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THE RELATED COMPANIES PRIVACY POLICY

Last Updated: February 28, 2019

The Related Companies, L.P., along with its affiliates and subsidiaries (collectively referred to as “Related”, and also referred to herein as “we”, “us” or “our”) is committed to the privacy of our residents, website visitors and other individuals who communicate with us or use our services.  We operate this website, and we wish to help you better understand the information we collect, how we use it and disclose it.

This following Privacy Policy applies to the information that we collect and use about you when you access or use any of Related’s sites (including www.related.com), mobile application or other online or mobile service that links to or otherwise presents this Privacy Policy to you (collectively, the “Sites”). 

We refer to all of the above as the “Services”.  By accessing and using the Services, you are consenting to the collection, use, disclosure and other handling of your information as described below. If you do not agree to this Privacy Policy, please do not use the Services.

We may also refer in this Privacy Policy to information we collect in other ways; however, this Privacy Policy does not govern all of the ways that we collect information about you offline, such as when you visit a Related building or other property, sign in on an open house/visitor sheet, apply for employment by other means than through a Site, or use our WiFi services.

  • Information we collect
  • How we use your information
  • How we disclose your information
  • Online analytics
  • Online advertising
  • Your rights and choices
  • Security
  • Data retention
  • Third-party links
  • Note to parents and children
  • Notice to California residents
  • Changes to this Privacy Policy
  • How to contact us

1. INFORMATION WE COLLECT

We collect information in multiple ways, including (a) information you provide directly to us; (b) information that is automatically collected from you when you navigate our Sites and use our Services, such as from your browser or device; and (c) from third parties.  We may combine all of the information we collect about you from these various sources.

a. Information you provide to us

You may provide information directly to us, in various ways. For example, we collect information from you through:

  • Requests or questions you submit to us via forms or email, such as signing up for our newsletter
  • Your communications and dealings with us (including on our Sites, at in-person events such as open houses, over the phone and by email)
  • The Services that you use and the purchases that you make from us
  • Employment applications and any related information you provide to us
  • Lease applications and related information that you provide to us
  • Uploads or posts to the Services
  • Requests to receive electronic newsletters or to receive information about events
  • Requests for maintenance support and assistance
  • Log-in credentials, if you create an account on any of our Sites
  • Billing information such as payment card number and expiration date; or bank account and routing number (which may be collected by our payment processor or similar service provider)
  • Your participation in a sweepstakes or contest sponsored or co-sponsored by us
  • Information about your maintenance interactions with us
  • User-generated content you post in your property’s residential forum
  • Any other information you choose to directly provide to us in connection with your use of the Services.  This may include, for instance, information you provide in connection with a reservation, appointment, purchase or communication with or through the Services.

Information about others. If you provide personal references in connection with your employment application, we use the information you provide to contact the individual to evaluate your employment application. If you provide personal references in connection with a lease application, we use the information you provide to inform the individual that we are processing your application and if accepted, to provide the individual with a referral bonus, if applicable.

User name. Some Services, such as our Resident Circle, Related Connect, and any bulletin boards or forums we offer, will require you to register, create an account and create a user name and password.  

WiFi Services.  We may offer WiFi Services, whether ourselves or through a business partner.  When we do this, those WiFi Services will be governed by separate Terms of Use and Privacy Policies, which will be made available through those services.

b. Information we collect through automated means

Device and usage information. We also collect certain information that is automatically generated by the computer, browser or device (including mobile devices or tablets) that you use to access or navigate our Services. As further described below, we may collect, combine and analyze information such as: (i) IP address, location information, unique device identifiers including mobile ad IDs, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (ii) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about your visit to the Services, the frequency of your visit to the Services, error logs, and other similar information. As further described below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and other tracking technologies. We also collect data about your visit(s) and use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A “cookie” is a standard software feature that is placed on your computer when you visit a website and assigns you a unique, random number. The cookie by itself does not personally identify you, it identifies the computer or device that you use to visit a Site and enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Sites you have visited; (iv) enhance your user experience by delivering content and advertisements specific to your inferred interests; (v) perform searches and analytics; and (vi) assist with security administration functions.  We may use local shared objects (including flash cookies) to store your preferences, e.g., for volume control or to personalize content, ads, or video features.  (Flash cookies are somewhat different from other cookies because of the amount and type of data and how the data is stored.)

We also may use tracking pixels (sometimes referred to as web beacons or clear GIFs), which are tiny electronic tags embedded in websites, online ads, and/or email, and that are designed to access cookies and provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising. We also may include web beacons in email messages, newsletters, and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we adopt additional technologies, we may also gather additional information through other methods.

You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). To manage Flash cookies, please click here. Please note that by blocking any or all cookies, you may not have access to certain features or offerings on our Services.  

We describe in Section 5, titled “INTEREST-BASED ADVERTISING AND YOUR OPT-OUT CHOICES.” how we use cookies and similar technologies for interest-based advertising, and how to opt-out of that type of advertising.

Location information. When you use the Services, we (and our service providers) may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device.  For instance, we or our service providers may collect precise location information (usually expressed in terms of latitudinal and longitudinal coordinates) through your mobile application (such as Related Connect), including when the app is operating in the background.   We likewise may collect precise location information when your mobile device is near a physical “beacon” system that we or our vendor operates. You may also prevent this by disabling location information in your device settings.

We may use your location information to provide customized services, content, promotional offers and other information that may be of interest to you. If you no longer wish for us and our service providers to collect and use location information, you may disable the location features on your device. Please see your device manufacturer settings. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services.

In addition, we (or ad and data platforms we work with) may sometimes collect mobile advertising identifiers in order to customize ads or content to you, when you are on  your device or online.  To “opt out” of this type of advertising, please see the instructions in Section 5, titled “INTEREST-BASED ADVERTISING AND YOUR OPT-OUT CHOICES.”

c. Information from third parties

We may collect information about you from other sources, including consumer credit reporting agencies to evaluate your lease application and other third parties, such as marketers and market research firms. We may combine the information we collect from third parties and combine it with information that we collect from you or through your use of the Services.

2. HOW WE USE YOUR INFORMATION

We may use your information for various purposes, depending on the type of information we have collected from and about you and the specific Services you use, in order to:

  • Respond to your requests for information
  • Provide you with updates and information about a Related property, or a service we provide
  • Verify your identity and for fraud prevention
  • Process your payments
  • Analyze and evaluate your employment application
  • Analyze and evaluate your lease application
  • Help us better understand your interest and needs to improve the Services
  • Engage in analysis, research and reports regarding the use of our Services
  • Provide you with content recommendations
  • Tailor the content and information that we may send or display to you, retarget content to you through our software application and elsewhere, and to otherwise personalize your experiences while using our Services
  • Tailor advertising or promotions to you when you use the Services or interact with other services, apps or content.  These ads and promotions may be for our Services, or for other services and products that may be of interest to you.
  • Provide, manage and improve the Services, and test and create new products, features and services
  • Understand and resolve any technical and security issues reported on our Sites
  • Comply with the law and protect the safety, rights, property or security of Related, the Services and the general public
  • Enforce any legal terms that govern your relationship with us or your use of the Services

Please note that we may combine information that we collect from you and about you (including automatically generated information) with information that we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.

Aggregate/Anonymous data. We may aggregate, de-identify and/or anonymize any information collected through the Services so that such information is no longer linked to your personally identifiable information (such as your name, address, phone number or email address). We may use and share aggregated and anonymized information for any purpose, including without limitation, for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners and others.

3. HOW WE DISCLOSE YOUR INFORMATION

We may disclose and/or share your information under the following circumstances:

  • Service Providers: We  disclose your information to third parties who perform services on our behalf, including without limitation billing, marketing, market research, data storage (such as hosting our information database), data enhancement (such as to learn more about our customers), billing and payment processing, data analysis and processing (including processing online and mail donations and credit card payments), customer support, security and tech and operational support, email services and legal services.
  • Legal Compliance and Protection of Relatedand Others. We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (i) to comply with legal process; (ii) to enforce this Privacy Policy, or other contracts with you, including investigations of potential violations thereof; (iii) to respond to claims that any content violates the rights of a third-party; (iv) to respond to your requests for customer service; and/or (v) to protect the rights, property, or personal safety of Related, our agents and associates, and the public or to prevent harm to any person. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and other similar purposes.
  • Business Transfers. We may disclose your information in the event that we undergo organizational restructuring (e.g., establish a subsidiary or merge with another entity), or an acquisition by another entity. In such transactions (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of our assets are sold or transferred to a third-party, your information would likely be one of the transferred business assets.
  • Public Forums. Certain features of our Services allow you to publicly share comments with other users. Any information that you submit through such features is not confidential and can be used by us for any purpose. 
  • Affiliated or Associated Companies. We may share information we collect with our affiliated or associated entities and, in some cases, with prospective affiliates.
  • Aggregated/Anonymous Information. We may share aggregated or de-identified information about your use of the Services, such as by publishing a report on usage trends.
  • Marketing and Advertising.  We may share information with various service providers and platforms in order to market to you, or to co-market to you with other companies.  For instance, if we believe that you would enjoy particular types of services, experiences, or events, we might work with third parties to curate, tailor and deliver those communications.  We may also use aggregated or de-identified datasets that we create from your information in order to market to you or others, as further described in Section 5, titled “INTEREST-BASED ADVERTISING AND YOUR OPT-OUT CHOICES.”
  • Consent. Without limiting the other ways we may use your information, we also may disclose your information to any third parties based on your consent to do so.

 

4. ONLINE ANALYTICS

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described above will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Services, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To learn more about Google’s privacy practices, please review the Google Privacy Policy; to prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

If you receive email from us, we may use certain tags or pixels to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

5. INTEREST-BASED ADVERTISING AND YOUR OPT-OUT CHOICES

“Interest-Based” Advertising.  We may allow third parties, such as ad exchanges, web analytics vendors and data analytics vendors to integrate with the Services to deliver relevant content and ads on the Services, and on other websites you visit and other applications and devices you use.  When these ads are based on your activities across various websites or apps, over time, or tied to other information about you, this is sometimes known as “interest-based” advertising. 

These third parties (or we) may use cookies, web beacons, pixel tags and similar technologies to collect information about your interactions on our Services and elsewhere on the internet or in apps (e.g., search and click stream information, browser and device type, time and date, cookie and session ID, and the identity or type of ads clicked or scrolled over).  They (or we) may use this information to display ads for Relatedwhen you use our Services or other websites or applications. These third parties may tie the data collected with information such as your name, email address, mailing address, and other demographic and behavioral information about you; we or they may create a “hash” of personal information (for privacy purposes), which may be associated with cookies or device identifiers.  

We may also engage in “cross-device” advertising.  Cross-device advertising is when these third parties (or we) tie the device identifier or IP address (or other information) associated with your current device to device identifiers associated with other devices that you may use (e.g., your computer, tablet and phone) in order to measure and target advertisements tailored to your interest across devices, and to try to identify you across multiple browsers or devices. 

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device to access the Services by such non-affiliated third parties.

Opting Out of Interest-Based Advertising.  If you are interested in more information about “interest-based” advertising and how you can generally control cookies and other tracking devices from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.  To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ad Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements -- for example, ads based on the particular website that you are viewing (i.e., contextually based ads).  Also, if your browser (like some Safari browsers) is configured to reject “opt out” cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.   

Mobile and “Cross-App” Advertising. When using our mobile app or other apps, you may also receive tailored “in-app” advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics, which (as in interest-based advertising) may tailor ads based on your activities across apps or across different locations. Each operating system -- iOS for Apple devices, Android for Android devices and Windows for Microsoft devices -- provides its own instruction on how to prevent the delivery of interest-based in-app ads. We do not control how the applicable platform operator allows you to control interest-based in-app advertisements; thus, you should contact the platform provider for further details on opting out.. You may review the support materials and/or the device settings for the respecting operating systems to opt-out of tailored in-application advertisements.

Do-Not-Track (“DNT”).  DNT is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.

6. ADDITIONAL MARKETING CHOICES YOU HAVE

You have certain choices about how we use your information. You can opt-out of or unsubscribe from our newsletters and promotional emails by clicking the “unsubscribe” link they contain, though please note that we may continue to send you emails relating to administrative and transactional interactions with us, such as emails about maintenance updates.  If you have registered for an account with us through the Services, you can also update certain information and your email communications options by logging into your account and updating your account information and communications settings.

7. SECURITY

We take technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, or method of electronic storage, is absolutely secure. Therefore, while we strive to protect your information, we cannot guarantee its absolute security.

8. DATA RETENTION

We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

9. THIRD-PARTY LINKS

Our Services may include links to third party websites, applications and services.  We do not control those sites or services and are not responsible for the content or practices of those sites or services. If you choose to use these sites or services, any information you provide to that site or service will be governed by the privacy policy of the operator of the site you are visiting or the services you are using. We encourage you to review the privacy policy of any site or service that you use.

10. NOTE TO PARENTS AND CHILDREN

The Services are not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are the parent or guardian of a child under 13 who has provided her or his information to us, please contact us at privacypolicy@related.com and we will seek to remove that information.

11. NOTICE TO CALIFORNIA RESIDENTS

California law (Cal. Civil Code section 1798.83) gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes.  We do not share personal information of California residents with external third parties for their direct marketing purposes, as those terms are defined in that law, but we may share personal information of California residents with affiliated entities for their direct marketing purposes.  To receive a list of our affiliated entities with which we have shared your personal information in the prior calendar year, please contact us at privacypolicy@related.com

Mailing Address:

Attention:  Legal Department
60 Columbus Circle
19th Floor
New York, NY 10023

12. CHANGES TO THIS POLICY

This Privacy Policy may be modified from time to time as our business practices and legal requirements evolve. If this Privacy Policy is modified, we will provide notice of the change by posting the updated Privacy Policy on the applicable Sites, and we will include the effective date of the update. If you are a California resident and would like to request this information, please submit your request to privacypolicy@related.com.

13. TRANSFERS OF PERSONAL DATA

As Related works with global companies and technologies, we may transfer your personal data outside of the country from which it was originally provided.  This may include transfers to third parties, such as service providers or affiliated entities who are located outside the EU, where data protection laws may not offer the same level of protection as those in the EU. 

When we transfer personal data outside of the EU, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. Our transfers of your Personal Data are safeguarded by data processing agreements incorporating the European Standard Contractual Clauses.  You may request a copy of the relevant portions of such agreements by contacting us using the information below.  

14. HOW TO CONTACT US

If you have any requests, questions, comments, or concerns regarding our Privacy Policy or practices, please contact us as at privacypolicy@related.com.