Kilroy Realty Corporation (“Kilroy,” “Company,” “our,” “us,” or “we”) is committed to your right to privacy and to keeping your personal information safe. This privacy policy (the “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.kilroyrealty.com (our “Website”), the Kilroy application including as accessed via a third-party mobile platform (the “Application”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy also applies to information we collect in electronic messages between you and us, including through this Website, the Application and information collected from Kilroy’s asset management, leasing, and other websites that include links to this Privacy Policy (collectively, with our Website and the Application, our “Platform”) or that is shared with us and collected offline. Except as otherwise described herein, this Privacy Policy does not apply to information collected through any other means, including on any other website operated by us or any third party or through any application or content (including advertising) that may link to or be accessible from our Platform. A third party service provider supports portions of the Application, and you may be subject to a separate privacy policy and terms with respect to that third party service provider’s collection and processing of information. This Privacy Policy applies to Kilroy’s collection and processing of information via the Platform.
Please read this Privacy Policy carefully and review our Terms and Conditions, which governs your use of and access to the Platform. By accessing or using our Platform you consent to our collection, use, sale, sharing, and disclosure of your personal information as described in this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use our Platform or provide us with any personal information. Our Platform is intended for users in the United States only. The servers that make our Platform available are located in the United States. If you are a non- resident of the United States, do not use the Platform or provide us with any of your personal information.
INFORMATION WE MAY COLLECT & HOW WE COLLECT IT
Our Platform collects information about you in the following ways:
Information You Give to Us When You Contact Us or Request Information.
When you choose to contact us (e.g., by email, phone, or an online contact form), register for an event, or request email alerts or other information, including in the context of your business relationship with us, we may receive information that can identify you or your business, which includes, but is not limited to, your name, your employer’s name, email, U.S. mail address, office address, and home telephone and fax number. If you join our email alert services, we may send you, via email, press releases or other similar messages. If you do not wish to receive these communications from us anymore, please use the unsubscribe mechanism included in the email communication or send an email to dataprivacy@kilroyrealty.com.
You may also elect to share information with us stored on your device. This information may include, for example, electronic documents and/or multimedia such as photos or videos that you store on your device. This information will only be collected from your devices it you choose to upload it to the Platform. This information will not be shared with other Platform users except for those with an associated or linked account or third parties except as described in this Privacy Policy.
Information We Automatically Collect About You.
As with many websites and applications, when you interact with our Platform, we may use automatic data collection technologies to collect and log certain information about your equipment, browsing actions, and patterns, including details of your visits to our Platform (e.g., traffic data, logs, other communication data, and resources that you access and use on our Platform), information about your computer, mobile device and internet connection (including your IP address, operating system, and browser type), and location data, such as precise geolocation and/or location information we derive from your IP address or other device settings, which we collect to ensure you reside in a jurisdiction in which you are eligible for using our Platform, to comply with relevant laws, and for fraud prevention purposes.
Cookies, SDKs and Other Technologies
The technologies we use for automatic data collection include cookies (i.e., browser cookies), flash cookies, software development kits (SDKs) and web beacons. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, better understand how site visitors use the website, and provide more targeted content to its site visitors. SDKs are a set of tools that provides a developer with the ability to build a custom platform which can be added on, or connected to, another program. SDKs allow us to develop web applications for a specific platform.
We may store cookies (e.g., locally stored objects) on your computer’s hard drive when you use our Sites. These devices help us speed up your future activities and improve your experience by remembering the information that you have already provided to us. Third parties operating on behalf of us and/or our affiliates may also use these devices to provide us with anonymous data and information regarding the use of our Platform. At your option, you may block or delete devices from your hard drive. However, by disabling such tracking devices, you may not have access to the entire set of features of our Platform. For more information about cookies, including links to web browser instructions for disabling and managing such tracking devices, visit https://optout.networkadvertising.org.
OTHER INFORMATION WE COLLECT ABOUT YOU
Kilroy may also collect and receive information, including personal information, about you from third parties, including the following websites. Kilroy will use the information it collects in accordance with this Privacy Policy and may combine this information with other information it collects about you.
Kilroy Property Websites.
We may receive personal information about you collected from other Kilroy property websites that are operated by third-party property managers.
Asset Management Websites.
We collect information about you when you visit our asset management websites, which includes contact information provided by prospective tenants, information related to onboarding new tenants and property managers, credit-related information, and information collected through a variety of web forms available (e.g., keycard registration, locker rental). These websites also use the automatic data collection technologies outlined in Section I(3) of this Privacy Policy.
Leasing Websites.
We may also receive information about you when you choose to contact us through our leasing websites (e.g., send us an email with a question about a Kilroy project or complete one of our online contact forms), register for an event, or request email alerts or other information. We may receive information that can identify you or your business which includes, but is not limited to, such items as your name, employer’s name, email, U.S. mail addresses, credit-related information, office address, and telephone and fax numbers. If you join our email alert services, we may send you, via email, press releases or other similar messages. If you do not wish to receive these communications, please use the unsubscribe mechanism included in the email communication or send an email to dataprivacy@kilroyrealty.com.
Event Websites.
We may also collect information about you when you register for one of our events on a third- party website (e.g., name, company name, email address, and comments).
HOW WE USE AND DISCLOSE THE INFORMATION WE COLLECT
We may collect, use, or disclose the information, including personal information, we collect for the following business purposes:
- To provide our Platform and its contents to you.
- To provide the services requested by you, including in the context of your business relationship with us, and perform our contractual obligations.
- To fulfill or meet the reason you provided the information (e.g., to respond to your email or request for information).
- To provide you with perks, promotional offers, or other features as provided on the Platform.
- To communicate with you about our properties and services or to provide you with information or marketing materials that may be of interest to you (which may include telephone, email, push notifications or other notifications within the Platform).
- In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personally identifiable information that you provide and other information concerning your relationship with us.
- If permitted by law or required to do so by law, court order, or government regulations or where we believe such action is necessary in order to protect or defend our interests or the interests of our customers or users of our Platform.
- To help maintain the safety, security, and integrity of our Platform, products and services, databases, other technology assets, and business.
- For system administration and to monitor the use of our Platform. We use the information to measure the number of visits to our Platform, the average time spent on our Platform, the number of pages viewed, and to monitor various other Platform statistics. This monitoring helps us evaluate how our Platform is used and helps us continuously improve the content we provide.
- For any other purpose disclosed by us when you provide the information or with your consent.
- To disclose to third parties for the performance of services provided to us, including third-party providers of services related to the operation and management of our Platform, or in connection with the administration and support of the activities noted above.
- To disclose to certain third-party partners that may offer promotional offers, perks or other features via the Platform, including, for example discounts on certain third-party products or services. Please be advised that the third party’s own privacy policy may apply to its use or your personal information.
THIRD-PARTY WEBSITES
Our Platform may contain links or references to other websites outside of our control, and this Privacy Policy does not apply to these websites.
CHILDREN’S PRIVACY
Our Platform is not intended for children under 13 years of age. No one under 13 may provide any personal information to or on our Platform. We do not knowingly collect personal information from children under 13 (or 16 where applicable by law). If you are under 13, do not use or provide any information on our Platform. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, contact us by phone at 833-319-2998 or email at dataprivacy@kilroyrealty.com.
YOUR COMMUNICATION CHOICES
There are the following mechanisms to provide you with control over your information and communications provided by or on behalf of Kilroy:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or may not function properly.
- Opt-Out Tools. You can also learn more about the options available to you to limit third party advertisers that use tracking or targeting tools in connection with our Website:
- Opt Out of Interest Based Advertising (National Advertising Initiative);
- Your Ad Choices (Digital Advertising Alliance);
- For mobile users, check out participating members of the Digital Advertising Alliance by installing the AppChoices mobile app and selecting the user's choices.
- Google Analytics. You can opt out by visiting Google Analytics Opt-out Browser Add-on.
- Push Notifications. You can opt not to receive push notifications from our Platform by following the instructions in your mobile application or device settings.
- Marketing or Other Promotional Communications. If you do not wish to receive marketing or other promotional emails, you can click “unsubscribe” in the bottom of the email. You can also always exercise your right to ask us not to process your personal information for marketing purposes by contacting us at the address below (see Section VIII “Contact Information”). However, please note that we reserve the right to send you certain communications relating to your use of our Platform, service announcements, informational and promotional messages and/or offers, notices of changes to this Privacy Policy or our Terms and Conditions or similar administrative or transactional messages, and these transactional account messages may be unaffected if you choose to opt out from certain marketing emails.
REVISIONS TO OUR PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your personal information, we will notify you via our Platform. The date this Privacy Policy was last updated/reviewed is identified below. You are responsible for periodically monitoring and reviewing any updates to this Privacy Policy. Your continued use of our Platform after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.
CONTACT INFORMATION
Should you have any questions or concerns about this Privacy Policy or any of its provisions, contact us by phone at 833-319-2998 or email us at dataprivacy@kilroyrealty.com.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (Civil Code Section 1798.100, et seq.) (collectively, “California Law”), provides eligible California residents with specific rights with respect to our collection, retention, disclosing, selling, sharing, and use of personal information. This section on Additional Information for California Residents supplements this Privacy Policy and applies solely to eligible residents of the State of California (“consumers” or “you”) as of January 1, 2023. Any terms used but not defined in this section have the same meaning as defined in California Law.
In this section, when we talk about “personal information,” we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Information We Collect
The categories below are those identified by California Law. Please note that we have not collected every type of personal information identified in the examples below, and the types of personal information we collect about you depends on how you interact with us and our Platform. The following are categories of personal information that we have collected from consumers within the last twelve (12) months:
Category Examples Collected? Identifiers. This category may include: name, postal address, unique personal identifiers, online identifiers, email address, account name, or other similar identifiers. Under the California Law, “unique identifiers” or “unique personal identifier” means a persistent identifier that can be used to recognize a consumer, a family, or a device that is linked to a consumer or family, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device. YES Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). This category may include: name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education or employment information, financial account numbers, medical information, or health insurance information. YES Protected classification characteristics under California or federal law. This category may include: age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex and gender information, veteran or military status, or genetic information. NO Commercial information. This category may include: records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies. YES Biometric information. This category may include: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted. NO Internet or other electronic network activity information. This category may include: browsing history, search history, and information regarding interactions with an Internet Website, application, or advertisement. YES Geolocation data. This category may include: physical location or movements. NO Sensory data. This category may include: audio, electronic, visual, thermal, olfactory, or similar information. NO Professional or employment-related information. This category may include: current or past job history or performance evaluations. NO Non-public education information This category may include: education records directly related to a student maintained by an educational institution or party acting on its behalf (e.g., grades, transcripts, schedules, and student ID numbers). NO Inferences drawn from other personal information. This category may include: inferences drawn from the above information that may reflect your preferences, characteristics, predispositions, behavior, attitudes, or similar behavioral information. NO Sensitive personal information. This category may include any personal information that reveals: government-issued numbers, financial account information that allows access to an account, precise geolocation, racial or ethnic origin, philosophical or religious beliefs, union membership, third-party communications, genetic data biometric information for the purpose of identifying a consumer, health data, or sexual orientation. NO Please note that some of the categories of personal information described in California Law overlap with each other; for instance, your name is both an identifier and a type of data described in Cal. Civil Code 1798.80(e).
Personal information does not include publicly available information from government records or any deidentified or aggregated consumer information. In addition, California Law excludes the following from its scope: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and personal information covered by certain sector- specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. You may receive separate notices about your rights under other applicable laws as required by those laws.
Information Sold or Shared With Third Parties
In the preceding twelve (12) months, we have not sold your personal information for direct, monetary profit. We may, however, engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. For instance, our Platform may include social media plug-ins (such as the Facebook like button), widgets (such as the “Share” button), cookies, or other tools made available by third parties, such as social media companies, that may result in information being collected or disclosed between us and the third parties for various purposes, including to select and serve personalized advertisements to you and others. These third parties may set and access their own cookies, web beacons, and embedded scripts on your device, and they may otherwise collect or have access to information about you, including unique personal identifiers such as an IP address, and they may disclose that information to us. Your interactions with these third parties are governed by the third parties' privacy policies.
In the preceding twelve (12) months, we have sold or shared the following categories of personal information:
Category Business or Commercial Purpose Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered a “Sale/Sharing” Under California Law Identifiers. To provide you with personal advertising and content Advertisers and advertising networks Internet or other electronic network activity information. To provide you with personal advertising and content Advertisers and advertising networks Geolocation data. To provide you with personal advertising and content Advertisers and advertising networks We do not knowingly sell or share the personal information of consumers under 16 years of age.
Information Disclosed to Third Parties for a Business or Commercial Purpose
Kilroy may disclose your personal information to third parties for a business or commercial purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient both to keep that personal information confidential and not to use it for any purpose except in performing the contract. In the past twelve (12) months, we have disclosed the personal information categories identified in the “Information We Collect” section above to the following categories of third parties for a business or commercial purpose:
- Internally: We may disclose your personal information to our affiliates, business partners, employees, and other parties who require such information to assist us with establishing, maintaining, and managing our business relationship with you.
- With Our Service Providers or Contractors: We may disclose your personal information to our service providers or contractors (including third-party hosting providers) that provide services on our behalf, such as for email marketing, data analytics, promotions, newsletters, notices, and other communications, or that assist us in monitoring, improving, and hosting the Platform.
- With Our Business Partners: We may disclose your personal information to our third-party business partners that provide promotional offers, perks or other features to you via the Platform, including, for example, certain third-party products or services. Please be advised that the third party’s own privacy policy may apply to its use of your personal information.
- In the Event of a Business Transaction: If we are exploring or go through a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of our assets, we may disclose your personal information to a party or parties in connection with exploring or concluding such transaction.
- For Legal Purposes: We will disclose your personal information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury, or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant, or similar legal process; or if necessary to assert or protect our rights or assets.
- With Your Consent or Authorization: To anyone for whom you have authorized disclosure of information in this Privacy Policy.
- Other: We may disclose your personal information for any other purpose disclosed by us when you provide the information.
Your Rights With Regard to Your Personal Information
Please see Section VI “Your Communication Choices” for more information on how you can adjust your communication preferences.
California Law provides consumers with specific rights regarding their personal information. The following section describes your California Law rights and explains how to exercise those rights. Your California Law rights include the:
Right to Know or Access Specific Information and Data Portability Rights
You have the right to request that we disclose to you your personal information that we collected, used, disclosed, shared, and sold. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, disclosing, selling or sharing that personal information.
- The categories of third parties to whom we sold, shared, or disclosed that personal information.
- The specific pieces of personal information we collected about you.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us (or our service provider(s)) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Help ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes, including to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information; protect against malicious, deceptive, fraudulent, or illegal activity and help prosecute those responsible for that activity; or ensure the life and physical safety of natural persons.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
- 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 the deletion of information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation (including complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)).
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correct Inaccurate Personal Information
You have the right to request that we correct any of your personal information that we maintain about you that is inaccurate.
Right to Opt-Out of Sales or Sharing of Personal Information
We do not sell your personal information for direct, monetary profit. However, as described above, we may engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. If Kilroy sells your personal information to or shares it such information with third parties, you may have the right to opt-out of the sale or sharing of such information.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://kilroyrealty.com/privacy-request-form
Do Not Sell or Share My Personal Information
If you have an opt-out preference signal enabled (e.g., the Global Privacy Control), you will automatically be opted out of the sale or sharing of your information, but we may ask you to confirm your preference if you have previously consented to the sale or sharing of your Personal Information. Please also note that that if you have an account with us, but are not logged into your account, we may not be able to associate the browser or device information connected to your opt-out preference signal with you. If you would like for us to make this connection, you may submit additional information to us through the interactive webform linked above and in the “Do Not Sell or Share My Personal Information” link at the bottom of our website.
To download and use a browser supporting the opt-out preference signal, please visit https://globalprivacycontrol.org/orgs. If you choose to you the opt-out preference signal, you will need to enable it for each supported browser or browser extension you use.
Right to Non-Discrimination
We will not discriminate against you for choosing to exercise any of your rights. If you exercise certain rights, understand that you may be unable to use or access certain features of the Platform. Unless permitted by applicable law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Rights
To exercise the rights described above, please submit a consumer request to us by:
- Calling us at 833-319-2998
- Emailing us at dataprivacy@kilroyrealty.com
- Sending us a request through our online request portal
To exercise your right to know, access, delete, or correct your personal information as described above, we need to verify your identity or authority to make the request and confirm the personal information relates to you. Only you, your parent, guardian (if you are under 13 years or age), conservator, a person to whom you have given power of attorney pursuant to California Probate Code sections 4000 to 4465, or an authorized agent may make a verifiable consumer request related to your personal information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. We will only use personal information provided in your consumer request to verify your identity or authority to make the request. Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request if we cannot verify your identity or authority to make the request. You may only make a verifiable consumer request for your right to access twice within a 12-month period.
Response Timing and Format
Once we have verified a request from a California consumer, where required, we will confirm receipt of the request within 10 days and explain how we will process the request. We will make our best effort to respond to a verifiable consumer request within 45 days of its receipt. We may require an additional 45 days (for a total of 90 days) to process your request, but in those situations, we will provide you a response and explanation for the reason it will take more than 45 days to respond to the request. Our responses will include required information under California Law. For right to access requests, we will select a format that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process your verifiable consumer request unless it is manifestly unfounded or excessive.
Data Retention
We may retain all categories of your personal information described above for as long as needed to carry out the purposes described herein or as otherwise required by applicable law. Unless we are required or permitted by law to keep your personal information for a longer period of time, when your personal information is no longer necessary to carry out the purposes for which we process it, we will delete your personal information or keep it in a form that does not permit identifying you. When determining the retention period, we take into account various criteria, such as the nature of the use of the Platform, your general relationship with us, the impact on our ability to provide you the Platform if we delete your personal information, mandatory retention periods provided by law and the statute of limitations, and our use of your personal information for aggregated market research.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, send an email to dataprivacy@kilroyrealty.com or call us at 833-319-2998.