Privacy Policy

Effective Date: March 17, 2026 | Last Updated: March 17, 2026

The Privacy Policy describes how 3650 Waialae LLC and affiliated entities (collectively, “we” and “us”) collect, use, disclose, and store personal information about you.  This Privacy Policy applies when you visit or use our websites (“Sites”), contact us, communicate with us on behalf of a vendor or customer, use our tenant portal, or otherwise interact with us.

This Privacy Policy does not apply to personal information collected in the course of your employment with us. If you have any questions, please contact us as provided below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

1. Categories of Personal Information We Collect

The type of information that we collect depends on your interaction and relationship with us.  We may collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.

• We may collect name, postal address, telephone number, email address, business contact information, and tenant portal login information.
• Audio/Visual Data. We may collect audio, electronic, photographic, visual or similar data, including photographs, and audio messages.
• Internet or Electronic Usage Data. We may collect data related to network and website interaction history, IP address, device information, session data, website cookie information, interaction with advertisements, and browsing time.

2. Sources of Personal Information

We collect personal information in the following ways:

• Directly from you. We may collect identifiers and audio/visual data that you provide directly to us.  This includes when you interact with us via email or phone, or when you visit our physical location.
• Automatically. When you access our Site, we may collect internet or electronic usage data using tools like browser cookies.
• From third parties, including vendors and service providers.  We may collect identifiers and internet or electronic usage data from third parties, including vendors and service providers.

3. Purposes for Collecting Personal Information

We use personal information for the following business and commercial purposes:

• Transactional Purposes. We use identifiers to (i) communicate with you; (ii) allow you to create a tenant account with us; and (iii) provide you with information and other support.
• Analytical Purposes. We use identifiers and internet or electronic usage data to analyze preferences, trends, and statistics.
• Marketing and Promotional Purposes. We use identifiers and internet or electronic usage data to improve our marketing efforts, relationship management, and to provide you with information about us, including personalized marketing communications.
• Combination of Data. We combine information we obtain from different sources with publicly available information, including to create inferences about you.  For example, we may combine information that we have collected offline with information we collect online.  We combine information that we have collected across other third-party sites.  We combine information across devices, such as computers and mobile devices.  We may also combine information we get from a third party with information we already have.
• Maintenance and Improvement of our Sites and Systems. We use internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.
• Security and Fraud Prevention. We use identifiers, audio/visual data, internet or electronic usage data to: (i) protect our Site, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, and others from fraud, theft, and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft, and misconduct including by verifying the identity of those we are considering hiring and those we are conducting business with.
• We use identifiers, audio/visual data, commercial information, and internet or electronic usage data, to comply with our legal obligations, contractual obligations, and other compliance obligations, including reporting requirements, and defend ourselves against allegations, complaints, claims and in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
• Other Purposes. We may use your information for other reasons we may describe to you or as required by law.

4. How We Disclose Personal Information

We disclose personal information in the following circumstances:

• Service Providers. We may share personal information with vendors and service providers who support the operation of our services, Site, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting providers, lawyers, bankers, tax consultants, auditors, insurers, payment processors, financial institutions, email delivery vendors, internet service providers, operating systems and platforms, maintenance and support services).  In some cases, the vendor or service provider may directly collect the information from you on our behalf.
• Marketing/Analytics Partners. We may share personal information with third-party marketing, analytics or advertising partners, who provide analytics services to us.
• Government Entities. We may share information with regulatory and government entities, including government, administrative, law enforcement, and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process, or other legal obligation.  This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
• Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
• Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

5. How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you with products or services, or as long as necessary to comply with our legal, contractual, and other compliance obligations, resolve disputes, and enforce our agreements.  We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• what the expectation for retention was at the time the data was provided to us.

6. Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology

When you access the website, we (and third-party companies we work with) may collect and store certain information by using technologies such as server logs, cookies, web beacons, clear gifs, tags, e-tags, flash cookies, log files, pixels, code, Javascript packages, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies.  The information collected includes information about your activities on our Sites, IP address, browser or operating system type and version, device IDs, and demographic or inferred-interest information, as well as information or communications you have submitted to us through the Sites.

We use this information to understand general usage and volume statistics, how users navigate to and around our Sites, what content is viewed or accessed, and which products and services have been obtained.  We also use these technologies to keep track of your preferences and profile information.  We also use these technologies to allow third parties to provide analytics services. They may match your browsers or devices if you log into the same online service on multiple devices.  These third-party partners may use this information for our and their own analytics, attribution, and reporting purposes.  To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices.

Do Not Track Signals

Some browsers have a “do not track” feature.  It lets you tell websites you visit that you do not want them to track your online activity.  These features are not yet uniform across browsers.  Our Sites are thus not currently set up to respond to these signals.  For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Google Analytics

We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Site, please visit www.google.com/policies/privacy/partners.  If you would like to opt out, Google provides an opt-out tool available at https://tools.google.com/dlpage/gaoptout.

7. Links to Other Websites

Our Sites may include links to other websites or applications whose privacy practices may differ from ours.  If you submit personal information to any of those websites or applications, your information is governed by their privacy policies.  We encourage you to carefully read the privacy policy of any website you visit or application that you use.

8. Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organizational, administrative, and physical measures to protect personal information.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security and encourage you to use the website and share information with caution.

9. This Website is Not Intended for Children

Our website is not directed to children under the age of 18.  We do not knowingly collect or store any personal information from anyone under the age of 18.  If we become aware that we have collected or stored personal information from an individual under the age of 18, we will remove that information from our files.  If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to info@3650waialae.com.

10. Marketing Communications

Marketing Emails.  You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in communications you receive from us.  You may also request to opt out of marketing or advertising emails by contacting us at info@3650waialae.com. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us, where permitted by law.

11. Processing in the United States

Please be aware that the information we obtain about you will be processed in the United States by our service providers or us.  By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions 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 or other jurisdictions may be different from the laws in your country of residence.  The United States may not afford the same level of protection as the laws in your own country.

12. Your Privacy Rights for EU/UK and US States with Similar Laws

(a) Residents of the European Union/EEA and the United Kingdom

Controller.  The controller of your personal information is 3650 Waialae LLC.

Disclosure and Cross-Border Transfer.  Personal information that is shared with affiliates and third parties as described in this Privacy Policy is done pursuant to contracts that include the requisite protections under applicable data protection laws.  In accordance with these laws, transfers of personal information outside of the EU/EEA and UK are conducted in accordance with compliant arrangements such as international data transfer agreements or legally recognized certifications and adequacy decisions.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Lawful Basis for Processing Personal Information. The lawful basis for our collection and use of your personal information described in this Privacy Policy is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with a third-party or with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary and appropriate, on your consent.

Special Categories of Data.  Unless we specifically authorize you to do so, do not send us any Special Categories of Data, which are defined under applicable data protection laws as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.

Segmentation and Automated Decision Making.  We do not use segmentation or automated decision-making without human intervention, including profiling.

Your Rights Over Your Personal Information.  Subject to certain exceptions and limitations, you have the right to:

• Ask us to confirm whether we are processing your personal information.
• Ask us to provide you or a third party that you designate with certain of your personal information in a commonly used, machine-readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
• Request that we update or correct your personal information when it is inaccurate or incomplete.
• Request that we delete your personal information in certain circumstances.
• Request that we limit processing or stop processing your personal information in certain circumstances, including for marketing activities, and profiling for marketing activities and profiling for statistical purposes, and, subject to certain exceptions, where such processing is based on our legitimate business interests.
• Withdraw or revoke consent previously granted to the extent permitted by law.

Exercising Your Rights.  To exercise any of your rights, please email us at info@3650waialae.com or call us toll-free at 808-524-1258.  We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity.

13. Contact Us

If you have any questions about this Policy or our data practices, please email us at  info@3650waialae.com.

14. Updates to Our Privacy Policy

From time to time, we may change our privacy policy.  We will notify you of any material changes to our privacy policy as required by law.  We will also post an updated copy on the Site where this appears.  Please check our Sites periodically for updates.  The “Last Updated” legend above indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on any of our Sites.