Updated and Effective Date: November 11, 2020
This Online Privacy Policy (this “Policy”) sets forth how SitusAMC Holdings Corporation and its subsidiaries (“SitusAMC” or “we”) gathers and uses information about your interaction with this website or through other interactions with us. This Policy concerns only SitusAMC websites (collectively, “Sites”), and does not concern any website to which this site may link. This Policy is applicable to all SitusAMC and subsidiary websites, including but not limited to:
Please read this Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of the Sites.
To learn about the SitusAMC Complaint Policy, please click here.
- THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU We collect the following categories of personal information from you in different ways, including from you directly, from you passively through your use of the Sites, from third parties and from publicly available sources. Personal Identifiers: In order to obtain access to certain services provided via the Sites and request certain information regarding SitusAMC directly from the company via the Sites, you may be required to provide personal information such as your name, postal address, e-mail address, telephone number, fax number and investor status. In some instances, we may receive biometric, personal and protected classification characteristics and similar information. You can choose not to provide this information, but then you might not be able to gain access to such information and services. We may collect this information from various sources, including from you directly, through your use of the Sites, recruiting agencies, financial institutions, service providers and other individuals. We use and share this information as noted below.
Commercial Information: We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties, including data brokers. We use and share this information as noted below.
Internet or other electronic network activity information: We may also collect information about you through technology. For example, when you visit the Sites, we may collect your IP address (an IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet Service Provider), or your company) or other information you choose to explicitly share or submit to us. At times, we use IP addresses to collect information regarding the geolocation and frequency with which visitors browse various parts of our Sites and combine this information with other information about you. The Sites also use Cookies. Cookies are pieces of information that a website sends to your computer while you are viewing the website. For more information about the processing of information we obtain by automated means and how to change your Cookie settings, please visit our Cookie Policy. To the extent required by applicable law, we will obtain your consent before using Cookies or similar tools. Our Sites also uses other technical methods to track visitor usage, including web beacons (“web beacons” are small pieces of data that are embedded in images on the pages of a website). We use these technical methods to analyze the traffic patterns on our Sites, such as the frequency with which our users visit various parts of our Sites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we may send visitors to our Sites to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails. Information we collect using these technologies is never combined with the information you provide (e.g. name, email etc…).We collect this information through your use of the Sites and from our services providers. We use and share this information as noted below.
Professional or Employment Information: When you register on the Sites, we may collect professional and employment information such as information about your employers, awards and associations. We may collect this information from various sources, including from you directly, through your use of the Sites, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.
Audio, electronic, visual, thermal, olfactory, or similar information: When you visit some of our physical locations, our CCTV cameras may capture your image. If you call SitusAMC, your calls may be recorded. We may collect this information from various sources from you directly. We use and share this information as noted below.
Educational Information: When you register on the Sites, we may collect educational information such as information about schools you attended, degrees awarded and academic status. We may collect this information from various sources, including from you directly, through your use of the Sites, financial institutions, service providers and other individuals. We use and share this information as noted below. - HOW PERSONAL INFORMATION WE COLLECT ABOUT YOU IS USED For each category of personal information above, we use your personal information to carry out the following purposes:
Provide you with Services: We use your personal information to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
Improve the Sites: We use your personal information about you to provide you services and improve our Sites. We might use your personal information to deliver the Sites and/or customize your experience with us. For example, we may use your personal information to improve the Sites and our other internal business purposes.
Security and Fraud Prevention and Detection: We use your personal information for security purposes such as fraud prevention and detection. We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our Sites, or a third-party website or platform.
Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes, including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Marketing: We use your personal information to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about. We use your personal information to make suggestions and recommendations to you and other users of our Sites about products or services that may interest you or them. We use your personal information to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. We use your personal information to provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you, where you have consented to being contacted for such purpose.
Communications: We use your personal information to communicate with you about your account or our relationship. We may contact you about your use of our Sites. We may contact you about your account, feedback or changes to our service. We might also contact you about this Privacy Policy or the Sites’ Terms of Use.
Debug and Identify Errors: We use your personal information to debug and identify and repair errors that impair existing intended functionality on our Sites.
Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes, including analyzing performance. We may also use your personal information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law. We may combine information we obtain about you (such as offline through our services or from third parties) for the purposes described above. - WAYS WE SHARE PERSONAL INFORMATION We do not disclose personal information we collect about you, except as described in this Privacy Policy. For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.
SitusAMC Companies and Affiliates: We may share your personal information within the SitusAMC family of companies and with our affiliates.
Service Providers: We share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include companies we hire to help deliver products or services, like a shipping company that delivers a package, and companies who help us either gather your information or communicate with you.
Comply with the Law: We also may disclose personal information (a) if required by law, including, for example, to comply with a court order or subpoena, or (b) to enforce our Terms of Use; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Sites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties. We also reserve the right to transfer personal information we have about you, as necessary, in the event that we sell or transfer all or part of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
Information You Elect to Share: We may share your information with third parties when you engage in certain activities on our Sites that are sponsored by third parties, such as electing to receive information or communications from a third party. When you participate in such, you will either be required or requested to agree that the sponsor or business associate may use your personal information (including, in some cases, your e-mail address) in accordance with the sponsor or business associate’s privacy practices.
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 Privacy Policy. - THE SECURITY MEASURES WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION The security and confidentiality of your personal information is important to us. We maintain reasonable technical, administrative, and physical security measures to protect personal information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or misuse. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite these efforts, no security measures are perfect or impenetrable.
- HOW LONG WE RETAIN PERSONAL INFORMATION To the extent permitted by applicable law, we retain your personal information for the duration of our relationship, plus a reasonable period in order to be able to run regular deletion routines or to take into account the applicable statute of limitation period or to comply with mandatory applicable law. If you have created an account with us, we will delete your account information once your account becomes inactive (i.e., when there has been no user log-in to the account in over 1 year).
- YOUR RIGHTS AND CHOICES We will provide you an opportunity to update your contact information and/or modify your communication choices by sending you an e-mail or other communication that invites your response, or by providing a means to update that information via our Sites. You also may unsubscribe from our e-mail marketing communications by clicking on unsubscribe links in those e-mails. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend, or delete your information, or restrict the processing of such information by contacting us as indicated below. Subject to applicable law, you also have the right to receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us about you, with your consent or based on a contract to which you are party. You have the right to have this information transmitted to another company, where it is technically feasible. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. To ask us to remove your information from our mailing lists, exercise your rights or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Policy.
- DATA TRANSFERS SitusAMC is headquartered in the United States of America. We may share personal information we obtain about you with our affiliates and suppliers in the United States listed under in this Privacy Policy. If SitusAMC is going to transfer personal data to a third-party that is acting as an agent, it will enter into a written agreement with such third-party requiring that the third-party provide at least the same level of privacy protection as is required by the data protection laws applicable to SitusAMC, including the Privacy Shield Principles. In the context of such onward transfer to third-parties of data of EU individuals received pursuant to data transfer agreement or any other mechanism recognised as adequate by the European data protection authorities, SitusAMC is potentially liable if we process such personal information in a manner inconsistent with the terms of such agreement or mechanism.
- INTERNATIONAL DATA TRANSFERS Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice. SitusAMC recognizes its obligation to comply with the requirements of EU Data Protection Law, and, accordingly, any transfer of personal data outside the European Economic Area (EEA) will only be performed in accordance with these requirements, through data transfer agreements or any other mechanism recognised as adequate by the European data protection authorities (the “DPAs”), and only to the extent necessary to the performance of its contractual obligations as an employer or service provider.
In order to ensure compliance with these requirements, SitusAMC continues to maintain the standards set out by the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) and the United Kingdom to the United States, until such time that these standards are amended or replaced by an equivalent mechanism. SitusAMC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, and commits to comply with the Privacy Shield Principles. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. - OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES We may provide links on our Sites to third parties. In addition, third parties may also provide links to our Sites. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-SitusAMC websites, apps or services (whether or not such site is linked on or to our Sites). These links are provided to you for convenience purposes only, and you access them at your own risk. The providers of third-party apps, tools, widgets and plug-ins on our Sites, such as Facebook and Twitter buttons, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, we are not responsible for these providers’ information practices.
- RESOLUTION OF DISPUTES AND COMPLAINT MECHANISM SitusAMC commits to resolve complaints about our collection or use of your personal information in accordance with the Privacy Shield Principles. Individuals in the EU may submit queries related to the processing of their personal information by SitusAMC by contacting us directly at Privacy@situsamc.com, or by writing to us at: SitusAMC, 150 East 52nd St., Suite 4002, New York, NY 10022, USA, Attn: General Counsel. SitusAMC has further committed to cooperate with the European data protection authorities (the “DPAs”) and comply with the advice given by such authorities with regards to unresolved Privacy Shields complaints concerning data transferred from the EU. If we have not been able to successfully resolve your query or complaint and you are based in the EEA, you may raise your query or complaint directly to the DPA. The services of the DPAs are provided at no cost to you. You can find details of the relevant DPA at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. SitusAMC will comply with any advice given by the DPAs, and take necessary actions to remediate any non-compliance with the Privacy Shield Principles. If your inquiry still has not been satisfactorily resolved, you may have other recourse mechanisms such as invoking binding arbitration by the Privacy Shield Panel.
- ENFORCEMENT SitusAMC privacy practices are subject to the jurisdiction of the United States Federal Trade Commission (FTC), and as such SitusAMC is subject to the investigatory and enforcement powers of the FTC.
- YOUR CALIFORNIA PRIVACY RIGHTS California Civil Code Section § 1798.83 permits users of our Sites whom are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to Privacy@situsamc.com or call toll-free at: 1-855-824-9297. You may also write us at: SitusAMC, 150 East 52nd St., Suite 4002, New York, NY 10022, USA, Attn: General Counsel. You may also have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as described in this section of our Privacy Policy. In addition, not all rights in this section of our Privacy Policy is applicable to personal information that constitutes NPI subject to the Gramm-Leach-Bliley Act and our GLBA privacy notice, or processed solely in the business-to-business context, or other data that is exempt from certain requirements of the CCPA.Your Right to Request Disclosure of Information We Collect and Share About YouSitusAMC is committed to ensuring that you know what information SitusAMC collects about you. You can submit a request to SitusAMC for the following information:SitusAMC is also committed to ensuring that you know what information SitusAMC shares about you. You can submit a request to SitusAMC for the following further information:Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.To exercise the right to request the disclosure of Personal Information that SitusAMC collects or shares about you, contact SitusAMC at Privacy@situsamc.com. Requests are typically free of charge.
Your Right to Request the Deletion of Personal Information We Have Collected From You Upon receiving and verifying such request, SitusAMC will delete the Personal Information that SitusAMC has collected about you, except for situations when that information is necessary for SitusAMC to: provide you with a good or service that the client requested; perform a contract SitusAMC entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to SitusAMC or that are reasonably aligned with expectations based on the your relationship with SitusAMC.To exercise the right to request the deletion of your Personal Information, contact us at Privacy@situsamc.com or call toll-free at 1-855-824-9297. Requests for deletion of your Personal Information are generally free.
Our Process for Responding to Requests for Access or Deletion Under the CCPA
Requests for Household Information Please note that certain types of Personal Information may be associated with a household, meaning a group of people living together in a single home. Each member of the household must make requests for access or deletion of household Personal Information. We will then verify each member of the household using verification criteria. If we are unable to verify the identity of each household member to the degree of required certainty, we will not be able to respond to the request. We will notify you to explain the basis of our denial. If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain personal information, depending on the nature of the information you require, which we will endeavor to match with information we may maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will also be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity. Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for specific pieces of personal information To respond to these requests, we will ask you for at least three pieces of personal information and will endeavor to match those to information we maintain about you. Additionally, we require that you provide a declaration attesting to your identity, signed under penalty of perjury. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. In addition, we will treat the request as one seeking disclosure of the categories of personal information we have collected about you and endeavor to verify your identity using the less-stringent standards applicable to such requests.
Requests for categories of personal information To respond to these requests, we will ask you for at least two pieces of personal information and endeavor to match those to information we may maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
Requests for deletion of personal information To respond to these requests, we will ask you for at least two pieces of personal information and endeavor to match those to information we may maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
Non-Discrimination You have a right not to be discriminated against for the exercise of the privacy rights conferred by the CCPA.
Do Not Track Signals Our Sites currently do not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.- The categories of Personal Information that SitusAMC has collected about you.
- The categories of sources where SitusAMC collected the Personal Information.
- The business or commercial purposes for why SitusAMC collected and/or sold the Personal Information.
- The third parties with whom SitusAMC shared the information.
- The specific pieces of information we collected.
- The categories of Personal Information, if any, SitusAMC has sold about you, categories of third parties to whom SitusAMC sold that Personal Information, and the category or categories of Personal Information sold to each category of third party. However, SitusAMC does not and will not sell Personal Information.
- The categories of Personal Information that we’ve shared with third parties for business or commercial purposes.
- CHILDREN Our products and services are not directed to minors under the age of 16 and we do not knowingly collect or sell the Personal Information of minors.
- LIST OF SITUSAMC U.S. SUBSIDIARIES ADHERING TO THE PRIVACY SHIELD PRINCIPLES
o Alan King and Company, Inc.
o AMC Diligence, LLC
o AMC Group Acquisition Corp.
o AMC Holdings, Inc.
o AMC Servicing Solutions, LLC
o American Mortgage Consultants, Inc.
o Baseline Analytics, LLC
o Baseline Holdings, Inc.
o Certainty Title, LLC
o CJC Worldwide Technologies LLC
o DynAMC Solutions, LLC
o Greenwich Street Community Capital LLC
o Hanover Street Capital, LLC
o LogicEase Solutions, Inc.
o MBMS Holding, Inc.
o MBMS Incorporated
o Meridian Asset Services, LLC
o Mountain View Financial Solutions, LLC
o MountainView Analytics, LLC
o MountainView GP III, LLC
o MountainView IPS, LLC
o MountainView Management Company, LLC
o MountainView Public Private Investment I, LLC
o MountainView Real Estate Investments, LLC
o MountainView Risk Advisors, LLC
o MountainView Transaction Advisory, LLC
o Promor Investments, LLC
o Ranieri Partners Asset Management
o RERC, LLC
o Situs Asset Management LLC
o Situs Consulting Solutions LLC
o Situs Group Holdings Corporation
o Situs Group LLC
o Situs Holdings, LLC
o Situs Real LLC
o Situs Technologies, LLC
o SitusAMC Holdings Corporation
o SitusCO LLC
o SPT Commercial Mortgage LLC
o String Real Estate Information Services, LLC
o STS Structured Products LLC
o TechEssential, LLC
o The Collingwood Group, LLC
- AMENDMENTS TO THIS ONLINE PRIVACY POLICYThis Privacy Policy may be updated periodically to reflect changes in our personal information processing practices. We will indicate at the top of the Policy when it was most recently updated.
- CONTACT US To ask us to remove your information from our mailing lists, exercise your rights or submit a request, or have any questions or comments about this Privacy Policy, please email us at Privacy@situsamc.com or call toll-free at: 1-855-824-9297.
