Privacy Policy

Effective Date: 12/7/2023

Thank you for visiting Plaza West Covina’s web site (the “Site”), brought to you by Pacific Retail Capital Partners (“we” or “us”). We provide this Privacy Statement to highlight our policy with regard to the privacy of information we may gather through your use of this Site. The policies contained in this Privacy Statement are incorporated by reference in the Terms of Use (“Agreement”).

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION
In order to use certain services provided on the Site, such as our site surveys and our customer relationship program (collectively the “Site Services”), or participate in contests or promotions, you will be required to register with us. In order to register, you will be required to provide certain personally identifiable information, such as your first and last name, postal address, and email address, and possibly volunteer certain other information, such as your birth date, gender, marital status, number of children and some personal preferences, on a page that will request such information (“Registration Profile Page”). If you are unwilling to disclose the required information in connection with your registration, you will still be able to access those portions of the Site available to non-registered users of the Site.You must be 13 or older to register with the site. The United States Children’s Online Privacy Protection Act went into effect on April 21st, 2000. In order to comply with that law, the mall will not knowingly process any data that was submitted to us by a visitor who is under 13 years of age.By completing the Registration Profile Page you have indicated that you are interested in receiving information on special offers and promotions, and we may send you such information by email or regular mail. In addition, we may share user information with affiliate businesses and third parties that we believe are reputable to offer products and services that may be of interest to you.If you also registered to participate in additional surveys, you may also receive surveys on a variety of topics sent to you via e-mail or direct mail.When you visit the Site, our server may place small temporary text files called “cookies” on your computer’s processor or in the browser directory of your hard drive. These cookies may contain a unique identifier that enables us to personalize your visit to the Site and create a better experience for you. For example, when you access the Site, a cookie will enable us to provide you with information on the Pacific Retail Capital Partners centers closest to you. You may choose not to accept cookies by setting your web browser to either refuse all cookies or to notify you each time before a cookie is set. If you choose to refuse cookies, however, you may not be able to use all the features of the Site, including but not limited to the site services, contests, and promotions. Even after you have become a registered user, you may later choose not to receive such information from us by sending an email to info@pacificretail.com. If you Opt Out, you will no longer receive such special offers and information from us, and will not be able to participate in contests or promotions. This Privacy Statement does not, however, apply to other Internet websites that are not under our control (“Third-Party Websites”), or to other third parties; you should contact such entities directly regarding their use of your information.

PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
We do not make available to the general public any personally identifiable information you provide to us in connection with your registration on the Site. We use industry standard technology and efforts to safeguard the confidentiality of your personal identifiable information. These include secure servers and firewalls. All of the user data we collect is protected against unauthorized access. Only authorized employees who need the information to perform a specific job are granted access to this information.

CHANGES TO YOUR PERSONALLY IDENTIFIABLE INFORMATION; YOUR ABILITY TO CORRECT INACCURACIES
To make changes to your personal information you must send an email toInfo@pacificretail.com. Following such correspondence a representative of the mall’s web site will contact you to arrange for the appropriate changes to your personal information profile.

LINKS TO THIRD-PARTY SITES
The Site provides links to Third-Party Websites that are not under our control. Also, if you click on a banner advertisement that appears on one of the pages of the Site, you may be transported to a Third-Party Website and away from this Site. THIS PRIVACY STATEMENT APPLIES TO THIS SITE ONLY, AND IS NOT INTENDED TO DESCRIBE THE PRIVACY POLICIES OF THIRD-PARTY WEBSITES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION; WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF THIRD-PARTY WEBSITES. IF YOU CLICK ON A BANNER ADVERTISEMENT OR A LINK TO A THIRD-PARTY WEBSITE, YOU SHOULD REVIEW THE Privacy Statement OF SUCH THIRD-PARTY WEBSITE, IF ANY, TO DETERMINE THAT SITE’S PRACTICES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION. Any link on the Site to a Third-Party Website does not imply an endorsement of the privacy practices of such Third-Party Website by us, and no such Third-Party Website is authorized to make any representation or warranty on our behalf.

NON-PERSONALLY IDENTIFIABLE INFORMATION
During your visit to the Site, we may ask for certain anonymous, non-personally identifiable information, such as your zip code, age, gender, consumer preferences, and the like. Such information is used to gain a better understanding of usage trends and we provide it to third parties for their general marketing research purposes. We may use your Internet Protocol (“IP”) address to help diagnose problems with our server, and to administer the Site. We may use IP addresses to gather non-personally identifiable demographic information, such as how many users visited a certain part of the Site, but not to track a specific IP address to the identity of an individual user.

THIS PRIVACY STATEMENT MAY CHANGE
This privacy statement may change from time to time. Pacific Retail Capital Partners reserves the right to change it without notice to you, so you should review it periodically.

CAPTIVE PORTAL OPT-IN POLICY & TERMS Plaza West Covina is committed to protecting your privacy and complying with all applicable laws in collecting and processing personal information. This Privacy Policy explains how personal information about you is collected, used, shared, stored and secured by Plaza West Covina (collectively referred to as the “Property,” “we,” “our” and “us”) when you use our complimentary Wi-Fi (the “Service”). This Privacy Policy also explains your choices regarding your personal information. WHAT INFORMATION WE COLLECT We may collect one or more of the following categories of information about you when you sign up and use our Service. The specific types of information included in each of these categories are described in more detail below.

CATEGORY OF PERSONAL INFORMATION COLLECTED	PERSONAL INFORMATION COLLECTED	SOURCES OF PERSONAL INFORMATION	BUSINESS PURPOSE FOR COLLECTION OF PERSONAL INFORMATION
Identifiers	Name (first and last), alias, zip code, telephone number, email address, unique personal identifier, online identifier, IP address.	Directly from you when you register to use our Wi-Fi; cookies.	Provide our Service, identification, communications, security, legal, compliance and regulatory obligations, marketing purposes.
Internet or other electronic network activity information	Access history, browsing history, search history.	Your device; cookies.	Improve and enhance our Service, security, legal, compliance and regulatory obligations.
Geolocation data	Physical location.	Your device; cookies.	Provide our Service, security, legal, compliance and regulatory obligations, marketing purposes.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	We may create a profile regarding your interests.	Marketing purposes

HOW WE USE YOUR INFORMATION
We use information about you to provide the Service to you, to communicate with you in connection with your use of the Service and/or requests for information, to market and promote the retailers, events, and activities offered at our Property, and to maintain and operate the Service, as follows:

To Provide the Service to You. We use your personal information to provide you with access to Wi-Fi including for example, your IP address.
To Communicate with You. We may use your personal information to communicate with you, regarding your use of our Wi-Fi including in providing support through our telephone, email and chat support channels, and in responding to your requests for information, questions and comments.
To Inform You of Offerings. We use your personal information to communicate with you about offers from retailers at our Property. We may contact you with news, offers, promotions, events, activities, and information we believe may be of interest to you based on the items you expressed interest in when you sign up to use our Wi-Fi. We may also inform you generally of items we believe may be of interest to all of the Property’s visitors and patrons.
To Maintain, Monitor and Secure the Service. We may use certain personal information to monitor and analyze trends, usage and activities in connection with our Service; to monitor, detect, investigate and/or prevent suspicious, fraudulent, unauthorized or illegal activity; and to secure the Service and communicate with you regarding any security incidents.
For Legal and Compliance Purposes. We may use your personal information as reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, and (b) enforce our agreements, policies and terms of service, or to exercise or defend any legal claims.

COOKIES & TRACKING TECHNOLOGIES
When you use the Service, we will collect and store necessary cookies in order to facilitate user access, local storage, and performance. These cookies cannot be disabled and are required in order to provide the Service. We do not utilize any non-essential cookies, such as analytical or targeting cookies.

Do Not Track. Our Service is not designed to respond to “do not track” requests from browsers.

HOW WE SHARE YOUR INFORMATION
We may share your personal information as discussed below. However, we do not sell your personal information to third parties.

With Service Providers. We work with third parties which may require access to information about you to perform their services on our behalf. Our service providers include our Wi-Fi manager vendors, our CRM platform vendor, our retail partners, and our advertising partners which include social media sites like Meta.
With Business Partners and Affiliates. We may share information about you with our business partners and affiliated entities.
With Your Consent. We may share information about you with third parties if you give us consent to do so.
For Legal and Compliance Purposes. We may share information about you with a third party if we believe that sharing such information is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, or to exercise or defend any legal claims, (c) protect the security or integrity of business, or (d) protect our customers, employees or other persons from harm or illegal activities.
Business Transfers. We may share your information in the event of a merger, acquisition, bankruptcy or other transaction in which a third-party assumes control of all or part of our business.

HOW WE STORE AND SECURE YOUR INFORMATION
The security of all personal information provided to us is important and we take reasonable steps designed to protect your personal information. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

RETENTION OF PERSONAL INFORMATION
We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including marketing purposes, as well as for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

YOUR CHOICES & RIGHTS
Depending upon where you are located, certain choices and rights may be available to you under applicable data protection laws, including the right to request access to your personal information or to have your personal information deleted. You may also unsubscribe from communications from us by using the “unsubscribe” link in the email you receive or replying “STOP” to a text communication.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, (collectively, the “CCPA”) provides California residents and/or their authorized agents with specific rights regarding the collection and storage of their personal information.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

The categories of personal information we have collected about you.
The categories of sources for the personal information we have collected about you.
The specific pieces of personal information we have collected about you.
Our business or commercial purpose for collecting or selling your personal information.
The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.

Sale or Sharing of Personal Information: California residents have the right to opt-out of the sale of their personal information. Please note that we do not sell or share personal information to third parties for purposes of cross-context behavioral advertising or profiling.

Sensitive Personal Information: We do not collect, use or disclose sensitive personal information for the purpose of inferring characteristics about individuals.

Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our third-party service providers to delete, your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.

Your Right to Correct: Under the CCPA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.

Notice of Financial Incentive: In exchange for providing your personal information, we provide you use of our complimentary Wi-Fi. This may constitute a financial incentive under the CCPA, and the benefit of the use of our Wi-Fi is reasonably related to the value of the personal information we collect. You may choose not to participate by simply not providing us your personal information or using our complimentary Wi-Fi.

“Shine the Light” and “Eraser” Laws: Residents of California may request a list of all third parties to whom we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

THIRD-PARTY LINKS
We may provide links to other websites or resources provided by third parties. These links are provided for your convenience only. We have no control over the content of those websites and this Privacy Policy does not apply to information collected through such websites. We recommend that you review the privacy policy of any website you visit to determine how the operator handles personal information collected through its website.

CHILDREN
Our Service is not intended to be used by individuals under the age of 13, and we do not knowingly collect personal information from children under 13. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide us with personal information. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.

CHANGES TO OUR PRIVACY POLICY
This Privacy Policy is effective as of the date stated at the top of this page. We may change this Privacy Policy from time to time. By accessing and using our Service after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

CONTACT US
If you have any questions regarding this Privacy Policy, our would like to exercise your outlined rights, please contact us at:

Plaza West Covina
112 Plaza Drive
West Covina, CA 91790
626.960.8032
info@plazawestcovina.com

If you believe that Pacific Retail Capital Partners has in some way not complied with the policies outlined in this Privacy Statement, or if you have any other questions relating to privacy, please let us know by sending an e-mail message detailing your concern to info@pacificretail.com. Our regular mail and phone contact information is:

Pacific Retail Capital Partners
2029 Century Park East, Suite 1550
Los Angeles, CA 90067
310.641.8060