PRIVACY POLICY
PRIVACY POLICY
WS Asset Management, Inc. and its affiliates (collectively, “WS Development”) are committed to protecting the privacy of visitors to this web site (the “Site”).
The purpose of this Privacy Policy is to inform you of what kinds of information we may gather about you when you visit the Site, how we may use that information, whether we disclose it, and the choices you have regarding our use of and your ability to manage and edit the information. This Privacy Policy applies to the Site. This Privacy Policy does not apply to other web sites to which we link.
If you are a California resident, you have additional rights as described here.
INFORMATION COLLECTION
We collect personal information when you wish to use certain features of the Site, such as registering to receive information from us, submitting questions or comments to us, or providing feedback to us. When you choose to use these features, we ask for information such as your name, e-mail address, mailing address, phone number, and other personal information (“Personal Information”). We may use Personal Information for the following general purposes: to fulfill your requests for certain information and services offered through the Site, to create personal accounts, to send users press releases, updates, or other general information about WS Development and its properties, to meet any applicable legal and regulatory requirements, and to respond to any questions, comments, or feedback you submit.
Through the Site, we may automatically gather certain information about the use of the Site, such as how frequently certain areas of the Site are visited, including through the use of cookies, web beacons and other technologies.
You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser (such as Internet Explorer, Chrome, or Firefox) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you turn cookies off, you may not have access to many features that make your site experience more efficient and some of our services may not function properly. For more information about cookies, please see www.allaboutcookies.org/.
PROTECTING PERSONAL INFORMATION
When you give WS Development your Personal Information, we take steps to ensure that your information is treated securely. WS Development uses industry-standard encryption technologies when transferring and receiving sensitive visitor data via the Site. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, WS Development cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems, and to protect against the loss, misuse, or alteration of information that we have collected.
DISCLOSURE
Unless otherwise stated in this Privacy Policy, we do not sell, trade or rent your Personal Information to others. We may permit certain trusted partners to access your information in connection with their performance of services to maintain and operate the Site and certain features on the Site. We may also share your information with the relevant owners, landlords, and brokers if you express an interesting in purchasing or leasing commercial or residential spaces at any of our properties. We do not otherwise disclose any Personal Information or any information about your individual visits to our Site except when we believe in good faith (i) that the law, a court order, or a subpoena requires such disclosure or (ii) that such disclosure is necessary to protect the security of the Site; to enforce or apply our online Terms of Use or other agreements; to prevent or investigate a possible crime, such as fraud or identity theft; or to protect the rights, property, or safety of WS Development or others.
We allow you to opt out of receiving e-mail from us. If you no longer wish to receive emails from us, you may opt-out of receiving them by emailing us at info@wsdevelopment.com.
We use non-personally identifiable information in the aggregate so that we can improve the Site and for business and administrative purposes. We may use or share with third parties for any purpose aggregated data that contains no personally identifiable information.
Our website may share information with companies that provide support services to us (such as web hosts) or that help us market our products and services (such as email vendors). These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.
We may decide, for strategic or other reasons, to sell, buy, merge, or otherwise reorganize one or more of our businesses or the properties or other assets thereof. A transaction of this type may involve the disclosure of Personal Information to prospective purchasers. In such cases, we will take reasonable measures to protect the Personal Information we disclose, for example, by requiring the prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the Personal Information.
Your Personal Information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with or sell our assets or equity interests to another organization, whether voluntarily or through insolvency or bankruptcy proceedings. If such a transfer occurs, the successor organization will acquire our rights to use your Personal Information, but the successor organization’s use of your Personal Information will still be subject to this Privacy Policy and the privacy preferences you have expressed to us.
Except as otherwise stated above, we will not publish or provide your e-mail address or other Personal Information to third parties without your consent.
UPDATING PERSONAL INFORMATION AND PREFERENCES; OPTING OUT
If you have provided us with Personal Information and would like to change, correct, or request access to your Personal Information or update or cancel your registration, you may do so by emailing us at info@wsdevelopment.com. In addition, you may opt out of receiving any or all communications from us by emailing us at info@wsdevelopment.com or by using the “unsubscribe” link that appears in e-mails received from us.
CHILDREN
The Site is not directed to children under the age of 13, and we do not solicit or knowingly collect any Personal Information from children under the age of 13. We encourage families to obtain additional information about safe use of the Internet at http://www.consumer.ftc.gov/topics/kids-online-safety.
NOTICE TO INTERNATIONAL USERS
The Site is operated in the United States. If you are located outside of the United States, you should be aware that we will collect, process, and maintain your information in the United States. By using the Site, accessing the Site, or providing any information to the Site, you consent to the transfer of your information to the United States, which may not offer the same level of privacy protection that would be required in your home country, and to the processing and maintaining of that information as described in this Privacy Policy.
PRIVACY POLICY CHANGES
We reserve the right to change our Privacy Policy for the Site at any time. If we decide to change our Privacy Policy, we will post the revised Privacy Policy on the Site and use commercially reasonable efforts to notify you so that you will know what information we gather, how we might use that information and whether we will disclose it to anyone. Please check periodically to keep informed of any changes. If we materially change this Privacy Policy, the new terms will apply only to (i) Personal Information and other information provided under a prior version of the Privacy Policy by users who affirmatively consent to the new terms and (ii) Personal Information and other information provided after this Privacy Policy has been amended. In other words, your continued use of this Site after we have posted the revised Privacy Policy constitutes your agreement to be bound by the revised Privacy Policy on a prospective basis, but we will honor the terms that were in effect when we gathered data from you.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: July 2020
This Privacy Notice for California Residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
If you have any questions or comments about this notice, the ways in which we collect and use your information described here and otherwise in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
WS Asset Management, Inc.
Attn: Reception
617-232-8900
INFORMATION WE COLLECT
We collect the information described in Information Collection available to us through your use of the Site. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include publicly available information from government records or deidentified or aggregated consumer information.
We may have collected the following categories of personal information from our consumers over the past 12 months:
Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name
Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Please visit Information Collection for information on our sources for collection of personal information.
USE AND SHARING OF PERSONAL INFORMATION
We do not sell your personal information. Please review Disclosure to see how we use and share your personal information.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sales of Personal Information
We do not sell your personal information. However, from time to time, we may share our list of contacts with third parties who are providing, sponsoring, or co-sponsoring events on our behalf or for their own purposes.
In the preceding 12 months, shared the following categories of personal information about our consumers to the following categories of third parties.
Category: Identifiers
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name
Category of Third Party to whom Personal Information is Disclosed: May be shared with event organizers, sponsors or co-sponsors to promote WS Development, the organizer or sponsor, or any third party
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you the requested information, which may include:
– The categories of personal information we collected about you.
– The categories of sources for the personal information we collected about you.
– Our business or commercial purpose for collecting that personal information.
– The categories of third parties with whom we share that personal information.
– The specific pieces of personal information we collected about you (also called a data portability request).
– If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we 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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
– Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
– Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
– Debug products to identify and repair errors that impair existing intended functionality.
– Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
– Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
– 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
– Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
– Comply with a legal obligation.
– Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
You have certain rights to access, update or correct your personal information as provided in Updating Personal Information and Preferences; Opting-Out. In addition, to exercise the access, data portability, and deletion rights described in this Privacy Notice, please submit a verifiable consumer request to:
WS Asset Management, Inc.
Attn: Reception
617-232-8900
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you must mail to the above address a notarized power-of-attorney, identifying yourself in a verifiable manner, and designating with specificity the actions that your agent is authorized to perform, or information authorized to request, on your behalf. The power-of-attorney must be signed by you within 12 months of the date on which we receive the request.
You may make a verifiable consumer request for access or data portability only twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information and confirm that you are a California resident. We cannot 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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your personal information.
For additional rights you may have relating to our collection or use of your personal information, please see Updating Personal Information And Preferences; Opting-Out.
NON-DISCRIMINATION
Financial Incentives
The CCPA allows businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information. Where we offer these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
Non-Discrimination
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write to us at the Contact Information.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Last updated: July 2020