Effective Date: September 1, 2021

Last Reviewed on: September 1, 2021

Peter Sullivan Associates, Inc., its subsidiaries and other affiliate companies (collectively, “PSAI,” “Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This privacy policy (“Privacy Policy”) describes our privacy practices in connection with the 155montgomery.com website, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy, and our privacy practices in connection with other aspects of our business, including our offline interactions and physical locations and our products and services related thereto (collectively, the “Sites”).  This Privacy Policy also describes the rights and choices available to individuals with respect to their information.  We may provide additional or supplemental privacy policies to individuals for specific interactions at the time we collect personal information, such as employment interactions. Any such supplemental privacy policies will govern how we may processes the information in the context of the specific interaction. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Sites. By accessing or using our Sites, you agree to this Privacy Policy. This Privacy Policy may change from time to time.  Your continued use of any Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates

Personal Information We Collect, Why, and How We Use It

“Personal Information” is information that is not publicly available that identifies, relates to, describes or may be associated with you.  We may collect such Personal Information in any of the following ways:

• Directly from you.  Personal Information you provide directly to us through the Site or otherwise.  Such Personal Information may include business and personal contact information, such as your first and last name, email and mailing address, phone number, professional information, and such information you may upload to our Sites, including in the process of creating an online account. We may also collect information from third parties authorized by you to provide such information to us, for example when you submit a rental application or any other form through a third-party provider.

• Indirectly from you.  We may use security and surveillance technologies, identity confirmation technologies (such as caller ID) or other data collection technologies, including those described under the heading Automatic Data Collection Technologies, below, to collect Personal Information about you when you visit our properties, use our Sites, or otherwise communicate or interact with our employees and service providers.

• Social Media.  We may maintain pages for the Company on social media platforms, including Facebook, Twitter, Google, LinkedIn, Instagram, and other third party platforms.  When you visit our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.  You or the platform may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

• Third Parties.  We may obtain Personal Information about you from third parties, including, without limitation, from credit reporting agencies, former employers, former landlords, social media platforms, rental listing companies, and other third party sources.

In the last twelve (12) months, we have collected the following statutory categories of Personal Information.  Descriptions of each category are provided as examples and do not necessarily identify the specific information we collect that falls into each category.

Sharing Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances and as described in this Privacy Policy. 

Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Sites (such as customer support, hosting, analytics, shipping, payment processing, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Governmental authorities. We may disclose your personal information to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Sites and our products and services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Automatic Collection Technologies

We use the following automatic collection technologies to collect Other Information, which may or may not be combined with Personal Information:

• Log Files: Most Internet browsers transmit certain information to Sites that you visit, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files. We use this information to ensure that the Site functions properly.

• Cookies: Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a Site. Cookies allow us to recognize your browsing device and preferences and generally help to improve your online experience, as well as to provide us with anonymous information to check the usefulness of, and make improvements to, our Site. Cookies may be placed on your computer and/or mobile device by both us and by third parties with whom we have a relationship, such as web analytics services. You may refuse cookies by activating the setting on your browser. However, if you select this setting, you may not have the same user experience. To learn more about how to manage cookies, visit www.allaboutcookies.org/manage-cookies/ (please note that this Site is not connected to us and we are not responsible for its content).

• Web Beacons and Pixel Tags: We may utilize a technology called a “web beacon” or “pixel tag”.  We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of Sites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site. 

• Third Party Analytics: We also use automated devices and applications, such as Google Analytics (more info https://support.google.com/analytics/answer/6004245?hl=en-GB) to evaluate the use of our Site. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Site with other information they have collected for their own purposes. This Privacy Policy does not cover such uses of data by third parties.

• Do Not Track Signals: We also may use these technologies to collect information about your online activities over time and across third-party Sites or other online services (behavioral tracking). Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Your Choices About How We Use and Disclose Your Information

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Site. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

  Marketing Communications. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending your request to info@155montgomery.com. You can also always opt-out by following the opt-out or unsubscribe instructions at the bottom of the email.  Please note that such requests may take up to ten (10) business days to become effective.  You may continue to receive service-related and other non-marketing emails.  If you receive marketing text messages from us, you may be able to opt-out of receiving further marketing text messages from us by replying STOP to our marketing message, or by contacting us at info@155montgomery.com.

• Telephone Communications. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

• Modify Your Information.   You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Site, or object to the use of such Personal Information by us.  For your protection, we will only implement requests with respect to the Personal Information associated with the particular individual if we can verify the identity of that individual (see Exercising Access, Data Portability, and Deletion Rights below for verification process). We aim to comply with requests as soon as reasonably practicable.

• Targeted Interest-Based Advertising. Some of the business partners that collect information about users’ activities on or through the Sites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.  You may stop or restrict the placement of cookies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides Sites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/, https://youradchoices.ca/choices/,  www.networkadvertising.org/managing/opt_out.asp, and http://www.youronlinechoices.eu/. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party Sites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across Sites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Important Information for California Residents

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information.  This section describes your CCPA rights and explains how to exercise those rights.  These rights are not absolute and, in certain cases, we may decline your request as permitted by law.

Information, Access and Deletion Rights

Information Rights

You have the right to request the following information about how we have collected and used your Personal Information during the past 12 months: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which we collected Personal Information; (c) the business or commercial purpose for collecting and/or selling Personal Information; (d) the categories of third parties with whom we share your Personal Information; (e) whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient; and (f) whether we have sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.

Access Rights

You have the right to request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion Request Rights

You have the right to ask us to delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions (“Deletion Request”).  We may deny your Deletion Request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Information, Access and Deletion Rights

You, or someone legally authorized to act on your behalf, may exercise your rights described above by:

• Calling us at (866) 719-2077

• E-mailing your request with the information required below to: info@155montgomery.com

We will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity, and understand and respond to the request.  A California resident can empower an “authorized agent” to submit request on his/her behalf.  We will require the authorized agent to have a written authorization confirming authority.  Parents or Guardians can submit a request on behalf of a minor child.

The Personal Information you provide with your request will only be used to verify your identity.  Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request.  If we deny your request, we will communicate our decision to you.

We will confirm receipt of the request within ten (10) days of its receipt.  We endeavor to respond to requests within forty-five (45) days of receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

You are entitled to exercise the rights described above free from discrimination.  This means that we will not penalize you for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights.

Third Party Sites 

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link. Please read the terms, conditions and policies of such third-party sites before accessing or using such sites. The inclusion of a link on the Site does not imply any endorsement of the linked site by us or by our affiliates.

Security

To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, we employ physical, technical and administrative procedures to safeguard this Site and the personal information we collect. All of our employees and any third parties we employ to process your personal information are obliged to respect its confidentiality. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.  Please do not send sensitive or confidential information to us by email or by any other means in connection with the Site. If you have reason to believe that your communications with us have been compromised in any way, please immediately notify us of the problem by contacting us as provided in the “Contacting Us” section below. 

Retention Period 

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. 

Use Of Site By Minors 

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or through any of its features, register on the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using a method provided under the heading “Exercising Information, Access and Deletion Rights.”

Governing Law and Jurisdiction

All matters relating to the Site and the Privacy Policy, and any dispute or claim arising therefrom or related thereto, shall be governed by and construed in accordance with the internal laws of the State of California without giving effect to any choice or conflict of law provision or rule (whether of the State of California or any other jurisdiction).  This Site is operated, in whole or in part, from the United States.  By using this Site, regardless of where you live in the world, you consent to have any Personal Information you provide through this Site transferred to and processed in the United States, and allow us to use and collect your Personal Information in accordance with this Privacy Policy.  Text on this Site may be published in languages other than English.  In all instances, the English language version of any text, including this Privacy Policy, controls the legal impact and interpretation of this Site and its use.

Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country. 

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership), or other information you consider to be confidential, on or through the Site or otherwise to us. 

Contacting Us 

If you have any questions or comments about this notice, the ways in which PSAI collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (866) 719-2077

Site: 155montgomery.com/contactus

Email: info@155montgomery.com

Postal Address:

Peter Sullivan Associates, Inc.
Attn:   
155 Montgomery Street Associates, LLC  
155 Montgomery Street, Suite 1600
San Francisco, CA 94104