(Public, Business Partners, and other non-Human Resources)
Skanska USA Commercial Development Inc. and its wholly owned subsidiaries (“Skanska”, “Company”, “we”, “us” or “our”) takes your privacy seriously. We want you to know how we collect, use, disclose, and retain your personal information.
Notice at Collection for California Residents: Company collects the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 5. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide Company with personal information about other California residents, you are responsible for providing this notice to them.
1. The categories of personal information we collect
2. The categories of sources from which we collect this personal information
3. The purposes for which we use your personal information
4. How we may disclose your personal information
5. How long we keep your personal information
6. Privacy rights for California residents
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We do not collect information from anyone under 13 years of age. The products and/or services we provide, together with our Sites, are all directed to individuals who are at least 13 years old. If you are under the age of 13, you are not authorized to use our services or our Sites.
Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Other web sites
Our services and Sites may contain links to web sites not operated or controlled by us (“Third-Party Sites”). The policies and procedures we describe here do not apply to Third-Party Sites. The links from the Sites do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those Third-Party Sites directly for information on their privacy policies.
1) THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT
- Identifiers, for example: real name, telephone number, license plate, postal address, e-mail address, and signature.
- Commercial Information, for example: residential history or monthly rent.
- Internet Activity Information, for example: information about your usage of our Sites or mobiles applications, such as the pages you viewed, the services and features you used or interacted with; your browser type and details about any links or communications with which you interacted; internet protocol (IP); browser plug-in types and versions; and operating systems and platform.
- Professional Information, for example: business contact information, title, professional memberships and affiliations, and employer/employing company.
- Financial Information, for example: payment card details and billing address.
- Sensory or Surveillance Data, for example: voicemails and recordings as described below in “User Content”, video surveillance footage when you visit one of our properties or projects.
- User Content, includes content you submit when you contact Skanska. This may include recordings you create, including audio recordings or voicemail you submit when you contact us.
- Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, e., date and time of the call or text (SMS or MMS) message and phone numbers.
- Inferences, for example: Skanska might infer your interests based on information you have asked us to provide about Skanska projects or initiatives.
- Household information, for example: when you complete a tenant or lease application, we may collect: residential history, including monthly rent or mortgage payments; household size; household type; family members; marital status; information about any pets; reason for moving; employment and income history; desired housing characteristics, and desired housing location or community.
- Preferences, for example: you might give us your size for personal protective equipment or t-shirt size for a giveaway.
- Information we may collect through Project mobile applications:
- Identifiers, for example: your name, building, and/or unit number when you submit service orders.
- Commercial Information, for example: when you make entertainment reservations for offerings at our properties, i.e., classes, events, sports tickets, tasting events; when you purchase food and other retail goods from retailers through the platform; level of electricity used when using the EV charger.
- Note on Inferring Characteristics: Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about you.
- Health information, for example: in the event of a construction injury/accident, Skanska may collect information about your hire date, injury status, type of injury, and health care provider information as needed to conduct an incident investigation; and COVID-19 information (e., diagnosis and vaccination status) for contact tracing and as required by law.
- Characteristics of Protected Classifications Under California or Federal Law, for example: disabilities if you request an accommodation.
Note on Sensitive Personal Information: Skanska only uses sensitive personal information as necessary to perform the services or provide the goods the average person would reasonably expect when requesting those goods or services, to detect data security incidents, to maintain the quality of our services, or for other purposes not granted the right to opt out under the California Privacy Rights Act (“CPRA”). In addition, Skanska does not infer characteristics from sensitive personal information.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Sites may not function properly.
We include small graphic images or other web programming code, called web beacons (also known as "pixel tags", “web bugs” or "clear GIFs"), on the Sites. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Rejecting cookies using browser settings may not stop web beacons from tracking you.
Tracking Across Time and Different Sites
The Sites track your online activities over time and across websites or online services on an individually identifiable basis. For example, we may serve you advertisements on other websites based on what appeared to interest you on our Site. We do not allow third parties to use our Sites to track your activities over time or across other websites.
Do Not Track Setting
The Sites currently respond to web browser “do not track” (DNT) signals or other mechanisms that indicate your preference for having information collected over time and across different web sites following your visit to our Sites. DNT is a preference you can set in your browser’s settings to let the websites you visit, including the Sites, know that you do not want the websites collecting your personal identifiable information. You can also visit https://allaboutdnt.com/ to learn more.
2) THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION
- You, for example, when you contact us or when you otherwise provide information directly to us.
- Service providers, for example, parking operators, property managers, analytics providers, IT, and system administration services.
- Automated technologies, for example, browsing activity collected by automated technologies on our Sites.
- Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Affiliated companies, for example, when a client of an affiliated company requests information about our properties.
- Marketing/advertising companies, for example, from analytics or marketing/advertising companies.
- Monitoring/recording technologies installed by Skanska, for example, video monitoring in common areas of Skanska facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
- Government or administrative agencies, for example, through the entitlement process.
- Acquired entity, if Skanska acquired another entity, Skanska might collect personal information from that entity.
- Other sources, for example, correspondence with local neighbors or community members.
- Public interest sources, for example, social media, job boards, public profiles and other public online sources.
3) THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
Conducting Our Business, including:
- To communicate with clients, customers, prospective clients/customers, vendors, suppliers, services providers, subcontractors, consultants and others with whom we have or are inquiring about establishing a business relationship.
- To carry out our obligations arising from any agreement that we have with, or concerning, you.
- To manage our business operations and administration of client relationships.
- To provide our services and fulfill transactions in connection with the acquisition, development, construction, leasing, management, operations, and divestiture of real estate holdings, developments, and properties.
- To create and administer accounts, complete transactions, and manage payments and billing.
- To engage through the entitlement process.
- To improve our products and services, develop new products and services, and conduct research on further improvements.
Support and Marketing, including:
- For customer support.
- To respond to any requests, queries, suggestions, feedback, or comments you may have.
- Where you have agreed to receive such information, to send you marketing information about our products and services, including notifying you of marketing events, promotions, and sweepstakes.
- To ensure our services are presented in the most effective manner for you and for your computer or other device from which you access our services.
- To perform operations to maintain the services, including to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
Monitoring, Security, and Compliance, including:
- To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
- To monitor compliance with our policies.
- To protect our business from security threats including, but not limited to, threats to our IT infrastructure.
- To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
- To protect the rights, property, or safety of Skanska, you, or others.
- In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Skanska or any of its subsidiaries or affiliates.
- To report suspected criminal conduct to law enforcement and cooperate in investigations.
- To exercise Skanska’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
- To comply with legal or regulatory obligations.
Incidental Purposes: Any incidental purposes related to, or in connection with, the above.
4) HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION
A. Disclosures Generally
Skanska discloses personal information as necessary for the purposes described in Section 3 above to the following categories of external recipients:
- Service providers and contractors: Skanska discloses your personal information to service providers and contractors for the purposes above to assist us in meeting our business needs and contractual and legal obligations. As an example, we provide our parking operator with your driver’s license information because we are obligated to let you in the building.
- Required disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
- Legal compliance and protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Skanska, our users, or others.
- Corporate transactions: We reserve the right to disclose and transfer your personal information, including your personal information:
- To a subsequent owner or co-owner.
- In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.
B. Disclosures for Business Purposes
Company may disclose each of the categories of personal information listed in Section 1, above, for the following “business purposes”, as that term is defined under the CPRA:
- Service providers: For the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in Section 3, above.
- Auditors, lawyers, consultants, and accountants engaged by Company: For the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on Company’s behalf.
C. Sales and Sharing
We do not sell or share your personal information, where “share” means disclosing personal information to third parties for cross-context behavioral advertising. Without limiting the foregoing, we have no actual knowledge that we sell or share the personal information of individuals of any age, including the personal information of children under 16.
D. Aggregated and Deidentified Information
We may aggregate and/or deidentify information, use it internally, and disclose it to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.
- “Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.
- “Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be data point that an unidentified visitor first entered the Sites through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.
5) HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We retain your personal information for the duration of the customer relationship with the Company, if any. We will retain personal information longer as necessary to comply with contractual, legal, administrative, procedural, or internal corporate retention requirements, for example, a litigation hold.
6) PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
a) Your California Privacy Rights
Subject to applicable law, California residents have the following rights:
- Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information and for information about Skanska’s collection, use, and disclosure of your personal information. Please note that the CPRA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, California residents generally just have a right to know categories, for example, categories of external recipients to which personal information is disclosed, but not the individual recipients.
- Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Skanska.
- Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Skanska, taking into account the nature of the personal information and the purposes of processing the personal information.
b) How to Exercise Your Rights
Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
- Call (877) 516-3385
c) How We Will Verify Your Request
If you submit a request through an adequately secure password-protected account that you created before the date of your request, we will use the authentication mechanisms in the account to verify your identity. Otherwise, we match personal data that you provide us against personal data we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal data), the more items of personal data we may request to verify you. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.
d) Authorized Agents
If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at
e) Company’s Non-Discrimination Policy
Skanska will not unlawfully discriminate against you for exercising your privacy rights under the California Privacy Rights Act.