Our commitment to privacy

Introduction

This policy explains Pembroke’s privacy practices when you interact with us through online channels (for example, Websites and mobile applications) owned and controlled by Pembroke (our “Websites”).

Pembroke’s Privacy Policy was developed as an extension of our commitment to maintaining the highest level of integrity in dealing with our investors, tenants and partners. The Policy is designed to assist you in making informed decisions when using our Websites. Pembroke continuously assesses this statement against new technologies and business practices, audience needs and changes in law.

About Pembroke

In this privacy policy, “Pembroke” refers to Pembroke Real Estate LLC, a company incorporated under the laws of Massachusetts, USA whose principal place of business is at 255 State Street, Boston, MA 02109 USA.

If you have any questions about this privacy policy, please contact Pembroke at privacy@pembroke.com

Information We Collect and How We Use It

When you browse our Websites, we may collect certain information from or about you. This may include name and contact details that you provide to us when registering with a Website, or when sending correspondence to us through a Website.

We use this information to provide you with the services you request and to respond to any correspondence you send us.

We also collect certain technical and navigational information from the visitors to our Websites, including by using cookies (see the section “Cookies and Similar Technologies” below). This includes information such as your device type, browser type, Internet protocol address, pages visited, and average time spent on our Websites, which we use:

To maintain the security of your online session;

To facilitate site navigation;

To improve our Web design and functionality; and

To personalize your experience on our sites.

Cookies and Similar Technologies

We use cookies and similar technologies to support the operation of our Websites. Cookies are small data files that a Website sends to or accesses from a Web browser on a visitor’s computer or other device. Cookies collect technical and navigational information about visitors to our Websites, including date and time of visits, pages viewed, amount of time spent on our Websites, or general information about the device used to access the Website.

Cookies that are set by Pembroke are called “first party cookies”, and cookies set by third party providers of services to Pembroke are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through our Websites (e.g. like advertising, videos and analytics). The providers that set third party cookies may be able to recognize your computer or device both when it visits our Websites and also when it visits other websites serviced by that third party.

Cookies can remain on your computer or device for different periods of time. Some cookies are “session cookies”, meaning that they exist only while your website browser is open and are deleted automatically once you close your browser. Other cookies are “permanent cookies”, meaning that they survive after your browser is closed and can be used by websites to recognize your computer when you later re-open your browser and browse the internet again.

Specifically, the types of cookies that Pembroke uses on our Websites include:

As well as cookies, Pembroke and third-party service providers we hire, may also use other technologies, such as Web beacons or pixel tags, in online advertising to help us measure the performance of our online advertising campaigns. These technologies do not collect any information that enables us or them to determine your actual identity.

How do I turn cookies off?

You can refuse or delete a cookie using the opt-out links provided above, where these exist. In addition, most browsers and mobile devices also offer their own settings to manage cookies.

If you refuse a cookie when on a Website, or if you delete cookies, you may experience some inconvenience in your use of Pembroke’s Websites.

If you want to change your browser’s cookie settings, these will typically be found in the ‘options’ or ‘preferences’ menu of your browser. In order to understand these settings, the following links may be helpful; otherwise you should use the ‘Help’ option in your browser for more details:

Advertising on Non Pembroke Websites

Pembroke also advertises our products and services on Websites not affiliated with Pembroke. We contract with third party advertising companies to display these ads, and they may use cookies and similar technologies to optimize the placement of our ads. We do not permit these companies to use the information they collect on Pembroke’s behalf for any purpose other than to assist them with advertising Pembroke services.

Who Does Pembroke Share Information With?

From time to time, Pembroke may share the information it collects from or about you with its affiliated group companies and with third party service providers that perform services on its behalf for the purposes described in this privacy policy. All service providers that Pembroke engages are required to implement appropriate technical and organizational measures to maintain the security of the information they process, and only to process that information in accordance with instructions from Pembroke.

Pembroke may also disclose information it collects from or about you where it believes this is necessary to comply with a law enforcement request, a judicial, regulatory or governmental order or otherwise to exercise, establish or defend legal rights.

Pembroke does not sell or rent your personal information to any third party for their marketing purposes.

How We Protect Your Personal Information

Pembroke maintains reasonable safeguards combining administrative, technical, and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.

We use data hosting service providers in the US to host the information we collect and we use technical controls to secure that data

We use Secure Socket Layer (SSL) encryption on our website when transmitting information and use other commercially reasonable efforts to protect your information. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate.

International Data Transfers

If you are a visitor from the European Economic Area, the information Pembroke collects about you will be stored on servers in the United States of America. Territories outside the European Economic Area (“EEA”) may not have data protection laws equivalent to those inside the EEA, but Pembroke will at all times protect your information in accordance with this privacy policy.

Your rights

You have the right:

• To request access to any personal information Pembroke holds about you (which may be subject to a fee specified by applicable law)
• To require Pembroke to correct any inaccurate or out-of-date personal information we hold about you, and
• To instruct Pembroke not to send you any marketing communications, even if you have previously indicated willingness to receive these.

If you would like to exercise any of these rights, please contact Pembroke using the details provided above.

Children’s Privacy

Pembroke is not directed to children, and we do not knowingly collect personal information from children under 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please let us know by contacting us at privacy@pembroke.com

Third Party Links

We may include links to other third party websites. These third party websites have separate and independent privacy policies. We therefore have no responsibility or liability for the content, and activities of these linked sites.

Changes to our Privacy Policy

Pembroke may from time to time amend or update this privacy policy. You should revisit this page regularly to keep up-to-date with Pembroke’s current privacy practices.

This policy was last updated in June 2018.