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Privacy Policy

Effective Date: February 24, 2026

1. Introduction and Overview

Rudin Management Co. Inc. (“Rudin,” “we,” “ours” or “us”) is committed to protecting your privacy. This Privacy Policy (“Privacy Policy” or “Policy”) describes how we collect, use, and share personal information (“Personal Information”) we receive from you when you access or use our websites, including https://www.rudin.com/ and https://www.rudinresidential.com (each a “Website”), interact with our Rudin team members, such as showing interest in or requesting information about our properties, or when you utilize our property management services and/or software provided in connection with access to or being a tenant of our properties (collectively, our “Services”). We provide our Services for both residential and commercial properties, and this Privacy Policy applies to personal information we collect in both contexts. You acknowledge that this Privacy Policy is part of our Terms of Use (our “Terms of Use”), and by agreeing to use our Services, you are agreeing to be bound by all of its terms and conditions and all applicable laws and regulations. If you do not agree to these terms, you should not access or use our Services. 

 

2. Information We Collect and How We Collect It

We collect the following categories of Personal Information:

Category

Examples

Personal
Identifiers and Contact Information

(“Identifiers”)

First and last name, date of birth, postal address, copy of your driver’s license, passport or other government or personal identification, telephone or mobile contact number, vehicle information, social security number or other unique personal identifier, your photo, online identifiers, Internet Protocol address, and email address

Commercial, Financial Information and Payment Information

(“Payment Info”)

Bank account information including routing and account numbers, credit and/or debit card numbers, credit history, records of personal property, and other financial details

Demographic Information

(“Demographics”)

Your ethnicity, sex, gender, birth date, age, spoken languages, disability and housing status, household size and type, number of family members, marital status, and housing preferences

Device, Internet or Network Activity

(“Device Info”)

Device identifier, browsing history, search history, and information on your interactions with a website, application, or advertisement, your browser information, mouse movements, device settings, information gathered via web beacons, tags and pixels, Wi-Fi network settings, signal strength, mobile carrier, MAC address and IP address

Location Information

(“Location Data”)

GPS information gathered from your devices, based on your IP address or network connection or wireless carrier, your ZIP code or postcode, or provided by you to us in person or in your communications or submissions to us

Professional or Employment Information

(“Employment Info”)

Job title, employer information, work history, qualifications, resume information, salary information and preferences, workplace skillsets, background checks (including criminal history), employment verification, resume information

 

In connection with job applications, we may also ask you to voluntarily provide information relating to your ethnicity, gender, disability and/or veteran status

Transaction History and Related Preferences

(“Transaction Data”)

Information about your purchase history, retailer preferences, leasing details, apartment rental history, property records, tenant data, and your other transactions and preferences. 

Audio and Visual Information

(“AV Info”)

At certain locations, such as office buildings and related garages, we may use cameras to capture information, which may include photo, video and infrared information. We may use biometric recognition or license plate reader technology on this information to gather facial biometrics, license plate and vehicle related information, including make, model, color and other identifying characteristics, all of which may be cross referenced by location and timestamp information.

 

We may record audio during calls to us and retain voicemail, including for tenant service purposes, tenant application, building maintenance requests and general inquiries

Information you Submit to Us

(“Submitted Info”)

Feedback you submit to us, the content of your email, mail and audio communications to us, the content of your comments that you post on our websites, apps or online tools, your responses to surveys you complete, the contents of your tenant application or related inquiries, the contents of your communications with us regarding tenant service or building maintenance

Inferences

(“Inferences”)

Based on the information we collect, we may draw inferences on your preferences. 

 

We collect Personal Information in the following ways:

 

We collect Personal Information you Provide to Us. This includes through tenant applications, requests for service, job applications, building management tools or software, requests for information regarding our properties, e-mails, text messages, our apps and online tools, and other hard or electronic copy forms where we ask for information, phone calls to us, by participating in our surveys, when you post to our websites or blogs, or when you provide us feedback about our Services. 

 

We Collect Information Automatically. We collect information directly from your digital devices, including through technologies such as “cookies,” “web beacons” (which are also called clear GIFs, pixel tags, tracking pixels or just ‘pixels’), “URL Parameters,” by tracking IP addresses or from your browser or device directly. 

 

  • “Cookies” are small data files that are stored by your web browser when you interact with a website. When you visit a webpage, the cookie sends back information. Some Cookies are required for our sites and services to function properly (“essential cookies”), while some are used primarily for analytics or advertising purposes.
  • “URL Parameters” (also known as Query Strings or Marketing Tags) are unique strings of data appended to the end of a webpage's address (URL). They typically follow a question mark (?) and are formatted as key-value pairs (e.g., utm_source=facebook).
  • “Web Beacons” are small graphic images (usually invisible) that can be embedded in content and ads on a webpage that track usage of the sites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.

 

For more information about your options regarding automated collection, please see the section entitled “All Users: Your Choices and Controls.” 

 

We Use Analytics Software.

We may share your information with Google Analytics to track and analyze the use of our Services. 

 

To opt out of being tracked by Google Analytics across our Services, visit https://tools.google.com/dlpage/gaoptout. 
 

You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps.

 

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

 

For more information about your options regarding information collection by analytics software, please see the section entitled “All Users: Your Choices and Controls.” 

 

We Collect Information from Social Networks.

Rudin may collect information about you from third-party social networking services (e.g., Google, Apple, Meta) (each, a “Social Network”). For details on how your Social Network collects, uses, and shares data, please review that Social Network’s privacy disclosures and terms, which govern the sharing of account information with us.

 

For more information about your options regarding information collected from Social Networks, please see the section entitled “All Users: Your Choices and Controls.” 

 

Other Third-Party Sources.

 

Rudin may also receive other information from Service Providers (as defined below) in connection with the operation of our Services, including when you place transactions through one of our Service Providers.

 

We may also collect Personal Information from:

  • brokers, service agents and support personnel;
  • advertisers, advertising networks, and marketing platforms (such as social media sites that provide us with information about your interactions with our advertisements);
  • third-party resellers and referral partners, vendors, and Service Providers;
  • partners with which we offer co-branded services or engage in joint event or marketing activities; and
  • anti-fraud and security Service Providers. 

 

3. How We Use Your Information

We may use your Personal Information for purposes consistent with this Privacy Policy or as permitted by applicable law. We will not use information we’ve collected from you for purposes that are materially different, unrelated, or incompatible with this Privacy Policy without providing you with prior notice. We may use your Personal Information in order to:

 

Description of Use

Categories of Information Used

Respond to your inquiries or fulfill your requests, such as information regarding our properties or properties we think may be of interest to you

  • Identifiers
  • Payment Info
  • Location Data
  • Employment Info
  • Transaction Data
  • Submitted Info
  • Device Info

Provide and manage our Services, including to monitor the usage of our Services or changes to our Privacy Policy or Terms of Use, to manage our properties and facilities, including responding to tenant inquiries

  • Identifiers
  • Biometrics
  • Payment Info
  • Demographics
  • Device Info
  • Location Data
  • Employment Info
  • Transaction Data
  • AV Info
  • Submitted Info
  • Inferences

Email you with apartment listings or other properties of interest

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Send you alerts and notices regarding premises you lease from us

  • Identifiers
  • Submitted Info

Respond to your comments, questions, and requests, and provide customer service

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Communicate with you concerning visits to a property or entry into a premises

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Understand and analyze your needs with respect to a property and third parties

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Send you advertisements and communicate with you regarding our and third-party products, Services, offers, promotions, and events

  • Identifiers
  • Device Info
  • Location Data
  • Demographics
  • Transaction Data
  • Submitted Info
  • Inferences

Engage with you through third-party social media sites such as LinkedIn, Facebook, Instagram and YouTube, either through direct communication or advertisements regarding our and third-party products, services, offers, promotions, and events

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Prevent and address fraud, breach of policies and terms, and threats of harm to property or building occupants

 

  • Identifiers
  • Biometrics
  • Payment Info
  • Device Info
  • Location Data
  • Employment Info
  • Transaction Data
  • AV Info
  • Submitted Info
  • Inferences

Perform analytics on our Website and our Services

  • Identifiers
  • Device Info
  • Location Data
  • Transaction Data
  • Submitted Info
  • Inferences

Process job applications and manage personnel

  • Identifiers
  • Demographics (voluntarily submitted)
  • Employment Info
  • Submitted Info

 

How We Use Artificial Intelligence. We use ‘artificial intelligence’ (“AI”) to provide certain features of our Services, in particular: providing chatbot support for building service requests; providing information services regarding current and future property availabilities; and intake and processing of communications submitted to us (collectively, the “AI Features”).  

 

How We Use Your Information for Identity Verification and Security Purposes. We also may obtain information about you from other businesses to verify your identity so we can properly process your requests and prevent fraud. 

 

How We Use Non-Personal Information. We may use and disclose, in our sole discretion, any non-Personal Information that does not alone or in combination with other information identify you, including, but not limited to, all anonymized and aggregated information, without restriction. Such use may include, but is not limited to, (1) analyzing requests; (2) tracking usage patterns; or (3) identifying usage barriers so that we may improve our Services and enhance our user experience. When aggregated or deidentified information is directly associated with Personal Information, such that the aggregated or deidentified information can be reasonably associated with a particular individual user or household, then this aggregated or deidentified information is treated as Personal Information.

 

4. How We May Share or Disclose Your Information

We may share or disclose your Personal Information to the following individuals or entities or for the following purposes:

  • Service Providers. This includes our agents, vendors, consultants, and other Service Providers, including our attorneys, brokers, real estate agents, facilities and service personnel, building and property management software tool providers, security providers (such as background check services, anti-fraud, anti-money laundering and ‘know your customer’ service providers), digital infrastructure providers (such as hosting for our Website and email), payroll providers, and payment processors (collectively “Service Providers”) in order for them to perform the activities listed above in the section entitled “How We Use Your Information” at our instruction and on our behalf.
  • Advertising and Social Media. We may share your Personal Information with third-party social media sites, including LinkedIn, in order to send you advertisements and communicate with you regarding our Services, offers, promotions, and events. We may share your Personal Information, including your Device Info, email address or other digital Identifiers, with our advertisers, so that we may show you ads about our Services. We also sometimes use “retargeting” to show you advertisements for our products or our Services after you have left our website. We may also use your Personal Information to build “lookalike audience” profiles, which allows us to target individuals who share your profile or characteristics. You may opt out of this use of your information as described in the section below entitled “All Users: Your Choices and Controls.”
  • Law Enforcement and Regulatory Agencies. We may share your Personal Information with law enforcement or other government agencies, in order to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or to otherwise protect the rights, property, life, health, security and safety of our organization, our Service Providers, or tenants.
  • Payment Processors. We provide your payment information to payment processors in order to complete transactions associated with our Services. Please note that we do not permanently store this information on our systems; rather, it is provided directly to the payment processors, who then process that information as set forth in their privacy policies.
  • Analytics Providers. We share your Personal Information with services, such as Google Tag Manager, to gather information about how our Websites and other digital properties are used.
  • Affiliates. To our affiliates for internal business purposes.

Our Service Providers are prohibited from using or disclosing your Personal Information for any purpose other than to perform the services listed in Section 3 (“How We Use Your Information”). However, we may permit our Service Providers to use aggregate information which does not identify you or de-identified data for any other purpose.

We Share Aggregated Information. We may share with third parties aggregated demographic information collected on or through our Services, including for marketing purposes. Aggregated demographic information does not include and is not linked to any Personal Information that can identify you or another individual person, but we may use your IP addresses to verify users’ locations for various purposes, including geographic restrictions.

 

We May Transfer Your Information In Connection with a Business Transfer. As we develop our business, we might sell or buy businesses or assets, such as the sale of some, all or most of Rudin’s assets or equity to another company. In the event of a corporate sale, merger, reorganization, dissolution, or similar event in which a third party assumes control of all or part of our business, Personal Information may be part of the transferred assets or business.‍

5. Communication Services and Community Features Chat Rooms, Forums, and Message Boards. 

Our Services may make chat rooms, forums, blogs, message boards, and other community features and activities available to you and other users. If you post Personal Information online, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose Personal Information in these areas. We reserve the right (but assume no obligation) to review and/or monitor any such community areas on our Services.

 

Short Message Service (SMS). We may make available a service through which you can receive messages on your wireless device via short message service (our “SMS Service”). You understand that your wireless carrier’s standard rates apply to these messages. If you subscribe to one of our SMS Services, you may be required to register and provide Personal Information. We may also collect the date, time, and content of your messages in the course of your use of our SMS Service. We will use the information we obtain in connection with our SMS Service for the purpose of sending the SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information to facilitate the transaction in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We may also contact your carrier, which may access the content of your wireless account, for the purpose of identifying and resolving technical problems and/or Service-related complaints. We do not guarantee that your use of our SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of our SMS Service. You may change your mind and unsubscribe from our SMS Services at any time by following the instructions in the “All Users: Your Choices and Controls” section below.

 

6. All Users: Your Choices and Controls

You have various choices with respect to the collection of and certain of our uses of the Personal Information we collect from you. If you have not consented to us using your Personal Information as described in this Privacy Policy, we will only use it to complete the transaction or provide the service or product you have requested.

 

Accessing, Reviewing, Updating, Correcting or Deleting Your Personal Information.

If you want to access, review, update, or correct inaccuracies in your Personal Information, or delete your Personal Information, you can:

  • email us at: [email protected]
  • write to us at Rudin Management Co. Inc., 345 Park Avenue, 33rd Floor, New York, NY 10154, Attention: Privacy Requests; and/or
  • on our online opt-out request portal. 

 

Upon receiving your communication, we will take appropriate steps to update or correct such information in our possession, or to remove you from our contact list. Your preferences may include, for example, your profile information, as well as any address and account information (if applicable), as well as whether you want to receive communications from us. If you want us to delete the Personal Information we have (except for information that we keep for record-keeping purposes), you should contact us via email at: [email protected]. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records.

 

Opting Out of Direct Marketing and Other Advertising. If you have agreed to receive communications or solicitations from us, and you later change your mind, you can revise your preferences by contacting us at the address listed above, or via email at [email protected]. You also may opt out of receiving all future promotional e-mails from us by clicking on an opt-out or “unsubscribe” link within the promotional e-mail you receive. You can manage your cookie preferences as described below or by using our cookie consent tool. You can submit requests to opt out of the sharing of your information for targeted advertising on our opt-out request portal.

 

Please note that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with updates to this Privacy Policy, our Terms of Use, changes or updates to our Services, administrative issues related to your account, your use of our Services, your transactions or your communications with us.

 

You may also opt out of our SMS messages by texting “STOP” or another applicable keyword to the short code applicable to the particular SMS Service (as further described below).

 

You may opt-out of receiving ads from network advertisers, including many Social Networks, by clicking the AdChoices icon on advertisements that are sent to you or visiting the opt-out pages at the Digital Advertising Alliance (DAA) https://youradchoices.com/control/, and the Network Advertising Initiative (NAI) https://thenai.org/how-to-opt-out/advertising-privacy-settings-on-mobile-devices/. Opting out does not prevent you from seeing ads; it simply means that network advertisers will no longer collect data for the purpose of providing you targeted ads. The DAA and NAI opt-out tools are cookie-based. They signal network advertisers so that they do not collect data online or deliver specific ads targeting you, and only affect the Internet/web browser on the computer where the cookies are installed. These opt-out tools will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie or all your cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is again reset on that browser. Opting out using one browser on one computer will not opt you out using any other browser on the same or another computer. 

 

Do Not Track. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. 

 

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

 

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online sites that you visit. We do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit allaboutdnt.com.

 

Cookie Preferences. Most browsers accept cookies, but you can change your browser settings to refuse cookies, disable existing ones or be notified when a new cookie is sent to your device. Similarly, some mobile operating systems, such as Android and iOS, enable you to opt out of the use of mobile advertising IDs for ads personalization. For your browser, you can generally find cookie preferences in your “settings” or “preferences” panel.

 

The following sites provide information on opting out of certain cookie practices:

  • youronlinechoices.com
  • allaboutcookies.org

Additionally, you can manage your cookie settings with our cookie consent tool.

 

Global Privacy Control. We respect Global Privacy Control (“GPC”) signals. When GPC is enabled, we automatically treat it as an opt-out request for selling or sharing your data, requiring no further action from you.

7. California Privacy Rights

California’s “Shine the Light” Law. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please contact us at Rudin Management Co. Inc., 345 Park Avenue, 33rd Floor, New York, NY 10154, Attention: Privacy Requests. Not all information sharing is covered by the “Shine The Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.

California Consumer Privacy Act (“CCPA”). If you are a California resident, then you also have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information:

  • Right to Know. California residents have the right to request more information regarding the categories of Personal Information we have collected about you, including:
  • The categories of sources from which the Personal Information was collected;
  • Our business or commercial purposes for collecting or disclosing Personal Information;
  • The categories of recipients to which we disclose Personal Information;
  • The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information;
  • The specific pieces of Personal Information we have collected about you.
  • Right to Request Deletion of Personal Information. California residents have the right to request the deletion of Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
  • Right to Correct Inaccurate Personal Information. If you believe that Personal Information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct.
  • Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right to receive non-discriminatory treatment by us.

 

The CCPA requires that we explain the categories of information we have collected in the past twelve months. That listing is below:

 

Category

Examples

Collected and from what source

Disclosed and for what purpose

Sold or shared for advertising purposes

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

You, brokers, real estate agents, your device, advertisers, social networks, security providers

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

B. Personal information as defined in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

You, brokers, real estate agents, your device, advertisers, social networks, security providers

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

C. Protected classification characteristics under state or federal law

Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

You, brokers, real estate agents, your device, advertisers, social networks, security providers

Tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

D. Commercial information

Transaction information, purchase history, financial details, and payment information

You, brokers, real estate agents, your device, advertisers, social networks, security providers

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

E. Biometric information

Fingerprints and voiceprints

You

Only with applicable biometric provider and law enforcement

No

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

You, your devices, advertisers, social networks

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

G. Geolocation data

Device location

You, your device

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

H. Audio, electronic, sensory, or similar information

Images and audio, video or voice recordings created or submitted to our Services, including in connection with purchases of goods

You

Current and potential tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance

Yes

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

You, brokers, real estate agents, advertisers, social networks

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance, employment and hiring

No

J. Education information

Student records and directory information

You, brokers, real estate agents, advertisers, social networks

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance, employment and hiring

No

K. Inferences drawn from collected Personal Information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Advertising, tenant communications and servicing, service improvement, security, fraud protection, analytics, legal compliance, employment and hiring

No

Yes

L. Sensitive Personal Information

Social security number, driver's license, account login information, geographic information

No

To provide requested services, in connection with employment and hiring

No

 

We retain Personal Information for as long as necessary for the purposes described in this notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

  • Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Information;
  • Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
  • Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
  • Personal Information may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.

 

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

 

To exercise your Right to Know or Right to Delete under the CCPA, please submit a verifiable request to us by either calling us at 1-8774372689 or by sending an email to [email protected].

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected Personal Information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.

 

We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

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.

 

Financial Incentive Notice. From time to time, we may offer various types of financial incentives in exchange for your Personal Information, such as coupons, discounts, promotions, loyalty points, sweepstakes, contests, surveys, and other exclusive offers for consumers who sign up to receive our marketing emails or refer other users. The amount and terms of such offers will be presented to you at the time of the offer. When you participate in a financial incentive, we collect Personal Information from you, such as Identifiers (like your email address) and Transaction Data (like your purchase history). Solely for purposes of California privacy law, we reasonably estimate the value of the discount, coupon, or other financial incentive that we offer to you to be equal to or greater than the value we receive from a consumer’s Personal Information collected in connection with the offer. We reasonably estimate the value of a consumer’s data by estimating the expenses related to the provision of each incentive program per consumer. We incur a variety of expenses for providing financial incentives, such as administrative and technical expenses associated with maintaining a loyalty program and costs associated with discounts on purchases. Participation in our financial incentives is voluntary. You may opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out by unsubscribing from our email.

8. U.S. Users Generally 

Your Rights In the U.S., Generally. You have rights under certain U.S. state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. Depending on the state in which you live, these rights include:

  • Right to know whether or not we are processing your Personal Information.
  • Right to access your Personal Information;
  • Right to correct inaccuracies in your Personal Information;
  • Right to request the deletion of your Personal Information;
  • Right to obtain a copy of the Personal Information you previously shared with us;
  • Right to non-discrimination for exercising your rights;
  • Right to opt out of the processing of your Personal Information if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of Personal Information, automated decision making or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”);
  • Right to obtain a list of the categories of third parties to which we have disclosed Personal Information (as permitted by applicable law, including California's and Delaware's privacy law);
  • Right to obtain a list of specific third parties to which we have disclosed Personal Information (as permitted by applicable law, including Oregon’s privacy law);
  • Right to limit use and disclosure of sensitive Personal Information (as permitted by applicable law, including California’s privacy law); and
  • Right to opt out of the collection of sensitive data and Personal Information collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law).

 

Right to Know. Depending upon the state where you live, you have the right to know and see what data we have collected about you over the past 12 months, including:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting your Personal Information;
  • The categories of third parties with whom we have shared your Personal Information; and
  • The specific pieces of Personal Information we have collected about you.

 

Right to Delete. Depending upon the state where you live, you have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same); provided, however, there are a number of exceptions, including, without limitation, when the information is necessary for us or a third party to do any of the following:

  • Complete a transaction you request;
  • Provide you a good or service;
  • Perform a contract between us and you;
  • Protect your security and prosecute those responsible for breaching it;
  • Fix our system in the case of a bug;
  • Protect the free speech rights of you or other users;
  • 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;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

 

Exercising Your Rights. To exercise your right to know or your right to delete, please submit a verifiable consumer request to us as indicated in the “Contact Us” section of this Privacy Policy or on our online opt-out request portal. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request to exercise your right to know twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; 
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; and
  • 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.

We will not discriminate against you for exercising any of your rights described above. Unless permitted by applicable law, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use Personal Information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

 

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

 

Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, depending on your state of residence, you may submit a complaint to your state attorney general.

 

9. Notice to International Users

We provide our Services exclusively within the United States (“U.S.”) and do not own or manage property outside the U.S., including in the EU, any EU–Member State, or any state belonging to the European Economic Area, or intentionally market our Services outside the U.S. Rudin only accepts payments in US Dollars. We do not intentionally market our Services to individuals in the EU, including EU residents. If an EU resident visits or uses the Site, its Related Uses and our Services, that person consents to the practices described in this Privacy Policy and agrees to its terms.

 

10. Third-Party Sites

If you click on a link to a third-party site or a third-party app, you will be taken to a website or service we do not control. This Privacy Policy does not apply to the privacy practices of that website or services, which may collect information from you. Read the privacy policy of other websites, apps, and services carefully. We are not responsible for these third-party websites, apps, and services or their policies. At certain public locations operated by Rudin, such as lobbies of office buildings, guests who wish to access Wi-Fi services may be required to agree to a different privacy policy at the time of access.

11. Children

Our websites and our Services are meant for adults. We do not knowingly collect Personal Information from anyone under 18. If you are a parent or legal guardian and think your child has given us information, you can contact us at [email protected].

12. Information Security

The Internet is not 100% secure. We cannot promise that your use of our websites, apps, or our Services will be completely safe from an information security perspective. 

13. Contact Us

If you have any questions regarding this Privacy Policy, you can contact us via email at [email protected], by regular mail at Rudin Management Co. Inc., 345 Park Avenue, 33rd Floor, New York, NY 10154, or by phone at 212.407.2400.

 

Accessibility Statement

Rudin is committed to facilitating the accessibility and usability of its Website for all people with disabilities. This site has been tested against, and is in material compliance with, the World Wide Web Consortium’s Web Content Accessibility Guidelines 2.1 level AA as its web accessibility standard. We periodically test our Website with assistive technology such as screen readers and screen magnifiers. If at any time you require assistance with accessing our Website and our Services, or if you have specific questions or concerns about the accessibility of a particular web page, please contact us at [email protected] or call 212.407.2400.