or mail address listed below. EU or Swiss residents have the right to raise their inquiry or complaint to the applicable data protection authority in their member country.

Children

Our website and services are not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us as set forth at the end of this privacy policy and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable legally required or permitted retention standards).

Disclosure of our Privacy Notice; Changes

We recognize and respect the privacy concerns of individuals. We are committed to safeguarding this data. As a member of the financial services industry, we are providing you this privacy notice for informational purposes and will update and distribute it as required by law. It is also available to you upon request. We may revise this privacy notice from time to time. If we make a material change to this policy, we will post the updated version (with the date of change(s) noted in the policy) on our website and other places we may deem appropriate, and/or notify you by mail or email, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.

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If you have any questions about our privacy policy, please contact us as set forth below, because your privacy and the confidentiality of your data are very important to us.

Email:    privacy@tcr.com
Mail:    Attn: TCR Privacy Team, 3819 Maple Avenue, Dallas, TX 75219

Last Updated: January 10, 2020