Please read this Privacy Policy to understand how we may process your Personal Data including personally identifiable information (defined below) via your use of the Mobile App and/or Company Services. If you do not agree to the practices set forth below, please immediately cease use of the Mobile App. If you have questions about this Privacy Policy or the practices described herein, please contact us.
We have designated a privacy officer who is responsible for our compliance with this Privacy Policy. The privacy officer may be contacted as described below.
KEY ELEMENTS OF THIS PRIVACY POLICY:
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Our Policy:
Welcome to the My HPP Office mobile application (the “Mobile App”) of Hudson Pacific Services, Inc. and its affiliated companies (“Company”, “we”, “us” and/or “our”), powered by HqO, Inc. (“HqO”). This Mobile App and related services are provided by Company to augment a tenant’s experience at a commercial or residential property through providing information, services, and functionality related to the property (collectively, the “Company Services”), and are subject to the Terms of Service. This privacy policy (“Privacy Policy”) sets out how Company collects, uses, discloses, and protects any Personal Data, including personally identifiable information, that you provide in connection with your use of the Mobile App and/or Company Services (“Personal Data”). We may receive and store any information that you provide to us or that we learn about you from your use of the Mobile App, the Company’s websites, services or other sources that would allow us to identify you personally. This Personal Data information may include Personally Identifiable Information (“PII”), which shall mean any information relating to an identified or identifiable natural person. An identifiable person as referred to in this Privacy Policy is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity. This Privacy Policy does not apply to any personal data collected by Company other than Personal Data collected through the Mobile App.
We do not sell or rent your Personal Data with other people or non-affiliated companies. Any Personal Data we share with HqO or other service providers shall be shared for the limited purpose of providing you services you request.
1. Information We Collect:
When you download and use the Mobile App to interact with us through the Company Services, we collect Personal Data and other information from you, as further described below:
- Administering Your Mobile App Account: When you download our Mobile App and set up an account, HqO will collect certain Personal Data from you such as, your email address and password, in order to create and administer your account. Additionally, HqO will collect Personal Data you provide as a part of any support requests submitted via the “Help” sections of the Mobile App, including your name, email address, and the content of your request.
- Personal Data That You Provide: We, or service providers acting on our behalf, collect Personal Data from you when you voluntarily provide such information through the Mobile App, such as when you use one of the available features to, for example, submit a maintenance request or work order, chat with the concierge, use mobile access to enter an area, view transit information, book certain amenities with a third party provider, or register a visitor. Depending on the feature used, the Personal Data collected may include your name and contact information, or that of your visitors, as well as any other Personal Data you voluntarily provide. You may also receive requests to enable (i) location services so that we may collect your location information, (ii) access to the photos and videos stored on your device, and/or (iii) biometric authentication; enabling these features will result in you providing the relevant information, but you can manage your permissions for these features in your device settings. Note that certain Personal Data you provide through the Mobile App (e.g., payment information) is collected directly by service providers acting on our behalf (e.g., our payment processor, Stripe) and we do not have access to such information. Additionally, certain features of the Mobile App may direct you to other web sites, applications, or services not operated or controlled by us (the “Third Party Sites”); any Personal Data you provide while using such Third Party Sites is not subject to this Privacy Policy (please see below for more information about Third Party Sites).
- Information Automatically Collected via the Mobile App: When you interact with Company through the Mobile App, we, and HqO acting on our behalf, automatically receive and store certain information regarding your actions taken within the Mobile App. Such information, which is collected using first-party tracking technologies known as JSON Web Tokens (JWT), cannot presently be used to specifically identify you and includes, but is not limited to, pages of the Mobile App used, content with which you interact, and building events which you attended or in which you have expressed interest. This information may be pooled with other information to track, for example, the total number of users of our Mobile App and the number of users who visit and interact with each page of our Mobile App for the purposes of product development and improvement and to notify you about events and features that may be of interest to you. It is important to note that no Personal Data is available or used in this process.
- Aggregated Data: In an ongoing effort to better understand and serve the users of the Company Services, Company often conducts research on its customer and user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents and business partners, including HqO, to use and disclose for their own purposes, as permitted by applicable law. This aggregate information does not identify you personally, nor can it reasonably be associated with you.
We will not collect Personal Data indiscriminately, but will limit collection of Personal Data to that which is reasonable and necessary. We may also collect Personal Data as authorized or required by law. Your Personal Data will only be used or disclosed for the purposes set out in this Privacy Policy and as authorized or required by law.
2. Our Use of Your Personal Data and Other Information:
As permitted by applicable law, we process your Personal Data as described in this Privacy Policy to provide the Company Services, perform the contract we are about to enter into or have entered into with you, ensure compliance with local legal and regulatory requirements, and for our legitimate business interests, including to:
- provide you with information, products and services that you request from us;
- respond to an enquiry or other request you make when you contact us via the Mobile App, including for customer support;
- identify a user for authentication to the Mobile App;
- notify you about any changes to Company Services;
- carry out our obligations arising from any contracts;
- issue a notice or corrective action to you in relation to any of the Company Services, if required;
- help us improve the content, functionality, and security of the Mobile App and Company Services, and to better understand how you use the Company Services;
- allow you to participate in promotions and contests we may offer from time to time.;
- maintain accurate customer records.;
- monitor your compliance with any of your agreements with us, including our Terms of Service;
- manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or merger;
- protect us, yourself and others from fraud and error and to safeguard our business interests;
- collect debts owed to us;
- comply with legal and regulatory requirements; and
- in accordance with applicable laws, provide you with information about events, promotions, features, or other services which we believe will be of interest to you similar to those that you have already attended, enquired about, or purchased, as described in the “Marketing / Push Notifications” section below.
We may also process your Personal Data for other purposes we may inform you about from time to time.
3. Marketing / Push Notifications
Company and service providers, like HqO, acting on our behalf may use information collected through the Mobile App, such as services you have used and events you have attended, to send you push notifications through the Mobile App about events, promotions, features, and services offered through the Mobile App that may be of interest to you. Where required by applicable law and to the extent they constitute marketing, we will obtain appropriate consent prior to sending you such notifications. If at any time you wish to opt-out of receiving any future notifications, please change your notification settings in the Mobile App or on your device, or contact us as indicated below.
4. Our Disclosure of Your Personal Data and Other Information
We may share your Personal Data with certain other entities without further notice to you, as required or permitted by law and set forth below:
- Agents, Service Providers, and Business Partners: Company sometimes hires other companies to perform certain business-related functions and provide other functionality of the Mobile App. Examples of such companies include HqO to build and host the Mobile App and Company Services; our IT service providers that maintain our databases; and companies with whom we partner or whose services are integrated into the Mobile App in order to provide certain Mobile App features, such as registering visitors, handling maintenance requests or work orders, providing mobile access, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. We will take reasonable steps to ensure that service provider adhere to privacy procedures and will keep your Personal Data confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
- Third Party Amenities Providers: We may, in accordance with applicable laws, share your Personal Data with third party providers of amenities offered through the Company Services, such as dry cleaning, chair massages, fitness classes, and salon appointments, in order to fulfill your requests, reservations, and contracts with these third party amenities providers.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets or shared during the diligence process, in accordance with applicable laws.
- Affiliated Companies: We may also share your Personal Data with our affiliated companies for purposes consistent with this Privacy Policy. If we do disclose your personal information to our affiliated companies, their use and disclosure of your personal information will be subject to this Privacy Policy.
- Legal Obligations: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
5. Location of Service Providers; Storing your Personal Data
Your Personal Data collected via the Mobile App and through our Company Services will be stored on servers located in the United States, and our service providers may be located outside of the country in which you are located. This includes by individuals or service providers engaged in, among other things, administration of an enquiry or request you make via the Mobile App, or the provision of support services. You therefore acknowledge that your Personal Data may be processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the US and elsewhere may be able to access or obtain disclosure of your Personal Data under a lawful order or otherwise through the laws of the foreign jurisdiction, irrespective of the safeguards we have put in place for the protection of your Personal Data.
6. Data Retention
We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise permitted or required by law.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. Children
Company does not knowingly collect Personal Data from minors. If you are a child, a person under the age of majority, please do not submit any Personal Data through the Mobile App. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Mobile App without their parents’ permission. If you have reason to believe that a child has provided Personal Data to Company through this Mobile App, please contact us, and we will endeavor to delete that information from our databases.
8. Links to Other Web Sites, Applications, or Services
This Privacy Policy applies solely to Personal Data collected via the Mobile App and the Company Services. This Mobile App, including certain features provided therein, may contain links to other web sites, applications, or services not operated or controlled by Company (the “Third Party Sites”). This Privacy Policy does not apply to the Third Party Sites. Instead, the data practices of those Third Party Sites are governed by their respective privacy policies, over which we have no control. The inclusion of features or links from the Mobile App do not imply that Company endorses or has reviewed the Third Party Sites or their privacy practices. We encourage you to review their respective privacy policies.
9. Security
Company takes reasonable steps to protect the Personal Data provided via the Mobile App and Company Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, and we will take reasonable measures, through contractual or other reasonable means, to ensure that our service providers implement a comparable level of protection.
We maintain commercially reasonable physical, electronic, and procedural safeguards that are designed to guard our customers’ Personal Data. For example, for the security of online visits to www.hudsonpacificproperties.com (or any of our property-related sites), we may make use of firewalls, encryption and other authentication procedures to attempt to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. Personal Data is maintained within a server environment that is intended to be secure. Unfortunately, no data transmission over the Internet or internal security system can be guaranteed to be absolutely secure. As a result, although we strive to protect your Personal Data, we cannot ensure, and do not guarantee or warrant the security of our servers nor can we guarantee that Personal Data you supply through the Company Site will not be intercepted while being transmitted over the Internet, and you acknowledge by your use of the Mobile App and Company Services that you do so at your own risk. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any Personal Data to Company.
Our internal data security policies restrict access to customers’ Personal Data to authorized employees, agents and subcontractors with a “need to know,” and we train those persons on the protection of Personal Data. These persons may use our customers Personal Data for Company’s business purposes only. Our employees are bound by our policies to maintain the confidentiality of our customers’ Personal Data, and are subject to disciplinary action for violating their confidentiality obligations.
If there is a breach of the confidentiality or security of your Personal Data, we may attempt to notify you as necessary by email or other means so you can take appropriate protective steps. By using the Mobile App or Company Services or providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Mobile App or Company Services or your account with us. Unless you indicate otherwise, we may notify you using the most current email address you provided to us.
10. Other Terms and Conditions
Your access to and use of the Mobile App is subject to the Terms of Service.
11. Changes to Company’s Privacy Policy
The Mobile App and Company Services may change from time to time. As a result, it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Mobile App and Company Services after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.
12. Your Rights
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Mobile App or the Company Services.
For California residents: Please refer to “Additional Information for California Residents” below for information about your rights.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with any local laws and our policies and procedures. You have the right to lodge a complaint about how we process your Personal Data with the supervisory authority in your country.
If you wish to exercise any of your rights, please contact us using the information provide in the “Contact Us” section below.
For Canadian residents:
- Consent. We will obtain your consent to collect, use or disclose Personal Data except where we are authorized or required by law to do so without consent. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your Personal Data collected, used or disclosed for various purposes after you have received notice of those purposes) or otherwise. You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of that withdrawal of consent. If you withdraw consent, we will inform you of the likely consequences of that withdrawal, which may include our inability to provide certain services for which that information is necessary.
- Accuracy: We will make a reasonable effort to ensure that Personal Data we are using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of your Personal Data, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. If a challenge regarding the accuracy of Personal Data is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
- Access: You have a right to access your Personal Data held by us. Upon written request and authentication of your identity, we will provide you your Personal Data under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so. In some situations, we may not be able to provide access to certain Personal Data (e.g., if disclosure would reveal personal information about another individual). We may also be prevented by law from providing access to certain personal information. If we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
13. Additional Information for California Residents
This section applies solely to California residents. In accordance with the California Consumer Privacy Act (“CCPA”), this section notifies California residents of (1) the nature of the PII that we collect and how we disclose that information; (2) the privacy rights California residents may have relating to their PII; and (3) how those rights can be exercised. Nothing in this section limits our ability to use or disclose information as described elsewhere in this Privacy Policy or in Company’s Website Privacy Policy, (https://www.hudsonpacificproperties.com/privacy-policy).
PII Collection and Disclosure
Categories of PII Collected: In the past 12 months, we have collected the following categories of PII:
- Identification Information, such as name, username, email address, phone number, and work address.
- Employment and Professional Information, such as employer name.
- Online Activity Information, such as IP address, device information, the date and time of your request, how you interacted with the Mobile App, and other usage information automatically collected using JSON Web Tokens.
- Commercial Information, such as purchase, payment, and billing information, although payment and billing information are provided directly to a payment processor.
- Location Information, if you choose to enable Location Services to use certain Mobile App features, such as mobile access.
- Photo/Visual Information, if you choose to grant the Mobile App access to your pictures or videos or otherwise upload such information.
- Biometric Information, if you choose to enable biometric authentication to make purchases through the Mobile App, although such information is provided directly to a payment processor.
Sources of PII: We collect the above categories of PII from you and as otherwise described in the “Information We Collect” section above.
Purposes of Collection and Disclosure: We collect and disclose the above categories of PII for the business and commercial purposes described in the “Our Use of Your Personal Data and Other Information” and “Our Disclosure of Your Personal Data and Other Information” sections above.
Your California Privacy Rights
Disclosure of Certain Rights and Our Obligations Under California Law
Under the CCPA, you have certain rights, including without limitation the right to request that a business disclose to you the specific pieces of your Personal Data such as PII collected by that business, and the right to request deletion of that collected information. If we receive a verifiable request from you requesting that we delete your Personal Data such as your PII, we shall delete your Personal Data from our records and direct any service providers or affiliates to delete your Personal Data from all records, unless your request is subject to one or more of the exceptions set forth below.
Please be advised that we are not required to comply with your request to delete your Personal Data if it is necessary for us, our affiliates, or service providers to maintain your Personal Data in order to:
- Complete the transaction for which the Personal Data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you (if applicable), or otherwise perform a contract between us and you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have previously provided us your informed consent;
- To enable internal uses that are reasonably aligned with your expectations based on your business relationship with us;
- Comply with a legal obligation; and
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.
Under the CCPA, you are entitled, upon request but not more than twice every twelve (12) months, to request disclosure of the following:
- The categories of Personal Data a business has collected about you;
- The categories of sources from which the Personal Data is collected;
- The business or commercial purpose for collecting or selling Personal Data (again, we do not sell any such information);
- The categories of third parties with whom the business shares Personal Data; and
- The specific pieces of Personal Data it has collected about that consumer.
Please see section entitled “Contacting Company” set forth below, for information on contacting us with any request for information collected or any Personal Data deletion request. Upon receipt of your Personal Data request, or your deletion request, we will promptly review and handle your request.
Non-Discrimination Rights: Pursuant to the CCPA, a business shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights under this title, including, but not limited to, by:
- Denying goods or services to the consumer;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing a different level or quality of goods or services to the consumer;
- Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, nothing in the CCPA prohibits a business from charging a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the consumer by the consumer’s data.
14. Contact Preferences
You have certain choices when it comes to how Company uses your PII. You may choose not to receive information about new services and special promotional offers from us by direct mail and/or email. If you elect not to receive such marketing information by direct mail or email, Company may continue to contact you as necessary to service your account. You can change your contact preferences by emailing us at [email protected] or by writing to us at the physical address set forth further below. Keeping your account information accurate and up to date is very important so we can provide you with excellent service.
15. Miscellaneous Provisions
- This Privacy Policy Applies to U.S. Customers: This Privacy Policy applies to customer relationships established in the United States. The Mobile App is hosted in the United States and is intended for United States visitors. Parts of this Privacy Policy may not apply to visitors to the Mobile App outside the United States because, for example, certain services may not be offered to non-U.S. customers. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. privacy and data protections laws and which may be more stringent than those U.S. laws, by visiting the Mobile App and providing us with Personal Data, including PII, you acknowledge and consent to the transfer to and processing of your PII in the United States.
- Links to Third-Party Sites and Websites Containing Company Branding: The Mobile App may contain links to third-party websites. Please be aware, however, that Company is not responsible for and cannot control the privacy policies of these other websites or their practices. We encourage you to read the privacy policies for these other websites, as they may differ from ours. The Mobile App also may contain links to websites that display Company branding and/or Company’s logo but which are maintained by third parties. Such websites may be identified in that they do not display a “Hudsonpacificproperties.com” URL. Please read the privacy policy on these websites for applicable privacy practices relating to Personal Data collected via those websites because they may differ from Company’s privacy practices. This Privacy Policy applies solely to Personal Data collected by Company directly, by phone, online and through our customer support services.
- Disclaimer: Company makes every effort to ensure that all information displayed on the Mobile App is accurate and complete, but it is not liable for any errors, inaccuracies or omissions. The majority of information is liable to change at short notice. The links contained in the Mobile App are displayed for ease of access, but Company is in no way responsible for any information displayed on any other website. Please read these terms carefully prior to using Company’s Site. By using the Mobile App, you indicate your acceptance of the terms set forth herein. If you do not accept or agree to these terms, do not use the Site. Company may modify this agreement at any time, and such modifications shall be effective immediately upon posting of the modified agreement. You agree to review the agreement periodically to be aware of such modifications and your continued access or use of the Site shall be deemed your conclusive acceptance of the modified agreement.
- Terms and Conditions: If you choose to visit our Company Sites, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including, but not limited to, disclaimers of warranty, limitations of liability, and your assumption of the risk of use of the Mobile App.
- Verification: In order to protect your PII from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete PII. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional PII for verification. If we cannot verify your identity, we will not provide or delete your PII.
- Authorized Agents: You may submit a request to know or a request to delete your PII through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
- Severability: In the event that any provision of this Privacy Policy shall, in whole or in part, be determined to be invalid, unenforceable or void for any reason, such determination shall affect only the portion of such provision determined to be invalid, unenforceable or void, and shall not affect in any way the remainder of such provision or any other provision of the Policy. Company’s failure to act with respect to a breach by User or others does not waive its right to act with respect to subsequent or similar breaches.
- What Else Should I Know About My Privacy? You should be careful to maintain the secrecy of your user ids and passwords and/or account information and be responsible about protecting your PII and identity, both online and off-line. You can refer to the US Federal Trade Commission’s website at http://www.ftc.gov/ for information on how to protect yourself from identity theft.
16. Contacting Company
If you have any questions, comments, or concerns about this Privacy Policy, please email us at [email protected] or write to us at:
Hudson Pacific Services, Inc.
11601 Wilshire Blvd
Suite 900
Los Angeles, California 90025
Attention: General Counsel
You may also contact us at this number (866) 934-4951 with any request for Personal Data disclosure or Personal Data deletion.