Bulfinch WPB1 Condo Holdings LLC (“Owner”), which owns The 110 Sudbury Condominium, is committed to protecting the privacy of visitors to this web site (the “Site”).

The purpose of this Privacy Policy is to inform you of what kinds of information we may gather about you when you visit the Site, how we may use that information, whether we disclose it, and the choices you have regarding our use of and your ability to manage and edit the information.  This Privacy Policy applies to the Site.  This Privacy Policy does not apply to other web sites to which we link.

INFORMATION COLLECTION

We collect personal information when you wish to use certain features of the Site, such as registering to receive information from us, submitting questions or comments to us, or providing feedback to us.  When you choose to use these features, we ask for information such as your name, e-mail address, mailing address, phone number, and other personal information (“Personal Information”).  We may use Personal Information for the following general purposes: to fulfill your requests for certain information and services offered through the Site, to create personal accounts, to send users press releases, updates, or other general information about Owner or The 110 Sudbury Condominium, to meet any applicable legal and regulatory requirements, and to respond to any questions, comments, or feedback you submit.

Through the Site, we may automatically gather certain information about the use of the Site, such as how frequently certain areas of the Site are visited, including through the use of cookies, web beacons and other technologies.

You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies.  You do this through your browser (such as Internet Explorer, Chrome, or Firefox) settings.  Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings.  If you turn cookies off, you may not have access to many features that make your site experience more efficient and some of our services may not function properly.  For more information about cookies, please see www.allaboutcookies.org/.

PROTECTING PERSONAL INFORMATION

When you give Owner your Personal Information, we take steps to ensure that your information is treated securely.  Owner uses industry-standard encryption technologies when transferring and receiving sensitive visitor data via the Site.  Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure.  As a result, while we strive to protect your Personal Information, Owner cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.  Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems, and to protect against the loss, misuse, or alteration of information that we have collected.

DISCLOSURE

Unless otherwise stated in this Privacy Policy, we do not sell, trade or rent your Personal Information to others.  We may permit certain trusted partners to access your information in connection with their performance of services to maintain and operate the Site and certain features on the Site.  We do not otherwise disclose any Personal Information or any information about your individual visits to our Site except when we believe in good faith (i) that the law, a court order, or a subpoena requires such disclosure or (ii) that such disclosure is necessary to protect the security of the Site; to enforce or apply our online Terms of Use or other agreements; to prevent or investigate a possible crime, such as fraud or identity theft; or to protect the rights, property, or safety of Owner or others.

We allow you to opt out of receiving e-mail from us.  If you no longer wish to receive emails from us, you may opt-out of receiving them by emailing us at residences@thesudbury.com.

We use non-personally identifiable information in the aggregate so that we can improve the Site and for business and administrative purposes.  We may use or share with third parties for any purpose aggregated data that contains no personally identifiable information.

Our website may share information with companies that provide support services to us (such as web hosts) or that help us market our products and services (such as email vendors). These companies may need information about you in order to perform their functions.  These companies are not authorized to use the information we share with them for any other purpose.

We may decide, for strategic or other reasons, to sell, buy, merge, or otherwise reorganize one or more of our businesses or the properties or other assets thereof, including The 110 Sudbury Condominium.  A transaction of this type may involve the disclosure of Personal Information to prospective purchasers.  In such cases, we will take reasonable measures to protect the Personal Information we disclose, for example, by requiring the prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the Personal Information.

Your Personal Information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site or The 110 Sudbury Condominium to another organization or if we merge with or sell our assets or equity interests to another organization, whether voluntarily or through insolvency or bankruptcy proceedings.  If such a transfer occurs, the successor organization will acquire our rights to use your Personal Information, but the successor organization’s use of your Personal Information will still be subject to this Privacy Policy and the privacy preferences you have expressed to us.

Except as otherwise stated above, we will not publish or provide your e-mail address or other Personal Information to third parties without your consent.

UPDATING PERSONAL INFORMATION AND PREFERENCES; OPTING OUT

If you have provided us with Personal Information and would like to change, correct, or request access to your Personal Information or update or cancel your registration, you may do so by emailing us at residences@thesudbury.com . In addition, you may opt out of receiving any or all communications from us by emailing us at residences@thesudbury.com or by using the “unsubscribe” link that appears in e-mails received from us.

CHILDREN

The Site is not directed to children under the age of 13, and we do not solicit or knowingly collect any Personal Information from children under the age of 13.  We encourage families to obtain additional information about safe use of the Internet at www.consumer.ftc.gov/topics/kids-online-safety.

NOTICE TO INTERNATIONAL USERS

The Site is operated in the United States.  If you are located outside of the United States, you should be aware that we will collect, process, and maintain your information in the United States.  By using the Site, accessing the Site, or providing any information to the Site, you consent to the transfer of your information to the United States, which may not offer the same level of privacy protection that would be required in your home country, and to the processing and maintaining of that information as described in this Privacy Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with Owner.

You can request to know what personal information we have collected, used, disclosed, and sold in the preceding 12 months. You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:

• Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
• Security: to detect data security incidents;
• Error Correction: to debug or repair any errors;
• Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
• Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

To submit a request to know or a request to delete, please email residences@thesudbury.com. In order to verify your identity, we will send you a verification email. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof by mail or e-mail to the address specified in this Policy (see Contact Information) so that it is received prior to the time the agent makes the request on your behalf. A request to know or a request to delete may alternatively be initiated by calling us at 617-227-2080. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.

We do not and will not sell any personal information (as “sell” is defined in CCPA ). We will not discriminate against you for exercising any of your CCPA Rights and, to the extent Owner is providing goods or services, we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.

PRIVACY POLICY CHANGES

We reserve the right to change our Privacy Policy for the Site at any time.  If we decide to change our Privacy Policy, we will post the revised Privacy Policy on the Site and use commercially reasonable efforts to notify you so that you will know what information we gather, how we might use that information and whether we will disclose it to anyone.  Please check periodically to keep informed of any changes.  If we materially change this Privacy Policy, the new terms will apply only to (i) Personal Information and other information provided under a prior version of the Privacy Policy by users who affirmatively consent to the new terms and (ii) Personal Information and other information provided after this Privacy Policy has been amended.  In other words, your continued use of this Site after we have posted the revised Privacy Policy constitutes your agreement to be bound by the revised Privacy Policy on a prospective basis, but we will honor the terms that were in effect when we gathered data from you.

CONTACT INFORMATION

If you have questions or concerns regarding this statement, please contact us at:

Bulfinch WPB1 Condo Holdings LLC
c/o The HYM Investment Group
Tel: 617-248-8905

E-mail: mfitzgerald@hyminvestment.com

Last updated:  May 2020