Harmony Housing Affordable Development Inc.
Client Privacy Notice
Last modified: 01/02/2024
Harmony Housing Affordable Development Inc. is an industry-leading affordable housing developer that constructs and preserves thousands of multifamily rental units annually, which provides homes for individuals and low-wealth family residents. Harmony Housing Affordable Development Inc. and its parent, subsidiaries, and other affiliate entities (“Harmony,” “we,” “our,” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.
This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect, use, maintain, protect, disclose, or otherwise process about you when you when you apply for or obtain, or we otherwise service investments, development services, construction management services or asset management services from Harmony (“Financial Products and Services,” “Financial Products or Services,” or individually, a “Financial Product or Service”), or when you access our websites [address for HHAD] and [address for Harmony Housing] (each, a “Website”), and our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information.
This policy applies to information we collect:
- when you apply for a Financial Product or Service or when we service such an account;
- in email, text, phone, and other electronic messages between you and us related to the Financial Products and Services; and
- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Except as described in this Privacy Notice, it does not apply to information collected by:
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
- any third party (including our affiliates, and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Websites or that you otherwise may provide your Personal Information to.
Please read this Privacy Notice 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, your choice is not to use any Financial Product or Service or our Websites. By accessing or using our Financial Products or Services or our Websites, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice ). Your continued use of any Financial Product or Service or our Websites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.
2. Children Under the Age of 18
Our Financial Products or Services and Websites are not intended for children under 18 years of age. No one under age 18 may provide any information in relation to any Financial Product or Service or to or on the Websites. We do not knowingly collect Personal Data (defined below) from children under 18. If you are under 18, do not use any Financial Product or Service or use or provide any information on our Websites or on or through any of its features, including your name, address, telephone number, or email address. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us through the contact information below.
3. Information We Collect About You and How We Collect It
Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information.
We collect Personal Data from various sources, including:
- directly from you when you provide it to us, including when you fill out forms to obtain a Financial Product or Service;
- automatically as you navigate through the Websites;
- information that we create about you when you apply for, obtain, or otherwise use a Financial Product or Service and as you use our Websites; and
- From third parties, for example, our business partners such as credit reporting agencies and payment processors.
Information You Provide to Us
We collect the following types of Personal Data directly from you when you apply for, obtain, or otherwise use a Financial Product or Service or otherwise access or use our Websites: real name, alias, postal address, unique personal identifier (such as a loan number or other account number), email address, work telephone number, social security number, drivers’ license or other state-issued ID number, insurance information, title, employer name, age, birthdate, records of goods and services purchased, obtained, or considered to be purchased or obtained (like property address, parcel number, property type, type of Financial Product or Service desired or obtained, and other similar information) and any other identifier by which you may be contacted online or offline. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.
We collect the Personal Data through:
- information that you provide by filling in forms to obtain a Financial Product or Service that you upload to the Websites or other forms on the Websites. This includes information provided at the time of registering to use our Websites. We may also ask you for information when you report a problem with our Website or your use of our Financial Products and Services;
- if you contact us, records and copies of your correspondence (including email addresses);
- details of transactions you carry when you use a Financial Product or Service. You may be required to provide financial information before obtaining a Financial Product or Service.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Websites, including information about your equipment, browsing actions, and patterns. This includes:
- details of your visits to our Websites. This includes browsing history, search history, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on the Websites;
- your preferences regarding your use of our Websites, such as language, contrast, font size, and other similar information;
- your general geographic location based off of IP addresses (i.e., town, city, state); and
- information about your computer and internet connection, i.e., your IP address, operating system, platform type, browser type, browser language. If you use a mobile device to access our Websites, this may also include your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and mobile device’s advertising ID (some of this information may be subject to your consent and/or the permissions settings on your device).
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences;
- secure our Websites and our customers’ accounts;
- customize our Websites according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Websites.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Harmony, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
Information We Create About You
We may also create certain information about you. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: records of real property or Financial Products or Services purchased, obtained, or considered by you and Financial Product or Service balance and payment history.
Information We Collect from Third Parties
We may collect Personal Data from third parties, such as credit reporting agencies, title companies, and real property recording offices and other government entities. We may also supplement your business contact information with information from other third party sources in order to verify your identity or to enrich what we know about you or your company through business intelligence services. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, alias, postal address, unique personal identifier (such as a loan number or other account number), email address, telephone number, social security number, drivers’ license or other state-issued ID number, insurance information, title, employer name, age, birthdate, records of Financial Products and Services purchased, obtained, or considered to be purchased or obtained, credit history, credit score, other credit check information, title history and title recording information, and any other identifier by which you may be contacted online or offline.
When you interact with our Websites or accounts on a social media platform (a “Social Media Platform”), we may collect the Personal Data that you or the Social Media Platform makes available to us on that page or account. This may include your account ID and/or user name associated with that Social Media Platform, your profile picture, email address, friends list, or information about the people and groups you are connected with and how you interact with them, and any other information you have made public in connection with that Social Media Platform. The information we collect from a Social Media Platform depends on your privacy settings on that Social Media Platform; we will comply with the privacy settings of each Social Media Platform and only collet and store such Personal Data that we are permitted to collect by those Social Media Platforms. When you access our Websites through Social Media Platforms or when you connect a Website to a Social Media Platform, you are authorizing us to collect, store, and use such Personal Data and other content in accordance with this Privacy Notice.
4. How We Use Your Information
We use Personal Data that we collect about you or that you provide to us:
- to provide and personalize our Websites and their contents to you;
- to provide you with information about our Financial Products and Services that you request from us;
- to provide you with answers to your questions about our Financial Products and Services;
- to review your application for a Financial Product or Service;
- to provide you with the Financial Product or Service you request from us (when applicable);
- to service the Financial Product or Service you obtain from us;
- to support, develop, troubleshoot, and debug our Websites and other Financial Products or Services;
- to create, maintain, customize, and secure your Financial Product or Service account with us;
- to provide you with notices and other information about the Financial Products or Services you use, including invoices, expiration, and renewal notices;
- to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- to help maintain the safety, security, and integrity of our Websites, Financial Products or Services, databases and other technology assets, and business;
- for internal testing, research, analysis, and product development, including to develop and improve our Websites and a Financial Products or Services;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- debugging to identify and repair errors that impair existing intended functionality of our Websites;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Websites or any Financial Product or Service we offer or provide;
- to meet our legal obligations, such as to pay our taxes, ensure compliance with “know your customer” requirements, and other similar requirements;
- to manage portfolio risk;
- to allow you to participate in interactive features on our Websites;
- in any other way we may describe when you provide the information;
- to fulfill any other purpose for which you provide it; and
- for any other purpose with your consent.
We may also use your Personal Information to contact you about our own Financial Products and Services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.
5. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business. The services these entities provide include IT and infrastructure support services (including web hosting and email delivery), postal/courier delivery services, analytics. services, marketing and advertising services, titling and government records services, payment processing services, and collection services;
- to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Harmony’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Harmony about our users of our Websites and/or any Financial Product or Service is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, if you give us insurance information, we will use such information to verify your insurance and to notify your insurance company about any loans on your insured items related to your use of our Financial Products or Services.
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Harmony, a dealer, our or their customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Choices About How We Use and Disclose Your Information
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- 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. If you disable or refuse some cookies, please note that some parts of our Websites may then be inaccessible or not function properly.
- Promotional Offers from Harmony. If you do not want us to use your contact information to promote our own products and services, you can opt-out by checking the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by contacting us through the contact information below and stating your request. If we have sent you a promotional email, you may click the unsubscribe link in the body of that email to be omitted from future email distributions. This opt out does not apply to information provided to Harmony as a result of obtaining a Financial Product or Service, customer service experience or other transactions, including any use to process your application for, provide you with, or service any Financial Product or Service.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
7. Accessing, Correcting, and Deleting Your Personal Data
You can review and change some of your Personal Data by logging into the Websites and visiting your account profile page to the extent applicable.
You may also contact us at the contact information below or shown on any invoice related to your Financial Products or Services to request access to, correct or delete any Personal Data that you have provided to us. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
8. Do Not Track Signals
We may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
9. Data Security
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Websites.
10. Consent to Processing of Personal Data in the United States
In order to provide our Websites and Financial Products or Services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Websites or a Financial Product or Service, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.
Your Personal Data is transferred by Harmony to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party, Harmony uses Data Protection Agreements between Harmony and all other recipients of your Personal Data when required by applicable law.
11. Changes to Our Privacy Notice
We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page with a notice that the Privacy Notice has been updated on the Websites’ home page or in an invoice. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account, through a notice on the Websites’ home page, or as an insert in an invoice. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Notice to check for any changes.
YOUR CONTINUED USE OF OUR WEBSITE OR OUR FINANCIAL PRODUCTS OR SERVICES FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.
12. Contact Information
If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Websites.
Postal Address: Harmony Housing Affordable Development Inc.
152 East 57th Street, 60th Floor
New York, NY 10019