This Privacy Policy describes the policies and procedures of Common Living Inc. d/b/a Noah Living and/or its affiliates (“Noah Living”, “we”, “our” or “us”) on the collection, use and disclosure of your information on www.noahapartments.com (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) if you apply to become a member of the Noah Living community (such membership, a “Membership,” and such members, “Members”) through the Services; (iii) your use of the Services generally; and (iv) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Services or to individuals that we do not manage or employ, including without limitation third party payment processors, third party background or credit check services, third party app providers, or third party perk providers. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect and Why?

Information That You Provide to Us:

For potential rental applicants, we may collect the following types of information from you at different points during your use of the Services: name, email address, telephone number, mailing address, information about your housing preferences (such as desired geographic area, home, budget and move-in date), information about your household, and other information about yourself needed for background and/or credit check. We use this information to match you to a potential home and may contact you regarding the same by email or telephone. We also use this information to evaluate your eligibility for Membership and for certain operational aspects of the Services, including communicating with you, and providing and improving the Services. If you create a Member Account, you will also provide a username and password to access your Account.

For potential real estate partners, we may collect your name, email address, telephone number, 

company name, your role at your company, other company information (such as units owned), and information about your interest in partnering with Noah Living (including geographic region and type of project). We may use this information to provide you with information about our Services and to contact you.

You acknowledge that this information may be personal to you, and by providing such Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. In addition, some of this information may include sensitive information, and we do not collect this information unless you voluntarily provide it or unless we are required to do so pursuant to applicable laws or regulations. We may use your contact information to send you information about our Services from time to time when we feel such information is important. You may unsubscribe from these messages through your Account settings or by request, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Financial Information:

We do not currently collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by a third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.

IP Address Information and Other Information Collected Automatically:

We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Email Communications:

We may receive a confirmation when you open an email from us. We use this confirmation to improve our Services.

Information Collected Using Cookies:

Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Aggregate Information:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services may be shared with third parties.

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. For example, you may elect to share Personal Information with Third Party Services for the purposes of running a background or credit check as part of your application for Membership, to process payments, or to access perks offered by third parties. We are not responsible for the privacy policies and/or practices of any Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Except as set forth elsewhere in this Privacy Policy, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as notifications of updates to our policies, password recovery, and information about Services that you may be interested in.

Financial Information:

As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

Information Shared with Our Agents and Third Parties:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you, such as name, email address, telephone number, household information, and mailing/physical address. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. In addition, if you apply for a Membership, we may share screening and application information, contact information and occupancy information, all of which may include Personal Information, with the owner of any property leased or managed by us (“Owner”) that you occupy, with a financing provider to us or such Owner, and with any data analytics, data processing or reporting agent of such Owner, us or a financing provider to such Owner or us as needed in the operation of its business. You hereby consent to our sharing of Personal Information with our Agents, and relevant Owners and financing providers.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety or our users, Members or the public (such as when harm or violence against any person is threatened). This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Notwithstanding any other provision of this Privacy Policy or the Terms of Service, we reserve the right, but have no obligation, to disclose any information that you provide through the Services, if in our sole opinion, we suspect or have reason to suspect, that the information involves a party who may be the victim of abuse in any form. Abuse may include, without limitation, elder abuse, child abuse, spousal abuse, neglect or domestic violence. Information may be disclosed to authorities that we, in our sole discretion, deem appropriate to handle such disclosure. Appropriate authorities may include, without limitation, law enforcement agencies, child protection agencies or court officials.

Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services through the Site. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights : Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 

Common Living Inc. d/b/a Noah Living

335 Madison Avenue, Suite 6A

New York, New York 10017

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing your request for account termination to residents@noahapartments.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

What Choices Do I Have Regarding My Information?

You can use the features of the Services that do not require registration, thereby limiting the types of information that we collect.

You can opt not to disclose certain information to us, even though it may be needed to take advantage of some features of the Services.

You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed elsewhere in this Privacy Policy.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to legal@noahapartments.com. We will make every effort to resolve your concerns.

Effective Date: October 25, 2019