PRIVACY POLICY

Panco Management of New Jersey, LLC, d/b/a Panco Management, and its subsidiaries and affiliates (referred to herein as “Panco Management”, “we”, “us”, or “our”) respect your privacy and are committed to protecting it through our compliance with this Policy. We adopt this Policy to comply with applicable data privacy and security laws, including the Virginia Consumer Data Protection Act (CDPA), and any terms defined in the CPDA have the same meaning when used in this Policy.

This Policy describes the types of information we collect from you or that you may provide when you visit the website https://www.pancomanagement.com (our “website”), or any of the websites Panco Management manages which include a link to this Policy, and our practices for collecting, using, maintaining, protecting, and disclosing that information.  The Policy applies to information we collect on this website, in email, text, and other electronic messages between you and this website, 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.  It does not apply to information collected by us offline or through any other means, including on any other website operated by any third party (including our subsidiaries and affiliates) or any third party, including through any application or content (including advertising) that may link or be accessible from or on the website.

Please read this policy 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 our website. By accessing or using this website, you agree to this Policy.  This Policy may change from time to time (see Changes to Our Privacy Policy).  Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Panco Management recognizes the importance of protecting the privacy of individual-specific information collected from our website users. Our website collects 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 consumer, household, or device (“personal information”).

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

Personal information collected from our website includes the following categories:

  • Contact Information. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Other Personal Identifiers. A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Demographic Information. Such as age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran, or military status, in each case subject to applicable laws. In certain jurisdictions, you may also choose to share with us any disabilities or other health-related restrictions so that we can provide you with adequate accommodations.
  • Commercial information. Products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, and rent amount.
  • Internet or other similar network activity. Browsing history, search history, IP address, operating system, browser type, cookie identification number, information on a consumer’s interaction with a website, application, or advertisement, and device type.
  • Correspondence. Records and copies of your correspondence (including email addresses) and responses to surveys, if you contact us, as well as your search queries
  • Geolocation data. Physical location or movements.
  • Sensory data. Audio, electronic, visual, or similar information.
  • Professional or employment-related information. Education, employment history, job title, other CV information, pay history and income.
  • Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Our website obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you when you provide it to us. For example, from forms, inquiries, or applications you complete on the website.
  • Indirectly from you, automatically as you navigate through the website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our website and its contents to you.
  • To provide you with information, products, or services that you request from us. To fulfill any other purpose for which you provide it.
  • To provide you with notices about your rental agreement, including expiration and renewal notices.
  • 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 website or any products or services we offer or provide though it. In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

USE OF PERSONAL INFORMATION

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about a residential community we manage, we will use that personal information to respond to your inquiry. If you become a resident of a residential community we manage and you provide your personal information to make payments for rent and other services, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate subsequent rental payments.
  • To communicate with you about our properties and promotions and conducting surveys about your experience.
  • To deliver remarketing or retargeting display advertisements to you using third-party vendors.
  • To provide, support, personalize, and develop our website and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • 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 website, products and services, databases and other technology assets, and businesses.
  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our consumers and information that does not identify any individual without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

WE MAY ALSO DISCLOSE YOUR PERSONAL INFORMATION:

•  To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

•  To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

•  If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Panco Management, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

SHARING PERSONAL INFORMATION

We may share your personal information by disclosing it to a third party for business purposes. We only make such business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We do not sell personal information.

PURPOSE FOR SHARING PERSONAL INFORMATION

Marketing. Customer development, Customer support

Internet or other similar network activity. Marketing, Customer development, Customer support

Correspondence. Marketing, Customer development, Customer support

Geolocation data. Marketing, Customer development, Customer support

Professional or employment-related information.  Marketing, Customer development, Customer support

HOW WE USE AND DISCLOSE YOUR INFORMATION

Applicable data privacy laws provide consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

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 cookies, please note that some parts of this website may then be inaccessible or not function properly.

Promotional Offers from the Company. If you do not wish to have your email address/contact information used by Panco Management to promote our third parties’ products or services, you can opt-out by sending us an email stating your request to Privacy@pancomgt.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Panco Management as a result of a rental agreement or other transaction.

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.

CHILDREN UNDER THE AGE OF 16

Our website is not intended for children under sixteen (16) years of age. No one under age sixteen (16) may provide any personal information to or on the website. We do not knowingly collect personal information from children under sixteen (16). If you are under sixteen (16), do not use or provide any information on this website or through any of its features, register on the website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under sixteen (16) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under sixteen (16), please contact us at Privacy@pancomgt.com.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights under the Policy and applicable law. Unless permitted by the law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of goods and services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods and services.

VIRGINIA RESIDENTS: YOUR VIRGINIA PRIVACY RIGHTS

Data We Collect and Process

We collect and process your personal data as follows:

  1. We collect and process the categories of personal data identified below (which are more fully described above):
  2. Contact Information,
  3. Other Personal Identifiers,
  4. Demographic Information,
  5. Commercial information,
  6. Internet or other similar network activity,
  7. Correspondence,
  8. Geolocation data,
  9. Sensory data,
  10. Professional or employment-related information, and
  11. Inferences drawn from other personal information.

2. We collect and process the data identified above for the following purposes:

  • marketing,
  • customer development,
  • customer support,
  • to support our business,
  • to fulfill the purpose for which you provide personal information or date,
  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request,
  • to enforce or apply our terms of use and other agreements, including for billing and collection purposes,
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Panco Management, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and
  • for any other purpose disclosed by us when you provide the information.

3. We share the categories of personal data described in subparagraph one (1) above with third parties; and

4. We share personal data with the following categories of third parties: our subsidiaries, affiliates, contractors, service providers, governmental entities and agencies, and other third parties we use to support our business and as required by law or legal process.

Personal Consumer Data Rights

Pursuant to the Virginia Consumer Data Protection Act, you have the following rights: 

  1. You have the right to confirm whether or not we are processing your personal information and to access such personal data;
  2. You have the right to correct inaccuracies in your consumer personal data, taking into account the nature of the personal data and the purposes of the processing of your consumer personal data;
  3. You have the right to delete personal data provided by or obtained about you;
  4. You have the right to obtain a copy of your consumer personal data that you previously provided to Panco Management in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
  5. You have the right to opt-out of any processing of personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

In connection with the above described rights, please be advised that Panco Management does not sell personal information of consumers.

How to Submit Your Consumer Data Rights Request

You may submit your consumer data rights request to us in writing by submitting your request to Privacy@pancomgt.com.

Response Timing and Format

We will confirm receipt of your consumer data rights request within ten (10) business days.  If you do not receive confirmation within the 10-day timeframe, please email Info@PancoMgt.com.

We endeavor to substantively respond to a verifiable consumer data rights request within forty-five (45) days of its receipt.  If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.

If we decline to take action regarding your request, we will inform you within 45 days of receipt of the request of the justification for declining to take action and instructions for how to appeal the decision.

If we are unable to authenticate your request using commercially reasonable efforts, we will not be able to comply with your request to initiate an action and we may request that you provide additional information reasonably necessary to authenticate your identity and your request.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We will not charge a fee to process or respond to your verifiable consumer data rights request unless it is excessive, repetitive, or manifestly unfounded in adherence with Virginia Consumer Data Protection Act.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Appealing a Consumer Data Rights Decision

You have the right to appeal our decision regarding your consumer data rights request if we refused to take action on your request.  You may submit your appeal request by contacting us at Privacy@pancomgt.com, include “Appeal” in the subject line.  Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General of Virginia at https://www.oag.state.va.us/ or by calling 1-800-552-9963 or (804) 786-2042 to submit a complaint.

Exemptions 

The following information and data is exempt from the Virginia Consumer Data Protection Act:

1. Protected health information under  the Health Insurance Portability and Accountability Act(“HIPAA”);

2. Health records for purposes of Title 32.1;

3. Patient identifying information for purposes of 42 U.S.C. §290dd-2;

4. Identifiable private information for purposes of the federal policy for the protection of human subjects under 45 C.F.R. Part 46; identifiable private information that is otherwise information collected as part of human subjects research pursuant to the good clinical practice guidelines issued by The International Council for Harmonisation

of Technical Requirements for Pharmaceuticals for Human Use; the protection of human subjects under 21 C.F.R. Parts 6, 50, and 56, or personal data used or shared in research conducted in accordance with the requirements set forth in this chapter, or other research conducted in accordance with applicable law;

5. Information and documents created for purposes of the federal Health Care Quality Improvement Act of 1986 (42 U.S.C. §11101 et seq.);

6. Patient safety work product for purposes of the federal Patient Safety and Quality Improvement Act (42 U.S.C. §299b-21 et seq.);

7. Information derived from any of the health care-related information listed in this subsection that is de-identified in accordance with the requirements for de-identification pursuant to HIPAA;

8. Information originating from, and intermingled to be indistinguishable with, or information treated in the same manner as information exempt under this subsection that is maintained by a covered entity or business associate as defined by HIPAA or a program or a qualified service organization as defined by 42 U.S.C. §290dd-2;

9. Information used only for public health activities and purposes as authorized by HIPAA;

10. The collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency or furnisher that provides information for use in a consumer report, and by a user of a consumer report, but only to the extent that such activity is regulated by and authorized under the federal Fair Credit Reporting Act (15 U.S.C. §1681 et seq.);

11. Personal data collected, processed, sold, or disclosed in compliance with the federal Driver’s Privacy Protection Act of 1994 (18 U.S.C. §2721 et seq.);

12. Personal data regulated by the federal Family Educational Rights and Privacy Act (20 U.S.C. §1232g et seq.);

13. Personal data collected, processed, sold, or disclosed in compliance with the federal Farm Credit Act (12 U.S.C. §2001 et seq.); and

14. Data processed or maintained (i) in the course of an individual applying to, employed by, or acting as an agent or independent contractor of a controller, processor, or third party, to the extent that the data is collected and used within the context of that role; (ii) as the emergency contact information of an individual under this chapter used for emergency contact purposes; or (iii) that is necessary to retain to administer benefits for another individual relating to the individual under clause (i) and used for the purposes of administering those benefits.

Consent

Your provision of personal information through any of our registration forms on the Website constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to the property where you reside and on various similar services available to you at or through the property and on various other properties that may be available and of interest to you in the future.  You may choose to opt out of receiving future commercial email messages from us as a result of your use of this website by emailing your request to Info@pancomgt.com.  Please note that if you are a resident of a Panco community and you use this website and your community website, you will need to opt-out of your community email communications separately. 

GENERAL DATA PROTECTION REGULATION NOTICE

The owner of this website is based in the State of New Jersey in the United States.  We provide this Website for use only by persons located in the United States.  We make no claims that the website or any of its content is accessible or appropriate outside of the United States.  This website is not to offer goods or services to anyone located outside of the United States.  If you access the website from outside the United States, you do so on your own initiative and are responsible for compliance with applicable local laws.   You recognize that, to the greatest extent permissible under law, any data you supply in connection with your use of this website or application for goods or services are subject only to United States law and the law of applicable States within the United States.

Notwithstanding this, Panco Management takes reasonable efforts to respect the data and privacy of consumers, including requests from consumers, and to comply with all State, federal, and other applicable law.  Nothing in this statement should be construed as a denial of compliance with any law applicable to Panco Management.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at our discretion and at any time.  It is our policy to post any changes we make to our Privacy Policy on this page.  When we make changes to this Privacy Policy, we will post the updated notice on the Website and update the notice’s effective date.  Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

 CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which Panco Management collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Website: www.pancomanagement.com

Email: Privacy@PancoManagement.com

Postal Address:

Attn: Digital Marketing

395 W. Passaic Street

#251

Rochelle Park, NJ 07662


Policy Effective Date:  October 24, 2022