PRIVACY POLICY

Last Updated: October 1, 2024 

This Privacy Policy applies to personal information about you that Curbline Properties Corp. (“Curbline,” “we,” “our,” or “us”) may obtain when you visit https://www.curbline.com (the “Website”), to connect with the Curbline Portal for tenants (the “Portal”) available on our Website, or visit our properties. 

Summary and Notice at Collection 

Our Privacy Policy outlines how we collect, use, share, and protect personal information. We typically collect personal information, such as your name, email address, phone number, and other information provided by you. We also use tracking technologies to obtain various data types regarding how you interact with our website and online services. We primarily use this personal information to provide and improve our services, to communicate with you, and to comply with legal obligations. In compliance with applicable laws, Curbline will not sell your personal information or share it for cross-context behavioral or targeted advertising purposes without providing you a chance to opt out. We will keep your personal information as long as necessary to achieve the objectives for which it was collected, unless a longer retention period is mandated or allowed by law. Please continue reading below for more details. 

Personal Information We Collect 

Personal information is information that can identify you directly, or indirectly in combination with other information. We currently collect, and, in the last 12 months, we have collected, used, or disclosed the following types of personal information. 

1. Identifiers and Non-Public Personal Information
   These may include your name, contact information (including business contact details), online identifier, IP address, email address, or other similar identifiers. Please note that your IP address may permit us to identify your general geolocation.
   
2. Customer Account Details / Commercial Information
   These may include records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
   
3. Internet Activity Information
   This may include browsing history and information regarding your interaction with our Website, Portal, or advertisements. 

Curbline typically will not collect sensitive personal information. When you provide such information to us – for example, if you include it in an email to us or we collect sensitive information from you as a job applicant – we only use it for legally permitted purposes. 

How We Collect Personal Information 

Personal Information You Provide. We obtain information from you directly when you interact with the Website or Portal (for example, when you use our contact form, sign up for investor alerts, send a message to investor relations, or create a tenant account). This information may include identifiers and non-public personal information. You may also give us your personal information when you visit one of our properties, such as if you complete an in-person survey or complaint form. 

Personal Information Collected Automatically. We use various tools and technologies like cookies and web server logs to collect information automatically on the Website and in the Portal. The personal information collected this way may include internet activity information, such as IP addresses, device identifiers, browser characteristics, operating system details, internet service provider details, language preferences, referring URLs, time and length of visits, and pages viewed. 

“Cookies” are small data files stored by your web browser on your computer. Cookies may allow a website to recognize a user’s device, record user preferences, track the pages a user clicks on while visiting a website, and identify the website visited immediately beforehand. Most web browsers accept cookies by default, but you may be able to adjust your browser settings to remove or reject cookies. Please note that blocking cookies may affect the availability and functionality of this Website, our Portal, and other websites or online services. Also, disabling cookies may invalidate opt-outs that use cookies to recognize devices that have opted out. 

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Website and Portal are not yet designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit www.allaboutdnt.com. 

Please note that we or third parties may collect personal information about your online activities over time and across different devices when you use our Website or Portal. 

Personal Information Collected from Other Parties. Our vendors may share with us your personal information that you submit to them. When you submit information to another party, you are subject to that party’s terms of use and privacy policies, for which we are not responsible. 

Use of Personal Information 

We may use any personal information we collect for various business and commercial purposes including: 

• Facilitating and personalizing your user experience, including allowing you to review your sales and payment history through the Portal; 
• Communicating with you, including to respond to your requests or inquiries; 
• Processing your transactions, including electronic payments through the Portal; 
• Marketing and conducting contests and processing prizes; 
• Monitoring and analyzing trends, usage, and activities of our visitors and users; 
• Improving the Website and Portal; 
• Preventing, investigating, identifying, or taking any other action with regard to any suspected or actual fraudulent or illegal activity or activity that violates our policies; 
• Complying with applicable laws, regulations, or legal process as well as industry standards and our company policies; or 
• Any other purpose, with your consent. 

Disclosing Personal Information 

We may disclose any of your personal information to our subsidiaries, affiliates, business partners, and vendors that provide services on our behalf. 

In the event of a business transaction, such as if we sell or transfer all or a portion of our business or assets (for example, as part of a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions), we reserve the right to disclose any personal information. 

Additionally, Curbline may disclose any personal information when required by subpoena, search warrant, or other legal processes; in response to activities that are unlawful or a violation of Curbline’s rules, policies, or terms; or to protect and defend our rights or property. 

Where restricted by applicable law, Curbline will not sell personal information or share it for cross-context behavioral or targeted advertising purposes without providing you the opportunity to opt out. Curbline does not currently sell or share personal information in this way. 

Analytics and Advertising 

We use web analytics services, primarily certain Google Analytics services, to help us understand and analyze how visitors use the Website and Portal. For example, we and our vendors may employ cookies and other tracking technologies to measure the performance of our Website or Portal and to understand the interests of visitors to our Website or Portal. 

For more information on how Google Analytics uses data, visit https://policies.google.com/technologies/partner-sites. To opt out of Google Analytics cookies, visit: https://tools.google.com/dlpage/gaoptout/. 

Please note that we do not control how other parties manage their opt-out processes. 

Sweepstakes, Contests, and Similar Promotions 

We may operate sweepstakes, contests, raffles, and similar promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting personal information. 

Each Promotion is governed by its own terms, and the specific financial incentive offered, if any, will be detailed in such terms. If you choose to participate in a Promotion, your personal information may be disclosed to third parties as described in the terms applicable to that Promotion. Insofar as the terms applicable to a particular Promotion conflict with this Privacy Policy, the terms applicable to the Promotion will control. 

Links to Other Websites 

Our Website and Portal may include links to other websites that are not owned or operated by Curbline. This Privacy Policy does not apply to those websites, which may have their own privacy policies or notices that you should review to understand how they may collect, use, or disclose your personal information. Curbline is not responsible for the content or privacy practices of any linked websites that it does not control. 

The Website and Portal also may provide links to other websites operated by Curbline or our subsidiaries, brands, or affiliates. Unless indicated otherwise, these websites are not governed by this Privacy Policy. We encourage you to review the privacy policies posted on these linked websites. 

Security and Retention 

We take reasonable measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. 

We retain personal information as permitted or required by law. Generally, this means that we keep your personal information for as long as we need it for a purpose you have been made aware of, such as those purposes described in this privacy policy, including when the personal information is reasonably necessary to: 

• manage our business operations or your relationship with us; 
• carry out a disclosed purpose or for another purpose that is reasonably related to any disclosed purpose; or 
• protect or defend our rights or property or those of another person or business. 

If you have questions about our personal information retention practices, you may contact us using the contact information at the end of this Privacy Policy. 

Your Choices 

Communication Preferences and Marketing. If you do not wish to receive marketing emails from us, you can opt out of future marketing emails by following the instructions provided in our marketing emails or by emailing us at privacy@curbline.com or calling us toll-free at 833-614-1213. Opting out of marketing emails will not affect our administrative emails to you (for example, emails about your tenancy). 

Changing Your Personal Information. Registered users can review and change certain personal information (for example, email, password, phone number, physical address) anytime by accessing their account via the Portal. Others may contact us at privacy@curbline.com or toll-free at 833-614-1213 to request changes. 

Privacy Rights. Residents of certain states, such as California and Texas, have legal rights related to their personal information. If you are a resident of a state that provides these rights, and we are subject to the applicable law, you may ask for the following: 

• Access to your personal information in our possession; 
• Information about your personal information, including the categories of sources that provided the personal information to us or to whom we disclose personal information; 
• The deletion of the personal information we collect directly from you; and/or 
• The correction of your inaccurate personal information. 

You may use an authorized agent to submit requests. We will not discriminate against any anyone for exercising their legal rights. 

To submit a privacy rights request to us, contact us via email at privacy@curbline.com, by phone toll-free at 833-614-1213, or by mail at ATTN: Privacy Dept., 3300 Enterprise Parkway, Beachwood, OH 44122. Please include your name and contact information in any rights request to us, so that we may communicate with you and to help us verify your identity before acting on your request. 

We may be required to verify your identity prior to taking action on your privacy rights request, and we may need additional information from you to process your privacy rights request. Please follow any instructions provided and promptly respond to any follow-up inquiries. If you request that we provide you with specific pieces of personal information about you, we may apply heightened verification standards. If we deny your request, we will tell you why, and you may request that we re-consider out decision be replying to any communication from us. 

California’s Shine the Light Law 

California law permits “customers” in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates if that personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@curbline.com or toll-free at 833-614-1213. 

Please note that California consumers’ privacy rights and “Shine the Light” rights exist under different legal regimes, so you must exercise your rights under each law separately. 

Information for Users Outside the United States 

If you are visiting our Website or using our Portal from outside the United States, please be aware that personal information we obtain about you will be processed in the United States and may be processed in other jurisdictions. By using the Website or Portal, you acknowledge your personal information may be transferred to and processed in a jurisdiction outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States may be different from the laws in your country of residence. 

Revisions 

This Privacy Policy is subject to change at our discretion. We will indicate changes to the Privacy Policy by updating the “Last Updated” date at the beginning of the Privacy Policy. 

Contact Information 

You may send comments or questions regarding this Privacy Policy or our privacy practices via email to privacy@curbline.com.