Soho Properties Privacy Policy
Last Updated December 1, 2020
Acceptance of Privacy Policy
Soho Properties Inc., (the “Company“, “we“, or “us“) and its corporate affiliates (collectively, “Affiliates“) are committed to respecting and protecting your personal privacy. This Privacy Policy, including any future modifications and/or addenda (collectively, this “Privacy Policy“) applies to all information (including personal and financial information) we may collect through your use of sohoproperties.com or linkedin.com (the “Site“), any information you provide to us voluntarily, and any other sites, applications (or “apps“), software, features, events, surveys or studies, or content offered by the Company or its Affiliates from time to time that links or otherwise refers to this Privacy Policy (collectively, including the Site, the “Services“), whether as a guest or a registered user.
This Privacy Policy is effective with respect to all information we have collected from you or will collect from you in the future. Please read this Privacy Policy carefully before you start to use the Services. By Accessing And/Or Using The Services, You Expressly Consent And Agree To Be Bound And Abide By This Privacy Policy And The Available At Http://Www.sohoproperties.com/Soho-Properties-Inc-Terms-Of-Use/ (The “Terms Of Use”)Incorporated Herein By Reference And To Comply With All Applicable Laws, Rules, And Regulations (Collectively, “Applicable Laws”).
If you do not want to agree to this Privacy Policy and the Terms of Use, you must not access or use the Services.
Note: If you are affected by a visual impairment that prevents you from reading the content of this Privacy Policy and/or any addenda, you may call the Company at +1-212-966-9600 for further assistance.
What Types of Information Might The Company Collect & How Do We Collect It?
General Categories
In general, the Company may collect the following categories of personal information:
- Identifiers: Examples might include your name, email address, phone number, IP address, device identifier, or account name;
- Personal Information: Relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Examples might include your financial information or business information;
- Classification Characteristics: Examples might include your age or sex;
- Commercial Information: Examples might include the products or services you’ve purchased, obtained, or considered, and other purchasing or consumer histories or tendencies;
- Biometric Information: Examples might include your face, fingerprints, and/or keystroke patterns or rhythms.
- Internet Activity: Examples might include your browsing history, your search history, and information on your interaction with the Site and the Company’s advertisements;
- Geolocation Data: Examples might include your physical location or movements;
- Sensory Information: Examples might include sensory information related to audio, visual, electronic, thermal, olfactory, or other similar stimuli.
- Professional or Employment-Related Information: Examples might include your employer, job position, salary, etc.
- Inferences: The Company may make inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitudes.
Information You Provide to Us
When you access, register, use, subscribe to, or purchase our Services, purchase a product, enter a sweepstakes or promotion, communicate with us, upload other information, submit a request online,(e.g., a request through customer services), attend an event (e.g., an educational seminar, webinar, a live event, etc.), in-person or otherwise, or otherwise communicate with us, directly or through a third party, we may collect and store any personal information you provide. This could also include any information you provide to our Affiliates. This information may include, without limitation, your: Personal Information, e-mail communications; phone communications; messaging platform communications; data entered into forms or surveys; dates and times of access, usernames; passwords; web cookies; g or other user-generated content that you disclose to us, payment information, and any information you provide to us about other people. By submitting such information, you agree it may be shared by the Company with Affiliates and with third parties for the purposes detailed in this Privacy Policy.
If you submit suggestions, ideas, enhancement requests, recommendations, or other feedback in connection with the Services (collectively, “Feedback“), the Company may use or act upon such Feedback without compensation and such Feedback will not be considered confidential.
Information About Your Use of The Services
The Services may use cookies and other means of collecting information. Cookies are messages placed on your computer or mobile device when you visit a website or page. A cookie may be used to store your login and profile details so you do not have to re-enter them each time you login. It is possible to disable the placement of cookies through your browser settings. However, as portions of the Services rely on cookies to enable certain functionality, if you choose to disable cookies, some of this functionality may not work properly.
The Services use cookies, web beacons, pixels, and other tracking technologies to collect information about your use of the Services, including without limitation, your browser type and version, IP address, operating system and platform, when you open email that we send you, and other similar information.
We may also use cookies to deliver ads, store visitor preferences, record session information (e.g., tracking items that visitors add to their shopping cart), record user-specific information on what pages users access or visit, track and record past activity at the Site (or on other Services).
We may collect and store information locally on your device using mechanisms such as browser web storage and application data caches. In addition, if you access the Service from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device. If you telephone us, or if we call you, the call may be recorded. Online interactions may also be recorded.
Information From Other Sources
We may obtain additional personal information about you from our service providers, the internet, offline sources, or other public or commercial sources including, but not limited to, social media services to which you have provided Personal Information. When you access the Services through a third-party service (e.g., Facebook, Twitter, etc.), you connect the Services to a third-party service, or share our content via a third-party service, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.
We may also receive additional personal information about you from certain third parties (e.g., researchers, analysts, and/or marketers) that provide us with statistical, demographic, or other similar information. Further, we may combine your online information with information we obtain from offline sources, including, without limitation, information that you may provide us with over the phone or via email. Lastly, we may obtain information about you from our service providers and our Affiliates.
The Company is not responsible for the privacy practices of third parties. When you provide information about yourself on such services, it may be publicly viewable by other users of such services and we cannot prevent further access by others. If you do not wish to have this information shared, you should not associate such third-party services with the Services. If you wish to know how social media services or other third-party service providers handle your information, you should review their respective terms of use, cookie policies, and privacy policies. Such services/parties may permit you to modify your privacy settings.
The Company may use local shared objects, sometimes known as Flash cookies, to store your preferences or display content based upon what you view on our Services to personalize your visit. Advertisers and other third-party services also may use Flash cookies to collect and/or store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage flash cookies please visit the following website for more details: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
We may merge the data we collect from your activity on the Services with data available from third parties, including, without limitation, advertisers. We have implemented Google Analytics including, the following features: Google Analytics (Standard), Google Tag Manager. You can use the Google Analytics Opt-Out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout/ to disable tracking by Google Analytics. We also use Adobe Analytics, a third-party analytics company, to track and analyze usage and browsing patterns of our users to help us improve our Services. For information about Adobe Analytics information collection practices and related opt-out choices go to: http://www.adobe.com/privacy/analytics.html.
How Does The Company Use Your Information?
The Company may use your Personal Information in order to provide and improve our Services. Specifically, the Company may use your Personal Information as follows:
To Provide and Improve The Services
The Company, its Affiliates, service providers, and other third parties may use the information collected from the Services to improve and provide and personalize the Services for you and other users. This includes, without limitation, maintaining, measuring, and enhancing users’ experiences on our Services, providing you with information, or services, fulfilling offers that you request from us, developing new services, understanding and resolving issues with the Services, and protecting you, other users, and the Services. We may share your information to allow our Affiliates, service providers, and other third parties to assist in providing and managing the Services.
Financial information may be used for billing purposes, including, without limitation, order tracking and fraud detection/prevention. If we have trouble processing an order, this information may be used to get in touch with the user.
To Communicate With You About Products, Technical Support And Assistance
The Company, and its Affiliates, may use your Personal Information to send you information about your account, the Services, or other services, upcoming events, and to notify you about issues with or changes to the Services. From time to time, we may use your information to send important notices, such as communications about the Company’s business activities, investment opportunities, and/or policies. We may also make various email series and one-time emails available to recipients in our database to help them get the most value from our Services. Such emails include, but are not limited to newsletters, new service offerings, service updates, educational materials, surveys, and special offers from the Company, its Affiliates, and/or its service providers.
We may use your information to provide technical support and assistance for the Services, depending on the specific Service, via telephone, text, e-mail, instant message, or another online platform.
We may also send you marketing or other promotional materials (including materials from our Affiliates and service providers). If you do not wish to receive these communications, you may opt-out, as described below in the section entitled “How Can I Change my Email Communication Preferences.” The Company will not send you marketing messages if you have opted out.
Please note that you cannot opt-out of certain administrative communications. The Company may send such messages via email to facilitate agreed on transactions or update customers about existing business relationships. Such emails include, but are not limited to: welcome emails, transaction receipts, billing notifications, service updates and announcements (including information about critical updates), renewal notices, notification of activation of online privileges, technical support responses, and other communications required to service customers’ accounts for the Services and/or customers’ subscriptions with the Company or its Affiliates.
To Communicate With You Using Automated Systems
The company may make calls and send text messages to numbers you have provided to us via use of an automatic telephone dialing system (“atds”) or another similar announcing device. You do not, however, have to consent to receive phone calls or text messages via an ATDS in order to do business with the Company or any of its Affiliates. If you wish to opt out of receiving ATDS communications, please do so by unsubscribing to email communications, per the instructions contained on the last Company email newsletter. You should understand that, when you opt out of receiving ATDS communications, you will also be placed on the Company’s internal “do not call” list and will no longer receive in-person marketing or promotional calls from the Company.
To Aggregate & Anonymize Data
The Company may aggregate and/or anonymize any information collected for various purposes. Once aggregated or anonymized, the information will no longer be considered “personal information” because it will no longer be able to identify you and/or any of your specific devices used to access the Services. The Company may use such information for any purpose (e.g., research and development purposes), including sharing such information with third parties.
To Fulfill Other Purposes To Which You Have Consented
Your information may be used to fulfill any other purpose for which you provide information or otherwise provide your consent for the Company and/or other third parties to use such information.
For What Purposes Does The Company Use Or Share Your Personal Information?
Organizational Purposes
As the Company is part of a larger group of companies, it may be necessary for the Company to transmit your Personal Information to its Affiliates. This may be necessary so that data can be shared among our Affiliates in order that that may carry out their legal, regulatory, and/or contractual responsibilities and/or coordinate/implement business plans, logistics, and/or operations. This is especially true because the Company and its Affiliates performs critical services on each other’s behalf, including services related to: accounting, human resources, legal, etc.
Operational Purposes
Processing your Personal Information may be necessary to facilitate the day-to-day operation of our business, to allow our Affiliates, service providers and other third parties assist in providing and managing the Services, and to allow for business planning for strategic growth. This may include sharing intelligence with internal stakeholders; implementing training procedures; planning and allocating resources and budgets; performing data modelling; facilitating internal reporting; and analyzing growth strategies; aggregating analytics.
Monitoring Purposes
The Company may need to process your Personal Information in order to identify recurring problems and/or analyze the patterns of behavior of users in order to monitor the performance of, and users’ behavior on, the Services.
Due Diligence Purposes
It may be necessary for the Company or its Affiliates to process your Personal Information for the purposes of conducting due diligence. This could include, for example, monitoring official watch-lists, sanction lists and “do-not-do-business-with” lists published by governments and other official bodies globally. This could also include keyword searches of industry and reputable publications to determine if companies and individuals have been involved in or convicted of relevant offenses, such as fraud, bribery, and/or corruption.
Fraud Detection & Prevention Purposes
Processing your Personal Information may be necessary for the Company to help detect and prevent fraud.
Network & Information Security Purposes
Processing your Personal Information and Financial Information may be necessary for the purposes of ensuring our network and information security, e.g., monitoring users’ access to our network for the purpose of preventing cyber-attacks, inappropriate use of data, corporate espionage, hacking, system breaches, etc. This could include preventing unauthorized access to electronic communications networks and malicious code distribution and stopping “denial of service” attacks and damage to computer and electronic communication systems.
Business Continuity & Disaster Planning Purposes
The Company may process your Personal Information because it may be necessary to allow for the backup and protection of your information (e.g., utilizing cloud-based services to archive/protect data) in order to ensure that such information is not improperly lost or modified. Such processing may also be necessary to archive/protect data in accordance with legal, regulatory, organizational, and/or contractual obligations.
Compliance With Laws & Regulations Purposes
The Company is subject to binding legal or regulatory obligations and may need to process your Personal Information in order to comply with such laws or regulations.
Compliance With Industry-Specific Self-Regulation Purposes
The Company’, and/or several of its Affiliates, are part of industry self-regulatory organizations. Such organizations were formed in order to address various concerns, including: developing industry standards and best practices to protect the industry; sharing intelligence or concerns about individuals (e.g., industry-specific watch lists); sharing intelligence or concerns that may have a negative or detrimental impact on the industry; and/or ensuring that participants in the industry are following agreed-upon standards. The Company may be required to process personal information so that we may stay in compliance with these self-regulatory requirements.
Reporting Potential Threats To Public Security & Safety Purposes
The Company may need to use personal information to report possible criminal acts or threats to public security/safety that we identify as part of our processing activities to a competent authority.
How Can I Change My E-Mail Communication Preferences?
With the exception of the mandatory transactional and business relationship emails mentioned above, recipients have an opportunity to update their email communication preferences. Customers may choose to “opt-in” or “opt-out” from these email communications at will.
To Unsubscribe: You may unsubscribe from specific email categories by clicking the “unsubscribe” link included at the bottom of any email sent by the Company or its Affiliates.
How Can I Correct Or Update My Information?
When you contact us or submit a request, we may include the information you provide to us in your customer account profile. If your information changes, you can correct, update, or remove your information provided to us by sending an email to the Company’s Customer Success Team at info@sohoproperties.com.
How Does The Company Protect My Information?
Security Measures and Safeguards
The security of our users’ information is very important to us. When users submit personal information via the Services, that information is protected by generally accepted industry standards, and in accordance with applicable data privacy laws, including both online and offline security measures and safeguards. The Company uses a combination of administrative, technical, personnel, and physical measures to safeguard personal information in its possession against loss, theft, and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.
If you think your interaction with us is no longer secure (for example, if you feel the security of any account you have with us has been compromised), please immediately notify us of the problem. However, please remember that no method of electronic storage or transmission over the internet is one-hundred percent secure and, therefore, while we strive to protect your personal information, and will comply with applicable data privacy laws, we cannot guarantee the absolute security of such information.
Phishing
Phishing describes an internet scam in which inauthentic communications that appear to come from a legitimate source but are sent in an attempt to trick you into providing confidential information. To learn more about phishing, click on www.occ.gov/consumer/phishing.html. If you believe you have been the victim of a scam, you can file a complaint with the Federal Trade Commission at: www.consumer.gov/idtheft/.
Do Not Track Signals
At this time, the Services do not recognize or respond to browser’s “Do Not Track” signals.
Data Retention
We will retain your information for the period necessary to fulfill the purposes for their collection as outlined in this Privacy Policy, unless a longer retention period is either mandated by the Company’s contractual requirements, internal policies, or otherwise required or allowed by applicable law. We may retain backup information related to any account/interaction on our servers for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial, or legal
requirements. Where it is not possible to remove or delete all information, the Company will continue to safeguard your information as set out in this Privacy Policy.
Sensitive Information
We do not intentionally collect sensitive personal information, such as political opinions, religious or other beliefs, health information, criminal background information, sexual history or sexual orientation information, or trade union membership (“Sensitive Information“). Please do not disclose it on the Services. If you do provide Sensitive Information to us, we will have access to it, and it will be treated in the same way as is information that is not sensitive.
Personal Information of Children
The Services are for a general audience and are not targeted to children. The Company, its Affiliates, and service providers do not knowingly collect, solicit, or share personal information from children under the age of sixteen (18) without parental consent. If such a situation is discovered, we will delete that information immediately. If you believe the Company has any information from a child under the age of sixteen (16), please contact us at info@sohoproperties.com.
California Privacy Rights
For users of the Services that are residents of the State of California, please review your rights under the California Consumer Privacy Act (“CCPA“), California’s “Shine the Light” law, provides you with an explanation of how you may exercise your rights, and provides you with additional disclosures as required under CCPA.
Using/Accessing Our Services From Outside the United States
The Company is a California corporation with its headquarters located at 31 West 27th Street, 9th Fl, New York, NY 10001, United States. Our Services are targeted at residents of the United States and our Services are governed by, and operated in accordance with, the laws of the United States. The United States is where the Services, including our servers and central database, are hosted, located, and operated. If you are accessing the Services from outside the United States, you will be voluntarily transmitting your Personal Information to the United States where your information will be stored and processed by the Company and/or its service providers.
There are obvious risks that apply when data are transferred from one jurisdiction to another (e.g., an unauthorized interception of the data, misuse, etc.) and the data protection and other laws of other countries might not be as comprehensive as those in your country. Additionally, in certain circumstances, law enforcement or regulatory agencies, courts, or security authorities may be entitled to access your personal information. Your Personal Information will be transferred to and processed in the United States and by those third parties with whom we share your information as described in this Privacy Policy. Please be assured that we take commercially reasonable steps to ensure that your privacy is protected.
Changes To Our Privacy Policy & Communicating Changes
This Privacy Policy is subject to change at any time. All changes will be posted on the Site. If the changes are significant, we will notify you by email (at the last email we have on file for you) or by prominently posting a notice on our Services. Changes will become effective as of the earlier of the date we post the revised Privacy Policy, send an email detailing any changes, or post such a notice. We encourage you to review our Privacy Policy periodically to ensure that you remain informed of changes that may have occurred, including changes that relate to what information we collect, how we use it, and how we share it. By continuing to use the Services after a change has taken place, you are confirming that you have read and agree to the latest version of this Privacy Policy and expressly consent to the use of your Personal Information as detailed herein.
Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose your Personal Information to others. In the event of a sale, merger, public offering, bankruptcy or other change in control of the Company and/or its Affiliates, your information may be shared with the person or business obtaining ownership and control. Disclosure of your information may be required by law where we have a good-faith belief that such action may be necessary to comply with a current judicial proceeding, a court order, or legal process. In such cases, we may raise or waive any legal objection or right available to us.
Third-Party Services
Other websites and services to which we link, through which you access the Services, or share information from the Services and which are not owned or controlled by us are not subject to the terms of this Privacy Policy. We are not responsible for the privacy practices or the content of any other web sites or services and any visit you make to those other services is at your own risk. We do not control third-party technologies or services and their use is governed by the privacy policies of third parties using such technologies. Such third party’s use of any information you share is governed by the third party’s privacy policy.
Interpretation
If any provision of this Privacy Policy (including any attachment) is held to be invalid, illegal, or unenforceable by a court or regulatory authority of competent jurisdiction, the rest of this Privacy Policy will remain valid and enforceable to the fullest extent permitted under applicable law. If the main body of this Privacy Policy conflicts with the terms of any addenda referenced herein, the addenda will control.
Company Contact Information
To ask questions or comment about this Privacy Policy and/or our privacy practices, please contact the Company via email at info@sohoproperties.com. For users with disabilities that would prefer to speak via phone, you may reach us at +1-212-966-9600.