Pendry Residences Privacy Policy

Effective 11th day of January, 2019

SUNSET SUBSIDIARY LLC, a Delaware limited liability company (“SUNSET SUBSIDIARY, LLC,” “we” or “us”) provides this privacy policy (the “Privacy Policy”) to describe our practices for collecting, using, and disclosing information we may collect about you. Click on one of the links below to jump to a specific section:

Information We Collect and How We Collect It

Information We Obtain From You

The personally identifiable information we collect directly from you may include information that you provide to us, including when you:

Request information regarding the Residences;
Sign up to receive emails, offers or other information;
Contact or interact with us in person or via telephone, email, or online form on our website.

This information may include:

Name
Contact information
Records and copies of your correspondence and submissions if you contact us, our properties, or our service providers;
Information you provide in response to surveys;
Details of transactions that you carry out through the Websites; and
Residence purchase information.

Information We Obtain from Third Parties

We may collect information from service providers and other third parties who help us to provide services. We may also collect publicly available information about you.

When you interact with us over social media, we may collect information about you. If you post information or otherwise interact with us through social media websites, social media platform plug-ins, or other applications we use, we may collect or receive information that you provide or that is automatically collected by the social media platform. Information collected by social media platforms when you interact with their services is governed by the social media platforms’ respective privacy policies.

Automatically Collected Information

As you navigate through and interact with our websites, we and our service providers may use automatic data collection technologies, such as cookies and other technologies, to collect certain information, including:

Information about you, including your location;
Information about your visits to our websites, such as traffic data, logs, page requests, search terms, the referring page, the time, date and duration of your visits to our websites, clickstream data, other communication data, the links that you click, your search queries, and the resources and content that you access and use on the websites;
Information about your Internet connection and computer or other devices used to access the websites, including your IP address, operating system or platform, browser type, mobile identifiers (IMEI; Apple IFDA, Android Advertising ID) and the name of your Internet Service Provider; and
Information about traffic patterns, number of visits to certain pages, visits from other websites or to third-party websites linked to the website, and visitors use of particular services and interest in services, information or features of the website.

We combine non-identifiable information with personally identifiable information that you provide to us or that we obtain in other ways. If we do so, the associated non-identifiable information will be treated as personal information.

What Cookies Are

“Cookies” are small text files that are stored on your computer or device when you visit a website, if your web browser or device settings permit. Some cookies are stored only temporarily during a browsing session and are deleted when you close your browser (session cookies). Other cookies are not deleted when you close your browser, but are saved on your computer or device for a fixed period of time or until you delete them (persistent cookies). Each time you visit our websites, the server that set the cookie will recognize the persistent cookie stored on your computer or device.

How We Use Cookies & Other Technologies

Like many other websites, our websites may use cookies and other technologies to help us and third parties:

Obtain information about your visits to the websites;
Deliver online and mobile advertisements and content for SUNSET SUBSIDIARY, LLC and for third parties that are tailored to your apparent interests;
Process your requests; analyze your visiting patterns; personalize your experience on the websites;
Facilitate social media functions; and
Engage in website and advertising analytics.

How We Use Your Personal Information

We may use information about you for the following purposes:

For the purposes for which you provided the information;
To present the websites and their contents to you;
To process and respond to your inquiries, comments, complaints, and requests for information;
To improve the content and navigability of the websites, or to administer or troubleshoot the websites;
To send you important notices, such as communications about changes to our terms, conditions and policies (because this information is important to your interaction with us, you may not opt-out of receiving these communications);
To conduct auditing, analytics, data analysis, monitor and analyze website traffic and usage, and research to evaluate user needs;
To contact you about our own and third parties products, services, hotels, real estate developments, opportunities, special events, and promotions that may be of interest to you;
To conduct customer satisfaction, market research and quality assurance surveys;
To improve our services and properties and to develop new services, properties, and offerings;
To validate your identity or verify communications from you;
To send you confirmations, notices, updates, security alerts, support, and administrative messages and to otherwise facilitate your use of, and our administration and operation of, the websites;
To protect our rights and the security or integrity of our websites, properties and business;
To prevent fraud and other prohibited or illegal activities, to investigate and resolve disputes, claims and problems, and to otherwise comply with applicable laws and regulations;
To enforce our Terms of Service and our other agreements and contractual obligations;
For any other purpose that is disclosed to you when you provide the information; and
For any other purpose with your consent.

Under certain circumstances, you may withdraw your consent by contacting inquiry@pendryresidencesweho.com.

How We Share Your Personal Information

We do not rent, sell, or disclose your information to non-affiliated companies except to provide products and services you have requested, when we have your permission, as permitted by applicable law, or as otherwise described in this Privacy Policy. We may disclose your personally identifiable information:

To our vendors, service providers, contractors and agents that we use to support our business and properties, including those performing core services such as data processing and storage, marketing, promotion and advertising services (including email marketing, direct mail, and online and mobile advertising), hardware and website support, website hosting, email management, surveys, fraud prevention, debt collection, customer service, administering sweepstakes and surveys, public relations, and security related to the operation of the websites and the development and operation of our business and our properties operated under the PENDRY brand.
To our strategic partners offering or providing products or services jointly with or on our behalf.
To other third parties to fulfill the purpose for which you provide it, for example, to provide products or services you have requested.
To a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users of our websites will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy.
To fulfill any purpose for which you provide it or that is disclosed to you when you provide the information.
To other third parties disclosed to you when you provide the information or with your consent.
To comply with a court order, search warrant, subpoena, or other legal process;
To comply with legal, regulatory or administrative requirements of any governmental or law enforcement authorities or to otherwise fulfill a government or law enforcement request for information;
To establish or exercise our legal rights and to protect and defend the websites, website users,inquiry@pendryresidencesweho.com, its affiliates, and all of their respective officers, directors, employees, attorneys, agents, contractors, property owners, licensors, and partners, in connection with any threatened or actual legal action, claim or dispute;
Respond to claims that any content on the websites violates the rights of third parties, including without limitation providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act;
In an emergency, to protect the health and safety of our websites users or the general public; or
To enforce, apply or comply with our Terms of Service and other agreements.

Your Choices Regarding Information Collected About You

We offer certain choices about how we communicate with you and what personal information we obtain about you and share with others, described below.

Information Provided by You

When corresponding with us or our representatives, or when making a request for information or otherwise interacting with us or others through the website, you choose what information to supply, what questions or comments to submit, whether you wish to receive further information, and by what method of communication such information should be delivered. Please take care to share only such information as is needed or that you believe is appropriate. You are under no obligation to provide us with personally identifiable information, but without it, we may not be able to provide you the products or services you request. You may contact us as indicated below if at any time you would like to ask us about our data collection and information security practices. Depending on the activity, some of the information we ask you to provide is mandatory and some is voluntary. Whether or not to provide such information is completely your own choice. But if you choose not to provide the information we request, you may be unable to purchase products, or access certain services, offers and content on our website as a guest.

Mailings

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us, please let us know by sending your written request via email to inquiry@pendryresidencesweho.com. Please provide your full name, mailing address, email address, and phone number when making this request.

You may also visit DMAChoice.org, a tool offered by the Data & Marketing Association, which lets you remove your name and address from a number of marketing lists as well as unsubscribe from entire categories of mail, like catalogs and advertisements.

Email

As required by law, at any time, you may opt out of receiving commercial emails from us in the future by clicking “Unsubscribe” at the bottom of any promotional email from us. You may also contact us at privacy@pendryhotels.com. Please include your current contact information and your requested changes.

Cookie Choices

Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. For more information on how to manage browser cookies, see http://www.allaboutcookies.org. Click on the links below to learn how to manage cookies on these browsers:

We use Google Analytics to help us analyze how visitors use our websites and mobile applications. The information generated by the cookie, including your IP address, is transmitted to Google. This information is then used to evaluate visitors’ use of the website and mobile applications, and to compile statistical reports on website activity for us. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser.

Please note that by disabling or deleting cookies, you may not be able to access the full functionality of our website. Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set.

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Some of the third parties that we work with may participate in the Digital Advertising Alliance’s self-regulatory program, which provides consumers tools to opt-out of receiving interest-based advertising. Click here to learn more about the DAA’s WebChoices tool. To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app by clicking here.

You also can learn more about opting out of third parties’ use of cookies used to tailor ads and other content by visiting http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices.

Do Not Track

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them at this time.

International Transfers

We may share your data across multiple jurisdictions in order, if reasonably necessary, to provide you with the best possible services. Your personal information may be transferred and stored in the United States of America and in other countries where our third party service providers, advisors and consultants are located.

Third Party Websites

The websites may contain hyperlinks to or advertising for third-party websites. By clicking on these links or advertisements, you are visiting websites outside of our control. We are not responsible for any content on third-party websites, or for the collection, use, maintenance, sharing, or disclosure of data and information by the operators of those websites. This Privacy Policy does not apply to information, including personal information, you provide when visiting third-party websites. We urge you to note when you leave our websites and to read the privacy statements of third-party websites for information about their data collection practices before submitting any personally identifiable information to other websites. Third-party websites include social media sites (such as Facebook and Twitter) on which we or our properties may have accounts or fan pages where you may be able to post information and materials. If you have any questions about the privacy practices of other websites, you should contact the relevant parties controlling these websites for more information.

Children

Our websites are not directed to or intended to be used by individuals under the age of 18. We do not knowingly collect personal information from anyone under the age of 18. If we are notified that we have collected or received personal information from a child under the age of 18, we will take reasonable steps to delete that information in accordance with applicable laws.

If you are the parent or guardian of a child under the age of 18 and you believe your child has provided us personal information about themselves, please contact us by emailing us at inquiry@pendryresidencesweho.com or by sending us a letter to Sunset Subsidiary LLC c/o Combined Properties, Incorporated, 9320 Wilshire Boulevard, Suite 310 Beverly Hills, California 90212.

Security of Your Information

We have put in place certain security measures to safeguard information that we have about individuals, including you, but the storage and communication of that information can never be completely secure. Hence, we do not guarantee that information that you transmit or otherwise supply to us, or any communications conducted on or through the website, is or will be totally secure. If you become aware of any breach of website security or this Privacy Policy, please notify us.

Unless otherwise expressly stated, email transmissions sent through the websites are not secure. Therefore, for your own privacy protection, we recommend that you do not include any confidential or sensitive personal information such as passwords, credit card details, social security numbers, or bank account information, in any emails that you send to us.

Your California Privacy Rights

Individuals who reside in California and who have provided their personal information to us may request information about our disclosure of certain categories of their information to third parties for the third parties direct marketing purposes. Such requests must be submitted to us at one of the following addresses: inquiry@pendryresidencesweho.com or Sunset Subsidiary LLC c/o Combined Properties, Incorporated, 9320 Wilshire Boulevard, Suite 310 Beverly Hills, California 90212. Please include the subject heading “California Privacy Rights.”

Within thirty days after receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year (if any), along with the names and addresses of these third parties. This request may be made no more than once per calendar year. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

Retention Period

To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfill the following:

the purposes for which that personal information was provided,
an identifiable and ongoing business need, including record keeping,
a specific legal or regulatory requirement, and/or
a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.

Changes to This Privacy Policy

We may change or update this Privacy Policy in the future. You can identify the date that this Privacy Policy was last updated by looking at the date at the top of this Privacy Policy. When we change this Privacy Policy, a notice will be posted on the homepage of the websites for a reasonable period of time following such update. Any changes to this Privacy Policy will take effect upon posting to the websites. Use of the websites following posted changes constitutes your acceptance of the revised Privacy Policy then in effect.

Contact Us

To ask questions or to comment on this Privacy Policy, please contact us by email at inquiry@pendryresidencesweho.com, or write to us at Sunset Subsidiary LLC c/o Combined Properties, Incorporated, 9320 Wilshire Boulevard, Suite 310 Beverly Hills, California 90212.