Privacy notice

Introduction

Kennedy-Wilson Properties, Ltd. (“KWP,” “Kennedy Wilson Properties,” “Kennedy Wilson Property Services,” “Kennedy Wilson Brokerage,” “Kennedy Wilson Management,” “we,” “us” or “our”) respects the privacy rights of individuals. We are committed to your right to privacy and handling personal information responsibly and in accordance with applicable law. This privacy policy (the “Privacy Policy”) explains how we may collect, share, use and protect information when you visit or use this website www.kennedywilsonservices.com (the “website”) and online services that include links to this Privacy Policy. This Privacy Policy does not apply to information collected by us offline or 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 website.

As you review this Privacy Policy, here are a few general principles to keep in mind:

Our website is intended for users in the United States only. If you visit our website or use one of our online services, your information may be transferred or processed in the United States.
If you are a California resident, you may have rights under the California Consumer Privacy Act of 2018 (the “CPPA”). Please see “Additional Information for California Residents” below.
None of our websites or online services are intended for or directed at children under 13 years of age. No one under 13 may provide any personal information to or on our website and we do not knowingly collect personal information from children under 13. We do not sell or disclose the personal information of anyone we know is under age 13 in compliance with Children’s Online Privacy Protection Act. If you are under 13, do not use or provide any information on this website.
Our social media websites or pages may have additional terms about the privacy of your information. Please review the privacy policy for the specific online service you are using.

Information We Collect

Personal Information You Give Us

When you choose to contact us, register for an event, or request e-mail alerts or other news or information about us, a property, an investment, or other services we provide, we may receive information that can identify you or your business and include such items as your title, name, email, phone number, contact details, postal address, your organization, country of residence, occupation, role, and preferences. Additionally, if you contact us via email, we may keep a record of that correspondence and the information you provide and any amended information you provide when responding to our emails including your title, name, contact details, and changes to your contact preferences.

Applicants for Employment

If you apply for employment with Kennedy-Wilson Properties, Ltd., we collect information you provide to us when you complete and submit a job application using the careers section on our website, including your resume, and any information you may provide to us as a follow-up to your application. [We may also collect information about you from vendors and service providers that we work with in the application process, such as vendors that process or review applications, that suggest candidates for us, or that assist with an applicant’s potential relocation.]

We may use the information we collect, in order to:

process and evaluate an applicant’s application, qualifications, and credentials for employment with us;
contact applicants regarding the status of their application for employment;
assist with the onboarding of an applicant into employment;
conduct internal research;
conduct background checks;
monitor our recruitment initiatives and equal opportunities policies;
determine an applicant’s need for special accommodations;
evaluate an applicant’s legal ability or capacity for employment;
detect security incidents, protect against malicious, deceptive, fraudulent, or otherwise illegal activity; and
determine the terms of an applicant’s potential employment with us.

We do not sell your personal information. However, we may share your information with our affiliates and with service providers who assist us in the application process. For example, we may share your information to conduct background checks, coordinate relocations, or utilize executive search vendors, or vendors who otherwise process applications. We may also share your information to satisfy any applicable law, regulations, subpoenas, court orders, warrants, governmental requests, or legal process if in our good faith opinion such is required or permitted by law. We may also share your information with a third-party performing audit, legal, operational, or other similar services for or on behalf of Kennedy-Wilson Properties, Ltd. Moreover, we reserve the right to disclose and transfer the information we collect: (i) to a subsequent owner, co-owner, or operator of the website or associated databases; or (ii) in connection with the negotiation, planning, or completion of a corporate merger, consolidation, restructure, sale of substantially all of our shares or assets, or other corporate change.

Usage and Other Information We Automatically Collect About You

When you visit our website, we may use automatic data collection technologies to collect and log certain information about your equipment, browsing actions, and patterns, including details of your visit to our website, (e.g., traffic data, logs, other communication data, and resources that you can access and use on our website) and information about your computer or device and internet connection (including, but not limited to, your IP address, operating system, browser type, broad geographic location (e.g. country or city-level location), mobile network information, your mobile operating system, and the type of mobile browser you use).

Additional Sources of Information We May Collect About You

We may also collect information about you from additional online and offline sources or commercially available third-party sources (e.g., credit reference agencies; law enforcement authorities; etc.). Additionally, if you choose to contact us regarding our certain of our services or a property or request other information about Kennedy-Wilson Properties, Ltd. and our services through a mobile application or one of our websites, we may receive information that can identify you or your business and include such items as your title, name, email, phone number, contact details, postal address, your organization, country of residence, occupation, role, and preferences. We may collect information such as unique device identifiers for your mobile device and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information, such as precise geo-location information.

Use of Information

If permissible under applicable laws and regulations, we may use the information discussed above in several ways, such as:

Marketing/prospecting: communicating with you via any means (including email, telephone, text message, social media, or in-person, etc.); and maintaining and updating your contact information where appropriate
Operation of our websites: operation and management of our websites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our websites
IT operations: management of our communications systems; operation of IT security; and IT security audits
Financial management: sales; finance; corporate audit; and vendor management
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details to our electronic systems, if applicable)
Investigations: detecting, investigating, and preventing breaches of our corporate policies; criminal offenses; and violations of other rules, regulations, or laws
Legal compliance: compliance with our legal and regulatory obligations under applicable law
Legal proceedings: establishing, exercising, and defending our legal rights
Improving our services: identifying issues with existing services; planning improvements to existing services; and creating new services
Risk management: audit, compliance, controls, and other risk management
Fraud prevention: detecting, preventing and investigating fraud

Additionally, we may use your information for any other purpose disclosed by us when you provide the information or with your consent. We may also use data that we collect on an aggregated or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.

We do not sell your personal information. However, we may disclose your personal information to a third party for a business purpose as described in this Privacy Policy.

Disclosure of Information

We may disclose your personal information to:

you and, where appropriate and with your consent, your family, your associates, and your representatives or any other person;
to our group companies and affiliates;
to third party services providers, suppliers, vendors, and partners that assist in providing our services, and other services to you; or
to any competent law enforcement body, regulatory, government agency, court, or other third parties where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish, protect or defend our legal rights, or to protect the interests of our customers or users of our website. This includes exchanging information with other companies and organizations for fraud protection.

Understanding Cookies

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why and how you can control Cookies, please see our Cookie Policy.

Linking to Third-Party Websites

We may provide links to websites that are owned or operated by other companies (“third-party websites”) and our Privacy Policy does not apply to these third-party websites. When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices. You should familiarize yourself with the privacy policy, terms of use, and security practices of the linked third-party website before providing any information on that website.

Security

We have implemented security policies, appropriate organizational and technical measures to protect the information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted through our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Updating your Information

You have the right to opt-out from marketing communications we send you at any time. If you wish to withdraw your consent to receive marketing materials, this can be done by:

updating your preferences on your online account, if you have one;
clicking the unsubscribe link on any emails we send you; or
emailing us at privacyKWP@kennedywilson.com

If you withdraw your consent, this will not affect our rights to have sent you marketing material before your withdrawal, but we will not send any further marketing.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise.

California Consumer Privacy Act Disclosure

The CCPA provides eligible California residents with specific rights with respect to our collection, retention and use of personal information. The following California Consumer Privacy Notice, which supplements this Privacy Policy and applies solely to eligible residents of the State of California (“consumers” or “you”) as of January 1, 2020.

Rights for California Residents

If you are a California resident you may have certain rights under the California Consumer Privacy Act (the “CCPA”) (Cal. Civ. Code §1798.100 et seq.) regarding your personal information, including:

the right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months;
the right to request, on legitimate grounds, deletion of your personal information that we collected;
the right to have someone you authorize make a request on your behalf; and
the right not to be discriminated against for exercising any of these rights.

To exercise one or more of your rights, you, or someone you authorize, may email us at privacyKWP@kennedywilson.com. We also must provide in this online disclosure certain details about our collection and handling of categories of personal information. The information that follows shows the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, and how we use and disclose it.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity, and understand and respond to the request. A California resident can empower an “authorized agent” to submit a request on his/her behalf. We will require the authorized agent to have a written authorization confirming that authority.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Verifying Your Identity

Once you submit your verifiable request, we will verify your identity by matching the information you provided us with information in our systems. If you submit a request to know specific pieces of personal information or a request to delete certain information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request. If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of personal information that we have collected about you.

We will generally avoid requesting additional information from you for verification. However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes. We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CCPA.

Generally, if we are unable to verify your identity, we will deny your request and inform you of our inability to verify your identity and explain why we were unable to do so.

Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period.

Personal Information

Categories of Personal Information

Personal identifiers, including those listed in other California statutes: Name; telephone number; email address; postal address; account name; online identifier; device identifier; IP address
Characteristics of protected classifications: date of birth/age; gender; military or veteran status; marital status; nationality; citizenship; request for leave
Professional or Employment: title; salary; employment files; references
Education information: details of your education and qualifications
Financial details: bank account numbers; accountholder name and details; transaction details
Internet or other electronic network activity information: browsing history, search history, information regarding your interaction with a website, application, or advertisement
Geolocation data: any information used to identify your physical location
Communications, recordings, images: audio, electronic, visual

Our Sources of Personal Information

Categories of Sources from which we Collect Personal Information

We collect or obtain your personal information when you provide it to us when registering details requesting news or information about us, a property, an investment, or other services or when contacting us via an online contact form.
We collect or obtain your personal information from additional online and offline sources or commercially available third-party sources.
We collect or obtain your personal information when you apply for a job using the careers section on our website, including your resume.
We collect or obtain your personal information when you visit our website. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

Use of Information

Business and Commercial Purposes for Use of Personal Information

Marketing/prospecting: communicating with you via any means (including via email, telephone, text message, social media, post, or in-person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate
Operation of our websites: operation and management of our websites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our website
IT operations: management of our communications systems; operation of IT security; and IT security audits
Financial management: sales; finance; corporate audit; and vendor management
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems)
Investigations: detecting, investigating, and preventing breaches of policy, and criminal offenses, in accordance with applicable law
Legal compliance: compliance with our legal and regulatory obligations under applicable law
Legal proceedings: establishing, exercising, and defending legal rights
Improving our services: identifying issues with existing services; planning improvements to existing services; and creating new services
Risk Management: Audit, compliance, controls, and other risk management
Fraud prevention: Detecting, preventing and investigating fraud

Disclosure of Information

Categories of Third Parties to Whom Personal Information is Disclosed

You and, where appropriate, your family, your associates, and your representatives or any other person with your consent;
To our group companies and affiliates;
To third party services providers, suppliers, and partners that assist in providing our services, and other services to you;
To any competent law enforcement body, regulatory, government agency, court, or other third parties where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person. This includes exchanging information with other companies and organizations for fraud protection

Sale of Personal Information

We do not offer an opt-out from the sale of personal information because we do not engage in the sale of personal information as contemplated by the CCPA. We share personal information with other businesses for a business purpose as described in our Privacy Policy. While we may benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information. As noted in our Privacy Policy, none of our websites or online services are intended for or directed at children under 13 years of age. No one under 13 may provide any personal information to or on our website and we do not knowingly collect personal information from children under 13. Neither our website nor our services are directed at children under age 13 and we do not sell or disclose the personal information of anyone we know is under age 13 in compliance with Children’s Online Privacy Protection Act.

Changes to this Disclosure

We may change this disclosure from time to time. When we do, we will let you know by appropriate means such as by posting the revised disclosure on our CCPA website with a new “Last Updated” date. Any changes to this disclosure will become effective when posted unless indicated otherwise.