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CBRE Urban Photographer of the Year Contest Privacy Policy 
Effective Date 27/03/15 (last updated 06/11/18)

This Privacy Policy is made available by CBRE, Inc. and its affiliated entities (together, “CBRE”, “we”, “us”), and explains how CBRE collects, uses, transfers, and discloses personal data relating to participants in the CBRE Urban Photographer of the Year Contest (herein, “Contest”) and Contest website users. 

This Privacy Policy is not intended for use with all CBRE websites. For more information about your privacy on other CBRE websites, please refer to CBRE’s Global Web Privacy and Cookie Policy

We collect information from and about you.

CBRE will collect and may use data that you provide throughout the Contest entry and submission process, or when you contact us. We may also obtain information from third-parties, such as social media platforms. 


Contact information. We may collect your name, email address, country of residence and other contact information when you enter the Contest on our website. 

Demographic information. We may collect information about you, such as your age or gender, when you enter the contest or communicate with us. 

Usage Data. We may collect information about your browser, interaction with our website, or information about prior or subsequent site visits. 

Other Information that you voluntarily provide. We also collect information that you provide to us, including information that you may post on our websites and provide through Contest entries. We may also collect information that you voluntarily provide when contacting us, or from third party platforms.  
We use information as described here. 

Responding to your requests. We may use your information to fulfill your requests and respond to your feedback or questions. 

Communication. We may use your information to communicate with you about the Contest, including to notify you if you win a prize. We may also contact you about your entry, feedback, or to discuss this Policy or Contest websites. Additionally, we may contact you to regarding future Contests. CBRE has a legitimate business interest in communicating with Contest participants and website users.  

Service Improvement. We may use your information to improve our website and the contest, or to make our other services better. We may also use your information to customize your experience, or combine it with information obtained from third-party sources. 

Security. We have a legitimate business interest in using information collected during the course of the Contest, or from our websites, for the purpose of ensuring the security of the Contest, CBRE, CBRE property, or other participants. 

Marketing. We may use your information for marketing purposes, on the basis of your consent. We may send you information relating to the Contest or special offers, features, and website updates. These may include offers from third-parties. To manage this, please refer to the sections below. 

Compliance. We may use your information, as necessary, to comply with legal obligations or in exercise or defense of legal claims. 

We may share information with third parties. 


We will share information with third parties who perform services on our behalf. For example, we share information with vendors who send emails for us.  We may also share information with companies that help operate the contest. We may also share information with other internal lines of business and our consultants in furtherance of the contest. 

We will share information with our business partners. For example, we will share information with the third parties who co-sponsor the Contest. If you opt in, these partners may send you information about events and products by mail or email.     


We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests. We might share information when we are investigating potential fraud. This might include fraud we think has happened during the contest. 


We may share information with any successor to all or part of our business. For example, if part of our business was sold, we may give our user information as part of that transaction. 


We may share information for other reasons we may describe to you. 

We may transfer your information to other countries.

CBRE is a global business. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed, in countries other than the country in which the information was originally collected, including the United States and elsewhere that may have less stringent data protection laws than the country in which you initially provided the information. By registering for the contest or providing any personal information to us, you fully understand and unambiguously consent to the transfer and processing of such personal information in the United States and other countries or territories.

When we transfer your information to countries other than the country in which the information was originally collected, we will protect your information as described in this Policy and will comply with all applicable data protection laws in making such transfers. In particular, CBRE US affiliates are EU-US and Swiss-US Privacy Shield certified, and CBRE has executed EU Standard Contractual Clauses with respect to personal information collected in the European Economic Area and transferred to CBRE in the United States and elsewhere.

We are Privacy Shield certified.

CBRE complies 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 personal information that is collected by CBRE affiliates or corporate customers located in the European Economic Area and/or Switzerland and transferred to CBRE, Inc. and its wholly owned US-based affiliates, which include CBRE Global Investors LLC, CBRE GCS Inc. (Puerto Rico Employees), CBRE Clarion Securities, LLC, CBRE Security Services, Inc., CBRE Capital Markets of Texas, LP, CBRE HMF, Inc., CBRE Multifamily Capital, Inc., CBRE Capital Markets, Inc., Trammell Crow Company LLC, and CBRE Technical Services, LLC in the United States (“CBRE US”). CBRE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the terms in this Policy 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/. CBRE is subject to investigatory enforcement powers of the Federal Trade Commission as it relates to conformation with Privacy Shield requirements.

You have independent recourse to resolve Privacy Shield complaints.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, CBRE commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CBRE at: PrivacyAdministrator@cbre.com

CBRE has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by JAMS. For additional information on binding arbitration, visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

We will protect your information during onward transfers.

In the context of an onward transfer, CBRE has responsibility for the processing of personal information it receives under the Privacy Shield and subsequent transfers to a third party acting as an agent on its behalf. CBRE shall remain liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless CBRE proves that it is not responsible for the event giving rise to the damage.

You have certain choices about sharing and marketing practices. 


After you register for the contest, you can opt out of receiving our marketing emails. To stop receiving our promotional emails, email us at uphotography@cbre.com with a copy of the email you have received and with “Remove” in the subject line of your email. You can also follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions. 


You can control if we share information with third parties for their marketing purposes. To opt out of having us share your information with third parties for their promotional purposes, email us at uphotography@cbre.com


You can control cookies and tracking tools. Your browser may give you the ability to control cookies or other tracking tools.  How you do so depends on the type of tool.  Certain browsers can be set to reject browser cookies.  To control flash cookies, which we may use on certain websites from time to time, you can go here.  Why?  Because flash cookies cannot be controlled through your browser settings.  Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our sites may not work.  If you block or reject cookies, not all of the tracking described here will stop. To learn more about cookies on our site, you can also read our Global Web Privacy and Cookie Policy.

You have certain rights with respect to your personal information.

You may also request to review, access, correct, delete, port or object to our processing your personal information processed by us by making a request on CBRE’s data subject rights portal or submitting your request to dsr@cbre.com. CBRE’s Guidance on Making a GDPR Data Subject Request is available on the DSR Portal. Requesting deletion of your information or objecting to processing may affect your eligibility for prizes in the contest. 


These sites are not intended for children. 


Our sites and apps are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at uphotography@cbre.com. You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children's privacy on-line here.

We use standard and reasonable security measures. 

CBRE endeavors to protect the security of your personal information and your choices for its intended use. We use Secure Socket Layer or SSL technology to protect the transmission of sensitive personal information. We store your personal information on a secure server, and use procedures designed to protect the personal information we collect from unauthorized access, destruction, use, modification or disclosure.

Although we will take (and require our third-party providers to take) commercially reasonable security precautions regarding your personal information collected from and stored on the sites, due to the open nature of the Internet, we cannot guarantee that any of your personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the sites, you acknowledge that you understand and agree to assume these risks.


We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law.  


We may link to other sites or have third party services on our site we don’t control. 
If you click on a link to a third-party site, you will be taken to websites we do not control. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them nor does such links imply that the content of such websites represents the policies or positions of CBRE.  This policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. We are not responsible for these third-party practices. 


Feel free to contact us if you have more questions. 


If you have any questions about this Policy, please email us at uphotography@cbre.com


You can also write to us or call at: 
Urban Photographer of the Year

CBRE Limited

St. Martin’s Court

10 Paternoster Row

London

EC4M 7HP


Additionally, if you have any questions about CBRE’s use of your personal information or would like to contact a CBRE Data Protection Officer, please contact us at Privacy.Office@CBRE.com.

We may update this Policy. 


From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website.  Please check our site periodically for updates. 
© 2018 CBRE, Inc. All rights reserved.
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