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Privacy Policy

Effective on:  February 13, 2024.


At 29th Street, we want you to know that we value your personal information and that we respect your privacy. Please read our Privacy Policy for more information.


  1. DEFINITIONS


A. “You” and “your” mean the individual or entity visiting or using the Site.


B. “29th Street”, “we,” “us” and “our” applies to and individually refers to each of the following entities for purposes of this Privacy Policy only:

  1. 29th Street Management, LLC
  2. 29SC Development Company, LLC
  3. 29th Street Property Management LLC
  4. 29SC Ventures LLC

C. “Site” refers to 29th Street’s website at www.29sc.com, and other related websites, blogs, domains, and mobile sites maintained by 29th Street.


D. “Non-Personal Information” is any information that is not Personally Identifiable Information (defined below). Non-Personal Information includes, without limitation, Personally Identifiable Information that has been anonymized. 


E. “Personally Identifiable Information” or “PII” is non-public information we receive from your use of the Site that can be used, alone or in combination with other information in our possession, to identify a particular person/individual. It may include information such as name, address, telephone number and other personal information you provide us.


F. "Data” includes both Non-Personal Information and Personally Identifiable Information.


2. INFORMATION COLLECTED AND CONSENT 

You do not have to provide any Personally Identifiable Information to browse the publicly available pages of the Site; however, in order to obtain or use products or services that are or may be provided through the Site or that we may otherwise offer online or offline (collectively, the “Services”) you may be required to register and/or provide Personally Identifiable Information. 


A. Personal Information you Provide Us


We may collect Personal Information from you in a variety of ways, including, but not limited to, when you visit the Site, communicate with us through the Site, provide Personal Information in connection with other activities, products, services, features or resources we make available on the Site or through any services we may offer online or offline. We may collect your name, mailing address, billing address, phone number, payment information, email address, your occupation, non-public financial information, investment portfolio information, and other information you provide us. We may also collect additional information from you depending on the nature of the transaction.


We will treat as personal information any item that, either alone or together with other information, we could use to identify an individual. Except as described below, we will not share with third parties any personal information without your permission.


By providing your Personal Information to us, you explicitly agree to our collection and use of such information as described in this Privacy Policy. By providing Personal Information belonging to another person, you expressly represent and warrant that you have the authority and right to do so, and that you obtained all appropriate and required consents.


We may also collect your Personal Information from sources that you have authorized to share with us or that you have authorized us to obtain information from.


We collect information about you from third parties related to transactions you are contemplating entering into with us or our customers or that you have entered into with us or our customers.


If you believe we received your personal information from a source without authority to share your personal information with us, please contact us so that we can resolve your complaint.


B. Information We Automatically Collect


29th Street also may collect information about you automatically when you visit the Site or use any of our online Services. 


System Information:
We may automatically receive certain information from your browser or mobile device, such as your browser type, the operating system of your device, the equipment you use to access the Site, and the unique identifier of your mobile device.


IP Address:
We may also receive your IP address and the name of the internet service provider (“ISP”) or your mobile carrier.


Browsing Information:
We may collect the URL of the site from which you came and the URL of the site you visit when leaving the Site or any of our online Services, and your activities on the Site, such as webpages you view and how you interact with those webpages. 


Location:
We may collect, depending on your device’s settings, location data and other types of information sent from third party services or GPS-enabled devices.


Site Usage:
As you use the Site or any of our online Services, we may also collect information about such usage and your actions on the Site, such as pages you viewed, access times, and how long you spend on a page. We may use cookies to collect such information, as described in more detail below. This information is considered Non-Personal Information, which we can use for any purpose, including, without limitation, to help us improve the Site or the Services and to enhance your, and other user’s experience. 


Aggregated Anonymized Data:
Unless otherwise agreed to in writing by 29th Street, we may also convert personal information into Non-Personal Information by excluding information that is personally identifiable. You acknowledge that Non-Personal Information and Personal Information that is converted into Non-Personal Information belongs to 29th Street and that 29th Street has the right to use such general information as it determines in its sole discretion.


3. COOKIES, ADVERTISING PLATFORMS AND SIMILAR TECHNOLOGIES USED ON THE SITE


The Site or our online Services may use “cookies,” or other identifiers, which may be stored on your device, to recognize you as a user when you return to the Site or use the online Services using the same computer and web browser and to maintain your preferences. We use cookies and other identifiers to identify which areas of the Site or online Services you have visited and how you interact with the Site. We also may use this information to better personalize the content you see on the Site or online Services, serve you with personal advertisements for 29th Street and third-party products, either via email, on our Site, or on other websites on the internet. We do not store unencrypted Personal Information in the cookies. We also do not link Non-Personal Information from cookies to your Personal Information.


In addition, we may use the services of advertising platforms to provide relevant marketing to consumers concerning our Services.


In general, we may use four different types of cookies:


Strictly necessary cookies:
These cookies are necessary to enable the basic features of the Site, including any of our applications, such as providing a secure login.


Functional cookies:
These cookies allow our Site to remember your site preferences and choices you make on the Site. We also use functional cookies to facilitate navigation, to display content more effectively, and to personalize your experience.


Advertising cookies:
Advertising cookies allow us to select which advertisements and offers you may like. We may also use cookies to track online responses to advertisements and other marketing to better understand your interests so that we can present more relevant advertisements and messages to you. 


Analytics cookies:
Analytics cookies help us improve our website by collecting and reporting information on how you use it.


Disabling Cookies on Your Browser: 
Some browsers may allow you to manage the storage of cookies on your device. If supported by your browser, you may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert you when a cookie is placed. However, if you select these settings, you may be unable to access certain parts of the Site or the online Services. Unless you have adjusted your browser setting to refuse cookies, the Site and online Services will issue cookies. For more information about how to manage your cookie preferences, use the ‘help’ menu of your web browser or explore the customer support sections of your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for your browser for instructions. 


Opting-out of Personalized Ads:
You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI’s opt-out tool can be found here: http://www.networkadvertising.org/choices and the DAA’s opt-out tool can be found here: http://www.aboutads.info/choices/.


In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.


4. HOW WE USE AND SHARE YOUR PERSONAL INFORMATION


Notwithstanding the foregoing, we will treat as Personal Information any item that, either alone or together with other information, we could use to identify an individual. Except as described below, we will not share with third parties the link between your IP address and your Personal Information without your permission.


By providing your Personal Information to us, you explicitly agree to our collection and use of such information as described in this Privacy Policy. By providing Personal Information belonging to another person, you expressly represent and warrant that you have the authority and right to do so, and that you obtained all appropriate and required consents. 


We may also collect your Personal Information from sources that you have authorized to share with us. We will use your Personal Information in those circumstances to provide the Services that your Personal Information was shared with us to fulfill. If you believe we received your Personal Information from a source without authority to share your Personal Information with us, please contact us so that we can resolve your complaint.


29th Street may use Personal Information for the following purposes:


A. To improve customer service:  Your information helps us to more effectively communicate with inquiries and existing customers, and to respond to your customer service requests and support needs.


B. To personalize user experience: We may use information in the aggregate to understand how our users as a group use the Services and resources provided on the Site.


C. To improve the Site: We continually strive to improve our Site and the Services based on the information and feedback we receive from you.


D. To provide products or services and to process transactions: Except as otherwise expressly provided in this Privacy Policy, we will use Personal Information only for the purpose of fulfilling our duties and providing the Services. 29th Street may use Non-Personal Information for product development, research, or other purposes. We may use the information that you provide about yourself or that you have provided to our clients for the purpose of providing and fulfilling the Services. We do not share this information with outside parties except to the extent necessary to provide the Services.


E. To send periodic emails:  The email address you provide for the Services will only be used to send you information and updates pertaining to the Services requested. It may also be used to respond to your inquiries, and/or other requests or questions. 


F. To develop new products or services:  We use your Personal Information and Non-Personal Information for research and commercial purposes. The information we collect may be used to develop new products or services. Except as otherwise provided in this Privacy Policy, we may use your Personal Information and Non-Personal Information internally or, among other things, to offer our own- or third-party products and services. Only 29th Street, its subsidiaries, its suppliers and contractors/service providers involved in distributing the new product or service will have access to your Personal Information. Our subsidiaries, suppliers and contractors/service providers will be required to use any Personal Information we provide to them only for that intended purpose and subject to the terms of this Privacy Policy.


G. For marketing:  Except as otherwise expressly provided for in this Privacy Policy or except as prohibited by applicable law, 29th Street may use your Personal Information and Non-Personal Information to enhance its networking, marketing, social, and recruiting activities, and for other similar business purposes. We may also use Personally Identifiable Information to provide you information regarding existing and new products or services. Personally Identifiable Information is not shared with entities outside of 29th Street other than our subsidiaries, suppliers and contractors/service providers who assist us in carrying out these business functions. 


H. Compliance with applicable law:  We may disclose your Personal Information as we may in our sole discretion determine is necessary or reasonably required to comply with the law, applicable regulations, court orders or subpoenas, to enforce our terms and conditions, or to protect our rights, property or safety, or the rights, property or safety of others.


I. Change in the Site Ownership:  If ownership of the Site or of 29th Street changes, whether in whole or in part, information collected through the Site and the Services about you may be transferred to the new owner of the Site and/or 29th Street, as the case may be, and any Services can continue. In that case, your user information would remain subject to the terms and conditions of the applicable version of the Privacy Policy.


5. RETENTION AND STORAGE OF PERSONAL INFORMATION


We retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage


6. SECURITY


We will use commercially reasonable methods to keep personal information securely in our files and systems.


7. DO NOT TRACK


Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, the Site is not programmed to recognize Do Not Track signals, so the Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.


8. EXEMPTIONS FROM THE PRIVACY POLICY


Our Privacy Policy does not apply to any information you may send to 29th Street by email or instant messaging programs (e.g., AOL, Yahoo, etc.), or through social media networks, even if you open such programs or services by clicking a link displayed on the Site. Email, social media, and instant messages are not recognized as secure communication forms. Please do not send any information you consider private to us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings.


9. LINKS TO OTHER SITES


The Site and the online Services may contain links to other websites. 29th Street is not responsible for the actions, practices, or content of websites linked to or from the Site or the online Services. You understand such websites may require you to agree to their terms of use and that we have no control over those terms. As always, you understand it is your responsibility to verify your legal use of a website, and use of information from the website with the corresponding website owner.


10. AGE OF CONSENT


29th Street takes special care to protect the privacy needs of children under the age of 13 and we encourage parents to be an active participant in their child’s online activities. 29th Street abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The Site does not target and is not intended for children under the age of 13, and 29th Street will not knowingly collect Personally Identifiable Information directly from them. If 29th Street discovers that a child has provided personal data directly through the Site, 29th Street will eliminate that data. This Site is only intended for persons 18 years of age or older. If you are under 18 you must ask a parent or legal guardian for permission prior to submitting any information to this Site or 29th Street.


If you have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to us, please contact us and we will delete the Personal Information collected belonging to that child. You may contact us via email or by writing to us at the address below. Parents and guardians can also email us at hr@havenresidential.com, but before any information is disclosed, the parent will be required to provide verification of his/her identity and authority related to any request. We will only send the information to the parent email address that has been verified.


11. CAN-SPAM COMPLIANCE NOTICE


29th Street fully complies with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from us.


12. CALIFORNIA PRIVACY RIGHTS


Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship. That information is about the Personally Identifiable Information those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of Personally Identifiable Information shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by 29th Street under Section 1798.83 of the California Civil Code, please contact us via email to hr@havenresidential.com. 


13. U.S. STATE LAW PRIVACY RIGHTS

Some US states have adopted privacy laws that require specific disclosures. The following explains your rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “Act”). Some or all of the rights provided for under the Act are also provided for under the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act. Collectively, these privacy laws are referred to as “US State Privacy Laws.”


The US State Privacy Laws supplements the information contained above in our general Privacy Policy and applies solely to visitors, users and others who reside in those referenced states or who’s state has adopted some or all of the privacy rights set forth below. The following terms in this Section 13 supersede any inconsistent terms in any other sections of the Privacy Policy.

A. We do not sell your personal information


29th Street does not sell your personal information. 


B. Your Rights Under US State Privacy Laws

1. Right to Access and Know. You may request that we disclose the following information:

a. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

b. The specific pieces of Personal Information we collected about you;

c. The business or commercial purpose of collecting or sharing Personal Information about you;

d. The categories of Personal Information about you that we shared (as defined under the applicable privacy law) and the categories of third parties with whom we shared such Personal Information; and

e. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).


Under US State Privacy Laws, the right to obtain “specific pieces” does not grant a right to the whole of any document that contains Personal Information, but only the right to obtain items of your Personal Information. Additionally, you have a right to know “categories” of sources of Personal Information and “categories” of third parties to which personal information is disclosed, but not the individual sources or third parties. 29th Street does not always track individualized sources or recipients.


2. Right to Request Correction of your Personal Information. You may request to correct inaccuracies in your Personal Information;

3. Right to Request Deletion of Your Personal Information. You may request to have your Personal Information deleted;

4. Right to Opt-out of Sharing for Cross-Context Behavioral Advertising. You may request to opt out of the “sharing” of your Personal Information for purposes of cross-context behavioral advertising.

5. Right to Data Portability. You have the right to request a copy of your data in a machine-readable format.


C. Verification of Requests to Exercise Rights. 


When receiving a request, we will verify that the individual making the request is the resident to whom the Personal Information subject to the request pertains. You may exercise your rights yourself or may use an authorized agent to make requests to disclose certain information about the processing of your Personal Information or to delete Personal Information on your behalf. If you use an authorized agent to submit a request, we may request that you provide us additional information demonstrating that the agent is acting on your behalf.


D. Categories of Personal Information We Collect


We collect information that identified you, your household or your device or is reasonably capable of being connected with or linked to you, your household, or your device. “Personal Information” does not include public information available from government records, de-identified or aggregated information, or information that is protected by certain laws such as HIPPA for health-related information and the Gramm-Leach Bliley Act for certain financial institutions.


We collect, process and share some or all of the following categories of personal information:

  • Identifiers
  • First and last name
  • Alias
  • Postal address
  • Telephone number
  • Cellular telephone number
  • Gender
  • Geographic area
  • Title 
  • Internet protocol address
  • State driver’s license number
  • Age
  • Commercial information
  • Transaction information
  • Financial information related to any transaction, including any investment
  • Investment portfolio information,
  • Your transaction, including investment, history or tendencies
  • Geolocation data
  • Professional or employment related information
  • Non-public education information 
  • Inferences may be drawn from this personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.


 
Categories of Sources of Personal Information 


We collect information from the following categories of sources:

  • Directly from you. For example, information you provide us directly during a telephone call or survey.
  • From third parties. For example, when we offer or promote services in conjunction with another company and they provide contact information to us. We may also receive information from a service provider when you apply for a job with us, and we run a background check. 


E. How We Use Your Information


See above for how we use your 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.


We are not required to (1) retain your Personal Information if collected for a single one-time transaction if, in the ordinary course of business, that information would not be retained and (2) re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a way that would be considered personal information.


F. How Long We Retain and Store Your Personal Information


We retain your personal information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage. 


G. Requests to Know


You have the right to request that we disclose certain information to you about our collection and use of your personal information over the prior 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you. 
  • The categories of sources for the personal information we collected about you. 
  • The business or commercial purpose for collecting or selling your personal information. 
  • The categories of third parties with whom we share your personal information. 
  • The specific pieces of personal information we have collected about you
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • In the case of a sale, the categories of personal information sold about the consumer and the categories of third parties to whom the personal information was sold, by category of personal information for each category of third parties; and 
  • In the case of disclosure for a business purpose, the categories of personal information that were sold or disclosed for a business purpose and if personal information has not been sold or disclosed for a business purpose, that we did not do so. 


We are not required to (i) retain personal information about a consumer if collected for a single one-time transaction if, in the ordinary course of business, that information would not be retained and (2) re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a way that would be considered personal information. 


H. Requests to Delete


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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies, which we will disclose to you. 


We are not required to grant your deletion request if retaining the personal information is necessary for us or our service providers to:


  1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall, 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. 
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity. 
  3. Debug to identify and repair errors that impact existing intended functionality. 
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law. 
  5. Comply with the California Electronic Communications Privacy Act. 
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest when the deletion of the public information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent. 
  7. For solely internal uses that are reasonably aligned with your expectations based on your relationship with us. 
  8. Comply with a legal obligation.
  9. Internally make otherwise lawful uses of your personal information that are compatible with the context in which you provided the personal information. 


I. How to Submit a Request to Know or a Request to Delete


To request this information, please submit a verifiable consumer request to us by either:


  • Emailing us at hr@havenresidential.com and submit our request in the body of the email with the subject heading: “Privacy Consumer Request.”


Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We are not required to provide you with personal information more than twice in a 12-month period.


To make a request mail, email or call us at:


29th Street Management, LLC

Attn: Human Resources, Chief People Officer

20 N. Wacker

Suite 2050

Chicago, IL 60606


Or email us at:

Hr@havenresidential.com


We will not be able 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. 


Unless legally obligated to respond in a shorter timeframe, we will try to respond to your request within forty-five (45) days of receipt of your written request. If we require more time (up to 90 days), we will inform you of the extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.


We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


J. How to Submit an Opt-Out Request

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at: 


29th Street Management, LLC

Attn: Human Resources, Chief People Officer

20 N. Wacker

Suite 2050

Chicago, IL 60606


Or email us at:

Hr@havenresidential.com


Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sharing with third parties. However, you may change your mind and opt back into personal information sharing with third parties at any time by emailing us at hr@havenresidential.com 


We will only use personal information provided in an opt-out request to review and comply with the request. We will act upon your opt-out request within 15 days of receipt.


K. Non-Discrimination


We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
  • 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, we may offer you certain financial incentives permitted by the CCPA that 
can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.


14. YOUR NEVADA PRIVACY RIGHTS


Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information should we change our practices in the future, you must send a request by email to hr@havenresidential.com.


15. AMENDMENTS

29th Street reserves the right to change the Privacy Policy from time to time at its sole discretion with or without notice. Any revisions are effective immediately once posted on the Site. Your continued use of the Site shall indicate your acceptance of the revision. Revisions to the Privacy Policy regarding the use of Personally Identifiable Information are not retroactive. 


16. EUROPEAN UNION DISCLOSURE

Personal information voluntarily submitted to 29th Street online, via electronic communication, or otherwise, may be maintained or accessed in servers or files in the United States of America, which the European Union or UK has not deemed to provide “adequate” privacy protection. If you do not consent to having your information processed and stored in the United States of America, please do not provide it to 29th Street.


17. Contact

If you have any questions about the Privacy Policy, or to report a violation of the terms and conditions, please contact us at hr@havenresidential.com or by mail at:


29th Street Management, LLC

Attn: Human Resources, Chief People Officer

20 N. Wacker

Suite 2050

Chicago, IL 60606


Or email us at:

Hr@havenresidential.com

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