INTRODUCTION

Welcome to the 260 Kent LLC (“260 Kent”) website (the “Site”). 260 Kent is committed to protecting the privacy of visitors to the Site. You (“You” or “Your” as applicable) should read and understand the following Privacy Policy (“Policy”). This Policy is intended to provide You with information regarding 260 Kent's collection, storage, use, and disclosure of Your personal information (“Information”). This Policy applies to all services available on the Site and does not apply to services or products offered by other companies or individuals, including third party sites made available through this Site. By using the Site, You consent to the collection and use of Your Information by 260 Kent as described in this Policy and the 260 Kent Terms and Conditions located at www.twotreesny.com, which is incorporated herein by reference and may include terms which are listed but not defined in this Policy.

260 Kent may update this Policy in the future and 260 Kent reserves the right to revise this Policy at any time. Any such revisions shall be effective immediately upon notice thereof. Such notice may be provided by any means, including by posting a revised Policy. Your use of the Site subsequent to such notice shall be deemed acceptance by You of such revised Policy.

INFORMATION COLLECTED /3RD PARTY WEBSITES:

We collect both "Personal Information" and "Anonymous Information" about our users.

"Personal Information" is information that can be used to contact or identify you or individuals about whom you enter information as part of your application on our Services, such as first name, last name, social security number, real estate license number, email address, phone number, street address, e-mail address, username and/or email address in combination with a password or security questions and answers, account numbers or credit/debit card numbers, even without a security code, access code, or password if the account could be accessed without such information, as well as information that is linked to the forgoing information.

"Anonymous Information" is information that cannot be used to contact or identify an individual and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Services, such as usage data, to the extent that information is not linked to your Personal Information.

Like most website and mobile app providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system. We also collect geolocation data from Users that use the Services.

a. Voluntarily submitted information

We collect Personal Information that you voluntarily provide to us during your use of the Services, including when you subscribe to our broker listings, fill out the Contact Us form, contact an agent, schedule a tour of an available apartment, submit an application, enter information in the Services, make payments or otherwise manage your account with us through the Services.

b. Information collected via technology

We may collect information from your use of the Services, including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name. If you are using a mobile device, 260 Kent may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use tools such as cookies to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. A “Pixel” is a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported.
Geolocation data: If you access the Services through a mobile device, we may access, collect, monitor and/or remotely store “geolocation data.”
We use third party services, such as Google Analytics and Google Search Console, to track and analyze online behavior data of Users. In particular, we utilize features of Google Analytics called “Remarketing,” “Demographics and Interest Reporting” and “Ad Words.” These services enable us to use Google Analytics’ third-party audience data help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Services, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.

USE OF COLLECTED INFORMATION

Personal Information

We may use your Personal Information for the following representative purposes:

Schedule an apartment tour for you
Send communications and administrative emails
Process and evaluate information provided by you through the application process and contact you regarding the same
Process information uploaded by you to our Services
Process application, rent and other payments
Send you information you request about the building, amenities and services
Send you promotional/marketing information, newsletters, offers or other information from us or on behalf of our sponsors or partners
Perform internal operations, including fraud detection
·Analyze, benchmark and conduct research on user data and interactions with the Services

Anonymous Information

We may use Anonymous Information for the following representative purposes:

Perform internal operations on the Services
Improve the Services and customize the user experience
Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns

SHARING AND DISCLOSING INFORMATION

We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described in this Privacy Policy.

If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Services or provide your Personal Information at any time.

In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.

In addition, by downloading and using the Services, you agree to allow us to share your geolocation information.

a. Service Providers

We share Personal Information with vendors, consultants and other third-party service providers who perform services on behalf of - and at the request of – 260 Kent, including without limitation, companies that provide email services and host the Services, and third-party payment processors to enable the ability for you to make payments through the Services.
260 Kent has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of 260 Kent and in accordance with the terms and conditions of this Privacy Policy.

b. Compliance with Laws, Law Enforcement and Safety

We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend 260 Kent's, or a third party's, rights or property.

c. Aggregated Anonymous Information

Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.

d. Business Transactions

We may share all or some of your Personal Information with any of our subsidiaries, joint venturers, or other companies under common control, in which case we will require them to honor this Privacy Policy.

SECURITY OF YOUR INFORMATION

260 Kent uses commercially reasonable procedures to protect the Information collected through the Site. Please understand that no security system is perfect and, as such, 260 Kent does not guarantee the security of the Site, or that Your Information won’t be intercepted while being transmitted to the Site. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or “personal information” (as defined in applicable state statutes on security breach notification) to you via email and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

LINKS TO THIRD PARTY WEBSITES

Although the Site contains links to third party websites, 260 Kent is not responsible for the privacy policies and/or practices on those third party websites. Where 260 Kent has linked You to a third party website You should read the terms and conditions and privacy policy stated on that third party website as it governs the use of that third party website.

CHILDREN'S PRIVACY

The Site is directed to persons 18 years of age or older. Accordingly, You must be 18 years of age in order to access the Site. If You are under 18 years of age You may not access the Site without the consent of a parent or guardian. 260 Kent does not knowingly collect, distribute or share any Information from persons under 18 years of age and 260 Kent is not under any obligation to verify that persons accessing the Site are, in fact, over 18 years of age. If 260 Kent becomes aware that a child under 18 years of age has provided Information to 260 Kent or the Site, 260 Kent will delete such Information as soon as is possible under the circumstances.

TERMINATION

If you decide at any time that you no longer wish to receive the Services, please follow the unsubscribe instructions provided in any of the communications You receive. 260 Kent will delete Your 260 Kent ID and/or cease providing You with Services within thirty (30) days of receiving Your termination request and all of Your Information will be removed and no longer available on the Site. Please note that 260 Kent reserves the right to use Your Information in any aggregated data collection after termination, however 260 Kent will ensure that the use of such Information will not identify You personally.

CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at tengrandstreet@twotreesny.com.

QUESTIONS

If You have any questions concerning this Policy or the Site, please contact 260 Kent at tengrandstreet@twotreesny.com

Effective Date: March 15th, 2023