Welcome. You have arrived at a website provided by The Related Companies, i-bei ventures (“Related,” “Company” or “we,” “our” or “us”). We respect your privacy and want to protect your personal information.

This Privacy Policy governs the Company’s family of brand websites, their subdomains, and all portals, applications, products, services, events, and any interactive features or other services that post a link to this Privacy Policy (each, a “Site”), as well as Related Connect, Related 360 Life, Related Office, the Hudson Yards app, The Square Rewards app and any future developed apps by Related (the “Apps”). This Privacy Policy also applies to information (including the “Personal Information” defined below) that we may collect from you in person at our physical locations (each a “Location” or collectively, “Locations”), via phone calls or other communications with our representatives, by using Company-provided Wi-Fi, by purchasing tickets at Locations, at Company-sponsored events, or in any other instance when you contact us. We refer to all of the above as our “Services.”

All references to “you,” “your” or “User” in this policy means the person who accesses, uses, or registers for our Site or our Services. If you use or access our Site or our Services on behalf of a company or organization, such company or organization will also be considered to be a party to this Privacy Policy and any agreements you make.

If you voluntarily provide your information in the course of interacting with our Sites or App, applying to lease or buy a property managed or owned by us, visiting one of our Locations, or otherwise using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy. This Privacy Policy is part of our Terms of Use, which govern your use of the Site and Services. By using our Sites, contacting us to inquire about our Services or properties, or visiting our Locations, you consent to our Privacy Policy and agree to our Terms of Use.

In this Policy, we tell you what information we collect from you, the sources from which we get that information, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and what choices you may make about that information. These choices may differ depending on where you live, so please check the location-specific choices for your state or country of residence. If you have questions about this Privacy Policy, contact us at privacypolicy@i-bei.com.

This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third-Party Services”), which are governed by their respective privacy policies. If you click a link for these Third-Party Services, please review the corresponding privacy policy and terms of use for the Third Party, as we are not responsible for their information collection practices.  

What Information We Collect

The type of information that we collect depends on the context in which you interact with our Site and our Services.

1. Information You Provide to Us

In connection with the Services we provide, we may ask you to provide us with certain information, including:

• contact information, like your first and last name, email address, home or business address, other shipping or billing addresses, telephone number, or mobile number;
• consumer information, like a username, your purchase and/or service history, your preferences or a consumer profile;
• financial information needed to complete a transaction with us, including credit card or debit card number, banking information, or other financial information;
• employment or tenancy information, such as a driver’s license, social security number, passport number, your birthdate, your educational information, your prior employment, your military or veteran status, your marital status, and information to validate your right to work for the Company, including immigration status and/or state or federal licensing information, if applicable.  This may include categories of information that is designated as “Sensitive Personal Information” under applicable law;
• demographic information, such as your country, state, or county of residence or business operation (“Demographic Information”); and
• other information that could reasonably be used to identify you personally or identify your household or device;

Separately, you also may provide us with the following personal information when you interact with us or the Services:

• Social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Site and other service (such as apps, tools, payment services, widgets and plug-ins offered by social media services like Facebook and Twitter) or posted on social media pages (such as our social media page or other pages accessible to us);
• recordings of your voice, as may be contained in customer service phone recordings kept for quality assurance purposes or training (you will always be notified in advance if we record our calls with you for quality assurance purposes);
• your image or likeness as captured on audiovisual recordings in the public spaces of our Locations;
• your biometric information (such as a handprint or fingerprint) if used for providing secure access to one of our Locations; and/or
• your geolocation information if you have enabled your device’s location services or if you type in your address.

Additionally, we may obtain other identifying information from you where you expressly provide us with the information. This information could come from interviews and telephone calls with you, letters, emails or other communications from you, information from your referral or reference sources, information provided via web forms or inputs/uploads into our Site or at events we attend or sponsor, documents you have provided to us, and employment applications.

These items are collectively referred to in this Privacy Policy as “Personal Information.”

We may collect this Personal Information when you:

• Request information from us via forms or emails, such as signing up for our newsletter or requesting information about a Location or a future Location;
• Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Sites, products and/or Services (including at in-person events such as open houses, or by phone or email);
• Register and create an account on our Site(s);
• Sign up or request to be placed on our mailing and/or email marketing lists;
• Sign up for free Wi-Fi at one of our Locations;
• Purchase tickets, products or Services from us;
• Apply for employment with one of our brands;
• Apply for a lease or to purchase a unit at one of the Properties that we own or manage;
• Are a resident or visitor of one of the Properties we own or manage;
• Use Related Connect;
• Request maintenance or concierge support and assistance, or inquire about your maintenance or concierge interactions with us;
• Provide billing information to us;
• Post user-generated content in your Property’s residential forum;
• Participate in a sweepstakes or contest sponsored or co-sponsored by us; and/or
• Otherwise interact with the Sites or our representatives.

Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services, including ordering products or Services, submitting inquiries, or signing up for newsletters or marketing lists.

2. Information that Is Automatically Collected

In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site(s) or use Wi-Fi at any of our Locations (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site(s) or with Wi-Fi at one of our Locations. Usage Information may include:

• Your IP address, MAC Address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier (“Device Identifier”);
• Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
• Referring and exit web pages and URLs;
• The areas within our Site(s) that you visit and your activities there, including remembering you and your preferences;
• Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
• Your Device characteristics; and
• Certain other Device data, including the time of day you visit our Site(s).

 

For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you.  If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer’s settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

1. 1. Our Use of Cookies and other Tracking Technologies

As part of our automatic collection of Device or Usage Information, we may use various methods and technologies to store or collect such Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site(s), include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

• Cookies.  A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, and other types of cookie technology to store information on local storage. 
• Web Beacons.  A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.  
• Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. 
• ETag, or entity tag.  An Etag or entity tag is a feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. 
• Browser Fingerprinting.  Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
• Recognition Technologies.  Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). 

 

We may use Tracking Technologies for a variety of purposes, including:

• To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of cart or payment functionality;
• To facilitate navigation, display data more effectively, collect statistical data, personal your experience while using the Site, and recognize your computer to assist in your use of the Site;
• To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
• To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
• To deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements and/or content.

 

You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our “Ads and Information About You” section below.

3. Information from Third Parties

We may collect information about you from other sources, including consumer credit reporting agencies or background check vendors, in order to evaluate your lease application and/or application for employment. We also may obtain Personal Information about you if you are listed as a dependent or beneficiary of a Related employee or tenant or owner. We may also obtain information about you (e.g., an email address), if another User has forwarded information about our Services to you. We also may also obtain information about you from marketers and market research firms. We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.

In addition, the Site(s) may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). We also may provide links to allow third parties to process credit card and/or electronic payments. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Site. 

Why We Collect Information

We may use your information for various purposes, including:

• Responding to your requests for information;
• Maintaining your account;
• Providing Services to you;
• Providing free wireless internet at any of our Locations;
• Verifying your identity and for fraud prevention;
• Processing your payments or purchases;
• Analyzing and evaluating your employment application;
• Analyzing and evaluating your lease and/or purchase application;
• Providing you with maintenance and/or concierge services; 
• Providing you with updates and information about a Related property, or a service we provide;
• Sending you marketing information about Related and our affiliated entities;
• Sending you email communications such as electronic newsletters about our products, Services, events, and promotions;
• Improving the effectiveness of our Site, our marketing endeavors, and our product and service offerings;
• Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you;
• Helping us address problems with and improve our Site and our products and services, including testing and creating new products, features, and services;
• Providing mobile marketing messages and other communications and messages;
• Protecting the security and integrity of the Site, including understanding and resolving any technical and security issues reported on our Sites;
• Engaging in analysis, research, and reports regarding the use of our Sites and Services;
• For internal business purposes;
• Complying with the law and protecting the safety, rights, property or security or Related, the Services, and the general public; and
• For other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

When We Disclose Information

Examples of when Related may share your information include as follows:

(a)          Other Community Members.  Certain features of our Site(s) and Services allow you to publicly share comments with other users. Any information that you submit through such features is not confidential and can be used by us for any purpose.  In addition, when you use the Site or the Services, we may share certain Personal Information (such as your name, photo, contact information, or other information you have made visible in the App or Site) to other users of the App or Site in order to facilitate contact among residents and/or between residents and our representatives. Note that other users are not bound by Related’s Privacy Policy. You agree that Related is not responsible for the actions of other users with respect to any Personal Information disclosed in the App or Site. It is important that you review the applicable Privacy Policy for the event, sponsoring organization, property or Location before providing your information in connection with that event. We request that you treat all Personal Information received about other Users with the same respect and care you would want for your own information.

(b)          Third Parties Providing Services to Related. We may use Third-Party Service providers to perform certain services on behalf of us or the Site(s) or Services, such as: (i) creating and updating Site(s) and app functionality; (ii) billing or processing credit cards, and/or electronic or manual payments; (iii) assisting us in Site(s) and app operations; (iv) managing a database of resident, tenant, customer and consumer information; (v) hosting the Site(s); (vi) designing and/or operating the Site’s features; (vii) providing any of the Services necessary to operate our business; (viii) tracking the Site’s activities and analytics, including marketing and market research; (ix) data enhancement (to learn more about our customers); (x) enabling us to send you special offers or perform other administrative services, such as customer service, security, tech, operational support, email and legal services; (xi) providing free Wi-Fi services at our Locations; and (xii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Service. You should be sure that you read and agree to those policies and Terms.

(c)           To Protect the Rights of Related and Others. To the fullest extent permitted by applicable law, we may also disclose your information when required to by law or if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Related, its affiliates, third parties or the general public (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) to respond to claims that any content violates the rights of a third party. This includes exchanging information with other companies and organizations for fraud prevention, spam/malware protection, and other similar purposes. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest any requests for such disclosures, all without notice to you. 

(d)          Affiliates and Business Transfer. We may share your information with our parent, subsidiaries, and affiliates. As part of this sharing of information with our parent, subsidiaries and affiliates, this means that once you provide us with information, any one of our related entities may use your information including for marketing purposes, pursuant to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process. 

We may aggregate, de-identify, and/or anonymize any information collected through the Site(s) or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

We also may share your information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. (If you are a California resident, you have the right to request additional information regarding the “sale” of your information. Please see the Section entitled “Your California Privacy Rights” below about these rights.) In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy.

Ads and Information About You

You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site(s), such as the pages you have viewed. This collection and ad targeting takes place both on our Site(s) and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.

We may also use Tracking Technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site. To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here. If you would like more information about behavioral advertising practices, go to the Digital Advertising Alliance’s WebChoices tool at www.aboutads.info. To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices. You may also click on the informational icon contained within each interest-based ad. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

You can set your web browser to alert you when a cookie is being used. You can also get information on the duration of the cookie and what server your data is being returned to. You then can accept or reject the cookie. Additionally, you can set your browser to refuse all cookies or accept only cookies returned to the originating servers.

You can opt in or out of cookies at any time – except strictly necessary cookies (these are used to help make our website work efficiently). If you wish to restrict or block the cookies set by any website, you can do this through the web browser settings for each web browser you use, on each device you use to access the internet. You may “clear” all cookies to force our cookie preferences panel to restart so that you may change your cookie preferences at any time. Currently, you cannot synchronize your settings between your browsers and devices (e.g., your computer and your smartphone), so you must manage your cookies on each browser, on each device.

Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org. Some of the more popular browsers (and links to manage your cookies on each) are:

Microsoft Edge

Firefox

Safari

Google Chrome

Some services may not function or may have more limited functionality if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them ‘trusted websites’ in your web browser.

If you do not wish to accept cookies from one of our emails, you can choose not to download any images or click on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies, whether included on websites or in emails. Depending on your email or browser settings, cookies in an email may sometimes be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). For more information, refer to your email browser or device instructions.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads) or ads that are not targeted at you which may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.

Your Choices About the Information We Collect and “Do Not Sell”

You have many choices when it comes to your Personal Information. You may always change the settings on your Device (such as location settings, cookies, or allowing apps to track you) to limit some of the information that is shared with us.

With respect to our marketing activities, if you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at marketing@related.com to opt out, or click the link in the email to “unsubscribe.”

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing.  To do so, please email us at privacypolicy@i-bei.com.  Your choice will not affect our ability to share information in the other ways described in this Privacy Policy. 

Depending on the jurisdiction in which you reside, you may have additional options to access, correct, delete, or limit the information you have provided to us. Please see the Location-Specific Privacy Notices below.

You may also adjust your cookies as described in the Ads and Information About You section if you are concerned about targeting and advertising.

Please note that certain of your personal information, such as your name or other identifying information, may remain in our database even after a data request in order to maintain the integrity and historical record of our database and systems. 

Children’s Privacy

Related recognizes the importance of children’s safety and privacy. The Site(s) are not designed to attract children and are not intended for use by any children under the age of 16. We do not request, or knowingly collect, any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided their information to us, please contact us at privacypolicy@i-bei.com to request the deletion of that information.

Do Not Track Disclosures

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.  If changes to applicable law require recognition of the Do Not Track signal, we will modify this section accordingly.

Visitors to the Site Outside of the United States and International Data Transfers

Because Related works with global companies and technologies, we may transfer your Personal Information outside of the country in which it was originally provided. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S.

Our transfer of your Personal Information may include transfers to third parties, such as service providers or affiliated entities who are located outside the United States, United Kingdom, or the European Union, where data protection laws may not offer the same level of protection as those in the U.S., U.K., E.U., or European Economic Area (“EEA”). When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information. Our transfers of your personal data outside of the E.U. are safeguarded by data processing agreements (“DPAs”) incorporating Standard Contractual Clauses. You may request a copy of the relevant portions of such agreements that may be applicable to you by contacting us at privacypolicy@i-bei.com.  Please include the nature of your request in the subject line. 

The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

Updating Personal Information

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at privacypolicy@i-bei.com to delete your information (if applicable).

If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.

In addition, please note that if you implement a deletion request but later sign up for information or Services, your most recent request will control our information relationship with you. 

Links

For your convenience, the Site(s) and this Privacy Policy may contain links to other websites. Related is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site(s) should be deemed to imply that Related endorses or has any affiliation with the links.

Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.

 

LOCATION-SPECIFIC PRIVACY NOTICES:

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

This section of the Privacy Policy applies if you are a data subject who resides in or is located in the European Economic Area (“EEA”).  We adopted this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section. Under applicable law, Related is considered the “data controller” of the Personal Information we handle under this Notice. As a data subject under GDPR, you have certain data protection rights.  These rights include:

 

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Related relied on your consent to process your personal information.

 

 

1. Legal Basis for Processing Personal Information Under GDPR. 

Related’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

 

We rely on the following legal bases for processing your Personal Information:

 

• Processing of your Personal Information is necessary to perform a contract or transaction with you;
• You have given us permission to do so (consent);
• The processing is in our legitimate interests, and it is not overridden by your rights; or
• To comply with the law.

 

2. Retention of Information

Related will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy or provided to you at the time of the collection of the information. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

Related will also retain Usage Data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

 

3. Transfer of Information

Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

 

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it there.

 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

Related will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

4. Disclosure of Personal Information

Related may disclose your Personal Information in the good faith belief that such action is necessary to:

 

• To comply with a legal obligation;
• To protect and defend the rights or property of Related or its partners or affiliated entities;
• To prevent or investigate possible wrongdoing in connection with the Services or the Locations;
• To protect the personal safety of users of the Service or the public; and/or
• To protect against legal liability.

 

Disclosure for Law Enforcement - Under certain circumstances, Related may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

 

5. Exercising Your GDPR Rights:
   

Email Address: privacypolicy@i-bei.com

Please note that we may ask you to verify your identity before responding to such requests.

 

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first. 

 

For more information, please contact your local data protection authority in the EEA. 

 

Your Rights Under the UK GDPR

If you are based in the United Kingdom, the following provisions also apply:

UK GDPR means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

Your Rights Under the Lei Geral de Proteção de Dados (“LGPD”)

If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados (“LGPD”). These rights include:

• The right to confirmation of the existence of the processing;
• The right to access the data;
• The right to correct incomplete, inaccurate or out-of-date data;
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
• The right to the portability of data to another service or product provider, by means of an express request;
• The right to delete personal data processed with the consent of the data subject;
• The right to information about public and private entities with which the controller has shared data;
• The right to information about the possibility of denying consent and the consequences of such denial; and
• The right to revoke consent.

1. Legal Basis for Processing Data Under the LGPD

Related’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.  We rely on the following legal bases for processing your Personal Information:

 

• Processing of your Personal Information is necessary to perform a contract or transaction with you;
• You have given us permission to do so (consent);
• The processing is in our legitimate interests, and it is not overridden by your rights; or
• To comply with the law.

 

2. Duration of Processing

Related will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy or provided to you at the time of the collection of the information. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

Related will also retain Usage Data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

 

3. Exercising Your LGPD Rights.

If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the following options:

Email Address: privacypolicy@i-bei.com

Please note that we may ask you to verify your identity before responding to such requests. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days or let you know if we need additional time.

 

Your California Privacy Rights – Privacy Notice for California Residents

This section of the Privacy Policy applies solely to California residents.  We have adopted this policy to comply with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA have the same meaning when used in this section. Related’s California employees, prior employees, contractors and job applicants may have additional disclosures available to them. Current employees may review the notice to California employees on Related Insider. Job applicants may review the link to the notice in any job listing after January 1, 2023.  

California residents have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;
• To know the length of time we intend to retain each category of Personal Information;
• To know whether your Personal Information is sold or disclosed and to whom;
• To access your Personal Information;
• To delete the Personal Information you have provided to us, with certain exceptions;
• To correct your Personal Information if it is inaccurate;
• To access information about automated decision making and to reject such automated decision-making in certain instances;
• To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
• To limit the use of your SPI, if it is used for cross-contextual behavioral advertising or for the purpose of inferring characteristics about you;
• To opt out of the sale or sharing of Personal Information; and
• Not to be discriminated or retaliated against, even if you exercise your privacy rights.

The earlier sections in this Privacy Policy describe in detail what categories of information we collect and the purposes for which we use that information.

1. Request For Information, Correction, or Deletion

California consumers have the right to request, under certain circumstances, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months:

• The categories of Personal Information we have collected from you;
• The categories of sources from which we collected the Personal Information;
• The business purpose we have for collecting your Personal Information;
• The specific pieces of Personal Information we have collected about you.
• The categories of Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose;
• The categories of Personal Information that we have sold, or if we have not sold the Personal Information;
• The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;
• The business purpose we have for disclosing or selling that Personal Information; and
• The categories of Sensitive Personal Information we have collected, and whether such information is sold or shared, except for such information that is collected or processed without the purpose of inferring characteristics about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You also have the right to request that we correct or delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

As permitted by the CCPA/CPRA, if you request deletion of Personal Information that we have collected about you, we, our service providers, and our contractors may be unable to comply with such a request if your Personal Information is necessary to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
• Prevent, detect, and investigate security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another Consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with a legal obligation; or
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

2. Do Not Sell or Share My Personal information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. You may exercise this right as set forth in the section entitled “Exercising Your California Privacy Rights” below. 

3. Right to Limit Use of Sensitive Personal Information

California consumers have the right to limit the use of each type of Sensitive Personal Information (“SPI”) for each purpose with each type of third-party partner. Consumers can revoke this permission at any time. Please note that Related only keeps SPI for the transaction for which it is required. At this time, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.  We do not share your SPI for cross-contextual behavioral advertising or for the purpose of inferring characteristics about you.

4. Right not to be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. Unless permitted by California law, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, as permitted by California law, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to the value of your Personal Information, for instance, if you sign up for a newsletter with us, we may provide you with discounts for future Services. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

5. Personal Information We Collect About California Consumers

In connection with your relationship with us, Related has collected and sold or shared the following categories of Personal Information (set forth in section 1798.140(v)(1) of the CCPA) from consumers within the twelve (12) months prior to the date of this Privacy Policy:

 

For job applicants, current and past employees or contractors, we use this information for the purposes stated below: 

For Job Applicants:

• To recruit employees, including evaluation of marketing and job offering services, website traffic, and referral sources;
• To process your application for employment;
• To conduct employment-related background screening and/or reference checks;
• To send you correspondence and information relating to your application or your employment with the Company;
• To verify your identity, citizenship, or legal right to work for the Company, or to assist or cooperate with obtaining relevant immigration documents;
• To verify your educational background and/or degrees, certifications, or qualifications for the position you apply for;
• To verify your prior employment;
• To offer you employment with Company;
• For testing, evaluation and/or reporting metrics, including but not limited to aggregating or anonymizing such information for workforce analytics, data analytics, and benchmarking;
• To comply with applicable law or regulatory requirements, including legal requirements under state and federal law, law enforcement investigations or inquiries, as well as internal company reporting obligations, such as diversity, equity and inclusion initiatives and/or Equal Employment Opportunity Act reporting obligations;
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;
• For quality assurance purposes, including call monitoring or customer service, and debugging to identify and repair errors that impair existing intended functionality;
• For auditing related to a current interaction with the applicant or employee and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with this and other standards;
• To analyze the effectiveness of placement of job listings and job descriptions;
• For fraud prevention; and
• For internal research for technological development and demonstration.

For Employees, Contractors, and Past Employees/Contractors:

All of the above, plus:

• To track time and attendance;
• To administer employee benefits, such as medical, dental, commuter and retirement benefits, including the recording and processing of eligibility of dependents and beneficiaries, absence and leave monitoring, insurance and accident management, and rewards or discount programs offered to employees;
• To provide healthcare-related services, such as accommodations and/or services based on eligibility (e.g., disability, worker’s compensation, medical condition);
• To provide payroll, invoice, and tax services, including reimbursement for expenses, salary administration, payroll management, payment of expenses, payment of state and/or federal income taxes (if applicable), social security and unemployment taxes, and to administer other compensation-related payments, including bonuses and equity, if applicable;
• To conduct performance-related reviews, including performance appraisals, professional development, career planning, skills monitoring, job moves, promotions and staff re-structuring;
• To monitor work-related licenses and credentials and ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies or governing agencies;
• To provide employees with other employment-related services, such as handling of employees’ claims, travel for the Company, moving or relocation services, or administration of separation from employment; 
• To assist you in case of an emergency, including maintaining contact information for you, your partner or spouse, and/or your dependents in case of personal or business emergency;
• To maintain the safety and security of our employees, residents, tenants, contractors, visitors and others, including maintenance of security on Company websites, apps, intranets and/or extranets (such as monitoring email and internet access, and ensuring secure network access and data integrity), maintenance of physical security (including controlled entry to Company worksites and/or real estate assets), monitoring of worksite locations and/or real estate assets, including using biometrics or location monitoring for keys, key fob or key card entry to Company property, ensuring that employees, contractors and visitors comply with all applicable safety regulations;
• In connection with audiovisual surveillance of public spaces;
• For internal company directories;
• For video presentations, interviews, training materials, and/or web conferences within the scope of your employment or contract;
• For the tracking of Company-owned or Company-leased vehicles, computers, equipment, and devices, including, but not limited to, remote deletion of Company data on business or personal devices;
• For verification of proper use of Company resources;
• To facilitate a better working environment;
• To maintain commercial insurance policies and overages, including for workers’ compensation and other liability insurance; and
• For other purposes stated at or before the time of the collection of the information. 

Further, please note that under the CPRA, we may use your employee or applicant information for Company business or other notified purposes, provided that the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed.

6. Exercising Your California Privacy Rights

To exercise your California Privacy Rights, you may choose one of the following options:

Email Address: privacypolicy@i-bei.com

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice a year. You may call, email, or write us with your request at the contact information below. Please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We will respond to your request within 45 days or let you know if we need additional time. 

 

We may be unable to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

 

Your Nevada Privacy Rights

If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from the Related Site(s), you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally). 

As a Nevada resident, you may also request to opt out of us sharing such information about you.  To make this inquiry, please submit a request in writing to privacypolicy@i-bei.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out. [You must complete a separate request for each Related company.]

We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond. 

Your Virginia Privacy Rights

If you are a Virginia resident, you have the right under the Virigina Consumer Data Protection Act (“VCDPA”), upon a verified request, to:

• To confirm whether or not a controller is processing your personal data and to access such personal data;
• To correct inaccuracies in your personal data;
• To delete your personal data;
• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. 

To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us as follows:

Web Form for Access/Correction/Deletion/Do Not Sell Requests: 

Email Address: privacypolicy@i-bei.com

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Virginia Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Virginia resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

If we decline to take action on your request, you can appeal our decision by submitting an email to privacypolicy@i-bei.com entitled “Virginia Privacy Rights Appeal” and we will review your request and respond within 60 days of the receipt of your appeal with a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Virginia Attorney General. to submit a complaint. 

 

Questions / Changes in Privacy Policy 

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacypolicy@i-bei.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates.