Privacy Policy

Effective Date: April 24, 2024

Introduction

Welcome. You have arrived at a website provided by Waterside Group and/or one of its divisions, affiliates, subsidiaries, or joint ventures. We respect your privacy and want to protect your personal Information.

This Privacy Policy governs the Company’s family of brand websites, their subdomains, and all portals, applications, products, services, events, and any interactive features or other services that post a link to this Privacy Policy (each, a “Site”), as well as Related Connect, Related 360 Life, Related Office, the Hudson Yards app, CityPlace Rewards app and any future developed apps by Related (the “Apps”). This Privacy Policy also applies to Information (including the “Personal Information” defined below) that we may collect from you in person at our physical locations (each a “Location” or collectively, “Locations”) or properties that we own or manage (each a “Property” or collectively, “Properties”), via phone calls or other communications with our representatives, by using Company-provided Wi-Fi, by purchasing tickets at Locations, at Company-sponsored events, or in any other instance when you contact us. We refer to all of the above as our “Services.”

All references to “you,” “your” or “User” in this policy means the person who accesses, uses, or registers for our Site or our Services. If you use or access our Site or Services on behalf of a company or organization, such company or organization will also be considered a party to this Privacy Policy and any agreements you make.

If you voluntarily provide your Information when interacting with our Sites or Apps, applying to lease or buy a Property managed or owned by us, visiting one of our Locations, or otherwise using our Services, we will consider that your agreement to our collection, use, and disclosure of your Information as set forth in this Privacy Policy.

By using our Sites or Apps, contacting us to inquire about our Services or Properties, or visiting our Locations, you consent to our Privacy Policy and agree to our Terms of Use.

In this Privacy Policy, we tell you what Information we collect from you, the sources from which we get that Information, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that Information, and what choices you may make about that Information. These choices may differ depending on where you live, so please check the location-specific decisions for your state or country of residence. If you have questions about this Privacy Policy, contact us at marketing@watersidegroup.com

This Privacy Policy does not apply to any products, services, websites, or content offered by third parties (“Third-Party Services”), governed by their respective privacy policies. If you click a link for these Third-Party Services, please review the corresponding privacy policy and terms of use for the Third Party, as we are not responsible for their information collection practices.

What Information We Collect

The type of Information we collect depends on how you interact with our Site and our Services.

Information You Provide to Us

In connection with the Services we provide, we may ask you to provide us with certain Information, including:

contact information, like your first and last name, email address, home or business address, other shipping or billing addresses, telephone number, or mobile number;
consumer information, like a username, your purchase and/or service history, your preferences or a consumer profile;
financial Information needed to complete a transaction with us, including credit card or debit card number, banking information, or other financial Information;
employment or tenancy information, such as a driver’s license, social security number, passport number, your birthdate, your educational Information, your prior employment, your military or veteran status, your marital status, and Information to validate your right to work for the Company, including immigration status and/or state or federal licensing information, if applicable. This may include categories of Information that is designated as “Sensitive Personal Information” under applicable law;
demographic Information, such as your country, state, or county of residence or business operation (“Demographic Information”); and
other Information that could reasonably be used to identify you personally or identify your household or device;

Separately, you also may provide us with the following Personal Information when you interact with us or the Services:

Social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Site and other service (such as apps, tools, payment services, widgets and plug-ins offered by social media services like Facebook and Twitter) or posted on social media pages (such as our social media page or other pages accessible to us);
recordings of your voice, as may be contained in customer service phone recordings kept for quality assurance purposes or training (you will always be notified in advance if we record our calls with you for quality assurance purposes);
your image or likeness as captured on audiovisual recordings in the public spaces of our Locations;
your biometric Information (such as a handprint or fingerprint) if used for providing secure access to one of our Locations; and/or
your geolocation information if you have enabled your device’s location services or if you type in your address.

Additionally, we may obtain other identifying Information from you where you expressly provide us with the Information. This Information could come from interviews and telephone calls with you, letters, emails or other communications from you, Information from your referral or reference sources, information provided via web forms or inputs/uploads into our Site or at events we attend or sponsor, documents you have provided to us, and employment applications.

These items are collectively referred to in this Privacy Policy as “Personal Information.”

We may collect this Personal Information when you:

Request information from us via forms or emails, such as signing up for our newsletter or requesting Information about a Location or a future Location;
Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Sites, products and/or Services (including at in-person events such as open houses, or by phone or email);
Register and create an account on our Site;
Sign up or request to be placed on our mailing and/or email marketing lists;
Sign up for free Wi-Fi at one of our Locations;
Purchase tickets, products or Services from us;
Apply for employment with one of our brands;
Apply for a lease or to purchase a unit at one of the Properties that we own or manage;
Are a resident or visitor of one of the Properties we own or manage;
Use any of our Apps;
Request maintenance or concierge support and assistance, or inquire about your maintenance or concierge interactions with us;
Provide billing information to us;
Post user-generated content in your Property’s residential forum;
Participate in a sweepstakes or contest sponsored or co-sponsored by us; and/or
Otherwise interact with the Sites or our representatives.

Your decision to provide us with Information is voluntary. Still, if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s or App’s features or our Services, including ordering products or Services, submitting inquiries, or signing up for newsletters or marketing lists.

Information that Is Automatically Collected

In addition to the Information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain Information when you visit or interact with the Site or use Wi-Fi at any of our Locations (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site or with Wi-Fi at one of our Locations. Usage Information may include:

Your IP address, MAC Address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier (“Device Identifier”);
Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
Referring and exiting web pages and URLs;
The areas within our Site that you visit and your activities there, including remembering you and your preferences;
Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
Your Device characteristics; and
Certain other Device data, including the time of day you visit our Site.

For location information, we may use this 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 or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer’s settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

Our Use of Cookies and other Tracking Technologies

As part of our automatic collection of Device or Usage Information, we may use various methods and technologies to store or collect such Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store Information on your Device. Our Site may use HTTP cookies, HTML5 cookies, and other types of cookie technology to store Information on local storage.
Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect Information about your interactions with the Site, such as the links you click on.
ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
Browser Fingerprinting. Collection and analysis of Information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including:

To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of cart or payment functionality;
To facilitate navigation, display data more effectively, collect statistical data, personal your experience while using the Site, and recognize your computer to assist in your use of the Site;
To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
To deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements and/or content.

You can get more Information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our “Ads and Information About You” section below.

Information from Third Parties

We may collect Information about you from other sources, including consumer credit reporting agencies or background check vendors, in order to evaluate your lease application and/or application for employment. We also may obtain Personal Information about you if you are listed as a dependent or beneficiary of a Related employee or tenant or owner. We may also obtain Information about you (e.g., an email address), if another User has forwarded Information about our Services to you. We also may also obtain Information about you from marketers and market research firms. We may combine the Information we collect from third parties with Information that we have collected from you or through your use of the Services.

In addition, the Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing Information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). We also may provide links to allow third parties to process credit card and/or electronic payments. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Site.

Why We Collect Information

We use the Information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our Site, Apps or Services, including to:

Provide you with maintenance and/or concierge services;
Analyze and evaluate your lease and/or purchase application;
Process your purchases of, or requests for, products and services;
Create and verify user accounts;
Facilitate the functionality of our Site and Apps, including payment-related functionality; and
If you have given permission for location sharing, you can customize experiences and personalize them when you are on our site, using our apps, or in and around our locations or properties.

To Communicate with You

We process certain Information to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including to:

communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
respond to your customer service inquiries and requests for Information;
post your comments or statements on our Site or Apps;
provide you with updates and Information about a Related Property, or a service we provide;
send you marketing information about Related and our affiliated entities;
send you email communications such as electronic newsletters about our products, Services, events, and promotions;
implement your communications preferences, such as sharing Information with our business partners so that they may email you about their promotions, products and initiatives; and
provide important safety information.

For Improvement of Our Site, Apps or Services

We want to ensure that our Site, Apps, and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

maintain, improve, and analyze our Site, Apps or Services; and
detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site, Apps, and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment

We use your Personal Information to evaluate your application for employment or administer employment benefits.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

When We Disclose Information

Examples of when Related may share your Information, including your Personal Information, include the following:

Other Community Members. Certain features of our Site and 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. In addition, when you use the Site, Apps or the Services, we may share certain Personal Information (such as your name, photo, contact information, or other Information you have made visible in the Apps or Site) to other users of the Apps or Site in order to facilitate contact among residents and/or between residents and our representatives. Note that other users are not bound by Related’s Privacy Policy. You agree that Related is not responsible for the actions of other users with respect to any Personal Information disclosed in the Apps or Site. It is important that you review the applicable Privacy Policy for the event, sponsoring organization, Property or Location before providing your Information in connection with that event. We request that you treat all Personal Information received about other Users with the same respect and care you would want for your own Information.
Third Parties Providing Services to Related. We may use Third-Party Service providers to perform certain services on behalf of us or the Site, Apps or Services, such as: (i) creating and updating Site and Apps functionality; (ii) billing or processing credit cards, and/or electronic or manual payments; (iii) assisting us in Site and Apps operations; (iv) managing a database of resident, tenant, customer and consumer information; (v) hosting the Site or Apps; (vi) designing and/or operating the Site’s or Apps’ features; (vii) providing any of the Services necessary to operate our business; (viii) tracking the Site’s or App’s activities and analytics, including marketing and market research; (ix) data enhancement (to learn more about our customers); (x) enabling us to send you special offers or perform other administrative services, such as customer service, security, tech, operational support, email and legal services; (xi) providing free Wi-Fi services at our Locations; and (xii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Service. You should be sure that you read and agree to those policies and Terms.

To Protect the Rights of Related and Others. To the fullest extent permitted by applicable law, we may also disclose your Information when required to by law or if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or Property of Related, its affiliates, third parties or the general public (including through the enforcement of this Privacy Policy, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) to respond to claims that any content violates the rights of a third party. This includes exchanging Information with other companies and organizations for fraud prevention, spam/malware protection, and other similar purposes. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest any requests for such disclosures, all without notice to you.
Affiliates and Business Transfer. We may share your Information with our parent, subsidiaries, and affiliates. As part of this sharing of Information with our parent, subsidiaries and affiliates, this means that once you provide us with Information, any one of our related entities may use your Information including for marketing purposes, pursuant to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such Information: (i) to a subsequent owner, co-owner or operator of the Site, Apps and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.

We may aggregate, de-identify, and/or anonymize any information collected through the Site, App or Services such that such Information is no longer linked to your personally identifiable Information. We may use and share this aggregated and anonymized Information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

We also may share your Information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. (If you are a California resident, you have the right to request additional Information regarding the “sale” of your Information. Please see the section entitled “Your California Privacy Rights” below about these rights.) In addition, we may share the Information we have collected about you, including Personal Information, as disclosed at the time you provide your Information and as described in this Privacy Policy.

Ads and Information About You

You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third-party websites and online services by collecting Information through automated means, including through the Tracking Technologies described above, and they use this Information to show you advertisements tailored to your individual interests.

They collect Information about your visits to our Site, such as the pages you have viewed or your use of our Apps. This collection and ad targeting takes place on our Site and Apps and third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.

We may also use Tracking Technologies, such as our cookies, to provide personalized online display advertising tailored to your interests. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site.

You can opt-in or out of cookies at any time – except strictly necessary cookies (these are used to help make our website work efficiently). If you wish to restrict or block the cookies set by any website, you can do this through the web browser settings for each web browser you use, on each device you use to access the internet. You may “clear” all cookies to force our cookie preferences panel to restart so that you may change your cookie preferences at any time. Currently, you cannot synchronize your settings between your browsers and devices (e.g., your computer and your smartphone), so you must manage your cookies on each browser, on each device.

Some services may not function or may have more limited functionality if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them ‘trusted websites’ in your web browser.

If you do not wish to accept cookies from one of our emails, you can choose not to download any images or click on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies, whether included on websites or in emails. Depending on your email or browser settings, cookies in an email may sometimes be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). For more Information, refer to your email browser or device instructions.

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 you are viewing (e.g., contextually based ads) or ads that are not targeted at you which may be less relevant. 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.

Your Choices About the Information We Collect

You have many choices when it comes to your Personal Information. You may always change the settings on your Device (such as location settings, cookies, or allowing apps to track you) to limit some of the Information that is shared with us. Depending on the jurisdiction in which you reside, you may have additional options to access, correct, delete, or limit the Information you have provided to us. Please see the Location-Specific Privacy Notices below.

Controlling Your Cookies

You may adjust your cookies as described in the Ads and Information About You section if you are concerned about targeting and advertising.

Communications Preferences

With respect to our marketing activities, if you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at marketing@watersidegroup.com to opt out, or click the link in the email to “unsubscribe.”

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing. To do so, please email us at marketing@watersidegroup.com. Your choice will not affect our ability to share Information in the other ways described in this Privacy Policy.

Please note that certain of your Personal Information, such as your name or other identifying Information, may remain in our database even after a data request in order to maintain the integrity and historical record of our database and systems.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Children’s Privacy

Related recognizes the importance of children’s safety and privacy. The Site is not designed to attract children and are not intended for use by any children under the age of 16. We do not request, or knowingly collect, any personally identifiable information from children under the age of 16.

Do Not Track Disclosures

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of Information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here. If changes to applicable law require recognition of the Do Not Track signal, we will modify this section accordingly.

Retention of Personal Information

Company will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All Information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

How long we have had a relationship with you or provided our Services to you
The business purposes for which the Information is used, and the length of time for which the Information is required to achieve those purposes;
Whether we are required to retain the Information, or the Information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;
The privacy impact on individuals of ongoing retention; and
The manner in which Information is maintained and flows through our systems, and how best to manage the lifecycle of Information in light of the volume and complexity of the systems in our infrastructure.

Links

For your convenience, the Site, Apps and this Privacy Policy may contain links to other websites. Related is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site or Apps should be deemed to imply that Related endorses or has any affiliation with the links.

Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of Information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site or App, and you provide us with your Information at your own risk.

Questions / Changes in Privacy Policy

If you have questions or concerns with respect to our Privacy Policy, you may contact us at marketing@watersidegroup.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted.