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PRIVACY POLICY

Effective Date: 2024-06-28

SCOPE

This Privacy Policy (“Policy”) describes how Howard Hughes Holdings Inc., its subsidiaries and affiliates (collectively, “HHH,” “we,” or “us”) treats personal information that we collect offline and through our websites and other online platforms where this Policy is located (collectively, our “Platform”). This Policy does not apply to our collection of employment-related personal information or information that is not personal information or does not individually identify you.

This Platform is operated in the United States and intended for use by individuals who are located in the United States.

NOTICE AT COLLECTION

We collect information from you and about you. Here are some examples of the information we may collect, how we may use it, how we may disclose it and whether we share it for cross-contextual advertising purposes (“share”) or sell it. Below this Notice At Collection, you will find more detailed descriptions of how we may collect, use and disclose personal information.

  • Contact Information. This may include your name, address, email address and telephone number.
    • How We May Collect It : Directly from you; passively or from third parties.
    • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners.  For more information about your right to opt-out, please click here .
  • Demographic Information. This may include information about your age, zip code, and income range.
    • How We May Collect It: Directly from you; passively or from third parties.
    • How We May Use It: To run and improve our business; to understand your interests; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here .
  • Commercial information. This may include information that could identify you and relates to the properties, events or businesses in which you may be interested. We may also collect personal information about your consuming history or tendencies, including reservation and event ticketing history.
    • How We May Collect It: Directly from you; passively or from third parties.
    • How We May Use It: To run and improve our business; to understand your interests; to determine your eligibility; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.
  • Information You Provide to Us. For example, we may collect personal information included in a post you make in public-facing forums on our Platform or when you send us a message through our Platform. We may also collect personal information that you leave on our social media pages or in a survey or an entry for a promotion, contest or challenge. We may collect personal information that you submit when you contact us. We may also collect your signature if you submit it to us.
    • How We May Collect It: Directly from you.
    • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.
  • Internet or other similar network activity. This may include unique online personal identifier, online or mobile device identifier, IP address, browsing history, search history, language and information regarding interaction with an Internet website, application, or advertisement. This may also include information about the state or country from which you accessed our Platform or browser or operating system you are using or what site you came from and what site you visit when you leave us. It may also include the specific pages you visited or items viewed on our Platform, the date and time of your visit, the number of links and specific links you click within our Platform and the functions used on our Platform.
    • How We May Collect It: Directly from you; passively or from third parties.
    • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.
  • Sensory data. This may include audio, visual or similar information.
    • How We May Collect It: Directly from you or from third parties.
    • How We May Use It: To run and improve our business; to understand your interests; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.
  • Professional information. This may include your current or past job history, title, employer or professional contact information.
    • How We May Collect It: Directly from you or from third parties.
    • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; for legal and security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.
  • Inferences drawn from other personal information. This may include creating profile based on other information we have collected about you that relates to your preferences, characteristics, predispositions and interests in properties, events and businesses.
    • How We May Collect It: Directly from you; passively or from third parties.
    • How We May Use It: To run and improve our business; to understand your interests; for marketing purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
    • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; for legal and security purposes; for other reasons we may describe to you; as requested or directed by you.
    • We May Share or Sell This Information With Our Business Partners. For more information about your right to opt-out, please click here.

Sensitive Personal Information: We may collect certain sensitive personal information, such as Social Security, passport and other government ID numbers, race, marital status, sexual orientation and financial and tax information, in connection with the sale or lease of, or residence in, our properties. We solely use this information in connection with such sales and rentals and we use and disclose this information in support of these transactions and your residence in our properties, to comply with the law or protect ourselves and as requested or directed by you. We may also disclose this information with any successors to all or part of our business. We do not share or sell sensitive personal information.

Our Personal Information Retention Criteria: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of personal information we collect Oftentimes, our records contain several of these categories of personal information combined together and therefore we consider, on a case-by-case basis, a number of factors to assess how long personal information is retained. These factors include what personal information is reasonably necessary to (i) administer our business or relationship with an individual; (ii) protect our business, employees, organization and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

HOW WE MAY COLLECT YOUR PERSONAL INFORMATION

We may collect your personal information in different ways. Below, you will find additional details and examples regarding how we may collect your personal information.

  • Directly From You. For example, when you:
    • Register for an account on our Platform.
    • Inquire about properties, businesses and events.
    • Lease or purchase one of our properties.
    • Submit an application, inquiry or other information to us.
    • Make reservations or reserve tickets for events.
    • Participate in one of our promotional sweepstakes or contests.
    • Enroll in a loyalty program.
    • When you register for Wi-Fi services in our communities.
    • Complete an online form.
    • Sign up to receive communications from us, such as text messages, emails or other promotional communications.
    • Download or use our mobile applications.
    • Contact our sales or support team.
    • Complete a poll or survey.
    • Interact with our social media pages.
    • Otherwise engage with us.
  • Passively. For example, we may collect personal information when you visit and navigate our Platform on any device. We may also collect information about you over time and across different websites, mobile applications and devices when you use the Platform. We may use tools such as analytics and cookies, including cookies run by third parties, to collect this information.
  • From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:
    • Our business partners, including real estate brokers and other real estate professionals, analytics companies, advertising networks and entertainment, ticketing and reservation companies. This may also include companies that manage our properties and companies that provide Wi-Fi services for our properties.
    • Social media sites, such as Facebook, Twitter and LinkedIn.
    • Your contacts who provide your information to us because they think you may be interested in our properties or events.
    • Companies that provide information to supplement what we already know about you, including data aggregators. Certain third parties may link your name and email address to other information they have collected. This might include online usage information.
HOW WE MAY USE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may use your personal information:

  • To Run and Improve Our Business. We may use your information to manage and develop our properties and make our Platform and our properties, businesses and events better. This may also include using your information for business administration purposes, such as for accounting, record keeping, legal, backup and other similar purposes. This may also include using your personal information to provide our loyalty program. Note that we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.
  • To Communicate With You. This may include responding to your feedback, inquiries and questions. We may communicate with you about your property or our relationship. We may also contact you about this Policy or our Platform terms and conditions. We may communicate with you through electronic means, including text message or email.
  • To Understand Your Interests. This may include understanding what properties, businesses and events may be of interest to you. This may also include customizing your experience with us.
  • To Determine Your Eligibility. This may include evaluating your eligibility for the lease or purchase of our properties or using personal information to request background checks.
  • For Marketing Purposes. We may provide you with information about our company, properties, businesses and events and our business initiatives. This includes using your information to personalize your experience on our Platform and our business. We may also engage in cross-contextual advertising and retargeting. We may also send you push notifications through our mobile applications or send you marketing communications through text message, email or online platforms. For more information about your choices related to these communications, see the Cookies and Electronic Communications  section below.
  • For Legal and Security Purposes. This could include defending, protecting or exercising rights related to our company, our residents and tenants and our Platform, properties, businesses and events. This could also include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might disclose information when we are investigating a potential fraud.
  • As Otherwise Permitted By Law or As We May Notify You.
  • As Requested or Directed By You.
HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may disclose your personal information:

  • Internally. We may disclose your information to our parent, subsidiary, and affiliate entities.
  • On Our Platform. For example, we may disclose your information on our Platform or on our social media sites.
  • With Our Service Providers. We may disclose your information with third parties who perform services on our behalf. For example, this may include companies that send communications on our behalf or help us run our Platform.
  • With Our Business Partners. For example, we may also disclose personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also disclose personal information to companies that help us learn more about our customers or to companies that co-sponsor events or promotions with us. If you participate in our loyalty program, we may disclose your personal information so you can receive benefits from a select group of our business partners. We may also disclose information to businesses and in connection with events that occur within our properties or communities.
  • With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.
  • For Legal and Security Purposes. This could include defending, protecting or exercising rights related to our company, our residents and tenants and our Platform, properties, businesses and events. This could also include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might disclose information when we are investigating a potential fraud.
  • For Other Reasons We May Describe to You.
  • As Requested or Directed By You.

YOUR PRIVACY RIGHTS

Based on your state of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

  • Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about the consumer.
  • Deletion. This means that you can request that we delete personal information about you which we have collected from you.
  • Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.
  • Opt-Out of Sale of Personal Information. This means that you have the right to opt-out of our “sale” of personal information. If you would like to exercise this right, in addition to submitting a request as described below, please also follow your Internet browser’s directions for turning off cookies. Please note that the choices you make may be browser and device-specific, and your choices may be deleted if you clear your browser cache or cookies.
  • Opt-Out of Sharing of Personal Information.  You may have the right to opt out of sharing of personal information with third parties for cross-contextual marketing purposes. If you would like to exercise this right, in addition to submitting a request as described below, please also follow your Internet browser’s directions for turning off cookies. Please note that the choices you make may be browser and device-specific, and your choices may be deleted if you clear your browser cache or cookies.
  • Right to Non-Discrimination. This means that we are prohibited from discriminating against you if you exercise your rights under applicable law.

If you wish to exercise your rights under this section, please submit a request here [email protected] Please include your name, email address and state of residence  and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at [email protected].

Agents. Agents that you have authorized to act on your behalf may also submit privacy requests as instructed above. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

Please note that we do not knowingly share for cross-contextual marketing purposes or sell the personal information of individuals who are under 16 years old.

Additional Information for California Residents. If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected]. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.

NOTICE OF FINANCIAL INCENTIVES

We may offer various financial incentives in relation to our business. For example, we may provide special offers, discounts and other benefits for customers who join our loyalty program. When you participate in a financial incentive, we collect personal information from you. You have the ability to opt out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by sending an email to [email protected]. The value of your personal information is reasonably related to the value of the offer, discount or benefit presented to you. In some instances, we may provide you with additional terms or conditions relating to a financial incentive.

CHILDREN UNDER 18

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18 and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 18 has provided us with information, please email us at [email protected]. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

COOKIES AND ELECTRONIC COMMUNICATIONS

You have certain choices about how we collect, use and disclose your information in connection with our use of cookies and our provision of electronic communications. Certain choices you make are browser and device specific.

Cookies & Other Tracking Technologies:

  • Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
  • Flash Cookies: You may need to take an additional action to manage flash cookies, which you can learn more about here. Why? Because flash cookies cannot be controlled through your browser settings.
  • Push Notifications: We may send you push notifications through our mobile applications. To stop receiving these messages, you can change the notification settings in the mobile application menu.
  • Google Analytics: We may use Google Analytics on our Platform to help us understand how you use our Platform. You can learn about how to opt-out of Google Analytics here.
  • Facebook: We may use Facebook cookies to target ads to you. You can learn about how to opt-out of receiving targeted advertisements from Facebook here.
  • Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
  • Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to “do not track” signals.  If you block cookies, certain features on our sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

Marketing Communications:

You can opt out of receiving our marketing communications, which we may send by email or text message. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

SECURITY

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control.  A username and a password may be needed to access certain areas of our Platform. It is your responsibility to protect your username and password and you must contact us or change your password immediately if the confidentiality of this information has been compromised.

STORAGE OF INFORMATION

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control.  We are not responsible for these third party sites or their privacy practices. We suggest that you read the privacy policies of those sites carefully.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, please feel free to contact us as follows:

Howard Hughes Holdings Inc.

9950 Woodloch Forest Drive, Suite 1100

The Woodlands, Texas

281.929.7700

[email protected]

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.