Privacy Policy

At NY Residential REIT (“we,” “our,” or “us”), accessible through nyresidentialreit.com, we are fully committed to protecting your privacy and handling your personal data with the utmost integrity, transparency, and accountability. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data in accordance with applicable data protection regulations, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”), as amended.

1. Commitment to Privacy and Data Protection

We recognize the importance of protecting your personal data and are dedicated to safeguarding all personal information we collect. Our policies and procedures are designed to ensure compliance with data protection laws while respecting your rights and expectations. Whether you are browsing our website or using our services, your information is processed securely and in line with best privacy practices.

2. Scope of This Privacy Policy and Our Role as Data Controller

This Privacy Policy applies to all personal data collected through nyresidentialreit.com and any other communications or services that refer to this policy. For the purposes of the GDPR, we act as the “Data Controller” in relation to the personal data that we collect, determine how and why your information is processed, and ensure that such processing is carried out lawfully.

For users subject to the CCPA, this Privacy Policy serves as our notice of collecting, using, and sharing personal information as defined under California law.

3. Categories of Data We Process

We may collect and process the following categories of personal data:

a) Usage Data
Includes details about how you access and navigate nyresidentialreit.com, such as browser type, IP address, geographical location, referral sources, pages visited, session duration, and browsing patterns.

b) Account Data
Information you provide while creating an account or subscribing to services, such as your full name, postal/mailing address, email address, and telephone number.

c) Profile Data
Includes your communication preferences, product or service selections, behavioral actions on our platform, and customer profile attributes.

d) Communication Data
Covers data exchanged through support queries, email correspondence, customer service interactions, and any messages or inquiries you make to us.

e) Technical Data
Comprises device-specific information, such as operating system, screen resolution, language settings, and other system configuration profiles relevant to accessing our digital services.

f) Transaction Data
Includes information related to financial transactions such as payment methods, billing addresses, service orders, order history, and delivery preferences.

g) Preference Data
We collect information relating to your subscription settings, consent status with respect to newsletters and marketing emails, and stated interests in particular offerings or investment products.

4. Legal Bases for Processing Personal Data

We only process your data when we have a valid legal basis to do so. These bases include:

– Performance of a Contract: When processing is essential to provide services you have requested or entered into with us.
– Legitimate Interests: When processing is necessary for our legitimate business interests, provided your data rights do not override such interests.
– Consent: When you have explicitly opted in for certain communications, data collection activities, or processing operations.
– Legal Obligation: When we are legally required to process data to comply with applicable laws, regulations, or lawful requests.

5. Your Rights Under GDPR and CCPA

Pursuant to applicable data protection laws, you may have the following rights:

– Right of Access: You may request details of personal data we hold about you and how it is used.
– Right to Rectification: You are entitled to correct inaccurate or incomplete data about you.
– Right to Erasure (“Right to be Forgotten”): Request the deletion of your data where legally applicable.
– Right to Restrict Processing: Restrict the use of your personal data under certain circumstances.
– Right to Data Portability: Receive a copy of your personal data in a structured, commonly used format.
– Right to Object: Object to certain forms of processing, including direct marketing and profiling.
– Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing.
– Right to Opt-Out of Sale (CCPA): California residents may request that we do not sell their personal data to third parties.

To exercise any of your rights, please contact us using the details provided in Section 13.

6. Security Measures

We employ comprehensive security measures to safeguard your personal information from accidental loss, misuse, unauthorized access, disclosure, alteration, or destruction. These include, but are not limited to:

– Encryption of data in transit and at rest
– Strict access control policies and audit logs
– Regular data backups and recovery plans
– Staff data privacy training and confidentiality obligations
– Firewall and intrusion detection systems

While we take commercially reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee absolute data security.

7. International Data Transfers

To provide our services, your information may be processed outside the country in which you reside, including in the United States or other jurisdictions. Where personal data is transferred internationally, we do so in compliance with applicable data protection laws using appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or other lawful mechanisms to ensure adequate protection of your personal information.

8. Data Retention

We retain your personal data only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required to comply with legal, regulatory, or contractual obligations.

– Usage Data is retained for up to 12 months for analytics and security purposes.
– Account and Profile Data are retained for the duration of your relationship with us and a period of up to 7 years thereafter.
– Transaction Data is retained for 7 years in accordance with tax and accounting regulations.
– Communication and Preference Data are typically retained for 3–5 years after the last interaction unless you request deletion earlier.

9. Cookie Policy

Our website, nyresidentialreit.com, uses cookies to enhance your experience, analyze performance, and provide personalized services. Cookies may include:

– Essential Cookies: Required for basic site functionality (e.g., login, navigation).
– Functional Cookies: Enable advanced features and user preferences.
– Analytical Cookies: Collect aggregated, anonymized data on how visitors use the website.
– Performance Cookies: Help test and improve website speed and usability.

10. Managing Cookies and Legal Compliance

Upon your first visit to nyresidentialreit.com, you will be presented with a cookie consent banner that allows you to customize or reject non-essential cookies in accordance with your preferences. You may also modify your cookie settings at any time through your browser settings or the cookie management interface on our site.

In line with the GDPR and CCPA, we do not use cookies to collect or process personal data without your consent unless they are strictly necessary for site operation.

11. Children’s Privacy

We do not knowingly collect or solicit personal information from children under the age of 13. If we become aware that we have inadvertently collected personal data from a child under 13 without appropriate consent or legal basis, we will take immediate steps to delete such data from our records.

12. Policy Updates

We may revise this Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements. Any material updates will be visibly posted on our website and, when required, communicated directly to you through appropriate channels. Continued use of nyresidentialreit.com following such updates constitutes your acceptance of the revised policy.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [email protected]

We take privacy seriously and are committed to addressing your inquiries promptly and respectfully. We aim to comply fully with all applicable privacy laws and encourage users to reach out to us directly whenever they have questions regarding how their data is used.

Thank you for trusting NY Residential REIT with your personal data.