We are the data controller and therefore we are responsible for, and control the processing of, your Personal Data (defined below) in accordance with applicable law.
1. TYPES OF INFORMATION WE COLLECT
We collect both “Personal Information” and “Anonymous Information” about our Users. Personal Information or “Personal Data” (collectively, “Personal Information”) is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Anonymous Information is information that cannot be used to contact or identify you and is not linked to information that can be used to do so. We passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
A. VOLUNTARILY SUBMITTED INFORMATION
We collect information, including without limitation, your name, street address and email address, that you voluntarily provide to us during your use of the Website and/or Service, such as when you register for updates about The Ritz-Carlton Residences, New York, NoMad.
B. INFORMATION COLLECTED VIA TECHNOLOGY
We may collect information from your use of the Website and Service, including your hardware model, browser type, operating system and Internet Protocol (IP) address. If you are using a mobile device, RP 1185 may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use tools such as cookies to gather information as well.
We use third party services, such as Google Analytics, to track and analyze online behavior data of Users. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.
2. HOW WE USE YOUR INFORMATION
A. PERSONAL INFORMATION
We may use your Personal Information in order to provide you with updates and other information regarding the The Ritz-Carlton Residences, New York, NoMad, among other purposes. Where you have allowed for RP 1185’s processing of your Personal Information, subject to applicable legal and ethical obligations that may apply and our lawful ability to enforce our rights or your obligations to us, you may withdraw that consent at any time and opt out.
B. ANONYMOUS INFORMATION
We may use Anonymous Information in order to perform internal operations on the Website, improve the Website, and help us track trends and analyze patterns, among other purposes.
3. HOW WE SHARE AND DISCLOSE INFORMATION
In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.
A. SERVICE PROVIDERS
B. COMPLIANCE WITH LAWS, LAW ENFORCEMENT AND SAFETY
We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend RP 1185’s, or a third party’s, rights or property.
C. AGGREGATED ANONYMOUS INFORMATION
Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.
D. BUSINESS TRANSACTIONS
4. YOUR CHOICES
5. UPDATING YOUR PERSONAL INFORMATION
You may revise your Personal Information by contacting us directly at email@example.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
This Website and Service are not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at firstname.lastname@example.org so that we may delete and remove such information from our system.
7. SECURITY AND DATA RETENTION
9. CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at email@example.com.
10. EU RESIDENT PRIVACY RIGHTS
To the extent required by law, we provide EU residents with reasonable access to the Personal Information they provide to us, a portable copy of the information and the ability to review, correct, delete, restrict or object to the processing of such information. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information would compromise others’ privacy or legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the information is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made and a contact point for further inquiries. To protect your privacy, RP 1185 will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. If you would like to review or update your Personal Information or preferences, or have your information removed from our mailing lists, please let us know by emailing us at firstname.lastname@example.org or by writing to us at RP 1185 LLC, 70 East 55th Street, 23rd Floor, New York, NY 10022. EU residents may also report privacy complaints directly to their local data protection authorities. You may contact us to be directed to the relevant authorities, as well.
11. COOKIES AND OTHER DATA
We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:
a) Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
b) Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html.
i. Opting Out of Cookies: You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.
12. CONTACT US
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