About this Policy
In connection with your use of the Services and your interactions with us, we generally collect the following information:
- Internet or other electronic network activity information when you use our websites, property-specific mobile apps or Wi-Fi network (such as your Internet protocol address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, advertiser ID, and other device identifiers, browser type, hardware type, operating system, Internet service provider, user preferences, and information about the pages you visit, the date and time, the amount of time you spend on each page, and the links you click within the Services); and
- Any information you provide to us (such as in any forms, surveys, questionnaires, phone conversations, written correspondence or otherwise); and
We and our affiliates and nonaffiliated third parties collect and process such personal information in connection with the following:
- Providing you with the Services;
- Responding to your inquiries or fulfilling requests for us to contact you;
- Acting in compliance with our legal obligations, rights, and interests;
- Preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws, as well as regulatory requirements; and
- Certain other purposes, depending on the specific product or service you have requested from us and/or the nature of your interaction with us.
Sources of Information
We generally collect and maintain certain personal information from the following sources:
- Information we receive from you on forms, contracts or that you otherwise submit to us;
- Information about your transactions with us, our affiliates, and nonaffiliated third parties;
- Information obtained from meetings and telephone conversations with you;
- Information you provide when requesting us to contact you or respond to an inquiry;
- Information obtained automatically about your activity on our internet sites, property-specific mobile apps, or Wi-Fi networks;
Information Disclosed/Shared with Third Parties
In order to provide you with the applicable products and services or fulfill our contract with you, we may disclose such personal information to our affiliates and nonaffiliated third parties as permitted by law, including:
- Service providers to our company, such as accounting, legal, and tax preparation services;
- Other third party service providers we may engage to provide services such as analytics and marketing, advertising, communications, customer service, payment processing, infrastructure and information technology services, and others as appropriate;
- A third party in the event of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business;
- For purposes of preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws; and
- Other parties depending on your relationship with us, as detailed below.
If one of the foregoing service providers needs to access Personal Information to perform services on our and your behalf, they are only authorized to collect, use, disclose, and store the Personal Information as described in our contract with them, including requirements to maintain reasonable security procedures.
We do not sell your personal information to third parties, and we do not rent, or share your personal information with third parties for such third parties’ direct marketing. As described in the Cookies and Other Technologies section, we use certain standard advertising tools on our websites which, provided you have allowed it in your cookie preferences, sends personal data to the tool providers, such as Google. This is not a “sale” of your data in the traditional sense of the word sale. However, California’s CCPA law has a very broad definition of “sale” under which using these tools to send the personal data to the third-party tool providers may be considered a “sale”. If you are a California resident, please see the “Jurisdiction Specific Information” section for California Residents for additional information.
Please see below for information on additional third parties with which we may disclose your personal information in the context of your relationship with us.
How to Access and Control your Information
We may send you marketing materials in which we believe you may have interest, and will comply with your request to stop sending any such further communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.
Where appropriate and where applicable by law, we shall provide you with the individual rights with respect to your personal information. See the “Jurisdiction Specific Information” sections for California Residents and EEA Residents below for more information on your rights in these jurisdictions. You can exercise your rights with respect to your personal information by contacting us.
We require certain information to provide our Services to you. For example, we must collect certain personal information from investors, tenants and vendors to comply with legal obligations. We also require certain personal information to provide you with access to certain websites, apps and networks. If you do not wish to share such required personal information, we may not be able to provide you with certain Services.
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law and industry standards. These measures include computer safeguards and secured files and buildings. We restrict access to personal information to those employees, affiliates, agents, and third parties who have a need to know the information to perform a business purpose. We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control.
Data Retention and Disposal
The personal information may be stored in our technology systems or those of our service providers, or in paper files. We will delete your personal information when it is no longer reasonably required for the uses described herein, or when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. Since we maintain our applications and systems to protect against accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or made unusable where deletion is not possible.
Cookies and Other Technologies
The “help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to receive notifications from the browser when you receive a new cookie, or how to disable cookies altogether. If you do not wish to have cookies placed on your browser by our Services, we recommend that you adjust your browser settings and delete cookies which have already been placed using your internet browser’s help menu. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.
We use pieces of code or scripts that collect certain information automatically through our website or other services (sometimes referred to as pixel tags, web beacons, web bugs, and similar technologies). This includes information such as pages that you visit, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, preferences you set, and data that you enter into certain forms. This information is used to help us understand how you engage with our Services, to track user behavior and conversions, to engage with customers, and to provide you with the Services.
We may use Google Analytics to help us understand how you engage with our Services. This tool collects data, including the URL of the page you’re visiting and your Internet Protocol (IP) address, and sends it to Google. This information is collected in order to provide and protect the security of the Service, and to give us a sense of which country, state, or city in the world you come from. Google Analytics may also set cookies on your browser or read cookies that are already there. For more information on Google Analytics, please see the site “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/ or other URL Google may provide from time to time). If you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on (located at https://tools.google.com/dlpage/gaoptout or other URL Google may provide from time to time).
If you want to learn more about controlling cookies and opting-out of certain internet-based advertising by third parties, please visit:
- http://www.aboutcookies.org for guidance on how to control, disable, and delete cookies
- http://optout.aboutads.info/ for the Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (if you are located in the United Sates.)
- https://youradchoices.com/appchoices for mobile application-based “AppChoices” download page (if you are located in the United States.)
- http://optout.networkadvertising.org/ for the Network Advertising Initiative (NAI)’s self-regulatory opt-out page (if you are located in the United States.)
- http://youronlinechoices.eu for the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (if you are located in Europe.)
Jurisdiction Specific Information
Details of Data Collected, Used and Disclosed
Please see above for the categories of personal information collected, the categories of sources from which information is collected, the business purpose for which the information is collected, and the categories of third parties with whom the information is shared.
Details of sale of data to third parties
As described in the Cookies and Other Technologies section, we use certain standard advertising tools on our websites which, provided you have allowed it in your cookie preferences, sends personal data to the tool providers, such as Google. This is not a “sale” of your data in the traditional sense of the word sale. However, the California Consumer Privacy Act of 2018 (“CCPA”) has a very broad definition of “sale” under which using these tools to send the personal data to the third-party tool providers may be considered a “sale”. Because of this interpretation, we provide a “Do Not Sell My Personal Information” link at the bottom of our website. You can use this link to change your cookie preferences and opt out of the use of these advertising tools. If you opt out, Personal Data that was used by these tools will no longer be shared with third parties in a way that constitutes a “sale” under CCPA.
Your Privacy Rights
If you are a California resident, you also have certain rights pursuant to the CCPA, including:
- 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 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 not be discriminated against for exercising the 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.
You can make a request under the CCPA using the web form, email or toll-free phone number listed in the “Contact Information” 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 CCPA.
Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose.
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. Such authorized agent must be a natural person or a business entity registered with the Secretary of State. In order to process a request by your authorized agent, we will need to receive proof that the authorized agent is authorized to act on your behalf. This may be in the form of a Power of Attorney executed pursuant to the California Probate Code sections 4000 to 4465. If you do not have such a Power of Attorney, we may require that you provide a copy of the written documentation authorizing the agent to act on your behalf and also require you to verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized to act on your behalf.
We do not offer financial incentives or price or service differences in exchange for the retention or sale of your personal information.
Do Not Track Signals
Do Not Track (DNT) is a privacy preference that users may be able to set in some web browsers to signal that they have requested to opt out of tracking by websites and online services. Currently, there is no legal or industry standard regarding DNT signals, and therefore, we do not alter our data collection and use practices when we see a DNT signal from your browser. Please see the Cookies section above for additional information on what information is gathered, the purpose and the third parties that collect information about your activity on our
If you have any questions or concerns about our privacy practices or wish to exercise your rights with respect to your personal information, please direct your inquiry to:
EEA Data Subjects
Legal Basis for Processing
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where: (i) we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; (ii) it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; (iii) you give us consent to do so for a specific purpose; or (iv) we need to process your data to comply with a legal obligation. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
International Data Transfers
The Services may be accessed or used by individuals located outside the United States. If you choose to use the Services from the European Union (EU) or other regions with laws governing data collection that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.
Automated Decision Making
We do not subject you to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Where appropriate and where applicable by law, we shall provide you with the following individual rights with respect to your personal information: (1) the right to access your personal information, (2) the right to correct or erase your personal information, (3) the right to restrict the processing of your personal information, (4) the right to object to the processing of your personal information, (5) the right to portability of your personal information, and (6) the right not to be subject to a decision based solely on automated processing. You have the right to lodge a complaint with supervisory authorities regarding the processing of your personal information.
You can exercise your rights with respect to your personal information by using the web form, email or toll-free phone number listed in the “Contact Information” section below. To the extent we are processing the personal information based on your consent, you may withdraw such consent at any time, provided that such personal information is not required by a legal obligation. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.
Consequences of failure to provide data
We require certain information to provide our Services to you. For example, we must collect certain personal information from investors, tenants and vendors to comply with legal obligations. We also require certain personal information to provide you with access to certain websites, apps and networks. If you do not wish to share such required personal information, we may not be able to provide you with certain Services. If you delete or refuse certain cookies, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.
Your information is controlled by the BYLT Group. If you are a resident of the European Economic Area and you have any questions regarding how your information is handled, or have questions about our privacy practices, please direct your inquiry to our EU Representative.
Children’s Online Privacy Protection Act (COPPA)
We are committed to protecting the privacy of children. The Services are not intended for use by children, and we do not knowingly collect personal information from children under the age of 13. If we learn that personal information has been collected from persons under the age of 13 through the Services, then we will take appropriate steps to delete this information. If a child under 13 provides us with personal information without parental or guardian consent, the parent or guardian may contact us and we will remove the information. No information should be submitted to or via our Services by users under the age of 13.
Changes to Policy
If you have any questions regarding how your information is handled, or have questions about our privacy practices, please direct your inquiry to the BYLT Group. as set forth below.
Third Party Site Links
You may have the opportunity to follow a link to other websites that may be of interest to you from our website or from our other Services. These links are provided only as a convenience. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification or monitoring by the BYLT Group of any information, materials, products, or services contained in or accessible through any linked site. We are not responsible for the privacy practices of those websites or the content provided thereon. The BYLT Group and its affiliates disclaim any and all liability for the information, including without limitation, any express or implied representations or warranties for information or errors contained in, or omissions from, such information. The BYLT Group and its affiliates, employees and officers shall not be liable for any loss or liability suffered by you resulting from the provision to you of the information or your use or reliance in any way on the information on such third party websites.
We are committed to ensuring effective communication and digital accessibility to all users. We are continually improving the user experience for everyone and apply the relevant accessibility standards to achieve these goals. We welcome your feedback on the accessibility of our websites and mobile apps. Please let us know if you encounter accessibility barriers in accessing any area of/on our website or mobile app by emailing us.
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The information contained on this web site does not constitute an offer of securities.
U.S. Treasury Circular 230 Tax Notice
The BYLT Group does not render advice on tax and tax accounting matters to clients. This website was not intended or written to be used, and it cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer under U.S. federal income tax laws. Investors should consult their own legal, tax investment or other advisors, at both the onset of any transaction and on an ongoing basis to determine the laws and analyses applicable to their specific circumstances.
Use of Historic Performance Data Risk Disclosure
Unless stated otherwise, any performance data quoted represents past performance. Past performance is not indicative of future returns. No representation or warranty is made that any returns indicated will be achieved.