Privacy Policy

1. Introduction

Your privacy is important to us. We understand that you are aware of and care about your privacy rights, and we take that seriously. This Privacy Notice describes how Sterling Bay, LLC and its affiliates and subsidiaries (collectively, “Sterling Bay,” “we,” “us,” or “our”) collect, use, share, and otherwise process your Personal Information (as defined below) in connection with the following (collectively, the “Services”):

our Websites (as defined below), mobile application services, social media properties, and any software provided on or in connection with digital services implemented by us and to which we post this Privacy Notice;
our direct marketing communications; and
our events and in certain other offline activities where we have posted this Privacy Notice.

Your decision to use our Services and provide your Personal Information is voluntary. We indicate on our online, mobile, and other forms what types of Personal Information are requested. You may choose not to submit requested Personal Information, or may choose to restrict the use of cookies (see our Your Rights & Choices below for more information), but that may limit the services Sterling Bay is able to provide to you.

Please do not provide Personal Information that you do not want us to have.

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new Personal Information practices or adopt new privacy policies. You are encouraged to check this page periodically so that you are aware of any changes. By using our Services, you agree to be bound by our then-current Privacy Notice.

2. Definitions

The following definitions shall apply to this Privacy Notice:

“Personal Information” means any data that relates to a living individual who can be identified from that data or from that data taken together with other information in the possession of, or likely to come into the possession of, Sterling Bay (or its representatives or service providers). Personal Information may include, but is not limited to, first name, last name, email address, mailing address, city, state, phone number, and Usage Data. For California residents, “Personal Information” includes the definition of “Personal Information” under the California Consumer Privacy Act (“CCPA”).

“Usage Data” means information about how the Services are accessed and used. Usage Data may include, but is not limited to, information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

“Websites” means Sterling Bay websites that link to this Privacy Notice unless such websites have their own posted privacy notices.

3. Cookie Notice

Our Services use cookies, which are small data files that are transferred from a website and placed on the hard drive or browser of your computer, tablet, smartphone, or other device when you visit a website for record-keeping purposes. Cookies may include strictly necessary, performance, functional, and personalization cookies, software logs, and other similar information gathering technologies. When we refer to cookies herein, this includes other similar tracking technologies such as pixel tags, or web beacons. For more information about these tools and your choices, please refer to Use of Our Services – Information Collected Automatically & Other Information and Your Rights & Choices below and https://www.allaboutcookies.org/.

4. How We Collect & Use Personal Information You Provide to Us

Sterling Bay protects the identity of visitors to the Services by limiting the collection of Personal Information. Personal information provided by you to us will not be posted or published by us and will be shared with third parties only as provided herein. When you visit our Services, we or our third-party service providers may collect Personal Information from you that you voluntarily choose to share with us through the Services or otherwise including:

Contact information, such as your first and last name, email address, mailing address, and phone number.
Communications, such as your questions or correspondence that you send us.
Employment information, such as your work history, educational background, and resume.
Identification, such as numbers or scans of your driver’s license or other government-issued identification.
Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Other information that we may collect and is not specifically listed here, which we will use as described in this Privacy Notice or otherwise disclosed at the time of collection.

We may use Personal Information provided by you to provide you with offerings and services, marketing materials, publications, and the like. We do not sell or share (i.e., disclose to third parties for the purpose of cross contextual advertising) Personal Information to anyone and only disclose it with our third-party service providers who help facilitate the delivery of our Services.

Communications from our approved, third- party partners and us

If you choose to provide us with Personal Information, you also may receive the following types of emails from us, including:

Emails related to Service-maintenance activities;
Emails highlighting new features, content, and usage tips for the Services;
Communications, news, or updates about our tenancies, building announcements, or other property-related information and/or other promotions and offers we think you may find of interest; and
Special offers or promotions
From us for additional Sterling Bay-affiliated promotions, events, and services, and
From our approved, third-party partners who offer products and services that may be of interest to you.

Purposes for processing (using) Personal Information provided directly by you

As explained above, Sterling Bay processes your Personal Information to provide you with the Services you have requested from us. Sometimes we use third-party service providers to facilitate the delivery of the Services described above, and these third-party service providers may be supplied with or have access to your Personal Information for the sole purpose of providing services to you on our behalf. Also, we may disclose your Personal Information in special legal circumstances. For instance, such information may be used where it is necessary to protect our rights, or if the law requires us to do so. We will use your personal information for one or more of the following business or commercial purposes:

To perform services for you.
To create, maintain, customize, and secure your account with us.
To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
To provide advertising and marketing services.
To keep a record of your relationship with us.
To evaluate your candidacy for employment.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

5. Use of Our Services – Information Collected Automatically & Other Information

Like other commercial websites, Sterling Bay and our authorized, third-party service providers and partners may use cookies throughout our Services to collect certain information automatically and store it in log files to monitor the use of the Services, gather non-Personal Information about our users, and for a variety of other legitimate business interests and purposes. This information may include (but is not limited to) Usage Data and other information about your use of our Services, including a history of the pages you view.

We also may receive other data about your use of our Services from other sources, including third-party websites. This information may include (but is not limited to) information about your activities across unrelated websites and mobile applications, information about the possible relationships between different browsers and devices and information that we receive from our third-party service providers, demographic data, information from social media providers, and information about your interests. We may add this information to the data we have already collected through our Services.

Links to third-party websites

The Services may contain links to other websites or apps that may offer content, functionality, or applications developed and maintained by third parties. These third-party linked services may use automated means to collect information about you and your use of these features. Sterling Bay is not responsible for the privacy practices or content of these third-party linked services. We urge all users of our Services to follow safe internet practices. Once you leave the Sterling Bay Services, do not supply Personal Information to these third-party linked services unless you have verified their security and privacy policies.

Purposes for processing (using) information collected automatically & other information

We may process information collected automatically through our Services and other information for any purpose, except if it is considered Personal Information or as otherwise prohibited by applicable law. If we combine information collected automatically with your Personal Information, we treat the combined information as Personal Information and use it only in the manner described above. See Purposes for processing (using) Personal Information provided directly by you above.

Specifically, we may use information collected automatically to help us design our Services to better suit our users’ needs, to provide and improve our Services, to provide support, for statistical and market research purposes, and for analytic purposes through tools such as Google Analytics. We also may use your Usage Data to help diagnose problems with our servers and to administer our Services, analyze trends, track user movements and gather broad demographic information that assists us in identifying user preferences.

6. Your Rights & Choices

This section describes the rights you have under this Privacy Notice. You may have additional rights under applicable law – please see Your California Privacy Rights below for more information.

How you can opt out of Sterling Bay marketing

You can unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails or by contacting us as indicated in the contact section below.

How you can manage cookies

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. For more information about cookies, please visit https://www.allaboutcookies.org/.

7. How we respond to “Do Not Track” signals

When you visit a website in any browser, you automatically share information with that website, such as your IP address, and other standard PC information. If the website contains content provided by a third-party website (for example a web measurement tools such as a web beacon or scripts), some information about you may be automatically sent to the content provider. This type of arrangement has several benefits, such as allowing you to access third-party content from our Services conveniently. Some internet browsers or other tools include “Do Not Track” (DNT) features that, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Sterling Bay does not currently respond to DNT signals.

8. Children’s Privacy

Sterling Bay does not knowingly collect or solicit Personal Information from or about children under 13, except as permitted by law. If we discover we have received any information from a child under 13 in violation of this policy, we will delete that information immediately. If you believe Sterling Bay has any information from or about anyone under 13, please contact us as indicated in the contact section below.

9. Data Storage and Security of Your Information

Any Personal Information collected through this site is stored on third-party cloud-based solutions that adhere to SOC 2 compliance. Also, to help protect the privacy of data and Personal Information you transmit using our Services, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We strive to restrict access to your Personal Information to those employees who need to know that information to provide benefits or services to you. In addition, we educate all our employees about the importance of confidentiality and maintaining the privacy and security of your information.

10. Data Retention

We retain your information for the duration of your business relationship with us and as long as necessary to permit us to use it for the legitimate business purposes that we have communicated to you and comply with applicable law or regulations.

11. Your California Privacy Rights

If you are a California resident, you are entitled to specific rights granted under the CCPA. This section is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this section is set forth elsewhere in this privacy policy.

We collect limited types of personal information through our Websites or off-line (including, through job fairs or an application for employment). The types of Personal Information we collect about you depends on the nature of your interaction with us. The categories of Personal Information we have collected from individuals on this Website over the last twelve (12) months include the following:

Category	Examples	Collected
A. Identifiers	Name, contact details, account name, social security number, driver’s license number, passport number and address (including physical address, email address and Internet Protocol address) or similar identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Telephone number and personal information provided in connection with obtaining account access	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Account data, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
E. Biometric information	Imagery of [the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings] or [keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data] that contain identifying information;	NO
F. Internet or other similar network activity	Information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information	Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	NO

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services.
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions.
As reasonably necessary and proportionate to ensure the physical safety of natural persons.
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us).
To perform services on behalf of our business.
To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, or to improve, upgrade, or enhance such service or device.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers. Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Human Capital Management and Website Traffic Analytics
B. California Customer Records personal information categories.	Human Capital Management
C. Protected classification characteristics under California or federal law	Human Capital Management
D. Commercial information	None
E. Biometric information	None
F. Internet or other similar network activity	Website Traffic Analytics
G. Geolocation data	Website Traffic Analytics
H. Sensory data	None
I. Professional or employment-related information	Human Capital Management
J. Non-public education information	Human Capital Management
K. Inferences drawn from other personal information	None

The California Consumer Privacy Act (CCPA) provides you with the following rights with respect to our use of your Personal Information:

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
the categories of personal information we collected about you;
the categories of sources from which the personal information is collected;
our business or commercial purpose for collecting such personal information;
the categories of third parties with whom we disclose the personal information;
the specific pieces of personal information we have collected about you; and
whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

If you wish to exercise any of the rights enumerated in this section, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number at 888-570-0060.
By emailing privacy@sterlingbay.com.

Within 10 business days, we will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact privacy@sterlingbay.com with any questions about your rights under this section.

12. Business Transfers

As we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Sterling Bay or substantially all of its assets are acquired, customer information will be one of the transferred assets and will remain subject to our Privacy Policy.

13. Acceptance of Privacy Policy Terms and Conditions

By using the Services, you signify your agreement to the terms and conditions of this Sterling Bay Privacy Notice. If you do not agree to these terms, please do not use this site. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this policy at any time. Please check this page periodically for any modifications. Your continued use of any of the Services following the posting of any changes to these terms shall mean that you have accepted those changes.

14. How to Contact Us

If you have questions about Sterling Bay or its products, visit our Contact page at https://sterlingbay.com/contact-us/