Privacy

Effective date: October 2024.

We at Sentinel Real Estate, including all our affiliates and subsidiaries, ( collectively, "Sentinel," "us" or "we") respect your concerns about privacy and are committed to complying with all applicable data privacy and security requirements in the countries in which we operate. This Privacy Policy, which applies to protected personal information collected by Sentinel, describes the types of personal information we collect, how we use the information, with whom we share it and the choices available to data subjects regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

If you are a California resident, please refer to our CCPA Privacy Notice section of this policy to learn more about your rights under the California Consumer Privacy Act.

If you are a Virginia resident, please refer to our Virginia Privacy Notice section of this policy to learn about your rights under the Virginia Consumer Data Protection Act.

If you are a European Union ("EU") resident, please refer to our EU Privacy Notice section of this policy to learn more about your rights under the General Data Protection Regulation.

Information We Collect

The types of personal information we may obtain through the Site includes:

• Contact information that you provide, such as name, address, phone number, and email address; and
• Other elements of personal information found in communications you provide, including email communications submitted through our contact form.
• Website visitor information which may include IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken and dates and times of activity.

Third Party Website or Other Services

We may use third-party web analytics services on our Site, such as Google Analytics. Such services help us analyze how visitors use our website. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these activities, click below:

• For Google Analytics: https://www.google.com/policies/privacy/

The providers of third-party plug-ins on our website, such as Google Maps, may use automated means to collect information regarding your use of our website and your interactions with the plug-ins. This information is subject to the privacy policies or notices of the plug-in providers and is not subject to this Privacy Policy. We are not responsible for these providers' privacy practices.

Website Use and Cookies

A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser, but it does not contain any of your personal information such as name or email address.

Cookies record information about your online preferences and allow us to tailor our website to your interests. Sentinel uses essential and analytics cookies for the purposes set forth above, including (i) customizing your visit to our Site, (ii) analyzing the manner in which you interact with our Site, and (iii) managing our website and other aspects of our business. We also use information to help diagnose technical and service problems, administer our website and identify users of our website.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website. For more information on deleting or controlling cookies we recommend www.allAboutCookies.org.

Types of cookies we use:

• Essential Cookies: These cookies enable the website to function. Certain functional cookies also allow us to respond to service or other inquiries received through a form.
• Functional Cookies: These cookies enable the website to function. Certain functional cookies also allow us to respond to service or other inquiries received through a form.
• Analytics Cookies: Analytics cookies track aggregate site performance, web speed, traffic sources, video plays and other aggregate data across our website. These cookies allow us to personalize web experience by type of visitor and, upon certain circumstances, by individual user. Individual user information is recognized through form completions or response to certain email marketing campaigns.

We do not obtain personal information about our visitors' online activities, overtime and across third-party websites. Our website is not designed to respond to "do not track" signals from browsers.

How We Use the Information We Collect

We collect personal data to offer and administer services and products. The information you provide to us will be used and process in accordance with the proposes specified below:

• Where processing is necessary to perform a contract or in order to take steps at your request prior to entering into a contract, such as respond to your inquiries, or to perform certain services requested by you;
  Where processing is necessary for our legitimate business interests in conducting and managing our business, including:
  • operate, evaluate and improve our business, including (i) providing a product or performing a service requested by clients pursuant to a contract or a website or web application requests, (ii) developing new products and services; (iii) enhancing and improving our products and services; (iv) analyzing our products, services and communications;
  • Manage and improve communications with you. Emails sent to you by Sentinel may include standard tracking, including open and click activities. Sentinel may collect information about your activity as you interact with our email messages and related content;
  • operating and improving our website and your customer experience.
  • For marketing purposes. Where permitted by law, to communicate, advise, and further discuss your interests in our services and products through email, phone call, or other means of communications about other products or services similar to the products or services we have provided to you and that we think will be of interest to you;
  • If you are located in the EU, UK, Australia, Japan, or Singapore, we will only send you marketing communications and updates about our products, services and events with your prior consent or based on our and your legitimate interests where permitted. In either case, you can withdraw your consent or opt-out or receiving such communications at any time.
  • If you are not located in the EU, UK, Australia, Japan, or Singapore, you may opt-out of receiving marketing communications and updates at any time.
  • You can manage your receipt of marketing and non-transactional communications by contacting us at privacy@sentinelcorp.com.
  • information regarding hosting of events and webinars. We may use your data to manage your registration and/or reservation, including sharing data with event co-hosts, venue and tracking and facilitating event attendance;
• Where the processing is necessary to comply with obligations provided by laws, regulations, legislations, and relevant industry standards and our policies, such as performing accounting, auditing, and other internal functions, protect against, identify and prevent fraud and other criminal activity, claims and other liabilities under, among others, tax and anti-money laundering regulations;
• With your consent. We also process your data for other purposes if you have provided us consent for such specified purposes, where such other purposes will be clearly provided at the time you provide consent.

Information We Share

We do not sell or otherwise disclose the personal information we collect about you on this Site, except as described in this Privacy Policy. We may share personal information with certain personal information with our affiliates for the purposes described in this Privacy Policy and with third parties, such as vendors, consultants and other service providers who perform services on our behalf, based on our instructions, such as updating or addressing issues with our website. These service providers are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. We require these third parties to undertake security measures consistent with the protection specified in this Privacy Policy.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, to enforce our rights and policies, or in connection with an investigation of suspected or actual fraudulent or illegal activity. Where we receive requests to disclose personal data from law enforcement or regulators, we carefully validate these requests, including reviewing the legality of any order and challenging the order if there are grounds under the law to do so, before any personal data is disclosed.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, merger, joint venture, divestiture, dissolution or liquidation). Following such a transaction, you may contact the entity to which we transferred your personal data with any inquiries concerning the use of that information.

Transfer of Personal Information to Other Countries

For the avoidance of doubt, Sentinel Real Estate is headquartered in the United States. Our servers may be located outside of the European Economic Area ("EEA") such as in North America or parts of the world other than the country in which you are located when using our website or providing information to us or in which you reside.

We may transfer the personal information we collect about you to recipients in countries other than the country in which you originally provided it or in which we are located. These countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements including ensuring transfers are governed by the requirements of the Standard Contractual Clauses adopted by the European Commission or another adequate transfer mechanism.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, disclosure or use.

While we cannot ensure or guarantee that unlawful or unauthorized access, disclosure or use of your information will never occur, we use all reasonable efforts to prevent it in light of the nature of information supplied.

You should bear in mind that submission of information over the internet, such as sending an email, is never entirely secure. We cannot guarantee the security of information you submit via our website while it is in transit over the internet and any such submission is at your own risk.

If you use a shared computer or a computer in a public place, it is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information.

We will retain the personal information we collect for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with Sentinels Data Retention Schedule.

Links To Other Websites

These websites and apps may operate independently from us. Linked sites and applications may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or applications are not owned or controlled by us, we are not responsible for their content, any use of the websites or applications, or the privacy practices of the websites or applications.

Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on this website and indicate at the top of this Privacy Policy when it was most recently updated.

How To Contact Us

To contact us regarding your personal information or to exercise any of your rights set out in this Privacy Policy, please contact us:

Noah Gold, DPO
Sentinel Real Estate Corporation
1251 Avenue of the Americas
New York, NY 10020
1-212-408-5000
privacy@sentinelcorp.com

If you are in the EU, Sentinel EU Data Protection Representative:
Max Berkelder
Mondriaantower
Amstelplein 54, 1096 BC Amsterdam, the Netherlands
+31-610-590-874
privacy@sentinelcorp.com

Residents of California: Your Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Sentinel to third parties for the third parties direct marketing purposes. To make such a request, please contact us as indicated in the "How To Contact Us" section of this Privacy Policy.

Pursuant to California Civil Code Section 1798.83(c)(2), Sentinel does not share your personal information with third parties for those parties' direct marketing use, unless you elect that we do so.

Your Rights

Subject to CCPA, CPRA and other applicable laws, you have the following rights with respect to your data processed by Sentinel:

• Deletion: You have the right to request that Sentinel erase your personal information, and we will erase such information unless it is reasonably necessary for us to maintain your personal data in accordance with CCPA 1798.105 (d) or 1798.145.
• Correction: You have the right to request that we correct inaccurate personal information, taking into account the nature and purpose of processing the information.
• Access: You have the right to request to access the personal information that we hold about you, including specific pieces of personal information we have collected about you.
• Non-discrimination: We will not discriminate against you because you exercised any of your rights under the CCPA or CPRA.

Contact Us:

If you wish to exercise your rights under the CCPA or CPRA, please contact us as indicated in the How To Contact Us section of this Privacy Policy.

Residents of Virginia: Your Rights

If you are a Virginia resident acting in an individual or household context (and not acting in a commercial or employment context), the Virginia Consumer Data Protection Act ("VCDPA") allows you to request information regarding the disclosure of your personal information by Sentinel to third parties, such as our vendors. We do not sell your personal data to third parties. We do not process personal data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

Your Rights

Subject to VCDPA, you have the following rights with respect to your data processed by Sentinel:

• Deletion: You have the right to request that Sentinel erase your personal information, and we will erase such information unless it is reasonably necessary for us to maintain your personal data in accordance with VCDPA 59.1-582.
• Correction: You have the right to request that we correct inaccurate personal information, taking into account the nature and purpose of processing the information.
• Access: You have the right to request to access the personal information that we hold about you, including specific pieces of personal information we have collected about you.
• Non-discrimination: We will not discriminate against you because you exercised any of your rights under the VCDPA.

Contact Us:

If you wish to exercise your rights under the VCDPA, please contact us as indicated in the "How To Contact Us" section of this Privacy Policy.

Residents of the European Union: Your Rights

If you are a resident of the European Union or provide personal information to us while located in the European Union, we offer you certain choices in connection with the personal information we collect from you. To update your preferences and consents, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the "How To Contact Us" section of this Privacy Policy.

Your Rights

Users in the European Union may have the right under certain circumstances:

• to be provided with a copy of your personal data held by us and the purposes for holding it;
• to request the rectification or erasure of your personal data held by us;
• to request that we cease processing your data;
• to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
• to request that your data be transferred to a third party; and
• where provided by law, to withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

We may use your data for marketing purposes or if we intend to disclose your information to any third party for such purposes by checking certain boxes on the forms, we use to collect your data. You can also object to receiving further marketing at any time without detriment. We will inform you prior to collecting or using your Personal Information for any purpose not mentioned in this Privacy Policy.

You can also exercise the rights listed above at any time by contacting us as indicated in the "How To Contact Us" section of this Privacy Policy.

If your request or concern is not satisfactorily resolved by us, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information for the supervisory authorities may be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en#me

RentCafe Privacy Policy

This privacy policy (the Privacy Policy or Policy) of Property Management Company (Company, we, us, or our) describes our privacy practices regarding personal information we collect, including from persons (you or your) who access our propertys RentCafe Portal website or our related mobile applications that may be available for download (collectively, the Site). To access the Privacy Policy of RentCafe, please visit: https://resources.yardi.com/legal/rentcafe-privacy-policy/.

PURPOSE. The purpose of this Privacy Policy is to inform you about the types of personal information we gather about you, including personal information gathered when you visit the Site, and personal information we may receive from third parties or affiliates in addition to that online information, how we may use that information, whether we disclose that information to anyone, and the choices you have regarding our use of, and your ability to correct, the information.  This Policy does not cover information that is exempted from privacy policy notification requirements, including information about employees, contractors, job applicants and information processed exclusively in the context of a business person acting in a business capacity.

THE SITE IS NOT INTENDED FOR CHILDREN AND COMPANY DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF COMPANY LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).

YOUR CONSENT AND POLICY CHANGES. PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION, INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE SITE.

Company may amend this Privacy Policy from time to time. We will post those changes on the website or update the Privacy Policy date below.  In certain cases, you will be notified via email or by a notice on our website. 

PERSONAL INFORMATION COLLECTED IN THE PAST 12 MONTHS

We collect, process and store various types of Personal Information.  For purposes of this Policy, 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 consumer or household.  It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Personal Information we collect may include:  your name, email addresses, postal addresses, postal codes, user Internet Protocol (IP) addresses, social security/insurance number, drivers license number, prior addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name and password (if you choose to become a registered user of the Site or our products and services), emergency contact information, information about your pets, information about your vehicles including license plate numbers, biometric information or biometric identifiers (if you choose to schedule a self-guided tour and/or use our identity verification services), when a smart device is on or off; when a door is locked, unlocked, opened, or closed; the unit with which the door is associated (if you choose to use Smart Home or the Home IQ Device(s) or Home IQ Hub), and other information either desirable or necessary to provide quality services to our residents and visitors.  We may also collect information about you such as your use of the Site and communication preferences.

Your Personal Information may be retained for as long as you use the Site or our products and services. Retention periods may be extended if we are required to preserve your personal information because of litigation, investigations and other similar proceedings, or if a longer retention period is required or permitted by applicable law.

We do not and will not sell your Personal Information.

Additional Information about How We Collect and Share your Personal Information

With respect to each of the categories of data above, we may also collect and share Personal Information with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; with contracted service providers; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites and mobile apps, or the public. With respect to biometric information or biometric identifiers, we may disclose such data to our technology service providers for the purpose of verifying your identity. We may also share Personal Information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

PERSONAL INFORMATION WE WILL CONTINUE TO COLLECT

We will continue to collect the same categories of Personal Information listed above, for the same purposes. 

USE OF COOKIES AND OTHER TECHNOLOGIES. Like many other website operators, Company may use cookies to customize content specific to your interests and track your use of the Site. Cookies are text files that are placed on your computer and may be used to store your personal information. In addition to cookies, Company may use other now known or later developed technologies, to assist Company in observing the behavior of users visiting the Site. These technologies access individual user information but the information is used only to compile aggregated statistics about the Sites usage.

Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.

This Site uses Lead Attribution or Marketing Attribution to assess the conversions of different channels that generate leads.

This Site uses Google Analytics (and in the future may use other similar sites or services), a web analytics service provided by Google, Inc. (Google), to better assist Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computers IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for Companys use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Googles behalf. The use of cookies by Google Analytics is covered by Googles privacy policy: https://www.google.com/policies/privacy/.

You can choose to delete existing cookies, allow or block cookies, and set preferences for certain websites in your browsers settings. Please note you may not be able to use the full functionality of the Site if you choose to block all cookies.

EMAIL AND TEXT MANAGEMENT. You may receive emails and texts from Company for a variety of reasons. We respect your desire to manage email and text correspondence. If you have an account with Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with information relating to your unit, the management of the property, and other important transactional or administrative information. 

THIRD-PARTY WEBSITES. This Privacy Policy applies solely to information collected by Company. This Privacy Policy does not apply to other websites that are accessible through this Site, including but not limited to any third-party websites.

ACCESSING, REVIEWING AND CHANGING YOUR CONTACT INFORMATION. As an account holder, you can see, review and change most of your contact information associated with your Account Profile by logging into your account and editing your Account Profile.  For assistance, you may contact us using one of the methods listed below. With some exceptions, you have the right to see what Personal Information we hold about you. We can help you identify what records we might have about you. We may need to confirm your identity before providing you with this access, and if we cannot verify your identity with the degree of certainty required, we will not be able to respond to your request.  If we cannot give you access, we will tell you within 45 days of receipt of your request and provide you with a reason, as best we can, as to why we cannot give you access.

PERSONAL INFORMATION OF MINORS. Our Sites are not directed to minors under the age of 16 and we do not knowingly collect Personal Information from minors.  We may collect Personal Information of minors, provided by parents or guardians, in connection with the application and rental of a unit, or the provision of property management services.  We do not sell the Personal Information of minors.

CALIFORNIA RESIDENTS RIGHTS. The California Consumer Privacy Act (CCPA) may apply to California residents whose Personal Information is collected by landlords of a certain size or that meet other criteria. If the CCPA applies to us, California residents may request to know about Personal Information collected about them and request deletion of that Personal Information. These rights are subject to certain exceptions, including without limitation, for Personal Information subject to the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act.  If we are subject to the CCPA, you can learn more about these rights and our processes for consumer requests by contacting us using one of the methods listed below. If you exercise any of the rights afforded to you by the CCPA, we will continue to treat you fairly.

Right to request disclosure of information we have collected about you

If the CCPA applies to us and to your information, you can submit a request to us for the following personal information we have collected: 

• The categories of personal information weve collected about you.

• The categories of sources from which we collected the personal information.

• The business or commercial purposes for which we collected or sold the personal information.

• The categories of third parties with which we shared the personal information.

• The specific pieces of personal information we collected about you.

• The categories of personal information (if any) that we have sold about you, the categories of third parties to which we sold that information, and the category or categories of personal information sold to each third party.

• The categories of personal information that we disclosed about you for a business purpose. 

Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.

Right to request the deletion of personal information we have collected from you 

Upon request, we will delete the personal information we have collected about you that is covered by the CCPA, unless a relevant exception to the right to deletion applies.

Do Not Track

Do Not Track is a privacy preference that users can set in certain web browsers.  We do not respond to browser or do not track signals.

INTERNATIONAL TRANSFER OF INFORMATION. To facilitate global operations, we may store, transfer and access Personal Information we collect (as described above) or you submit on the Site around the world, including the United States, Canada and other countries in which we or our service providers have operations.

ACCESSIBILITY.  We are committed to ensuring that our communications are accessible to people with disabilities.  To make accessibility-related requests or report barriers, please contact us using one of the methods below.

ACCEPTABLE USE. You agree you will not modify, tamper with, reverse engineer, decompile, or otherwise attempt to discover the source code for, any Site or related hardware or software associated with the Site.

CONTACTING US.

If you have questions regarding this Privacy Policy or use of information collected, please contact your property manager using the Contact Us form.

Canada. To the extent it is applicable, this policy is made under the Personal Information Protection and Electronic Documents Act. There are some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

Address: 112 Kent Street, Ottawa, ON K1A 1H3 
Phone: (613) 995-8210
Toll-free: (800) 282-1376
Facsimile: (613) 947-6850
TTY: (613) 992-9190
Website: www.priv.gc.ca/en/

Updated:  July 24, 2023