1. Who We Are.
Welcome to Crossgates
Management Inc.! We are a family-owned, full-service property management and
real estate development firm (together, “Crossgates,” “we”, “us”, “our”). Through
our on-line platform and services, we enable residents to seamlessly manage
their stay at our affiliated companies.
This Privacy Policy
applies to personal information collected on our on-line platforms, websites and
any other offline or online locations that link to or post this Privacy Policy.
You may find this Privacy Policy on the following non-exhaustive list of
websites:
Crossgates
Management - crossgatesmanagementinc.com
Clarksburg
Towers - clarksburgtowers.com
Conway
Towers - conway-towers.com
Cumberland
Manor - cumberland-manor.com
Emery
Towers - emerytowers.com
G.
W. Petroplus Towers - gwpetroplustowers.com
Greenville
House - greenville-house.com
Holiday
Acres - holiday-acres.com
Market
Street Commons - marketstreetcommons.com
Midtown
Towers - midtown-towers.com
Old
Plank I & II - oldplankestates.com
Penn
Towers - penn-towers.com
Princeton
Park Apts. - princetonparkapts.com
Riverview
Towers - riverview-towers.com
Scottswood
Apts. - scottswoodapartments.com
Somerset
Towers - somerset-towers.com
Swissvale
Towers - swissvaletowers.com
This
Privacy Policy describes how Crossgates collect, use, and process personal
information we learn about individuals (“you,” “your”) when:
You
visit or use services available on Crossgatesmanagementinc.com and any other Crossgates
websites or Resident Portal of each website where this Privacy Policy is posted
(together, our “Sites”);
You
communicate with us by phone call, text message, e-mail, postal mail, in-person
at one of our properties;
You
engage in a transaction with us, are or become a resident in a Crossgates
property;
We
receive information about you from Crossgates Affiliates (defined below), and
other third-party companies with which we collaborate (“Business Partners”); or
You
represent a Business Partner or other company doing business with Crossgates.
2.
Consent
Please
review this Privacy Policy carefully. By using our Sites or interacting with us
through channels where this Privacy Policy is posted, you are agreeing to the
collection, use, disclosure, and other processing of your personal information
as described in this Privacy Policy. If you do not agree with the terms in this
Privacy Policy, please do not use our Sites or services and do not provide your
personal information to us. We may make changes in this Privacy Policy, so be
sure to reread it from time to time. Changes to this Privacy Policy will be
posted on our Sites and will be effective when posted. Your continued use of
our Sites or communications with us following the posting of any changes
constitutes your acceptance of our Privacy Policy as revised.
3.
Personal Data That We Collect.
When
you use or interact with us on our Sites or engage with Crossgates
representatives we may collect Personal Information. We use the term “personal
information” in this Privacy Policy to refer to information that identifies,
relates to, describes, or is reasonably capable of being associated or linked,
or could reasonably be linked, directly or indirectly, with you (and your
household if you are a resident of California).
This
policy does not apply to information collected by:
Any
information that does not relate to a person and/or cannot be used to identify
a person.
Any
third-party, including through any application or content (including
advertising) that may link to or be accessible from or through the Sites.
Information
that has been modified in a substantial way so that it no longer can reasonably
identify or be linked to an individual, also known as anonymized information.
Information
we obtain about our employees, job applicants, and other personnel or the
employees and representatives of business customers, service providers,
suppliers, and business partners.
Business-to-business
communications (except where required by applicable law). Personal information
we obtain about an individual who interacts with us in a business (not consumer
or household) capacity, such as representatives of retailers, service providers,
business partners, and media influencers.
Categories
of Information We May Collect
The
categories of personal information we collected and used for our business and
commercial purposes during the past 12 months included the following:
Identifiers
(such as name, postal address, email address, social security number, driver’s
license number, passport number, internet protocol address, device identifier,
online account name and other online identifiers).
Demographic
data including age, marital status and military/veteran status.
Consumer
information (such as signature, telephone number, health and other insurance
information).
Commercial
information (such as credit reports, and transaction history).
Internet
activity including browsing history, search history, and a user’s interaction
with a website, application, or advertisement (“Internet Usage Data”).
Audio/visual
data collected on company owned properties for security purposes. We may record
customer service calls for quality assurance and training.
Professional
and employment-related information.
Customer
profile records that combine information and draw inferences from various
sources about, for example, your transactions, home preferences, interests, and
history of experiences with us.
Specific
Types of Personal Information You May Provide
Resident Portal. To create an account on a Resident Portal, we may request
and collect, your name, email address,
new account password, phone number, state and county of residence. We may also
obtain additional information that you may provide at your option, including
your mailing address, proposed move in date. Furthermore, your comments,
including maintenance request the Resident Portal may be collected and stored.
Request for
information. If you submit an online or other
request to receive information about our properties products and services, we
will collect and retain the information you provide including name, address,
email address, telephone number, location and Crossgates property of interest
to you and other information we need to fulfill your request.
Payment card and
bank account information. When paying your
rent or services through a Resident Portal, you are asked to provide your
credit card, debit card or bank account information. This information will be
processed by a Third Party Vendor. We do not collect any of the financial data. Consult
the Third Party Vendor’s Privacy Policy that is posted on the Resident Portal.
Other information
you may choose to provide. In the course
of doing business with Crossgates, you may provide information about your
employment, education, family, age, gender, interests and preferences for home
location and features, and other personal matters.
Sensitive Personal Information. Some of the information we collect is considered
sensitive personal information under the laws of some states (“Sensitive
Information”). When we request Sensitive Information, we will use it only for
purposes we reasonably believe are compatible with the disclosed purpose for
which the Sensitive Information was collected, or as authorized by law. Unless
we request Sensitive Information for a specific purpose (for example to obtain rental
payment information), we ask that you not send or disclose any Sensitive
Information including financial and medical information, to Crossgates. The
categories of Sensitive Information we may collect for a business purpose
include: social security, driver’s license passport and other government
identification numbers; citizenship or immigration status; and precise
geolocation data.
Information from Crossgates
Affiliates and Business Partners
We
may receive, collect and share personal information about your transactions
with Crossgates Affiliates (subject to your consent to share certain credit and
other financial information with Crossgates Affiliates in accordance with the
Fair Credit Reporting Act and other applicable laws). This information may
include your payment history, the status of a loan or other application
submitted to Crossgates Affiliates, or other information about your
transactions. Some Crossgates Affiliates have posted their own privacy policies
posted on their websites that explain how they collect, use and disclose
personal information.
In
addition, we may receive personal information from and provide personal
information to Business Partners and third parties not owned or controlled by Crossgates
for marketing programs and prospective customer lead generation, subject to
your consent where required by law. We may use third-party services to combine
information gathered through our Sites with information collected from other
online and offline sources. For example, these services may aggregate
information from multiple sources to correlate IP addresses with zip codes help
us to target and assess the performance of marketing campaigns.
Information we
automatically collect:
We also automatically collect certain technical data that is sent to us from
the computer, mobile device and/or browser through our Sites ("Automatic
Data"). Automatic Data, includes without limitation, a unique identifier
associated with your access device and/or browser (including, for example, your
Internet Protocol (IP) address) characteristics about your access device and/or
browser, statistics on your activities on the Services, information about how
you came to the Services and data collected through Cookies, Pixel Tags, Local
Shared Objects, Web Storage and other similar technologies. We and our vendors
use such technologies to collect information on a real-time basis about how you
use and navigate our Sites. The information (including your IP address)
collected by these technologies will be disclosed to or collected directly by
these vendors, who use the information to help us evaluate your use of the
Services.
4.
How We Use Your Personal Data.
We
collect and use the Personal Data we collect in a manner that is consistent
with this Privacy Policy, and applicable privacy laws. We may use the Personal
Data as follows:
Specific
Reason.
If
you provide Personal Data for a certain purpose, we may use the Personal Data
in connection with the purpose for which it was provided. For instance, if you
contact us by email, we may use the Personal Data you provide to answer your
question or resolve your problem and will respond to the email address from
which the contact came.
Access
and Use.
If
you provide Personal Data in order to obtain access to or use of the Sites or
any functionality thereof, we will use your Personal Data to provide you with
access and to analyze your use of such Services or functionality. For instance,
if you supply Personal Data relating to your identity or qualifications to use
certain portions of the Services, we will use that information to make a
decision as to granting you access to use such Services and to assess your
ongoing qualification to use such Services.
Internal
Business Purposes.
We
may use your Personal Data for internal business purposes, including without
limitation, to help us improve the content and functionality of the Services,
to better understand our Users, to improve the Services, to protect against,
identify or address wrongdoing, to enforce our Terms of Service, to manage your
account and provide you with customer service, and to generally manage the
Services and our business.
Marketing.
We
may use your Personal Data for our marketing and advertising purposes,
including (without limitation) by email, SMS marketing, display media, and
targeting other devices (such as tablets, mobile devices and televisions). We
do this in order to inform you about services or events we believe might be of
interest to you, develop promotional or marketing materials. See "Opt Out
from Electronic Communications" below on how to opt out of various
marketing communications.
Other
Purposes.
If
we intend to use any Personal Data in any manner that is not consistent with
this Privacy Policy, you will be informed of such anticipated use prior to or
at the time the Personal Data is collected or we will obtain your consent
subsequent to such collection but prior to such use.
5.
How We Disclose And Transfer Your Personal Data.
Background
We
are not in the business of selling your Personal Data. However, the operation
of our business and Sites involves sharing or allowing third parties to have
access to certain personal information collected consistent with the purposes
for which we collected the information. The categories of those third parties
are identified below.
Business
Partners
We
may share your Personal Data with our contractors and service providers (business
partners) who process Personal Data on our behalf to perform certain
business-related functions. These companies include our marketing agencies,
online advertising providers, data enhancement and data services providers,
database service providers, backup and disaster recovery service providers,
email service providers, payment processing partners, customer support, tech
support, hosting companies and others. When we engage another company to
perform such functions, we may provide them with information, including
Personal Data, in connection with their performance of such functions.
Business
Transactions
As
we develop our business, 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. We may also
disclose your Personal Data in the course of due diligence for such an event.
You acknowledge and agree that any successor to or acquirer of Crossgates (or
its assets) will continue to have the right to use your Personal Data and other
information in accordance with the terms of this Privacy Policy.
Subsidiaries
and Affiliates
We
may also share your Personal Data with subsidiaries and/or affiliates for
purposes consistent with this Privacy Policy. Our subsidiaries and affiliates
will be bound to maintain that Personal Data in accordance with this Privacy
Policy.
Legal
Requirements
We
may disclose your Personal Data if required to do so by law in order to (for
example) respond to a subpoena or request from law enforcement, a court or a
government agency (including in response to public authorities to meet national
security or law enforcement requirements), or in the good faith belief that
such action is necessary to (a) comply with a legal obligation, (b) protect or
defend our rights, interests or property or that of third parties, (c) prevent
or investigate possible wrongdoing in connection with the Services, (d) act in
urgent circumstances to protect the personal safety of Users of the Services or
the public, or (e) protect against legal liability.
6.
How We Store Your Personal Data
We
may store Personal Data itself or such information may be stored by third
parties to whom we have transferred it in accordance with this Privacy Policy.
We take what we believe to be reasonable steps to protect the Personal Data
collected via the Services from loss, misuse, unauthorized use, access,
inadvertent disclosure, alteration and destruction. However, no network,
server, database or Internet or email transmission is ever fully secure or
error free.
Therefore,
you should take special care in deciding what information you send to us
electronically. Please keep this in mind when disclosing any Personal Data.
7.
How Long We Retain Your Personal Data
We retain and use your information for as long
as is necessary to fulfill the purposes for which it was collected, to comply
with our business requirements and legal obligations, to resolve disputes, to
protect our assets, to operate our business, and to enforce our agreements.
At
our sole discretion, we may delete your information if we believe
it is incomplete, inaccurate, or that our continued storage of it is contrary
to our objectives or legal obligations. When we delete data, it will be
removed from our active servers and databases, but it may remain in our
archives when it is not practical or possible to delete it.
To the extent permitted by law, we
may retain and use anonymous, de-identified, or aggregated information for
performance reporting, benchmarking, and analytic purposes and for operational
improvement.
8.
Cookies, Pixels Tags, And Similar Technologies
The
general categories of cookies used on our Site are described below. Note that
some cookies fit into more than one category and some do not fit well into any
of these categories.
Necessary
cookies are essential for important Site features to work properly, including
saving your login data and supporting reliable performance. These cookies
cannot be disabled because basic Site functions require these cookies.
Essential cookies are generally first-party (placed by us) session cookies.
They do not store your name, IP address or mobile device identifier, or other
directly identifying personal data and are deleted when you close your browser.
Preference
cookies support Site functionality and enable the Site to retain information
based on your actions and choices during previous visits to the Site, such as
your preferred language, geographic region, and cookie selections. These are persistent cookies and generally set
on our behalf by website service providers. You can set your browser to alert
you to these cookies, but some parts of the Site will not work if you block
these cookies.
Analytics cookies are placed by third-party platforms such as Google
Analytics to track, for example, how many users visit the Site, time and date
each visit, which pages they view, which links and ads they click on, and how
long they remain on the Site. They also identify a user’s device, operating
system, browser, and general location based on IP address. Individual users are
not identifiable to Crossgates because the information from these cookies is
used to report Site performance to us on an aggregated, and therefore,
anonymous basis. However, they allow Google Analytics and other analytics
services to store a cookie that identifies you as a unique user and track your
browsing activities on multiple websites and mobile apps. These cookies will
remain on your browser after you close the session.
Other Third-Party Technologies
Some third parties may use automated
data collection technologies to collect information about you when you browse
the Internet. The information they collect about your online browsing
activities over time and across different websites and other online services
may be associated with your personal information and used to provide you with
targeted content. We do not control these third parties’ technologies or how
they may be used. If you have any questions about targeted content, you should
contact the responsible party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default
to accept cookies. If you do not wish to receive cookies, you may set your
browser to refuse all or some types of cookies or to alert you when cookies are
being sent by website tracking technologies and advertising. These settings may
affect your enjoyment of the full functionality of the Site. In addition,
adjusting the cookie settings may not fully delete all of the cookies that have
already been created. To delete them, visit your web browser settings after you
have changed your cookie settings. Additional information is provided below
about how to disable cookies or manage the cookie settings for some of the
leading web browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-
website-preferences
Microsoft Edge: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265
For more information about how to
modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/.
You may learn more about internet advertising practices and related consumer
resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work,
or http://www.networkadvertising.org/choices. To learn how you can manage
your Flash cookie settings, visit the Flash player settings page on Adobe’s
website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html
9.
Your RIGHTS AND CHOICES
Please
use the “Contact Us” details provided at the end of this Policy to exercise
your rights and choices under this Policy. We honor such requests when we
are required to do so under applicable law.
Email
and Newsletter Opt-Out. We may send you emails or newsletters about our services
and other updates. If you no longer wish to receive communications from us via
email, you may opt-out by clicking the “unsubscribe” link at the bottom of our
emails, if applicable, or by submitting a request via the “Contact Us” details
at the end of this Policy and providing your name and email address so
that we may identify you in the opt-out process. Once we receive your
instruction, we will promptly take corrective action. Please note that
registered users cannot opt out of receiving transactional e-mails related to
their account.
Complaints. If you believe your rights relating to your
personal information have been violated, please contact us via the “Contact Us”
details provided at the end of this Policy.
Withdrawing Consent. You can withdraw any previously granted consent to use or disclose your personal information by contacting us as explained below.
Data
privacy Rights and requests
The
personal data privacy rights of individuals are based on the laws of the place
where the person resides. Most privacy laws require notice of an organization’s
personal data collection and use practices, including the categories of
personal data collected, how the information is used, and to whom it is
disclosed. That is the purpose of this Privacy Notice.
Crossgates
will honor requests to exercise specific privacy rights granted by your place
of residence as applicable to our operations. While we may not be required by law to agree to all requests, we will
attempt to accommodate reasonable requests, regardless of where you
live, to:
Confirm
if we have collected your personal data and to know what personal data we
collected about you in the past twelve months;
Correct
or update any inaccurate information we may have about you;
Remove
you from receiving e-mail or text messages from us for promotional purposes by
using the unsubscribe feature in our e-mails or text STOP in response to a text
message;
Withdraw
any consent you previously granted to use or disclose your personal data.
Requests to exercise U.S. state law privacy rights. Crossgates will
honor requests to exercise specific privacy rights granted by your state of
residence as applicable to our operations.
Depending on where you live, these rights may include, for example, the
following:
Right to opt out of the sale of your personal data or
sharing your personal data for targeted advertising. You may have the right to direct us not to sell
your personal data or share your personal data for any purpose classified under
state laws as a "sale," "sharing," "targeted
advertising," or "cross-context behavioral advertising." To
submit a contact us as described below.
Request to delete information. You may ask us to delete (or de-identify)
certain personal data we have collected.
We will honor your request subject to our legitimate business reasons to
retain the data (for example, to complete transactions or protect our legal
rights) and as permitted by applicable law.
Request for portable data.
At your request and if technically feasible, we will make your data
available in a portable format so that you may transmit the data to someone
else.
Right to limit use and disclosure of sensitive personal
data. You may have the right to limit how we use
your sensitive data. We generally do not
collect sensitive data and will only use sensitive data for the purpose
disclosed at the time you were asked to provide it. We will request your express consent before
using your sensitive data for any other purpose.
Appeal. Where applicable,
you may have the right to appeal our refusal to take action on, or respond to,
a verified request and to receive from us an explanation of the reasons for our
decision within the time frame set by applicable state law. If we deny your appeal, you have the right to
contact the State Attorney General.
Authorized Agent. Where
applicable, you may designate an authorized agent to submit a request to
exercise a personal data request on your behalf. We may require the agent to provide
verification of authority.
Profiling with legal or significant effect. We do not process personal data for the
purpose of profiling in furtherance of decisions that produce legal or
similarly significant effects.
How to submit a personal data request. You can submit a request about
your personal data as described above or to exercise your data privacy rights
using any of the methods as discussed in “How to Contact Us” in this Privacy
Notice.
How we respond to personal data requests. We may request additional
information necessary to verify your identity before fulfilling your
request. We reserve the right to decline
to consider unsubstantiated requests.
Where applicable laws set a timeframe for responding to a request, we
will respond within that timeframe.
Otherwise, we will try to respond to a verifiable request within 45 calendar
days of receiving it. We will contact
you using the e-mail address or postal mailing address you provided us when
making the request or that we have on file for you.
If we do not fulfill all or part of your request, we
will explain the reasons why. For data
portability requests, we will select a format to provide your personal data
that is readily useable and should allow you to transmit the information
readily from one entity to another entity.
We do not charge a fee to process or respond to your
verifiable consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the
request warrants a fee, we will tell you why we made that decision and provide
you with a cost estimate before completing your request.
10.
Children
We
do not knowingly collect Personal Data from children under the age of thirteen
(13). If you are under the age of thirteen (13), please do not submit any
Personal Data through the Services. 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 through the
Services without their permission. If you have reason to believe that a child
under the age of 13 has provided Personal Data to us through the Services,
please contact us and we will endeavor to
delete that information from our databases.
11.
PROCESSING OF PERSONAL DATA IN THE UNITED STATES
Crossgates
operates in the United Stats under its federal and state laws and
regulations. If you reside or are
located in a different country, the data protection laws of that country may
differ from the laws of the United States in the ways your personal data is
protected. We want you to understand
that when you provide your personal data to us (directly or through our service
providers, data processors, or third-party platforms), you are giving your
consent to (1) the transfer of your personal data outside of your country of
residence, and (2) the processing of your information in accordance with the
laws of the United States and the guidelines of this Privacy Notice. We will
respond to requests about your personal data as described in the section titled
“Data Privacy Rights and Requests.”
If
you are resident in the European Economic Area and you believe we are
unlawfully processing your personal information, you also have the right to
complain to your local data protection supervisory authority. You can find
their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
12.
Exclusions.
Third
Party Links.
This
Privacy Policy applies only to the Services. The Services may contain links to
other websites not operated or controlled by us (the "Third Party
Sites"). The policies and procedures we described here do not apply to the
Third Party Sites. The links from the Services do not imply that we endorse or
have reviewed the Third Party Sites. We suggest contacting those sites directly
for information on their privacy policies.
13.
How to contact Us
For more information, or if you have any questions or
concerns regarding this Policy, you may contact us using the information below,
and we will do our best to assist you.
By Postal Mail: Crossgates
Management Inc.
Attn: Cindy Knotts
1000 Noble Energy Drive
Suite 420
Canonsburg, PA 15317
By Email: cknotts@crossgatesinc.com
14.
Changes To This Privacy Policy.
The
Services and our business may change from time to time. As a result, at times
it may be necessary for us to make changes to this Privacy Policy. We reserve
the right, in our sole discretion, to update or modify this Privacy Policy at
any time (collectively, "Modifications"). Modifications to this
Privacy Policy will be posted to the Site with a change to the
"Updated" date at the top of this Privacy Policy. In certain
circumstances we may, but need not, provide you with additional notice of such
Modifications, such as via email or with in-Service notifications.
Modifications will be effective thirty (30) days following the
"Updated" date or such other date as communicated in any other notice
to you.
Please
review this policy periodically, and especially before you provide any Personal
Data. This Privacy Policy was updated on the date indicated above. Your
continued use of the Services following the effectiveness of any Modifications
to this Privacy Policy constitutes acceptance of those Modifications. If any
Modification to this Privacy Policy is not acceptable to you, you should cease
accessing, browsing and otherwise using the Services.