Privacy Policy
Effective Date: October 14, 2020
1. Introduction and Overview
Rudin Management Company (“Rudin,” “we,” “ours” or “us”) is committed to protecting your privacy. This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share information we receive from you when you access or use our website, https://www.rudin.com/ (“Website”), interact with our Rudin team members, such as showing interest in or requesting information about our properties, or when you utilize our property management services and/or software provided in connection with access to or being a tenant of our properties (collectively, our “Services”). We provide our Services for both residential and commercial properties, and this Privacy Policy applies to personal information we collect in both contexts. You acknowledge that this Privacy Policy is part of our Terms of Use, and by agreeing to use the Services, you are agreeing to be bound by all of its terms and conditions and all applicable laws and regulations. If you do not agree to these terms, you are prohibited from using or accessing the Services.
2. Information We Collect
We collect the following categories of personal information:
| Category | Examples |
|---|---|
| Personal Identifiers |
First and last name, date of birth, postal address, copy of your driver’s license or passport, telephone or mobile contact number, vehicle information, social security number or other unique personal identifier, online identifiers, Internet Protocol address, and email address |
| Commercial and Financial Information | Bank account information including routing and account numbers, credit and/or debit card numbers, records of personal property, transaction and purchase history, and other financial details |
| Internet or other similar network activity | Device identifier, browsing history, search history, and information on your interactions with a website, application, or advertisement |
| Geolocation Data | Whether you are located within the New York Designated Marketing Area (NY DMA) |
| Professional or employment | Job title, employer information, work history, and salary information |
| Related information | |
| Audio an visual information | Security footage |
We collect the above categories of information from various sources, including (i) directly from you when you provide it to us, including through a tenant application, building management tools or software, request for information regarding our properties, e-mail, text message, and other hard or electronic copy forms where we ask for information; (ii) third-party resellers and referral partners, vendors, and service providers; (iii) partners with which we offer co-branded services or engage in joint event or marketing activities; and (iv) tracking technologies, such as cookies, web beacons, and embedded scripts.
Some of our properties may offer public Wi-Fi access. If you choose to use our public Wi-Fi network, we may automatically collect your Internet or other similar network activity (as described above), as well as any additional information you provide directly to us when using the network. Information collected from our public Wi-Fi network is subject to the terms of this Privacy. Your use of our public Wi-Fi network is subject to our Terms of Use.
3. How We Use Your Information
We may use your personal information for purposes consistent with this Privacy Policy or as permitted by applicable law. We will not use information we’ve collected from you for purposes that are materially different, unrelated, or incompatible with this Privacy Policy without providing you with prior notice. We may use your personal information in order to:
| Description of Use | Categories of Information Used |
|---|---|
| Respond to your inquiries or fulfill your requests, such as information regarding our properties or properties we think may be of interest to you |
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| Provide and manage our Services, including to monitor the usage of our Services or changes to our Privacy Policy or Terms of Use |
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| Email you with apartment listings or other properties of interest |
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| Send you alerts and notices regarding premises you lease from us |
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| Respond to your comments, questions, and requests, and provide customer service |
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| Communicate with you concerning visits to a property or entry into a premises |
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| Understand and analyze your needs with respect to a property and third parties |
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| Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, and events |
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| Engage with you through third party social media sites like Facebook and Instagram either through direct communication or advertisements regarding our and third party products, services, offers, promotions, and events |
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| Prevent and address fraud, breach of policies and terms, and threats of harm to property or building occupants |
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| Perform analytics on our Website |
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4. How We May Share or Disclose Your Information
We may share or disclose your personal information to the following individuals or entities or for the following purposes:
- To our agents, vendors, consultants, and other service providers, including our building and property management software tool providers, (collectively “Service Providers”) in order for them to perform the activities listed above in Section 3 (“How We Use Your Information”) at our instruction and on our behalf.
- To third party social media sites, including Facebook, in order to send you advertisements and communicate with you regarding our, services, offers, promotions, and events.
- To law enforcement or other government agencies, in order to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or to otherwise protect the rights, property, life, health, security and safety of us, our Service Providers, or tenants.
- In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company.
- To our affiliates for internal business purposes.
Our Service Providers are prohibited from using or disclosing your personal information for any purpose other than to perform the services listed in Section 3 (“How We Use Your Information”). However, we may permit our Service Providers to use aggregate information which does not identify you or de-identified data for any other purpose.
5. Third Party Services, Features, and Devices
Our Website contains contents from hyperlinks to websites, locations, social media, platforms and services operated and owned by third parties (“Third Party Services”). In addition, our Website contains features that allow you to interact with, connect to, or access our Services through certain Third Party Services and third party devices (“Third Party Features”). For example, you interact with a Third Party Service when you submit maintenance requests or post comments through the resident portal on our Website. Third parties may use cookies, web beacons, embedded scripts, location-identifying technologies, device fingerprinting and other tracking technologies (collectively, “Tracking Technologies”) to independently collect information about you and may solicit personal information from you. If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature.
Our Website also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Website to help us analyze your use of our Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties, including Facebook, may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
The information collected and stored by third parties, whether through our Website, a Third Party Service, or a third party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. We are not responsible for and make no representations regarding third party policies and practices, and encourage you to familiarize yourself with and consult their privacy policies and terms of use.
6. Our Use of Cookies
When you use our Website we or our Service Providers may store cookies on your computer in order to facilitate and customize your use of our Website. A cookie is a small data text file, which a website stores on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Certain pages of the Websites and/or html email correspondence may use session cookies, persistent cookies or web beacons to anonymously track unique visitors, save website preferences and to allow us to recognize visits from the same computer and browser.
There are several types of cookies.
- Cookies that are essential for the operation of our Website (“Essential Cookies”). These cookies enable services you have specifically asked for. These cookies remain on your device only until you close your browser after visiting our Website.
- Cookies that are used to collect anonymous information on the pages visited (“Performance Cookies”). For example, we might use Performance Cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. These cookies remain on your device only until you close your browser after visiting our Website.
- Cookies that remember choices you make to improve your experience (“Functionality Cookies”). These Functionality Cookies remain on your device for an extended period of time. When you revisit our Website we recognize Functionality Cookies and remember your preferences or can automatically log you on to the Website. Personal information on our system may be associated with Functionality Cookies but the cookies themselves do not contain any of your personal information.
In general, the cookies on our Website make your use of the Website easier, makes the Website run more smoothly and help us to maintain a secure Website. You are always free to decline our cookies if your browser permits, but some parts of our Website may not work properly in that case.
7. Your Choices
A) Accessing Your Information
You may access, update, or remove certain account information that you have voluntarily submitted to us by sending an e-mail to us at privacy@rudin.com. We may require additional information from you to allow us to confirm your identity. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B) Tracking Technologies
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove cookies some parts of the Website may not work and that when you revisit the Website your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit www.allaboutdnt.com.
C) Analytics and Advertising Tracking Technologies
You may exercise choices regarding the use of cookies from Google Analytics by going to tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
You may choose whether to receive Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit www.aboutads.info/choices. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting-out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
D) Communications
You can opt-out of receiving certain promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link or by sending an e-mail to us here with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or ongoing business relations.
8. Notice to Minors
Our Website is directed at and is not intended for use by anyone under the age of 18. Visitors under the age of 18 should not provide any personal information through the Website. If you are under the age of 18, do not send any type of personal information about yourself to us or our Website.
9. International
Our Website is based in the United States, and operate under United States Law. We make no representation that information provided by the Website is appropriate or available for use outside the United States or complies with laws outside of the United States. If you are located outside of the United States, the information we collect may be transferred to and processed in the United States and in other countries where the privacy laws may not be the same as the laws where you reside. Those who choose to access the Website from outside the United States do so on their own initiative and at their own risk and are responsible for compliance with all applicable laws and regulations outside the United States. By using the Website, you hereby consent to having any information you provide to us transferred to and processed in the United States.
10. Notice to California Residents
Rudin does not conduct business in the State of California and does not consider itself a “business” under the California Consumer Privacy Act (“CCPA”). Accordingly, Rudin is not subject to the CCPA or California Civil Code Section 1798.83 (the “Shine the Light” law). Any consumer requests for information made under CCPA or the Shine the Light law are inapplicable to Rudin and we will not respond to such requests. If you have questions regarding our information collection, use, or disclosure practices, please contact us at privacy@rudin.com.
11. Changes to Our Privacy Policy
We may update this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page and, where appropriate, notify you of any changes we make to the Privacy Policy by email. Please check back frequently to see any updates or changes to our Privacy Policy.
12. Contact Us
If you have any questions regarding this Privacy Policy, you can contact us via email at privacy@rudin.com, by regular mail at 345 Park Avenue, New York, NY 10154, or by phone at 212.407.2400.
