Effective Date: July 15, 2019
McNair Interests, together with any subsidiaries and affiliates (the “Company,” “we,” “us,” or “our”), are committed to protecting the privacy of individuals who visit the Company’s website(s) or other connected content, including but not limited to www.mcnair.com and www.mcnairinterests.com (collectively, the “Site”) or who otherwise interact with the Company.
“Personal Data” means any information that relates to an identified or identifiable natural person (one who can be identified, directly or indirectly, to the information).
“Processing” means any operations or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (and “Process” and other cognate expressions shall be defined accordingly).
Who has Responsibility for your Personal Data
Categories of Individuals About Whom We Process Personal Data
We process Personal Data from or about the following categories of individuals:
- Users of the Site;
- Job applicants to the Company;
- Individuals who are, or are associated with, the Company’s affiliates, joint venturers, vendors, or other business contacts with whom we interact or seek to establish a relationship with; and
- Individuals identified in data provided by or on behalf of affiliates, joint venturers, vendors, or other business contacts in connection with a project in which the Company is, or may become, associated with.
Categories of Information We Collect and How We May Use It
We may collect several types of information from and about users of our Site, including:
- Personal Data, such as name, postal address, e-mail address, telephone number, and any other identifier by which You may be contacted online or offline.
- Information that is about You, but that, standing alone, does not identify You (which may be Personal Data if you can be identified indirectly from it).
- Information about your internet connection, the equipment You use to access our Site, and usage details.
Information You Provide to Us
Information we collect on or through the Site may include:
- Information that You provide by filling in forms on our Site. This includes information provided at the time of registering, subscribing, or requesting services from or through the Site. We may also ask You for information when You report a problem with our website or if You enter a contest, promotion, or
- marketing campaign through our Site or sponsored by us.
- Records and copies of your correspondence (including email addresses), if You contact us.
- Your responses to surveys that we might ask You to complete for research purposes.
- Your search queries on the Site.
Non-Personal Data We Collect Through Automated Means
As You navigate through and interact with our Site, we may use various automatic data collection technologies to collect certain information about your equipment, browsing actions, and patters, including:
- Details of your visits to our Site including traffic data, location data, logs, and other communication data and the resources that You access and use on the Site.
- Information about your computer and internet connection, including your IP address operating system, and browser type.
The information we collect automatically does not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. This information helps us improve our Site and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Site according to your individual interests.
- Speed up your searches.
- Recognize You when You return to our Site.
The tracking technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the section “Your Choices About How We Use and Disclose Your Information” below.
- Web Beacons. Pages of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, 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 providers, see the section “Your Choices About How We Use and Disclose Your Information” below.
How We Use Collected Information
We Process information that You provide us, including Personal Dataor that we otherwise collect for the following purposes:
- To present our Site 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 account, 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 Site or any products or services we offer or provide through it.
- To allow You to participate in interactive features on our Site.
- In any other way we may describe when You provide the information
- To comply with any legal or regulatory obligations
- For any other purpose with your consent.
We may also use your information to contact You about our own or our affiliates’ goods and services that may be of interest to You unless you have opted out. If You do not want us to use your information in this way, please do not consent to its collection at the time or send an opt out request to us as specified in the “How to Contact Us” section below.
We may use the information we have collected from You to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Data for these purposes without your consent, if You click on or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria.
You may voluntarily disclose Personal Data to us in the event You choose to use or submit information through the Site, including through the “Contact Us” link. Except with respect to Aggregated Data noted below, any Personal Data You submit through our Site will be used generally to respond to your request unless otherwise stated herein or permitted by law. As described below, we may share Personal Data about You with third parties that perform services for us or on our behalf, for the limited purpose of carrying out such services. This includes, without limitation, third parties that assist in managing our organization, hosting or administering the Site or other systems, sending communications on our behalf, maintaining or analyzing our data, providing marketing assistance, or in otherwise providing services to us or our members.
We may use your information to communicate with You in response to your requests for contact made through our Site or to personalize your visit to our Site. We may also use this information to prevent or detect fraud or abuses of our Site and to enable third parties to carry out technical logistical or other functions on our behalf.
We may collect information or data about You in various ways through and from your visit, use, or access of our Site. We may collect this data in various ways, including through device finger printing or other biometric or traditional analytics (including IP address identification and cookies). Some examples of information we may collect include:
- browser name, devise operating system, computer platform, browser version, and browser plugins;
- devise screen size, color profile, color depth, and pixel ration;
- whether the devise is cookieEnabled;
- language used on the devise;
- internet service provider or network name used when accessing our Site;
- number of visits, views of content, and downloads from our Site;
- timestamps of visits to our Site; and
- duration of your stay on our Site and how You learned of or arrived to our Site (e.g., if You clicked on a paid advertisement or search engine result).
Note that if the Company is able to identify that You are a European Individual when visiting or using our Site, You will be prompted to provide your consent in order for cookies to track and communicate certain information about You back to the Company. If You do not provide our consent, no cookies web beacons, or other tracking devices will be permitted to attach to your information.
For European Individuals, the legal basis for the above Processing of your Personal Data is that the processing is:
- necessary for legitimate business interests pursued by the Company which are not overridden by your interests, rights or freedoms;
- in some cases, necessary for the performance of a contract with You or to take steps at your request before entering into a contract;
- in some cases, necessary to comply with our legal obligations (such as record-keeping obligations), compliance screening or recording obligations;
- where you have specifically and voluntarily requested to the Processing.
Accountability for Onward Transfer
If You are a European Individual, where we transfer your Personal Data to third-party service providers (see above) who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your Personal Data in a manner inconsistent with GDPR or the Privacy Shield Principles referred to below or any other applicable law, unless we prove that we are not responsible for the event giving rise to the damage.
Cross-Border Transfers of Personal Data
The Company is located in the United States, but many of its projects and/or investments may be located in different countries. This Site (and all Personal Data collected via this Site) is hosted in the United States. All Personal Data that we collect and maintain via the Site will be processed and stored in the United States, where data protection and privacy regulations may provide different levels of protection compared with your jurisdiction.
Whenever the Company transfers Personal Data from one country to another, it will do so in compliance with applicable privacy and data protection laws.
If You are a European Individual, please be aware that we will receive your Personal Data directly in the United States, where we are established. The United States does not have the same data protection laws as the European Union. We do not anticipate Processing Your Personal Data in the European Union or, therefore, transferring Your Personal Data from the European Union to a third country.
Personal Data Retention Period
All Personal Data retained by McNair Interests will be deleted when such Personal Data is no longer necessary for the purposes for which it was processed, unless applicable law requires a longer retention period, in accordance with our retention policy. This policy currently states that if You engage in any transaction with us, we will usually retain your Personal Data for seven (7) years from the date the last transaction with You is concluded. Otherwise, we will usually delete your data seven (7) years from the date on which we last received a communication from You. This is however subject to the requirements of applicable data protection laws and the purpose for which the data is collected and used, taking into account legal and regulatory requirements to retain data for a minimum period.
Disclosure of Your Information
We may disclose Aggregated Data about our users without restrictions.
- To our subsidiaries, joint venturers, 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
- Data confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of
- McNair Interest’s assets.
- To fulfill the purpose for which You provide the information. For example, if You request additional information regarding a project listed on the Site, such as leasing information for a rental property, the Company may disclose your Personal Data to the applicable individual or entity responsible for such project’s leasing in order to respond to your request.
- With your consent.
- For any other purpose disclosed by us when You provide the information.
Further, we may disclose aggregated information or 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 McNair Interests, our customers, or others.
Your Choices About How We Use and Disclose Your Information
We strive to provide You with choices regarding the Personal Data You provide to us. We have created mechanisms to provide You with the following control over your information:
- Promotional Offers from the Company. If You do not wish to have your email address or contact information used by the Company to promote our own or third parties’ products or services, You can opt-out by contacting us as specified in the “How to Contact Us” section below.
- Target Advertising. If You do not want us to use information that we collect or that You provide us to deliver advertisements according to our advertisers’ target-audience preferences, You can opt-out by contacting us as specified in the “How to Contact Us” section below or, if applicable, logging into the Site and adjusting your user preferences in your account profile (for this opt-out to function, You must have your browser set to accept all browser cookies).
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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) through the NAI’s website.
European Individuals – Rights as Data Subjects under GDPR
If You are an European Individual, You have the following rights:
- to obtain confirmation as to whether we process your Personal Data;
- to access a copy of your Personal Data that we do process, along with information on what Personal Data we use, why we use it, who we share it with and, how long we keep it for;
- to request the correction of inaccurate Personal Data we hold about You;
- to request that we delete your data, or stop processing it or collecting it, in some circumstances; and
- in certain cases, to request that we transfer or port elements of your Personal Data either to You or a third party providing You with similar services.
We do not generally impose any charge for these requests (except where excessive or unfounded). For any such request, You can contact us as specified in the “How to Contact Us” section below. We will endeavor to respond to all reasonable requests in a timely manner, but in no event longer than the amount of time required by applicable law.
To the extent the Company is not the controller of your data, we will notify the controller of your request if required by applicable law.
In addition, where the lawful basis of our processing under the GDPR is that You have consented to it for a particular identified purpose, You have the right to withdraw that consent at any time. To do so, please contact us as specified in the “How to Contact Us” section below. If You do withdraw consent, this will not affect the lawfulness of any processing that was based on your consent before its withdrawal.
In addition to the foregoing, You have the right to lodge a complaint in respect of your data protection rights with the applicable supervisory authority for data protection in your jurisdiction. If You are in the United Kingdom, that supervisory authority is the UK’s Information Commissioner’s Office: https://ico.org.uk/.
Third-Party Tracking and Do Not Track
Links to Non-Affiliated Websites
Sensitive or Financial Information
The Company does not and will not intentionally collect or maintain any sensitive or financial information, such as information pertaining to your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, and payment information. If You are prompted to provide such information while You believe You are on our Site, please do not provide the requested information and contact us immediately as specified in the “How to Contact Us” section below.
Children’s Online Privacy Protection
Our Site is not designed for or directed to children under the age of 13. If You are a parent who believes we have collected information regarding your child under the age of 13, please contact us immediately as specified in the “How to Contact Us” section below to request deletion of such information from our records. We will respond to your request as soon as reasonably practicable, but no later than 5 calendar days after your request.
Opt Out of Communications
If we obtain Personal Data about You as described above, we may contact You in connection with your request made through our Site. You can manage your receipt of non-transactional communications from us by contacting us as specified in the “How to Contact Us” section below.
Security of Personal Data; Data Integrity and Purpose Limitation
The Company implements appropriate technical and organizational measures, including administrative, technical, and physical safeguards to help protect Personal Data we obtain against loss, theft, and misuse as well as unauthorized, access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data. While we follow generally accepted standards to protect information, including the use of secure socket layer (SSL) technology, no method of storage or transmission is 100% secure.
The Company shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by You. To the extent necessary for those purposes, the Company shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.
Confidentiality of Social Security Numbers
To the extent an applicable state law (such as Connecticut) requires any person or entity that collects Social Security numbers from the state’s residents in the course of business to create a privacy protection policy and to publish or display it publicly, this is the Company’s policy: It is the policy of the Company to protect the confidentiality of Social Security numbers in its possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to the Company personnel who need access to such information in order to perform their job functions at the Company.
How to Contact Us
By e-mail: email@example.com
By phone: 713-336-7800
109 North Post Oak Lane, Suite 600
Houston TX 77024
ATTN: Help Desk
Through “Contact Us” Link on Site