Privacy policy

TENANTCONNECT PRIVACY POLICY

Last Updated: August 18, 2021

Protecting your (“you” or the “user”) privacy is important to Horizon Property Group, LLC (“The Outlet Shoppes of the Bluegrass,” “we,” or “us”). This Privacy Policy explains our policies and practices regarding the collection, use, storage and disclosure of information used by the TenantConnect Application (the “Application”). All capitalized words used in this Privacy Policy have the same meanings as in our Terms of Use or are defined below.

We may revise this Privacy Policy at any time and update you by changing the “Last Updated” date above. Please check this policy regularly for updates. Your continued use of the The Outlet Shoppes of the Bluegrass Application or Platform constitutes your acknowledgement that you understand and will adhere to this Privacy Policy.

We collect, use, and store the information we need to promote, provide, administer, manage, support, promote and improve the Application, and to provide additional services to its users. We disclose the information we collect only as this Privacy Policy states. We will collect personal information (or “PII”) from users of the Application; “personal information” for the purposes of this Privacy Policy means information we collect from a user that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

The Outlet Shoppes of the Bluegrass does not solicit or otherwise attempt to obtain personal information from people under 18 in connection with its Platform or services. Please do not submit any personal information of children, including use of children in videos, to The Outlet Shoppes of the Bluegrass. If you submit or believe The Outlet Shoppes of the Bluegrass is in possession of a child’s PII, please delete such information or contact us at bluegrassaa@horizongroup.com.

  1. THE INFORMATION WE COLLECT

 

  • Account Information. When you create an account on the Application, we request information from you such as your name, email address, password, language preference, and phone number. If you are the manager of a tenant account, we will collect your job description in addition to the information above. The above information, including PII, is “Account Information”.
  • Device Information. The Outlet Shoppes of the Bluegrass may collect information about your device, including make, operating system, and times of use (any one or more items of such information, “Device Information”). Device Information may also include information such as a user’s device type, internet protocol (IP) address, browser type, or features a user accesses and the time spent on those pages or features, offers on The Outlet Shoppes of the Bluegrass’s Application that a user clicks on, and additional statistical information.
  • Usage Information. We will collect information about how you interact with the Application, including without limitation: messages and notifications you send and receive; groups in which you participate; the recipients of your messages and notifications; your tasks and offers; your calendar events; issues or emergencies you report; and any other information you input or upload into the Application. We will also collect and store your documents, pictures, and videos if you take them when prompted by our Application. All of the above is “Usage Information”. We do not scrape information provided by you in your responses to our prompts, such as biometric data or the content of your media. Although no user is required to provide such information, whatever User Information the user provides will not be shared except as you direct.
  • Communications Information. If directed at us, we will collect and store the content of any communications, including without limitation documents, group chats, issue reports, emergencies, or other requests. If you communicate in the Application with your workers or your workers communicate between themselves, we will store your communications but will have no responsibility or oversight with respect to the content of those communications. If you use the Application’s emergency notification system, we may collect and store all information related to that notification, including recipients, timing, content, location of recipients when they receive the alert, and other metadata. The above is “Communications Information”.

 

  1. HOW WE USE THE INFORMATION WE COLLECT

The Outlet Shoppes of the Bluegrass uses:

2.1 Account Information to provide, manage, and administer access to The Outlet Shoppes of the Bluegrass’s Application and Platform Services and to maintain compliance with our Terms of Use. In addition, The Outlet Shoppes of the Bluegrass uses Account Information to provide support and additional services to users as they request, to allow communication between users, to allow communications between us and users (and vice versa), and to otherwise assist you efficiently manage your business. Finally, we will share your phone number and email with our third party SMS and email providers to notify you about emergencies and other issues relevant to your workers, business, and store;

2.2 Device Information to administer, secure, improve and enhance The Outlet Shoppes of the Bluegrass’s services and Platform;

2.3 Usage Information to provide the Platform Services and to internally improve, secure, maintain, operate, and administer the Platform Services, or for any other lawful purpose. We do not share your Usage Information except with your express consent, for which we will prompt you, or as set forth in the “Disclosure of Information” section below; and

2.4 Communications Information to enable communications by and between us, you, and your workers.

We may create data or analytics derived from PII or any other information we collect (“De-Identified Information”). We are the sole owner of the De-Identified Information. So long as we do not enable the re-identification of such information, we reserve the right to use De-Identified Information for any lawful purpose and in perpetuity, internal or external, commercial or otherwise.

  1. DISCLOSURE OF INFORMATION

 

  • Only the manager of the premises of which you or your employer is a tenant may see all the organization’s contacts in the Application. Depending on your role within the tenant, you may be able to contact other workers of the tenant, but users without elevated permissions may not see each other’s personal information.
  • The Application and Platform are hosted by Mallfinder Network, LLC d/b/a Placewise, a Colorado limited liability company (“Placewise”); we share all information and PII collected by the Application and Platform with Placewise.
  • We share Account Information and Usage Information to enable one or more The Outlet Shoppes of the Bluegrass agents, vendors, or service providers to perform under their respective agreements, including agreements to provide The Outlet Shoppes of the Bluegrass with marketing services, emergency communications, text and email messaging, which third parties are contractually bound to keep your information secure and confidential. For example, we share Account Information and Communications Information with a text notification vendor to provide SMS notifications and with an email distribution vendor for email notifications. We use cloud service providers to host and secure information collected, but those service providers do not process your PII. We do not sell PII to third parties or share it for valuable consideration. We may use contact information you provide to us to send you updates about your account and similar topics.
  • We may also share information with third parties as follows:
    • A user requests or authorizes the disclosure of its Account Information or Communications Information;
    • The disclosure is required in the judgment of The Outlet Shoppes of the Bluegrass’s management;
    • To comply with a search warrant, subpoena, discovery request, court order or other legal requirement; or a request made by a law enforcement or other government agency acting within its authority;
    • To prevent the unlawful or illegal use of The Outlet Shoppes of the Bluegrass’s services or Platform;
    • To enforce the Terms of Use or other agreements between The Outlet Shoppes of the Bluegrass and one or more users, or as otherwise appropriate to protect the rights, interests and property of The Outlet Shoppes of the Bluegrass;
    • Pursuant to the merger or acquisition of The Outlet Shoppes of the Bluegrass’s or Placewise’s stock or assets to which the Platform Services relate;
    • To protect personal safety, including the safety of The Outlet Shoppes of the Bluegrass’s workers;
    • To respond to emergencies;
    • To respond to disputes, claims, and to users’ successors in interest; and
    • Pursuant to the duly authorized and lawful direction of the organization for which you work or the agreement between your organization and The Outlet Shoppes of the Bluegrass (if any, the “Agreement”).

 

  1. LEGAL BASES

When you access or use the Platform Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

  • Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
  • Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
  • Necessary to accomplish the purposes or our obligations pursuant to the Agreement;
  • Necessary in the public interest, such as to prevent crime;
  • Occasionally necessary to protect your vital interests or those of others (where we may need to share information to prevent loss of life or personal injury); and
  • Pursuant to our legitimate interests in:
    • Providing and Improving the Platform Services:We use your information to improve and customize the Platform Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Platform Services for our users.
    • Keeping our Services Safe and Secure:We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to our systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds.
    • Retaining Service Providers:We also need to engage third-party companies and individuals (such as hosting, analytics and security providers) to help us operate, provide, and market the Platform Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Platform Services to you, particularly where such companies play important roles like helping us keep our Platform Service operating and secure.

 

  1. INFORMATION RETENTION

We store: (a) Account Information, Communications Information, and Usage Information, including PII, for each user while its account exists. We retain that information in accordance with applicable law, the Agreement, the instructions of The Outlet Shoppes of the Bluegrass’s management, and this policy; (b) Device Information, for long enough to analyze and use it as this policy contemplates; and (c) De-Identified Information, for as long as we deem fit.

  1. Foreign Transfers

The Application is intended for use solely within the United States and is not usable by residents of the European Economic Area (“EEA”). If you are an EU data subject (as defined by the GDPR), do not use this Application. As a user however, your information may be transferred to the EEA for hosting and servicing by Placewise and other third party service providers as set forth in Section 3 above. By using our Platform Services, you understand that we and Placewise may share some of the personal information gathered with service providers located in the EEA for hosting, processing, and other aspects of the Platform Services as set forth in Section 3 above.

 

When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the United States, it may be accessed by government authorities in accordance with United States law.

  1. SECURITY

We implement a variety of security measures to maintain the safety of your PII.

We offer the use of a secure server. All supplied payment information is transmitted via Secure Socket Layer (SSL) technology and then encrypted by our hosting service providers only to be accessible by those authorized with special access rights to such systems and who are required to keep the information confidential.

While we use industry-standard precautions to safeguard your PII, we cannot guarantee complete security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us is compromised), please immediately notify us of the problem.

  1. LINKS TO OTHER SITES

This The Outlet Shoppes of the Bluegrass Privacy Policy applies only with respect to The Outlet Shoppes of the Bluegrass’s Application and Platform Services. The treatment of information that users provide on or to any other site or service, even if accessed from the Application or Platform Service, will be governed by the terms of service and privacy policy applicable to that site or service, if any.

  1. YOUR RIGHTS
    • Individuals located in certain countries may have certain statutory rights in relation to their personal information. Subject to any exemptions provided by law, you may have the right to request access to your personal information to seek to update, delete or correct this data, to restrict or object to processing of your data, as well as right to portability of your personal information.
    • Where available pursuant to applicable law, you may exercise these rights by logging into your Application account or by getting in touch with us using the contact information provided below.
    • Furthermore, if you believe that we have unlawfully processed your personal information, you have the right to submit a complaint to us by using the contact information provided below, or you may submit complaint to a respective data protection supervisory authority in your country.
    • If you are an individual whose personal information has been provided to us by a tenant, please contact that tenant to exercise your rights as a Data Subject stated above.
    • If we receive a complaint or request from an individual whose personal information has been provided to The Outlet Shoppes of the Bluegrass by a tenant exercising his/her rights, we will not respond to such complaint or request without prior written authorization by the Client.
    • Notwithstanding the foregoing, you may stop collection of personal information at any time by deleting the Application, by contacting your manager, or by requesting deletion of your profile by using the contact information below.

 

  1. CALIFORNIA RESIDENTS.

 

  • The California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in Section 2 above, the categories of personal information that we have collected, as described by the CCPA, are:
    • Identifiers, including name, email address, phone number, IP address, and any other identifier assigned to your account;
    • Commercial information including engagement with offers on the Application;
    • Internet activity, including your interactions with our Platform Services and Usage Information;
    • Audio, electronic, and visual information, including any content you upload to the Application, such as to document an issue or emergency; and
    • Professional and employment-related information, including the organization for which you work, your title in that organization, and Communications Information.

 

  • The Purposes for Our Collection

We collect and share these categories of personal information for our business and commercial purposes described in Section 3 above, including providing and improving the Platform Services, and maintaining the safety and security of the Platform Services.

  • No Sale

We do not sell or share personal information to third parties for monetary value or other valuable consideration, as the term “sell” is defined under the CCPA.

  1. QUESTIONS?

Please contact us at bluegrassaa@horizongroup.com if you have any questions about the The Outlet Shoppes of the Bluegrass Privacy Policy. You may also contact us at:

The Outlet Shoppes at the Bluegrass

1155 Buck Creek Rd.

Simpsonville, KY 40067