Privacy Policy

OneWall Privacy Policy

This Privacy Policy sets forth the terms and conditions with respect to how OneWall Management (the “Company,” “we,” “our,” or “us”) collects, uses, and processes personal information about you (hereinafter “you” or “your”) and other third parties. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information you provide us when you access or use any of our websites (collectively, the “Site”), including any content, offerings, products, materials, functionality, and/or services offered through the Site (collectively, the “Online Services”).

BY ACCESSING OR USING THE ONLINE SERVICES OR BY OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE COMPANY TERMS OF USE. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND THE COMPANY TERMS OF USE, YOU SHOULD NOT USE THE COMPANY’S ONLINE SERVICES, AND YOU SHOULD LEAVE THE SITE IMMEDIATELY AND NOT PROVIDE THE COMPANY WITH ANY PERSONAL INFORMATION.

1. Scope

This Privacy Policy applies to personal information that the Company receives during its business operations. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

2. The Types and Categories of Personal Information We Collect

The Company collects personal information in order to provide the Online Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the Online Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:
Personal Information
Category
Description/Examples
Personal Identifiers
Identifiers, such as your name, alias, address, email address, account name, telephone number, and date of birth.
Registration
Information provided when you register for an account to use the Online Services, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)
Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial Information
Records of properties you leased, purchased, or considered, or your other leasing or purchasing histories or tendencies.
Business Contact Data
Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Marketing and Communications Data
Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network Data
Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.
Your Feedback
Information you provide about the Online Services, which may include data gathered from any the Company surveys or reviews submitted by you.
Geolocation Data
Information about the general city, state, or region in which a user of the Site is located.
Leasing and Property Management Services Data
Data needed for leasing and underwriting activity, credit and background checks, compliance with loan covenants, insurance claims management, and the sale of properties, which may include social security numbers, driver’s license numbers and financial information, bank account numbers, and credit/debit card numbers.
Investment Data
Data about your investments with us, including investment amounts and information provided by completing subscription documents for deals closed, your personal investment entities and their co-owners and beneficiaries, and tax related information in connection with your investments with us.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)
If you apply for a job with the Company, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.

3. Technical Data

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged.

Google Analytics. We use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other websites they used prior to coming to the Site. We use the information we gather from Google Analytics only to improve the Site and the Online Services. Google Analytics collects the IP address assigned to your device on the date you visit the Site. We do not combine the information collected through the use of Google Analytics with other personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser. You can find additional information on how to install a browser add-on to prevent your data from being used by Google Analytics at tools.google.com/dlpage/gaoptout.

4. Sources of Information

We collect the personal information identified herein directly from you when you use the Online Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use the Online Services (e.g., account registration, completing applications) or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

5. How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform the Online Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote the Online Services, (ii) enable you to access and use the Online Services, (iii) process and complete transactions, and send you related information, including invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for the Online Services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about the Online Services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with the Online Services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of the Online Services, and other illegal activities, and (x) personalize the Online Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, the Company may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that the Company may contact you via any means, including SMS/text message and email, to furnish you information pertaining to a commercial transaction.

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of the Online Services.

Payment Card Transactions. All payments for purchases made through the Site are completed using a third-party vendor’s online payment system. The Company does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.

Disclosure for Other Reasons. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, the Company may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.

7. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on one of these platforms for customer support or otherwise, we may contact you via the social media’s direct message tools. Those communications are governed by this Privacy Policy as well as the policies and terms of the relevant social media platform. The information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site may include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Online Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with the Online Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy. The Company is based in the United States and the personal information that we collect and process is retained and stored in the United States. Please be aware that the United States may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States, your personal information may be accessible by, or otherwise made available to, government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations applicable in the United States. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States.

10. Information Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access the Online Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to the Online Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11. No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age without verified consent from their parents or guardians. If you are under the age of sixteen (16), you are prohibited from accessing or using the Online Services (including the Site) or with providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.

12. Publicly Posted Information; Reviews

The Site may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss certain types of properties, leases, and property managers (a “Review”). Any information or content you post in a Review will be available to other users of the Site and may be retrievable by third-party search engines, and third parties may also be able to download or share your Review to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Review that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part and we recommend you carefully consider the information you choose to make publicly available. You agree not to submit a Review or upload any material to the Site that: (i) is or could be interpreted to be infringing, defamatory, libelous, inaccurate, unlawful, harmful, threatening, abusive, harassing, vulgar, offensive, obscene, pornographic, objectionable, hateful, or promotes discrimination, bigotry, racism, or hatred; or (ii) introduces viruses, time-bombs, worms, Trojan Horses and/or other harmful or malicious code to the Services. We have no obligation to monitor this Site or any portion thereof. However, we reserve the right to review any Review and remove, delete, redact or otherwise modify from the Site such Reviews, in our sole discretion, at any time and from time to time, without notice or further obligation to you. We reserve the right to disclose, at any time and from time to time, any information or posted in a Review that we deem necessary or appropriate, including without limitation to satisfy any applicable, law, regulation, contractual obligation, legal, dispute process, or governmental request.

13. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY THE COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY.

14. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your online account to update and change your personal information (e.g., name, telephone number, email, address) and you must do so, when such changes are warranted. If your account does not contain such features, then you must directly notify the Company of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

15. Email Marketing and Your Rights

You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

16. Canada Privacy Rights

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by the Company in accordance with this Privacy Policy and the Company’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to Canadian law, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email and request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. When permitted by law, we may charge you a fee to access your personal information, provided however, we advise you of any such fee in advance. Your right to access personal information is not absolute, and in some cases we may not be able to allow you to access certain personal information in certain circumstances (e.g., if it contains personal information of other persons or the information is subject to legal privilege). In the event that we cannot provide you with access to, or correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please follow the applicable opt-out instructions listed above (see “Email Marketing and Your Rights”) or contact us in accordance with the “Contact Us” section listed below. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

17. Nevada Privacy Rights

The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

18. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

19. Persons with Disabilities

The Company strives to ensure that every person has access to information related to the Online Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

20. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

21. Events and Video Teleconferencing

The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by us or our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

22. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review this Privacy Policy to determine whether any amendments have been made hereto. Your use of the Online Services, and continued use of the Online Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review this Privacy Policy to determine whether any amendments have been made hereto.

23. Contact Us

If you have any questions regarding this Privacy Policy or would like to exercise a right set forth herein, correspondence may be sent to OneWall Management, ATTN: Legal Department, 707 Summer Street, 5th Floor, Stamford, CT 06901.