Jamestown Mobile Application Privacy Policy

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Our Policy:

Welcome to the mobile application (the “Mobile App”) for The Innovation and Design Building of Jamestown, L.P., and its affiliates, subsidiaries, and related companies (“Company”, “we”, “us” and/or “our”), powered by HqO, Inc. (“HqO”). The Innovation and Design Building App and related services are provided by Company to augment a tenant’s experience at our commercial or residential property through providing information, services, and functionality related to the property (collectively, the “Services”), and are subject to the Terms of Service. This privacy policy (“Privacy Policy”) sets out how Company collects, uses, discloses, and protects any personal information that you provide in connection with your use of the Mobile App and/or Services (“Personal Data”). This Privacy Policy does not apply to any personal data collected by Company other than Personal Data collected through the Mobile App or the Services.

Please read this Privacy Policy to understand how Company may process your Personal Data via your use of the Mobile App and/or Services. If you do not agree to the practices described below please do not use the Mobile App. If you have questions about this Privacy Policy or the practices described herein, please contact us.

 

1. Information We Collect

When you download and use the Mobile App to interact with us through the Services, we collect Personal Data and other information from you, as further described below:

• Personal Data That You Provide: We, or service providers acting on our behalf, collect Personal Data from you when you voluntarily provide such information through the Mobile App, such as when you use one of the available features to, for example, submit a maintenance request or work order, chat with the concierge, use mobile access to enter an area, view transit information, book certain amenities with a third party provider, or register a visitor.
• Depending on the feature used, the Personal Data collected may include your name and contact information, or that of your visitors, as well as any other Personal Data you voluntarily provide, for example, by enabling the following features when requested: (i) location services so that we may collect your location information, (ii) access to the photos and videos stored on your device, and/or (iii) biometric authentication; enabling these features will result in you providing the relevant information, but you can manage your permissions for these features in your device settings. Note that certain Personal Data you provide through the Mobile App (e.g., payment information) is collected directly by service providers acting on our behalf (e.g., the payment processor) and we do not have access to such information. Additionally, certain features of the Mobile App may direct you to other web sites, applications, or services not operated or controlled by us or our service providers (the “Third Party Sites”); any Personal Data you provide while using such Third Party Sites is not subject to this Privacy Policy (please see below for more information about Third Party Sites).
• Information Automatically Collected via the Mobile App: When you interact with Company through the Mobile App, we, and HqO acting on our behalf, automatically receive and store certain information regarding your actions taken within the Mobile App. Such information, which is collected using first-party tracking technologies known as JSON Web Tokens (JWT), cannot presently be used to specifically identify you and includes, but is not limited to, pages of the Mobile App used, content with which you interact, and building events which you attended or in which you have expressed interest. This information may be pooled with other information to track, for example, the total number of users of our Mobile App and the number of users who visit and interact with each page of our Mobile App for the purposes of product development and improvement and to notify you about events and features that may be of interest to you. It is important to note that no Personal Data is available or used in this process.
• Aggregated Data: In an ongoing effort to better understand and serve the tenants of our building and users of the Services, Company and HqO often conduct research on tenant and user demographics, interests and behavior based on the Personal Data and other information provided via the Mobile App. This research may be compiled and analyzed on an aggregate basis by HqO, and Company may share this aggregate data with its affiliates, agents and business partners, including HqO, to use and disclose for their own purposes, as permitted by applicable law. This aggregate information does not identify you personally, nor can it reasonably be associated with you.

 

2. Categories of Personal Data Collected

We collect the following categories of Personal Data:

• Identification Information, such as name, username, email address, phone number, and work address.
• Employment and Professional Information, such as employer name.
• Online Activity Information, such as IP address, device information, the date and time of your request, how you interacted with the Mobile App, and other usage information automatically collected using JSON Web Tokens.
• Commercial Information, such as purchase, payment, and billing information, although payment and billing information are provided directly to a payment processor.
• Location Information, if you choose to enable Location Services to use certain Mobile App features, such as mobile access.
• Photo/Visual Information, if you choose to grant the Mobile App access to your pictures or videos or otherwise upload such information.
• Biometric Information, if you choose to enable biometric authentication to make purchases through the Mobile App, although such information is only processed by and provided directly to a payment processor.
• Inferences drawn from any of the above information with the exception of sensitive personal information.

3. Administering Your Mobile App Account

When you download the Mobile App and set up an account, HqO will collect certain Personal Data from you such as, your email address and password, in order to create and administer your account. Additionally, HqO will collect Personal Data you provide as a part of any support requests submitted via the “Help” sections of the Mobile App, including your name, email address, and the content of your request.

 

4. Our Use of Your Personal Data and Other Information

We, and in certain instances HqO, process your Personal Data as described in this Privacy Policy to provide the Services, perform the contract we are about to enter into or have entered into with you, ensure compliance with local legal and regulatory requirements, and for our legitimate business interests, including to:

• provide you with information, products and services that you request from us;
• respond to an enquiry or other request you make when you contact us via the Mobile App, including for customer support;
• identify a user for authentication to the Mobile App;
• notify you about any changes to the Services;
• carry out our obligations arising from any contracts;
• issue a notice or corrective action to you in relation to any of the Services, if required;
• help us improve the content, functionality, and security of the Mobile App and the Services, and to better understand how you use the Services; and
• provide you with information about events, promotions, features, or other services which we believe will be of interest to you similar to those that you have already attended, enquired about, or purchased, as described in the “Marketing / Push Notifications” section below.

 

5. Marketing / Push Notifications

Company and service providers, like HqO, acting on our behalf may use information collected through the Mobile App, such as services you have used and events you have attended, to send you push notifications through the Mobile App about events, promotions, features, and services offered through the Mobile App that may be of interest to you. Where required by applicable law and to the extent they constitute marketing, we will obtain appropriate consent prior to sending you such notifications. If at any time you wish to opt-out of receiving any future notifications, please change your notification settings in the Mobile App or on your device, or contact us as indicated below.

 

6. Our Disclosure of Your Personal Data and Other Information

We may share your Personal Data with certain other entities without further notice to you, as set forth below:

• Agents, Service Providers, and Business Partners: Company sometimes hires other companies to perform certain business-related functions and provide other functionality of the Mobile App. Examples of such companies include HqO to build and host the Mobile App and the Services; our IT service providers that maintain our databases; and companies with whom we partner or whose services are integrated into the Mobile App in order to provide certain Mobile App features, such as registering visitors, handling maintenance requests or work orders, providing mobile access, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
• Third Party Amenities Providers: We may share your Personal Data with third party providers of amenities you interact with through the Services, such as dry cleaning, chair massages, fitness classes, and salon appointments, in order to fulfill your requests, reservations, and contracts with these third party amenities providers.
• Business Transfers: As we or HqO develop our respective businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets or shared during the diligence process.
• Affiliated Companies: We may also share your Personal Data with our affiliated companies for purposes consistent with this Privacy Policy.
• Legal Obligations: Company or HqO may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company or HqO, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

 

7. Storing Your Personal Data

Your Personal Data collected via the Mobile App and through our Services will be stored on servers located in the United States. This includes by individuals or service providers engaged in, among other things, administration of an enquiry or request you make via the Mobile App, or the provision of support services.

 

8. Data Retention

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

9. Children

Company does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Mobile App. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Mobile App without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to Company through this Mobile App, please contact us, and we will endeavor to delete that information from our databases.

 

10. Links to Other Web Sites, Applications, or Services

This Privacy Policy applies solely to Personal Data collected via the Mobile App and the Services. This Mobile App, including certain features provided therein, may contain links to other web sites, applications, or services not operated or controlled by Company (the “Third Party Sites”). This Privacy Policy does not apply to the Third Party Sites. Instead, the data practices of those Third Party Sites are governed by their respective privacy policies, over which we have no control. The inclusion of features or links from the Mobile App do not imply that Company endorses or has reviewed the Third Party Sites or their privacy practices. We encourage you to review their respective privacy policies.

 

11. Security

Company takes reasonable steps to protect the Personal Data provided via the Mobile App and the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, messages sent to or from this Mobile App may not be secure. Therefore, you should take special care in deciding what information you send to us via the Mobile App. Please keep this in mind when disclosing any Personal Data to Company.

 

12. Changes to this Privacy Policy

The Mobile App and the Services may change from time to time. As a result, it may be necessary to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Mobile App and the Services after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.

 

13. Your Rights

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Mobile App or the Services.

For California residents: Please refer to the “Additional Information for California Residents” section below for information about your rights.

For Virginia residents: Please refer to the “Additional Information for Virginia Residents” section below for information about your rights.

 

14. Additional Information for California Residents

This section applies solely to California residents. In accordance with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), this section notifies California residents of (1) the Personal Information that we collect and how we disclose that information; (2) the privacy rights California residents may have relating to their Personal Information; and (3) how those rights can be exercised. As used in this section “Personal Information” means information maintained in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Nothing in this section limits our ability to use or disclose information as described elsewhere in this Privacy Policy.

Details of Data Collected, Used and Disclosed 

Please see above for the categories of data collected and information on our use and disclosure of your Personal Information.

Details of sale of data to third parties 

We do not, and will not, sell your Personal Information, and we do not rent or share your Personal Information with third parties for such third parties’ direct marketing.

Details of Processing of Sensitive Personal Information

We do not collect or process sensitive personal information as defined in section 1798.140 of the CPRA for the purpose of inferring characteristics about a consumer. 

Your Privacy Rights

To the extent provided for by the CCPA and CPRA, and subject to applicable exceptions and exclusions, California residents have the following privacy rights in relation to the Personal Information we collect: :

• The right to request that we disclose to you the specific pieces of Personal Information that we have about you;
• The right to request that we disclose to you the categories of Personal Information that we have collected about you;
• The right to request that we disclose to you the categories of sources from which the Personal Information is collected, 
• The right to request the categories of Personal Information that we sold or disclosed for a business purpose; 
• The right to request the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;
• The right to request the business or commercial purpose for collecting or selling Personal Information;
• The right to opt-out of the sale or sharing of your Personal Information to third parties; 
• The right to request that we delete any Personal Information about you which we have collected from you;
• The right to request the correction of inaccurate Personal Information;
• The right to limit the use of sensitive personal information to what is necessary and reasonably expected;
• The right to not be discriminated or retaliated against following opt-out or exercise of other rights described above.

You also have the right, under California Civil Code Section § 1798.83, to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Your options for making such a request are listed below.

Exercising Your Rights: You can make a request under the CCPA and CPRA using the web form, email or toll-free phone number listed in the “Contact Us” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request.

Upon receipt of a request, we will first need to determine that the individual making the request is the individual about whom we have collected personal information. The specific steps in the verification process will depend on the type and sensitivity of the request. After verification, we will review the request and contact you if any follow-up information is needed to process your request. We will then determine whether your request can be fulfilled or whether there are exceptions that apply. We will respond to your request within the time frames set forth in the rules.

Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose.

Verification: In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: You may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

 

15. Additional Information for Virginia Residents

Details of Data Collected, Used and Disclosed 

Please see above for the categories of data collected and information on our use and disclosure of your Personal Data.

Details of Processing of Sensitive Data

From time to time, Jamestown will process geolocation data which may be considered sensitive data as defined in § 59.1-575 of the Virginia Consumer Data Protection Act (VCDPA). The data processing will not commence until consumer opt-in has been received. 

Your Privacy Rights

If you are a Virginia resident, you also have certain rights pursuant to the VCDPA, including:

The right to request information on whether or not a controller is processing the consumer’s Personal Data and to access such Personal Data;

The right to correct inaccuracies in the consumer’s Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the consumer’s Personal Data;

The right to delete Personal Data provided by or obtained about the consumer;

The right to obtain a copy of the consumer’s Personal Data that the consumer previously provided to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and

The right to opt out of the processing of the Personal Data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Request Process

You can make a request under the VCDPA using the web form, email or toll-free phone number listed in the “Contact Us” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request.

Upon receipt of a request, we will first need to determine that the individual making the request is the individual about whom we have collected personal information. The specific steps in the verification process will depend on the type and sensitivity of the request. After verification, we will review the request and contact you if any follow-up information is needed to process your request. We will then determine whether your request can be fulfilled or whether there are exceptions that apply. We will respond to your request within the time frames set forth in the VCDPA.

Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose.

 

16. Contact Us

If you have any questions about this Privacy Policy or the practices described herein, or wish to exercise your rights with respect to your Personal Data, please direct your inquiry to Jamestown, L.P. as set forth below.

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308

Email: [email protected]

Toll Free: +1-888-914-9661 (PIN: 773 067)

Online: Web Form

If you have questions about your Mobile App account or the information described in Section 3, contact HqO by email at [email protected], call HqO at 833-225-5476, or write HqO at 38 Chauncy Street, Floor 12, Boston, MA 02111.