OUR PRIVACY & ACCESSIBILITY POLICY

YOUR ACCEPTANCE THROUGH EXPRESS CONSENT

Your privacy and informed consent are important to Cortland. This Privacy Policy describes how Cortland collects, uses, and discloses certain personal information obtained through this website (“Site”) and other Cortland business activity. This Privacy Policy is incorporated into, and is part of, the Terms and Conditions, which govern your use of Cortland Properties, Services, Amenities, and this Site in general.

THE TYPES OF INFORMATION WE COLLECT

The types of personal information we may collect from you or you may choose to provide include the following:

When you apply for leases, we may collect information such as your name, address, government ID, date of birth, income, and employment information.
When you visit our websites, we may collect information such as your computer IP address, your device identifier, your location, and what pages you view or visit.
When you visit our offices or attend events that we sponsor or organize, we may collect contact information such as your email address, your phone number, or your physical address. We may also collect audio or visual information about you as a result of security measures we use in our facilities.
Your social media interactions with us (for example, when you “like” a post on social media platforms)
Technical information from advertisements we place on third-party websites (such as your IP address, browser type and version, device identifiers, location, and time zone setting)

HOW WE USE YOUR INFORMATION

Our Communications to You – Offerings Where You Expressed Interest
When you visit our Site, you may be required to register with us or be requested to provide us with personal information. When you provide us with this information, we may use it to contact you about the residences or services in which you have expressed an interest. Cortland has a legitimate business interest to use the personal information we collect from you to provide such requested information. Where we have relied on your express consent, however, if you tell us that you do not want us to use this information as a basis for further contact with you (by contacting us and requesting our opt-out process), we will comply within three (3) days.

Our Communications to You – Events, Newsletters, and Marketing
To keep our residents informed about our latest news, communities, and events, we may send texts, emails and marketing communications to the phone numbers or email address provided to us while registering on our Site or requesting information from us. Cortland complies with applicable laws when using your personal information for this purpose and, where applicable, relies on your express consent. If you opt–in for any of our email lists, newsletters, or other promotional offerings and later change your mind, you may unsubscribe by following the instructions contained in each email we send to you.

General Business Uses
We may also use the personal information we obtain about you for the following purposes:

Evaluating and improving our business reach – including decisions about where to develop new communities, the amenities needed, and pricing.
Improving our business processes
Resident satisfaction surveys
Enforcing our other legal rights

INFORMATION PROVIDED TO US ABOUT YOU BY THIRD PARTIES

Third-Party Content
We may present or embed content on our Site, such as property listings, that is provided by our third-party vendors. This content may contain links to other sites not operated by Cortland or may request personal information. For example, this content may ask for an email address to subscribe to alerts or share a listing with a friend. This information is collected by our vendors and not by us. In some cases, these vendors may share the personal information they collect from you with us. We are not responsible for the privacy practices of our vendors. We encourage you to review their privacy policies to understand how they will use and share the personal information you provide to them.

Third-Party Usage
You may also separately share your information with other Web sites or entities, such as those that create professional marketing lists, to receive special offers and promotions from their affiliates. These Web sites or entities may share your information with us. Cortland is not responsible for and accepts no liability if a partner or other Web site or entity collects, uses or shares, any information about you in violation of its own privacy policy, or applicable law.

Marketing Data
Where applicable law allows, we will purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may also associate this marketing data to the personally identifiable information that you provide to us.

THIRD PARTIES WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

Third Parties for Retargeting Advertising
We will, in some cases, share information about how you use our Site with third-party vendors to present you with more relevant advertising. For example, our vendors may track your browsing activity on our Site using cookies to show you ads based on your interests when you browse the Web or use social media. Our vendors will, in some cases, also share information about your browsing activity on our Site with us for analytics purposes. Cortland relies on your express consent for such processing of your personal information. More information on these cookies, including how to provide or revoke your consent, may be found in our Cookie Policy below.

Service Providers
We may share your personal information with companies acting as our authorized agents in providing our services, including the following categories of service provider:

Infrastructure and IT service providers, including cloud service providers
Marketing, advertising, and communications agencies
External auditors and advisors
Utility companies
Construction service suppliers such as painting contractors
Residential service providers such as pest control and appliance repair
Cookie analytics providers
Online advertisers
Providers of website testing / analytics services

Each service provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. Because we operate globally, we may transfer your information to other countries or jurisdictions. These transfers are managed by Binding Corporate Rules. If we make such a transfer, we will, or our vendors will, as applicable, provide for the proper safeguards required by applicable law to ensure that your information is protected. More information on International Data Transfers of your personal information is below.

Where we share your personal information for our legitimate interests you can object to this disclosure. Please be aware that when you object to disclosure of your personal information for Cortland’s legitimate interests it may affect the services we provide to you. More information on your privacy rights is below.

Legally Compelled Disclosure
We will also disclose your personal information when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to lawful requests by public authorities, including to meet national security or law enforcement agency’s requirements, or in special cases when we have reason to believe that disclosing your personal information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with our rights or property.

INTERNATIONAL DATA TRANSFERS

Processing in the US and Elsewhere by Registration on This Site
Cortland is a business that operates in the United States of America, the United Kingdom, and the EU. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed, in countries other than the country in which the information was originally collected, including the United States and elsewhere. When we transfer your information to other countries, we will protect your information as described in this Policy.

With respect to data transfers outbound from the European Economic Area (EEA) to the United States, Cortland has executed EU Binding Corporate Rules with respect to personal information collected in the European Economic Area and transferred to Cortland in the United States and elsewhere.

Cortland Real Estate Investment Advisors is proud of our compliance, cybersecurity, and data privacy programs. We invite you to contact us to ask questions and find out more about our data management practices.

Disclosure and Liability for Onward Transfer
Cortland is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Cortland may, as disclosed above in Third Parties with Whom We Share your Personal Information, transfer personal information onward to third parties. Cortland remains liable if a third-party processes such personal information in a manner inconsistent with the principles established in this document, unless we prove we are not responsible for the event giving rise to the damage.

Independent Recourse of Privacy Shield Complaints
In compliance with the EU-US and Swiss-US Privacy Shield Principles, Cortland commits to resolve complaints about our collection or use of your personal information. United Kingdom residents with inquiries or complaints regarding our Privacy Shield Policy should first contact Cortland’s Data Protection Officer at dpo@cortland.com.

SECURITY

Cortland endeavors to protect the security of your personal information and your choices for its intended use. We use Secure Socket Layers or SSL technology to protect the transmission of sensitive personal information such as your Personally Identifying Information. We store your personal information on a secure server and use systems and procedures that are designed to protect the personal information we collect from unauthorized access, destruction, use, modification, or disclosure.

Although we will take (and require our third-party providers to take) commercially reasonable security precautions regarding your personal information collected from and stored on the Site, due to the open nature of the Internet, we cannot guarantee that any of your personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the Site or other Cortland services, you acknowledge that you understand and agree to assume these risks.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will only retain the personal information we collect about you for as long as necessary for the purpose for which that information was collected and to the extent permitted by applicable laws. We take steps to ensure that when we no longer need to use your personal information, we remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

YOUR PRIVACY RIGHTS

Your Right to Be Forgotten
Cortland retains resident and applicant data for 90 days after last contact. There are some pieces of data we are required to keep for US records, such as the demographic makeup of our communities. Any resident can request an “Article 17” action at any time after moving out. We will comply within three (3) business days. The data we retain will be anonymized so that it no longer identifies you in any specific way.

Your Right to Request Modification or Correction of Your Data
Mistakes happen. If you notice that we have made a mistake in your data, please let us know. You have the right to request a copy of all the data we have about you and, if you notice an error, request that we fix it. This process is handled through our Data Protection Officer (“DPO”). You may contact us through the following methods:

a) By telephone: +1 404-965-3988
b) By following the opt-out or unsubscribe instructions contained in the body of any marketing email from us
c) By sending us an email at dpo@cortland.com, including a copy of the email you have received, and by typing “Remove” in the subject line of your email
d) By mail: Cortland, 3424 Peachtree Rd, Atlanta, GA 30326, Attention: Cortland Data Protection Officer

Your Rights Regarding Marketing Communications
When you register on this Site, we may ask you to select whether you would like to receive text, email, social media connections, and electronic communications from us such as offers, news, event invitations, and other promotional communications. You may withdraw your consent or opt-out of receiving such communications at any time by contacting us as described below.

Additionally, where we process your personal information for our interests you will have the right to object to such processing. Please be aware that where you object to this sort of processing may affect our ability to carry out tasks as listed in this policy.

You may contact us through the following methods:

Your election not to receive newsletters or promotional and marketing correspondence from us will not: (i) preclude us from corresponding with you, by email or otherwise, regarding your existing or past relationship with us, and (ii) preclude us, including our employees, contractors, agents, and other representatives, from accessing and viewing your personal information in the course of maintaining and improving the Site.

Your Right to Request Access to Your Personal Information and Other Rights
You may also have rights under applicable law to request to review, access, correct, delete, port, or object to our processing your personal information processed by us and lodge a complaint with a supervisory authority. If so, you may do so by making a request to the DPO.

You may contact us through the following methods:

CHANGES TO THIS POLICY

We are a high-growth, global business. We will continue to assess this Policy against new technologies and services and business practices, as well as our residents’ needs, and make changes to this Policy from time to time as we require. If we make any material changes to this Policy, we will make changes here and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes).

DATA PROTECTION OFFICER

We have appointed a data protection officer (“DPO”) for our global operations to address privacy concerns for our residents and those who interact with us. If you have any questions or concerns about our personal data policies or practices, you may contact the DPO using the following contact details:

COOKIE POLICY – AUTOMATIC DATA COLLECTION

By browsing on our Site, you are agreeing to our use of cookies.

What Is a Cookie?
A cookie is a small text file that a website stores on your personal computer, telephone, or any other device, with information about your navigation on that website. Cookies facilitate browsing and a more user-friendly experience. A cookie contains the name of the server it came from, the expiry of the cookie, and a value – usually a randomly generated, unique number. Cookies do not give access to nor damage your device.

How We Use Cookies
We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into four categories, which you can manage through our Cookie Preference Manager:

Strictly Necessary Cookies: These cookies are necessary to enable the basic features of this Site to function, such as identifying you as a valid user, ensuring that no one else can sign on simultaneously with your account from another computer, and helping us serve you better based on your registration preferences. These cookies also allow you to select your cookie preferences.
Performance Cookies: These performance tracking cookies help us to track whether an email recipient has completed an event, such as signing up for a free trial. Such information is non-personally identifying and collected on an aggregate level. We sometimes utilize third-party service providers to help us track the activity within our Site.
Functional Cookies: These cookies allow us to analyze your use of the Site to evaluate and improve our performance. They may also be used to provide a better customer experience on this Site. For example, providing us information about how our Site is used and helping us facilitate any promotions or surveys that we provide.
Targeting Cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our Site.

Cookies Are Not Used to Store Sensitive Data
The cookies we use do not store sensitive personal information, such as your address, your password, or your credit card data.

Performance Tracking
We sometimes use cookies, as well as tracking technology, such as web beacons, within the promotional emails that we send to our subscribers or advertisements for our Site. These performance tracking devices help us to track whether an email recipient has completed an event, such as signing up for a free trial. Such information is non-personally identifying and collected on an aggregate level.

We sometimes utilize third-party service providers to help us track the activity within our Site. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking, but the data would not be tracked in a personally identifiable way. Third parties whose products or services are accessible on our Site may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

If you would like more information about the third-party cookies on our website and to find out more about your choice to not have your information used by third parties, please contact us at dpo@cortland.com.

MANAGING YOUR COOKIE PREFERENCES

Cookie Preference Manager
Our preference manager allows you to restrict our use of cookies other than Required Cookies. If you use our preference manager on a mobile device, we process your device’s Advertising Identifier. When you access our preference manager, persistent cookies will be set by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. If you clear your browser cookies, this will remove all cookies including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie preference manager only knows your last set of preferences and does not reflect the current state of cookies on your browser.

Do Not Track
We currently do not respond to “Do Not Track” signals from your browser. Our use of tracking technologies may instead be controlled through our Cookie Preference Manager.

Avoiding Use of Cookies on this Site
If you prefer to completely prevent us from using cookies on your devices, before navigating on this Site, you must first disable the use of cookies in your browser and then delete the cookies saved in your browser associated with this Site.

Disabling and Preventing Further Use of Cookies
You may restrict, block, or delete the cookies from this Site at any time by changing the configuration of your browser.

CONTACT US

You are always free to contact us if you have questions or concerns regarding this Policy, have a question or problem related to your use of the Site, or wish to exclude your personal information from our direct marketing purposes. Our standard business practice is to retain any communications from our Site visitors for 90 days to help us to serve you better.

You may contact us by emailing dpo@cortland.com or by writing to us at Cortland, 3424 Peachtree Rd, Atlanta, Georgia, USA 30326, Attention: Data Protection Officer.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) STATEMENT

To comply with the California Consumer Privacy Act (CCPA), Cortland has established a process to validate the identity of an individual making a request of us. We will require a request in writing that includes a state or government issued form of identification that includes a matching name, address and photograph of the individual making the request. After a request is made, Cortland will respond with a request for that information as CCPA requires us to do.

Cortland does not sell or share the personal data we collect, except as explained in this Policy. If you require a specific statement regarding how we process and manage the data we collect, please refer to the relevant sections in the document above. Questions should be addressed to the Data Protection Officer at dpo@cortland.com.

WEBSITE ACCESSIBILITY

We firmly believe that the internet should be available and accessible to anyone, and we are committed to providing a website that is accessible to the widest possible audience, regardless of circumstance and ability. You can view our full accessibility statement and choose the right accessibility profile for you on our website through the accessibility icon on the bottom right of the screen. If you are a user with a disability, or an individual assisting a user with a disability, and have difficulty accessing or navigating our content on cortland.com, please contact us at digital@cortland.com.

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