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Privacy Policy

Last updated: January 24, 2020

Alexander & Baldwin, Inc. and its subsidiaries and affiliates (collectively, “A&B,” “Company,” “we,” “our,” or “us”) respects your concern about privacy. This Privacy Policy describes the policies and procedures on the collection, use and disclosure of your information when you use our websites, mobile sites, and social media sites (collectively, “Sites”) and tells you about your privacy rights and how the law protects you. We use your personal data to provide and improve our Sites. By visiting our Sites, you are agreeing that you have read and understand the information provided in our Privacy Policy and that you consent to the privacy practices described.

The Sites may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by A&B. Please review the privacy policies of these third parties to familiarize yourself with their practices.

Collection and Use

A&B and our third-party service providers may collect certain information from or about you in connection with your use of, or your submissions to or via, the Sites. Personal identifiable information may include, but is not limited to:

  • First name and last name
  • Company
  • Title
  • Email Address
  • Address, State, Province, ZIP/Postal code, City
  • Telephone Number
  • Usage data

Other Information Provided by You:

  • In person
  • By Telephone
  • Via email
  • Through social media

For example, some areas of the Sites may include registration forms that require users to provide some or all of the above information. We may also keep any information you provide to us when you communicate with us.

Usage Data

Usage data is collected automatically when using the Sites, which may include information such as:

  • Internet Protocol address (e.g. IP address)
  • Browser type
  • Browser version
  • Device type
  • Operating system or platform
  • Name of internet service provider
  • Referring website
  • Exiting website
  • Pages visited on the website
  • Frequency, time, data, and duration of your visit on our website
  • Whether you access our website from multiple devices
  • Other interactions you may have on our website
  • Unique device identifiers
  • Other diagnostic data

Tracking Technologies and Cookies

Use of Personal Data

A&B may use your personal data for the following purposes:

  • To conduct data analytics to enhance our Sites and support our business. These analyses are done using aggregated or otherwise non-attributable data from automatically collected information to manage and improve our website and business.
  • Monitor, analyze, and enhance the Sites’ performance and functionality. For example, we analyze Site user behavior and conduct research and analysis about the way you and other users use our Sites.
  • Manage the risk and protect the Sites. We use data to better protect our Sites, and you by helping to detect and prevent fraud and abuse of the website and our services.
  • Improve our Sites by analyzing information to understand what Site functionalities or services may interest you.
  • Operate and improve our business.
  • Maintain our records.
  • Provide you with news and events about our business.
  • Manage requests that you submit to the Sites.
  • For legal, contractual, and safety purposes. We will use your information as necessary to enforce the terms of our website; to comply with all applicable laws and regulations; to defend or protect us, our users, you, or third parties from harm or in legal proceedings; to protect our rights; to protect our security and the security of our users, employees, and property; to respond to court orders, lawsuits, subpoenas, and government requests; to address legal and regulatory compliance; to verify your identity or communications from you; to comply with contracts and other agreements to which we are a party; and to notify you of changes to our terms, policies, or practices.
  • For other purposes for which you provide your consent. We will use your information for other purposes that are disclosed to you at the time your information is collected, or for purposes that can be inferred from or are obvious given the circumstances of collection. For example, if you give us your personal information when entering a contest, we will use that information to facilitate your participation in that contest

A&B may share your personal information in the following situations:

  • We may share your personal information with service providers to monitor and analyze the use of our online channels, to show advertisements to you to help support and maintain our service, to contact you, or to advertise on third party websites to you after you visited our Sites.
  • We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • We may share your information with our business partners to offer you certain products, services or promotions.
  • When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

Detailed Information on the Processing of Personal Data

Service providers have access to your personal data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We use Google Analytics to monitor and analyze the use of our Sites.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Sites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use email marketing service providers to manage and send emails to you.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process personal data under the following conditions:

  • Consent: You have given your consent for processing personal data for one or more specific purposes.
  • Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, A&B will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

A&B undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your personal data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data. Please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
  • Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the website.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the data controller of your personal data collected while using the online channels. As operator of the Facebook Fan Page (https://www.facebook.com/WaipioShoppingCenter/, the Company and the operator of the social network Facebook are joint controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook fan page and on the basis of the GDPR, in order to obtain anonymized statistical data about our users.

For this purpose, Facebook places a cookie on the device of the user visiting our Facebook fan page. Each cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if you are a resident of California, you have the following rights:

  • The right to notice. You must be properly notified which categories of personal data are being collected and the purposes for which the personal data is being used.
  • The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your personal data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
  • The right to say no to the sale of personal data. You also have the right to ask the Company not to sell your personal data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
  • The right to know about your personal data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of personal data collected
  • The sources from which the personal data was collected
  • The business or commercial purpose for collecting or selling the personal data
  • Categories of third parties with whom we share personal data
  • The specific pieces of personal data we collected about you
  • You also have the right to request the deletion of your personal data that have been collected in the past 12 months.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email communications@abhi.com.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Children’s Privacy

We do not use the Sites to knowingly solicit personal information from children under the age of thirteen (13) without parental consent. We request that such individuals not provide personal information through our site. If you are a parent or guardian and believe that your child has provided us with their information, please let us know by contacting us at communications@abhi.com, we will remove identifiable information regarding that child from our records and will not disclose that information to any other companies.

If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

We also may limit how we collect, use, and store some of the information of users between 13 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the Sites to these users.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Do Not Sell My Personal Information

We do not sell personal information. However, the service providers we partner with (for example, our analytics partners) may use technology on the service that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our service providers by following our instructions presented on the Service:

  • From our “Cookie Consent” notice banner

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our online channels do not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Business Partners

We do not sell, trade, or otherwise transfer to third parties your personal information except to trusted service providers who assist us in operating our Sites, conducting our business, or providing services to you, so long as those parties agree to keep this information confidential.

These business partners are responsible for their own compliance with data protection laws. For example, we may share information about you with certain of our service providers (e.g., our web hosting provider) in order to provide the Sites to you. We may also share your information with some of our business and marketing partners for delivering content, materials, and services available on or through the website to you.

These third parties are contractually restricted from using or disclosing the information except as necessary to perform services or to comply with legal requirements.

We and our service providers may also produce reports on website traffic, usage patterns, and similar data generated from information we automatically collect, and we may share these reports with our business and marketing partners and others. We may disclose aggregated, de-identified information, and analyses and reports derived from such information, to third parties including utilities, service providers, advertisers, merchants, consumer and market research companies and other organizations. If we have obtained your personal information from one of our service providers, they may have the same information we do.

Retention of Personal Data

A&B will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer time periods.

Legal Requirements and Business Transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests; (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that A&B is subject to mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may subsequently be used by a third party.

Mailings

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us, please let us know by sending your written request via email to communications@abhi.com. Please provide your full name, mailing address, email address, and phone number when making this request. Include your email address, full name, and specifically what information you do not want to receive.

Email

At any time, you may opt out of receiving emails from us by clicking “Unsubscribe” at the bottom of any promotional email from us. You may also contact us by email or postal address as noted below. Please include your current contact information and your requested changes.

Links to Other Websites

A&B online channels has links to other websites that are not operated by us. Be aware that other sites may collect data and personal information and operate according to their own privacy practices. Because we have no control over them, the information found in our Privacy Policy does not apply to any websites not owned or controlled by us. We are not responsible for what they do. The information found in our Privacy Policy does not apply to the privacy practices of other companies or their websites. We strongly advise you to review the Privacy Policy of every site you visit.

Transfer of Personal Data

Your information, including personal data, is processed at the Company’s corporate office and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. A&B will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are reasonably adequate controls in place including the security of your data and other personal information.

Location of This Website

This website is hosted and operated in the United States. However, we and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries.

Visitors from jurisdictions outside the United States visit us at their own choice and risk.

If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States or other non-European countries from which you may access our website may not be as stringent as that under European Union privacy standards or the privacy laws of other countries, possibly including your home jurisdiction.

Disclosure of Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements

A&B may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Sites
  • Protect the personal safety of users of the Sites or the public
  • Protect against legal liability

Security of Your Personal Data

The security of your personal data is important to us, however, there is no method of transmission over the internet, or method of electronic storage that is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

California Residents

California residents have the right to request information regarding the disclosure of personal information to third parties for their direct marketing purposes. You may make the request by emailing communications@abhi.com.

Changes to Privacy Policy

We may update our privacy practices and the information found in our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via a prominent notice on our online channels, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact

If you have any questions about this Privacy Policy, you can contact us by email at communications@abhi.com.

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