COMMONWEALTH PARTNERS PRIVACY NOTICE
What Information Do We Collect?
- Information You Share With Us
- Information Collected Automatically
- Information Collected From Our Service Providers
- Information Obtained From Third Parties
How Do We Process Personal Data?
- Operational Uses
- Marketing Uses
- Sharing of Personal Data
Protecting Personal Data
Your Rights Regarding Personal Data
- Accessing, Modifying, Rectifying, and Correcting Personal Data
- Your California Privacy Rights
- Your Nevada Privacy Rights
- Communications Opt-Out
- Location Information
- Cookies, Web Tracking and Advertising
Retention of Personal Data
Other Important Information About Personal Data and the Services
- Collection of Personal Data from Persons Under 21
- Third-Party Websites and Services
- Business Transfer
- Payment Information
- Do Not Track
- International Use
Modifications and Updates to this Privacy Notice
Applicability of this Privacy Notice
Additional Information and Assistance
CommonWealth Partners (CommonWealth Pacific, LLC, Fifth Street Properties, LLC, National Office Partners, LLC, CommonWealth Partners Management Services, LP, CWP-NYC Property Management Services LP) and its affiliates, subsidiaries etc. (“CWP”, “we”, “us”, “our”) respect your privacy. This Privacy Notice explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our website located at https://www.commonwealth-partners.com/, together with all services and products we may offer from time to time via our website, social media sites (such as LinkedIn, Twitter, Facebook, VTS Rise app) or otherwise through your interactions with us (the website and products, collectively, the “Services”).
Please review the following to understand how we process personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.
2. WHAT INFORMATION DO WE COLLECT?
We collect personal data from and about you through the Services, including:
- Information You Share With Us. When you provide it to us directly whether online, respective mobile applications, by email, phone, or in-person, for example, when you create an account, sign-up to receive emails from us, sign up for push notifications, contact us, or participate in questionnaires, written correspondence, or when you process a payment, and provide your shipping and mailing address.
- Information Collected Automatically From You. For example, through logging and analytics tools, cookies, pixel tags (such as Google Analytics and ScoreCard), and as a result of your use of and access to the Services, or through your interactions with us on social media websites.
- Information Collected From our Service Providers. The information we collect may vary based upon the Services we are providing to you, or you are providing to us. For example, we may collect the following information from vendors:
- Vendors: Personal data, name and email address, government issued documents, such as licenses; geolocation data, such as location data based upon security badge usage or visitor access system usage; and beneficial ownership information, such as the names of key people and their addresses. We collect this information only as needed to support Operational Uses in the section captioned “How Do We Process Personal Data” below.
Also, the information we collect may vary based upon the Services we are providing to you, or you are providing to us. For example, we may collect the following information from tenants, visitors and investors:
- Tenants: Personal data, contact information such as email address and phone numbers; financial account information such as credit cards for parking permits; government issued identification; leasing information; car details for parking registration; geolocation data, such as location data based upon security badge usage or visitor access system usage; electronic, visual or similar information, such as CCTV systems at CWP’s properties; and professional or employment-related information;
- Visitors at Our Properties: Personal data, such as government issued identification, car details for parking registration; geolocation data, such as location data based upon security badge usage or visitor access system usage; and electronic, visual or similar information, such as CCTV systems at the CWP’s properties; and
- Investors: Personal data, such as date of birth, tax identification number/social security number; financial account information; government issued identification; and professional and employment information.
You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as described below in the section captioned “Your Choices” it is possible to change your browser settings to block the automatic collection of certain information.
Finally, we may collect data from or about you that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
3. HOW DO WE PROCESS PERSONAL DATA?
a. Operational Uses. We process your personal data as part of our operations, which include:
- Providing or performing, including maintaining or servicing accounts, providing customer service, and verifying customer information;
- Managing your inquiries, responding to inquiries and requests via email, and communicating with you through any newsletters or other updates;
- Communicating with you by email, text message (SMS, MMS), telephone, push notification, about Services, products, and marketing communication;
- Operating, maintaining, and improving the quality of the Services and such content, products and/or services as we may make available through the Services;
- Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
- Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties; and
- For other purposes, as permitted or required by law.
b. Marketing Uses. We may process your personal data as part of our marketing, which include:
- We process your personal data to send messages, including text messages, to you about us, our partners, and the products and services we and our partners offer, which may from time to time include rewards, events, promotions, new offerings, and special offers for products and services. Personal data you enter into incomplete or unsubmitted forms on the Services may be processed to send you reminders about completing the forms, as well as to save that information to make completing the forms easier. These communications will only occur with your prior consent, if such consent is required in accordance with applicable laws.
- We also process personal data collected through social media platforms (such as LinkedIn) and web tracking technologies to market to and understand our audience.
- We do not disclose personal data to third parties for their own direct marketing purposes.
c. Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers and other third parties:
- We share personal data with our service providers or vendors we engage so that they may provide services to us or on our behalf related to property management, security, life safety, maintenance, and parking services at the CWP properties. This may include, but is not limited to, VTS Rise, Electronic Tenant Solutions (ETS), Angus, and Everbridge that handle our work order, visitor management, and communication systems; LifeStart and Vivecorp, that handle the Fitness Centers located at the CWP properties; CCTV systems such as FLIR, Avigilon, BluBØX, Open Eye, that provide CCTV surveillance for occupant safety, access control systems such as BluBØX, HID, AMAG, C-Cure, Schneider, S2, Hirsh, Kastle; lobby directory and visitor management systems such as Navigo, Meridian, TouchSource, and Easy Lobby; and Parking management systems such as Hub;
- We may share personal data we collect in aggregated form, with certain business partners, such as agencies for analytics and reporting purposes, in order to provide us with information about the use of the Services and levels of engagement with the Services and to allow us to enter into new business relationships;
- We may share personal data to market and promote our, and our partners’, products and offerings (such as Wris, that handle potential property bidding opportunities); and
- We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.
See the Your Choices section below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.
4. PROTECTING YOUR PERSONAL DATA
We employ reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.
5. YOUR RIGHTS REGARDING PERSONAL DATA
You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests. Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests. These rights vary depending on the particular laws of the jurisdiction applicable to you.
a. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data.
We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.
If you wish to access, review, or make changes to certain personal data you have provided to us through the Services, you may do so at any time through your account on the Services, at our locations, and/or by contacting us as provided below.
b. Your California Privacy Rights.
California residents, see our “CALIFORNIA PRIVACY NOTICE” [https://www.commonwealth-partners.com/crpa/] section for more information about certain legal rights.
c. Your Nevada Privacy Rights.
Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to the email address below, and are free of charge.
6. YOUR CHOICES
You have the ability to make certain choices about how we communicate with you, and how we process certain personal data.
a. Communications Opt-Out. You may opt-out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received or by contacting us as provided at the end of this Privacy Notice. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email.
b. Location Information. If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
c. Cookies, Web Tracking, and Advertising. You may opt out of certain tracking technologies through your device’s or browser’s cookie and/or advertising settings (including by blocking, deleting, or restricting cookies, or resetting your device’s applicable advertising ID). Consult your device and/or browser documentation for more information about how to do this.
Please note that blocking, deleting, or restricting cookies may negatively affect the performance or certain functionality of the Services, and opting out of online behavioral advertising will not prevent the delivery of ads, but rather may result in more repetitive and/or less relevant advertisements.
To opt out of many online behavioral advertising mechanisms, including Facebook, Google, and others, you can use the Network Advertising Initiative’s Consumer Opt-Out service and/or the Digital Advertising Alliance’s Consumer Choice Tool.
If you would like to opt out of Google Analytics, and certain Google advertising functionality, you may do so using Google’s opt-out tool.
7. RETENTION OF PERSONAL DATA
We retain personal data for to the extent we deem necessary, for marketing purposes and to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.
8. OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.
a. Collection of Personal Data from Children. Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.
b. Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the privacy notice or policies for such third-party services for information about how they collect, use, and process personal data.
c. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
e. Do Not Track. We use analytics systems and providers that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.
f. International Use. Your personal data will be stored and processed in the United States. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.
9. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.
10. APPLICABILITY OF THIS PRIVACY NOTICE
This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
11. ADDITIONAL INFORMATION
If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at:
515 South Flower Street
Los Angeles, CA 90071
For more information about how users with disabilities can access this Privacy Notice in an alternative format, please contact us through above contact methods.
Effective: January 1, 2023