Privacy Policy

LAST UPDATED:  29 August 2024

Pembroke Real Estate LLC and its affiliates  (the “Company,” “we,” or “us”) want you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Software applications operated by third-party service providers and made available by us for use on or through computers and mobile devices (the “Apps”);
• Our social media pages (collectively, our “Social Media Pages”);
• Email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the services provided through Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services may collect Personal Information, including:

• Name and employer’s name
• Postal address
• Telephone number
• Email address
• Log in credentials (for tenants’ administration portals)
• IP address
• Any Personal Information that you might include in messages to us when you contact

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways through the Services, including, for example, when you register an account to access a software application, or request service through a tenant administration portal or respond to a survey.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
• To provide the Services’ functionality to you, such as providing tenants with accounts, accessible via a login page, where tenants can access tenant amenity services or building management services, or providing you with related benefits, special promotions, or customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise.
• To send administrative information to you, such as changes to our terms, conditions, and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Analyzing Personal Information for business reporting and providing personalized services.
• To better understand your interests and preferences, so that we can provide you with excellent customer service and improved tenant experience.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

• Aggregating and/or anonymizing Personal Information.
• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.
• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new services;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests. 

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Information  

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• You can consult the list and location of our affiliates here .  Our affiliates will be responsible for handing all of your legitimate requests regarding shared Personal Information.
• To our third party service providers, to facilitate services they provide to us.
• These can include providers of services such as website hosting, platforms which provide the tenant login page where tenants can login to access tenant amenity services or building management services, data analysis, information technology and related infrastructure provision, email delivery, auditing, and other services.
• By using the Services, you may elect to disclose Personal Information.
• On message boards, chat, profile pages, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
• This may include laws outside your country of residence.
• To cooperate with public and government authorities.
• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.
• To cooperate with law enforcement.
• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
• To enforce our terms and conditions; and
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

The collection and processing Other Information are described in Pembroke’s Cookies & Similar Technologies Policy.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt out from receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking on the “Unsubscribe” link in each email or emailing us at privacy@pembroke.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information 

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.  If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).  

If applicable, you may also lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA AND UK: Some non-EEA/UK countries are recognized by the European Commission and/or the UK government as providing an adequate level of data protection according to EEA/UK standards (the full list of countries recognized by the EEA is available here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en and countries recognized by the UK government are listed here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-transfers-a-guide/. For transfers from the EEA/UK to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.   

CONTACTING US

Pembroke Real Estate LLC, a company incorporated under the laws of Massachusetts, USA, whose principal place of business is at 255 State Street, Boston, MA 02109 USA, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at privacy@pembroke.com, or:

Pembroke Real Estate LLC
255 State Street
Boston, MA 02109 USA

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. 

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), we are providing the following additional details regarding the categories of “Personal Information” (as that term is defined by the CCPA) that we collect, use, and disclose about California residents.  This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at Company.

Categories of Personal Information Collected, Disclosed, Sold, and Shared

The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.  We do not “sell” Personal Information or share it for purposes of cross-context behavioral advertising.  For purposes of this Privacy Policy, “sell” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, contact information, and online identifiers	Our affiliated entities and third-party service providers
Personal information, as defined in the California customer records law, such as name and contact information	Our affiliated entities and third-party service providers
Characteristics of protected classifications under California or federal law, such as age and gender	Our affiliated entities and third-party service providers
Commercial information, such as transaction information	Our affiliated entities and third-party service providers
Internet or network activity information, such as browsing history and interactions with our Services	Our affiliated entities and third-party service providers
Geolocation data, such as approximate location derived from IP address	Our affiliated entities and third-party service providers
Audio and video information, such as security video footage	Our affiliated entities and third-party service providers
Professional or employment related information, such as current profession	Our affiliated entities and third-party service providers
Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics	Our affiliated entities and third-party service providers

Sources of Personal Information

We collect Personal Information from:

• Our interactions with you, for example, when you create an account or contact customer service; and
• Our affiliates, publicly available online sources, and joint business partners.

Purposes for the Collection, Use, and Disclosure of Personal Information

As described above under the “PERSONAL INFORMATION” section, we collect, use, disclose, sell, and share Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including to:

• Develop, improve, repair, and maintain our products and services;
• Fulfill your requests; 
• Advertise, and market our products and services;
• Conduct research, analytics, and data analysis;
• Disclose Personal Information to our service providers to enable them to provide services to us such as information technology and related infrastructure provision, email delivery, customer service, auditing, and other services;
• Maintain our property and our records;
• Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping; and
• Comply with law, legal process, and internal policies, and exercise and defend legal claims.

Retention Period

We retain each category of Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

Individual Rights and Requests

Requests to Know and Delete

If you are a California resident, you may request:

1. To receive the following information:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   1. The categories of Personal Information about you that we “sold” or “shared” for purposes of cross-context behavioral advertising and the categories of third parties with whom we “sold” or “shared” such Personal Information; and
   1. The business or commercial purpose for collecting, “sharing,” or “selling” Personal Information about you;
   1. The specific pieces of your Personal Information; and
   1. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information.
2. To correct inaccuracies in your Personal Information.
3. To delete your Personal Information we collected from you.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

To make a request, please contact us at:  

https://privacyportal.onetrust.com/webform/0eed0401-3fa0-4eac-af40-ebc20bde018d/a4c57026-1e7c-4a0d-967c-33387e21bfa1 or 844-643-2487. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Do Not Track Signals

We do not currently respond to browser do-not-track signals.