Privacy Policy
PRIVACY POLICY
222 East Broadway Property Owner, LLC (“Company” “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for the website located at www.222les.nyc (the “Website”) and any other services provided by us or our affiliates (the “Services,” and collectively with the Website, the “Properties”).
BY USING OR ACCESSING THE PROPERTIES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE PROPERTIES OR PROVIDE US WITH ANY PERSONAL INFORMATION.
WHAT OUR PRIVACY POLICY COVERS
This privacy policy applies to the personal information that we obtain in various contexts, including when you:
Access or use our Properties; or
Communicate with us over email or text message, or otherwise via the Properties.
We may provide different or additional privacy notices in connection with certain activities, programs, and offerings.
PERSONAL INFORMATION WE COLLECT FROM YOU
We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.
The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Properties:
Identifiers, such as your name and email address;
Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement;
Geolocation or other information that permits us to determine your location;
Any other personal information that you voluntarily provide us.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Personal Information You Provide
We collect personal information that you provide to us directly. This may include, but is not limited to:
Information you provide when you contact us via email or text message, or through other Internet-enabled communications;
Information you provide when you access the Properties or obtain our Services;
Details relating to transactions that you carry out through our Properties or when you obtain our Services, including any orders that you ask us to fulfill, and any payment or other financial information you provide to us relating to such orders;
Your search queries on the Properties;
Any other information that you provide us on or through the Properties.
Personal Information We Collect Automatically
When you visit our Properties, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.
Cookies and Similar Technology
“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Properties, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Properties you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Properties. We may also use cookies to customize your visit to the Properties and for other purposes to make your visit more convenient or to enable us to enhance the Properties and Services.
Clickstream Data
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Properties. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Properties, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Properties and our Services.
Analytics
We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Properties and other Services.
HOW WE USE YOUR PERSONAL INFORMATION
We collect and use personal information for the following purposes:
To communicate with you, which may include:
Contacting you about and providing you and our clients with our Services;
Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
Adding you to our mailing lists and sending you emails from time to time;
To provide our products and services, which may include:
Operating the Properties, and providing you with any specific services that you have requested;
Fulfilling your orders and/or completing the transactions you have requested, processing your payments, and providing you receipts and order updates;
For marketing and promotional purposes, which may include:
Marketing Company goods and services or goods and services of those of our affiliates, business partners, and other third parties;
Providing you advertising for products and services that may be of interest to you;
Administering sweepstakes, contests, and other similar promotions;
For analytics and personalization, which may include:
Identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners;
Conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners;
Understanding how you interact with our Properties, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve Properties and marketing campaigns;
Personalizing your experience to save you time when you visit our Properties, and to customize the marketing and advertising that we show you;
Better understanding our customers’ needs;
Providing personalized recommendations about our products and services;
For security and fraud prevention, which may include:
Helping maintain the safety, security, and integrity of our Properties, databases and other technology assets, and business;
Internal research; technological development and demonstration; and improving, upgrading, or enhancing our Properties;
Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Properties;
To comply with legal obligations, which may include:
Compliance with legal or regulatory obligations, establishing or exercising our rights, and to defending against a legal claim;
Responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;
To support core business functions, which may include:
Maintaining records related to business process management, loss and fraud prevention, and to collect amounts owing to us;
Providing and provide and maintaining the functionality of our Properties, including identifying and repairing errors or problems; and
For any additional purposes that you specifically consent to.
HOW WE DISCLOSE OR SHARE YOUR INFORMATION
In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:
Service Providers
We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, payment processing, auditing, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
Corporate Affiliates
We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
Business and Advertising Partners
We may share your personal information with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).
Legal Compliance and to Defend Our Rights
We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Business Transfers
We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Properties.
Non-Personal Information
We may share non-personal information with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Properties, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.
Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.
INTEREST BASED ADVERTISING
Targeted Advertising / Behavioral Advertising
We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our Properties or other websites. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.
If you would like to opt out of these interest-based advertisements, please follow the opt-out process described in the section titled Your Choices below.
Cross-Device Matching
We may use your information to help us, or our third-party vendors, determine if you have interacted with our Properties across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis. To opt-out of or restrict our use of certain cross-device data, please see the section titled Your Choices below.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this privacy policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at L&C@optimumam.com.
DATA RETENTION
We will retain your personal information for as long as your inquiry is active or as needed to provide you with the Properties, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
YOUR CHOICES
Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.
Opting Out of Messages or Services
We may send you marketing messages via email, [SMS message, postal mail, or telephone]. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at L&C@optimumam.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.
Cookies and Tracking Technologies
If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Properties or some of its functionality may be affected.
Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.
Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Interest-Based Advertising
You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.
For targeted advertisements delivered through mobile apps, users may opt out of certain ads or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, visit the following links:
iOS – https://support.apple.com/en-us/HT202074
Android – https://support.google.com/ads/answer/2662922?hl=en
You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices).
Finally, to learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.
CROSS-BORDER DATA TRANSFERS
If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers.
CHILDREN’S PRIVACY
Our Properties are intended for users ages 18 and over, and we do not knowingly collect personal information from children under the age of 16. When we become aware that personal information (or other information that is protected under applicable law) from a child under 16 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 16, please contact us by emailing L&C@optimumam.com
CHANGES TO THIS POLICY
We reserve the right, at our discretion, to update this Privacy Policy at any time and will notify you of any material changes to the way in which we treat personal information by posting an updated Privacy Policy or other notice on relevant areas of our Website. Any updated version of this Privacy Policy will be effective immediately upon posting unless otherwise specified. Your continued use of the Properties after the effective date of the revised Privacy Policy will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected. We encourage you to periodically review the Website for the latest information on our privacy practices.