Last Modified: July 12, 2023
OAC 550 Owner LLC (d/b/a 550 Madison) (“OAC,” “we,” or “us”) respects your privacy and is committed to protecting your personal information.
I. PERSONAL INFORMATION WE COLLECT
Personal information means any information about a natural person from which that person can be identified. We (and the third-party service providers and other parties we use to perform services on our behalf, or with whom you interact at the Property, including, for example, building and property managers, concierges, fitness center staff, security personnel and other staff, and real estate brokers) may collect, use, store, and transfer different categories of personal information about you depending on the nature of your interactions with us. We have grouped that information together as follows:
Contact Information, including your name, email addresses, office address and number, home address, account username, password, telephone numbers, and social media account handles. We may also collect contact information for your emergency contacts or next of kin (name, relationship, and home and mobile telephone numbers).
Identification Information, including your government-issued identification cards (e.g., driver’s license and passport) and, date of birth, and signature.
Personal Preference Information, including your purchase and request history, retailer preferences, leasing details, responses to surveys you complete that we or our service providers have given to you, and other information concerning your other transactions and preferences. We may also collect information in connection with certain services that we offer, including food and beverage offerings, concierge services, and event planning, attendance, and management. For example, we may collect personal information, including dietary requirements, allergies or physical access requirements, so that we can appropriately cater to your needs when you visit and attend events at the Property. We may use this and other personal information collected about you to draw inferences about you to better serve your needs when you visit the Property.
Device, Internet and Network Activity Information, including information about your use of our IT, communication and other systems, other monitoring information including your browsing history, search history, login information, online and device identifiers, MAC address, and your IP address. We may collect and record page and application interaction information and other electronic communications and content from your use of the Sites or Apps (such as content entry, mouse movements, screen captures, the date, time, and location of your visit, what areas of the website you visit and for how long, what search terms or other data you enter, and what products or content or links you view and click on), and methods used to browse away from the page. If you use the Apps, we may also look at how often you use the Apps and from where you downloaded them. We or our third-party service providers may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our third-party service providers send to you to help us understand how you interact with those messages, such as whether and when you open a message or click on any content within the message. We may also collect information from your devices if they connect to, or are detected by, the wireless networks at the Property (“Wi-Fi”). If you connect to the Wi-Fi, we may collect information about how you use our Wi-Fi and other services, such as the websites you visit while using our Wi-Fi.
Health and safety information, including health conditions (if relevant to providing you with accommodations at the Property or emergency management). From time to time, we may also require health-related screenings to be completed in connection with your entry to the Property and may ask you to provide information concerning any symptoms of COVID-19 you are experience or may have experienced in the past, and whether you have been tested for, and vaccinated against, COVID-19. We may also take your body temperature upon entry. We may also ask you about your “close contacts,” such as whether you recently have been in close contact with an individual who has tested positive for COVID-19 or who has experienced any COVID-19 symptoms, as well as travel-related information, such as locations to which you have traveled within a certain period of time prior to entering the Property.
Wellness information, including the classes and services you book, and information provided when you book training sessions and spa treatments at the Oasis Fitness Center or elsewhere at the Property. When you enroll to use the Oasis Fitness Center as a member or guest, you will be required to complete an Electronic Fitness Disclosure so that our service providers offering services understand what activities are safe for you to perform. When you prepare to and/or participate in services offered at the Oasis Fitness Center, our service providers also collect information pertaining to your fitness, health, nutrition, and/or training goals, programs, and progress, as well as notes related to any physical limitations that you provide to your trainers or which are observed and recorded by them.
Location Information, including network data from building access controls at the Property and precise GPS location when you access our Apps. Please note that the Apps will track your device location when you visit or are in close proximity to the Property. The Apps provide you a choice to grant location permission while the Apps are in use, at all times, or never. If you decline to grant location permission to the Apps, please note that the Apps may not be able to offer full functionality to you. We may also automatically collect your precise GPS location and IP address when your wireless device connects to, or is detected by, our Wi-Fi.
Images and Video, including photographs and video recordings (including through the use of CCTV cameras and other technologies). For example, when you visit our security desks, we may take a photograph of you for security purposes for admission to the offices of one or more of the Property’s tenants.
Biometric information, including an image of your fingerprints and a reference template created from your fingerprints if are eligible for and choose to enroll in our card-less entry option.
Information You Submit, Provide, or Post, including any information you provide to us when you comment or post on our Sites, social media pages, or the Apps. We also collect any information you provide when you contact us or our third-party service providers concerning your interest in, or experience at, the Property, in connection with any maintenance or administrative works orders that you submit to us, use mobile access to enter areas of the Property, place a food or beverage order, make a restaurant reservation, book amenities at the Property, book services and amenities with third-party providers, register visitors to visit the Property, or answer any health questionnaires. For example, when you use the 550 Madison App to create a visitor pass, you may choose to view your contacts list, and click on a contact to auto-fill the information you have stored on your mobile device for that specific contact.
Payment Information. We offer products and/or services at the Property. In such cases, we and our third-party service providers use third-party services for payment card processing (e.g., payment processors). We will not store or collect your payment card details. That information is provided directly to third-party payment processors whose use of your personal information (including payment card information) is governed by their own privacy policies (for example: Toast — https://pos.toasttab.com/privacy, a Authorize.Net — https://usa.visa.com/legal/privacy-policy.html, and Stripe — (https://stripe.com/privacy).
When you make use of third-party services that are integrated with the Apps, such as Alexa, those third-party services may receive information that you share with them. If you interact with a third-party service integrated with the Apps, information about you, like your voice recording may be provided to such third party. Please note that when you use third-party services at the Property, their own terms and privacy policies will govern your use of those services and products.
II. PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
We use the above-referenced categories of personal information for the following purposes:
To provide our services. We may use your personal information in connection with the management, operation, administration, leasing, and development of the Property or any purchases, or event reservations that you make. We and our third-party service providers, such as our property manager and concierge and amenities vendors, also use information to fulfill your requests and provide you with products and services, such as scanning pictures of the address labels on packages that are delivered to you, fulfilling your food and beverage orders, assisting you with travel or restaurant and entertainment reservations, or ensuring you receive services at the Oasis Fitness Center.
For marketing purposes. For example, we may use your personal information to provide you with information about events, promotions, retailer discounts, purchase incentives, prize promotions, shopping guides, or offers made by us or other third parties (“Offers”). Our third-party service providers may also use your information to send push notifications on our Apps regarding such Offers and to tell you about new features or services we are offering. You may opt out from allowing push notifications by adjusting the permissions in your mobile device and the Apps, however, this opt-out choice does not apply to in-app notifications. You will not receive marketing calls, text messages, or push notifications from us or our third-party service providers unless you have opted-in to receive such calls, messages or notifications. We may send you marketing messages as described in this paragraph, but you can opt out from receiving them at any time. To learn about your choices for these communications, read Section V below.
To provide you with support and respond to your requests and inquiries. We use your personal information to contact you in response to questions, inquiries, or other feedback you provide to us, including with respect to customer support, or in connection with other matters related to our relationship with you, which may include your use of or access to the Property, your lease, product purchases, or event reservations.
To test, develop, analyze, improve, and provide the Sites, the Apps, the Property, our products and services. We might use your information to improve our content, the use, functionality, and configuration of the Property and our services, customize your experience with us and to conduct research and analysis, including to better understand how you use the Property and our services, including those available at the Oasis Fitness Center. For example, the Property is outfitted with beacons, which are small devices that allow us and our third-party service providers to gather valuable analytics on how different areas of the Property are being utilized (including occupancy and density levels) and to push you timely notifications based on your location and the time of day.
To administer our Sites and Apps, and for property management or internal operations. When you download the Apps or access the Sites, we and our third-party service providers collect certain information from you such as your name, email address, and password in order to create and administer your accounts and to identify you for authentication purposes. We and our third-party service providers also use your personal information to administer the Sites and the Apps, including to troubleshoot, perform data analysis and testing, and to notify you when updates to the Apps are available, or of changes to (i) any products or services we offer or provide through the Apps or the Property, or (ii) our terms, conditions and policies.
For security, safety, compliance, and due diligence purposes. We may use your personal information to safeguard and secure OAC and the Property and its tenants, licensees, occupants, visitors, guests, customers, business partners and their respective Personnel. For example, when you scan your identification access card or fingerprints at the entrance to one of our turnstiles or elevator banks, we and our third-party service providers use that information to verify your identity to ensure you are authorized by us, our property manager, or one or more of our tenants to enter a restricted area of the Property before unlocking the turnstiles or elevator banks. We may also use the information you provide during a COVID-19 health-related screening to maintain a safe environment at the Property, to help mitigate the risk of transmitting the virus and exposing others to COVID-19, and to identify individuals who are displaying COVID-19 symptoms. We also may use your personal information to protect our Sites, Apps, or services (including our IT systems, architecture and networks), as well as to detect and investigate activities that may be fraudulent, or otherwise illegal or prohibited (such as cybersecurity incidents, thefts, property damage, or fraudulent transactions). We may use your personal information to enforce our contractual rights, take precautions against liability, investigate suspected or actual illegal activities, or to investigate and defend ourselves against third-party claims or allegations.
We may also use your personal information for any other purpose that we describe to you at the time we collect it, and for any other purpose with your consent.
III. SOURCES OF PERSONAL INFORMATION
We and our third-party service providers collect personal information about you from various sources, directly and indirectly, including:
Directly from you. We collect personal information from you if you sign up for our Apps, communicate with us through the Sites or the Apps, register to access the Wi-Fi at the Property, enter into a lease, license, or other agreement, participate in a promotion, use our concierge services, sign up for or use services as the Oasis Fitness Center, or sign up for our text and other messaging services. We also collect any personal information you provide to us when you contact us, including when you communicate with us through the Sites or Apps, for example, if you post a comment, make a request, or complete a survey. We also collect video or image information about you using surveillance cameras and information from our Wi-Fi network hubs.
From your devices. As part of the standard operation of the Sites and the Apps, we and our third-party service providers use tracking tools like browser cookies and web beacons to automatically collect information about your computer or device, including IP address, domain name (that you visited from www.company.com, for example), referral or exit data (the last website that you visited before coming to the Sites and the next website you visit afterwards, respectively), as well as browser and platform type (a Google browser or an Apple platform, for example). We also collect information about how you use the Sites, such as the date and time of your visit, the amount of time you spend on the Sites, how often you visit the Sites, the areas or pages that you spend the most time on, and other click-stream data.
From our third-party service providers. For example, third-party service providers that host or maintain our Sites and Apps, help us operate our concierge, event spaces, the Oasis Fitness Center, or send promotional or other operational emails may provide us with personal information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information.
From other sources. Other parties may give us personal information about you. These other parties may include business and marketing partners and social media platforms that give us information they have collected either directly or indirectly from you. We may also receive personal information from your employer, real estate brokers, and other parties in the commercial real estate sector. Our Apps and certain services offered at the Property also include an opportunity to let your coworkers, friends, or family members give us your personal information in connection with services offered at the Property.
We combine information. We may combine information about you that we (i) have collected offline with information we collect online, or (ii) receive from another party about you with information that we already have. We may also aggregate your information with other individuals’ information to understand preferences and trends related to use of the Property and its services.
IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION
With third-party service providers who perform services on our behalf. We may share personal information with third-party service providers that help us manage and operate the Sites and the Apps, send emails on our behalf, manage the Property, fulfill purchases, provide tenant, licensee, guest, amenity, and concierge services (such as fitness classes and training and wellness sessions, dry cleaning delivery, and other travel, food, and beverage, and entertainment reservations), provide advertising or marketing services or place our advertisements on other platforms, provide analytics and search engine support, track advertising impressions, investigate and prevent data and security incidents, provide physical and digital security services, audit our business and financial statements, and provide us with legal advice. Personal information that you provide directly to our third-party service providers also will be subject to their own privacy policies.
With our clients, tenants, licensees, business partners, and marketing companies. We may share your personal information with our tenants, if for example you are a visitor or guest, by alerting the tenant that you have arrived at the Property for your visit. We may also share information with third parties, including our tenants and licensees, who co-sponsor promotions or events at the Property or promote our services. Some of these third parties may send you information about products or services by mail or email. They may share your information with other third parties. We also may share the above categories of personal information with companies that help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal information received by our partners and other third parties also may be subject to their privacy policies. Please note that we are not responsible for the privacy practices of our clients, tenants, licensees, business partners, and marketing companies, or each of their third-party service providers.
With third parties, including law enforcement or government agencies, for safety and security or other legal reasons. We may share some or all of your personal information to comply with our legal obligations, such as, to comply with financial reporting obligations, court orders, warrants, subpoenas, or other governmental agency or investigatory body requests, including requests for cooperation. We may share your personal information to enforce our legal rights and the rights of others, including our property and contractual rights. We may also share your personal information to protect against or investigate potential fraud, abuse, or harm, to provide a secure physical and digital environment at the Property, or where otherwise required by applicable law.
With third parties (including successors), as part of a corporate transaction. If part of our business (including any of our parents, subsidiaries, affiliates, portfolio companies, divisions, and business units) is acquired by a third party, or if there is another change to our corporate structure, including in connection with any restructuring, reorganization, or other sale or transfer of some or all of our assets, including, but not limited to, as part of a bankruptcy, liquidation, or similar proceeding in which personal information held by us about you is among the assets transferred, we may include personal information as part of that transaction, which may include some or all categories of your personal information. In addition, we may share some or all of your personal information if we apply for loans or other forms of financing, or open bank or investment accounts. In connection with these transactions, we may disclose some or all of your personal information to prospective buyers, investors, partners, lenders, investment advisers, banks, and each of their advisers, as the case may be, as they conduct due diligence.
V. CHOICES CONCERNING OUR USE OF YOUR PERSONAL INFORMATION
You can opt out of receiving our marketing emails. To stop receiving our marketing emails, you can follow the instructions in any promotional message you receive from us to “unsubscribe.” You can also opt out by logging into the Apps and adjusting your user preferences in your account profiles by checking or unchecking the relevant boxes or by sending us an email stating your request to dataprivacy@550Madison.com.
Transactional Messages. Even if you opt out of receiving our promotional messages, we may still send you transactional messages related to the provision of our services that you have requested or as pertain to the management of your account and other administrative matters. These include responses to your questions. We and our service providers may also send you email notifications in the event of an emergency, none of which will have any marketing element.
VI. COOKIES AND LOCATION TRACKING
You can control certain location tracking tools. To control the collection of your precise location on your mobile device, you can adjust the settings on your mobile device, such as by disabling location services and turning off the Bluetooth and Wi-Fi. You can also choose whether or not to allow the Apps to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Apps may become inaccessible or not function properly.
In addition, with the assistance of our third-party partners and service providers, third-party advertising networks, social media companies, and other services may collect information about your use of our Sites and Apps over time so that they or we may display interest-based advertising using information gathered about you over time across multiple websites or other platforms. To do this, we and our third-party service providers we may use technologies such as web beacons, tags, Flash cookies or HTML5 to collect or use information about visitors to the Site and their actions on the Site. You can visit https://optout.networkadvertising.org/?c=1 and https://www.aboutads.info/choices, https://www.preferences-mgr.truste.com/ to opt out of certain uses of cookies for advertising purposes.
Options you select and choices you make are browser, website, and device specific. If you clear your cookies or your browser’s cache, you will need to set your preferences again. For more information about cookies generally, you may visit All About Cookies.
Do-Not-Track Requests. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. The Site does not currently respond to “do-not-track” requests or similar browser settings.
We retain your personal information for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish and support legal claims and defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
When we no longer have a purpose to use or retain your personal information, we will either delete or anonymize it, or if that is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
VIII. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
OAC is headquartered in and has offices in the United States, and the Property is located in New York, New York. Our servers are also located in the United States. This means that, if you are located outside of the United States, personal information that you transfer to us through use of the Sites and Apps will be transferred to, stored, or processed in the United States or in other jurisdictions where our affiliates, business partners, third-party service providers, employees, agents, contractors, consultants, professional advisers, data processors and persons employed and/or retained by each of them operate.
The security of all personal information provided to OAC is important to us. While we take responsible steps endeavoring to use appropriate technical and organization measures to protect your personal information, we cannot guarantee or promise that your use of the Sites, the Apps or the services will be completely safe. Any transmission of your data to the Sites or the Apps is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
The safety and security of your information also depends on you. We encourage you to use caution when using the Internet. For example, where we have given you (or where you have chosen) a password for access to certain parts of the Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
X. COLLECTION OF INFORMATION FROM CHILDREN
The Sites and the Apps are not intended for children under the age of thirteen years of age, and we do not knowingly collect personal information from children except as permitted under applicable law. If you become aware that a child has provided us with their personal information, please contact us and we will delete such information from our files or obtain parental consent in accordance with applicable law.
XI. THIRD PARTIES
XII. OTHER TERMS AND CONDITIONS
This Policy is to be read in connection with any other policies and terms posted on our Sites and Apps. You do not have a right to change the terms of this Policy or any other policies or terms on our Sites or Apps.
XIV. HOW TO CONTACT US