Your privacy is important to us. We understand that you are aware of and care about your privacy rights, and we take that seriously. This Privacy Notice describes how Sterling Bay and its affiliates and subsidiaries (collectively, “Sterling Bay,” “we,” “us,” or “our”) collect, use, share, and otherwise process your Personal Information (as defined below) in connection with the following (collectively, the “Services”):
- our Websites (as defined below), mobile application services, social media properties, and any software provided on or in connection with digital services implemented by us and to which we post this Privacy Notice;
- our direct marketing communications; and
- our events and in certain other offline activities where we have posted this Privacy Notice.
Please do not provide Personal Information that you do not want us to have.
We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new Personal Information practices or adopt new privacy policies. You are encouraged to check this page periodically so that you are aware of any changes. By using our Services, you agree to be bound by our then-current Privacy Notice.
The following definitions shall apply to this Privacy Notice:
“Personal Information” means any data that relates to a living individual who can be identified from that data or from that data taken together with other information in the possession of, or likely to come into the possession of, Sterling Bay (or its representatives or service providers). Personal Information may include, but is not limited to, first name, last name, email address, mailing address, city, state, phone number, and Usage Data. For California residents, “Personal Information” includes the definition of “Personal Information” under the California Consumer Privacy Act (“CCPA”).
“Usage Data” means information about how the Services are accessed and used. Usage Data may include, but is not limited to, information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
“Websites” means Sterling Bay websites that link to this Privacy Notice unless such websites have their own posted privacy notices.
3. Cookie Notice
4. How We Collect & Use Personal Information You Provide to Us
Sterling Bay protects the identity of visitors to the Services by limiting the collection of Personal Information. Personal information provided by you to us will not be posted or published by us and will be shared with third parties only as provided herein. When you visit our Services, we or our third-party service providers may collect Personal Information from you that you voluntarily choose to share with us through the Services or otherwise including:
- Contact information, such as your first and last name, email address, mailing address, and phone number.
- Communications, such as your questions or correspondence that you send us.
- Employment information, such as your work history, educational background, and resume.
- Identification, such as numbers or scans of your driver’s license or other government-issued identification.
- Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
- Other information that we may collect and is not specifically listed here, which we will use as described in this Privacy Notice or otherwise disclosed at the time of collection.
We may use Personal Information provided by you to provide you with offerings and services, marketing materials, publications, and the like. We do not sell Personal Information to anyone and only share it with our third-party service providers who help facilitate the delivery of our Services.
Communications from our approved, third-party partners and us
If you choose to provide us with Personal Information, you also may receive the following types of emails from us, including:
- Emails related to Service-maintenance activities;
- Emails highlighting new features, content, and usage tips for the Services;
- Communications, news, or updates about our tenancies, building announcements, or other property-related information and/or other promotions and offers we think you may find of interest; and
- Special offers or promotions
- From us for additional Sterling Bay-affiliated promotions, events, and services, and
- From our approved, third-party partners who offer products and services that may be of interest to you.
Purposes for processing (using) Personal Information provided directly by you
As explained above, Sterling Bay processes your Personal Information to provide you with the Services you have requested from us. Sometimes we use third-party service providers to facilitate the delivery of the Services described above, and these third-party service providers may be supplied with or have access to your Personal Information for the sole purpose of providing services to you on our behalf. Also, we may disclose your Personal Information in special legal circumstances. For instance, such information may be used where it is necessary to protect our rights, or if the law requires us to do so. To carry out these activities, Sterling Bay may rely on many legal bases to process your Personal Information, including where:
- necessary to perform the contractual obligations and to provide the requested Services to you;
- necessary for a third party’s, or our, legitimate interests;
- necessary to comply with a legal obligation or to defend legal claims;
- necessary to protect the public interest or vital interest of others;
- you have expressly made information public; or
- you have consented to the processing, which may be revoked at any time.
5. Use of Our Services – Information Collected Automatically & Other Information
We also may receive other data about your use of our Services from other sources, including third-party websites. This information may include (but is not limited to) information about your activities across unrelated websites and mobile applications, information about the possible relationships between different browsers and devices and information that we receive from our third-party service providers, demographic data, information from social media providers, and information about your interests. We may add this information to the data we have already collected through our Services.
Links to third-party websites
The Services may contain links to other websites or apps that may offer content, functionality, or applications developed and maintained by third parties. These third-party linked services may use automated means to collect information about you and your use of these features. Sterling Bay is not responsible for the privacy practices or content of these third-party linked services. We urge all users of our Services to follow safe internet practices. Once you leave the Sterling Bay Services, do not supply Personal Information to these third-party linked services unless you have verified their security and privacy policies.
Purposes for processing (using) information collected automatically & other information
We may process information collected automatically through our Services and other information for any purpose, except if it is considered Personal Information or as otherwise prohibited by applicable law. If we combine information collected automatically with your Personal Information, we treat the combined information as Personal Information and use it only in the manner described above. See Purposes for processing (using) Personal Information provided directly by you above.
Specifically, we may use information collected automatically to help us design our Services to better suit our users’ needs, to provide and improve our Services, to provide support, for statistical and market research purposes, and for analytic purposes through tools such as Google Analytics. We also may use your Usage Data to help diagnose problems with our servers and to administer our Services, analyze trends, track user movements and gather broad demographic information that assists us in identifying user preferences.
6. Your Rights & Choices
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. For more information about cookies, please visit http://www.allaboutcookies.org/.
7. How we respond to “Do Not Track” signals
When you visit a website in any browser, you automatically share information with that website, such as your IP address, and other standard PC information. If the website contains content provided by a third-party website (for example a web measurement tools such as a web beacon or scripts), some information about you may be automatically sent to the content provider. This type of arrangement has several benefits, such as allowing you to access third-party content from our Services conveniently. Some internet browsers or other tools include “Do Not Track” (DNT) features that, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Sterling Bay does not currently respond to DNT signals.
8. Children’s Privacy
Sterling Bay does not knowingly collect or solicit Personal Information from or about children under 13, except as permitted by law. If we discover we have received any information from a child under 13 in violation of this policy, we will delete that information immediately. If you believe Sterling Bay has any information from or about anyone under 13, please email us at email@example.com.
9. Security of Your Information
Any Personal Information collected through this site is stored on 3rd party cloud-based solutions that adhere to SOC 2 compliance. Also, to help protect the privacy of data and Personal Information you transmit through the use of our Services, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We strive to restrict access to your Personal Information to those employees who need to know that information to provide benefits or services to you. In addition, we educate all of our employees about the importance of confidentiality and maintaining the privacy and security of your information.
10. Data Storage and Retention
We store your Personal Information on our servers located in the United States. We retain your information for the duration of your business relationship with us and as long as necessary to permit us to use it for the legitimate business purposes that we have communicated to you and comply with applicable law or regulations. For more information on where and how your Personal Information is stored, and for more information on your rights of erasure and portability, please contact the Sterling Bay at firstname.lastname@example.org.
11. Your California Privacy Rights
If you are a California resident, you are entitled to prevent sharing of your Personal Information with third parties for their own marketing purposes through a cost-free means. We will only knowingly share your Personal Information with third parties for third-party direct marketing purposes if you have consented to that sharing (opt-in) or are given an opportunity to terminate that sharing (opt-out) prospectively. California Civil Code Section 1798.83 permits California residents who have supplied Personal Information, as defined in the statute, to us, under certain circumstances, to exercise such opt-in /opt-out rights and inquire further about how to do so and how we comply with Section 1798.83.
In addition, effective January 1, 2020, the California Consumer Privacy Act (CCPA) provides you with the following rights with respect to our use of your Personal Information:
- The right to refuse to provide any Personal Information and the right to object at any time to the processing of your Personal Information. Please note that such refusal or objection may prevent us from providing the Services to you.
- The right to obtain information regarding the processing of your Personal Information and access to the Personal Information about you that Sterling Bay holds (including any available information as to the source of the Personal Information).
- The right to request that Sterling Bay rectify your Personal Information if it is inaccurate or incomplete.
- In some circumstances, the right to request that Sterling Bay erase your Personal Information. Please note that such a request may prevent us from providing the Services to you and there may be circumstances where Sterling Bay is legally entitled to retain Personal Information regardless of any such request.
- In some circumstances, the right to request that Sterling Bay restrict or block its processing of your Personal Information. Please note that such a request may prevent us from providing the Services to you and there may be circumstances where Sterling Bay is legally entitled to retain Personal Information regardless of any such request.
- The right to request, up to twice in a twelve-month period, your Personal Information in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow you to transmit it to another entity.
- The right to request that Sterling Bay delete your Personal Information, except in circumstances where Sterling Bay is legally entitled to retain Personal Information regardless of any such request.
- The right to opt out of any sale of your Personal Information to any third parties, without experiencing any discrimination, as defined under the law, as a result of your exercise of this right. Note that Sterling Bay does not sell Personal Information to third parties.
If you are a California resident, Personal Information will include the full definition of “Personal Information” under the CCPA. If you wish to exercise any of the rights enumerated in this section, please contact us at 312.466.4100 or email@example.com and provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to firstname.lastname@example.org. Any such request must include “California Privacy Rights Request” in the subject line and include your name, street address, city, state, and ZIP code. Please allow at least thirty (30) days for a response.
12. Business Transfers
By using the Services, you signify your agreement to the terms and conditions of this Sterling Bay Privacy Notice. If you do not agree to these terms, please do not use this site. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this policy at any time. Please check this page periodically for any modifications. Your continued use of any of the Services following the posting of any changes to these terms shall mean that you have accepted those changes.
14. Questions, Comments or Complaints
If you have questions about Sterling Bay or its products, visit our Contact page at https://www.sterlingbay.com/contact to find email addresses and other contact information for the appropriate department. To correct, update, or remove Personal Information or if you have any questions or concerns, please email us at email@example.com.