Privacy Policy

June 18^th, 2024

Unpack Labs Inc. (together with its affiliates, “we”, “us” or “our”) recognizes the importance of protecting our consumers’ privacy during their use of this website, HelloPortico.com (“the “Website”), and all related subdomains, and all portals, applications, products, services, events and any interactive features, together with any other related Unpack Labs Inc. services (individually and, collectively with the Website, referred to as the “Site”) This Privacy Policy governs collection and use of personal information on the Website and any Site as well as any other service that posts a link to this Privacy Policy (each such linked service a “Related Use”). We are firmly committed to protecting the information you may provide through the Site.

We continually update our privacy practices and our procedures for safeguarding the personal information you may provide to us, and accordingly we may amend this Privacy Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Website. Any material changes to this Privacy Policy will be effective seven (7) days after our posting of such updated Privacy Policy (or as otherwise required by applicable law). Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy.

As the Site may change at our sole discretion, we recommend that you refer to this Privacy Policy periodically for any updates. Your continued use of the Site or any Related Use following the posting of any changes to this Privacy Policy means that you accept those changes.

Collection and Use of Information

The Site and its Related Uses may collect personal information that you voluntarily provide to us in order to provide you with information or services you request from us. Personal information includes your name, email, phone, address, and any other information that is specific to you and which you may provide to us or which is obtained from third party sources, and is needed in order for us to provide other services to you. We will process your personal information when one or more of the following conditions exist: (i) with your consent, or (ii) to perform or enter into contracts with you, or (iii) in conformance with our legitimate business interests (maintaining our books and records, maintaining the security and integrity of the Site, its Related Uses and our systems, enforcing the terms and conditions and Privacy Policy associated with the Site, its Related Uses and our systems, monitoring the use and performance of the Site, its Related Uses and our systems, quality assurance of our customer service operations, and product improvement and development) where our interests do not outweigh your individual rights and freedoms, or (iv) to comply with legal obligations. Where processing is based on consent, you have the right to withdraw your consent at any time. To withdraw your consent, contact the UNPACK LABS INC. Privacy Office in writing per the ‘How to contact us with requests concerning your personal information” provision in Part 10, below.

What personal information we collect and the purpose of processing.

The following are categories of personal information we may collect from you through contact or Application form submissions, in addition to information we receive when you use the Site:

First and last names
Phone number, Email address
Personal information provided to us by or on behalf of our clients, third party partners or service providers or generated by us in the course of providing our services which may, where relevant, include special categories of personal information, such as gender, age, national origin and disability accommodations.
We collect these categories of personal information from the sources described in the “Sources of personal information we collect” section below, and for the purposes described in the “How we may share and use your personal information” section below.

Sources of personal information we collect.

The personal information that we collect and process is gathered in various ways. We collect personal information directly from individuals who use the Site or its Related Uses, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third party services that we use). For example, some of the ways we collect information are as follows:

You may provide personal information to us directly, such as:

When we receive the personal information you submit to us through the Site forms (e.g., name, address, telephone number, and email address) for the purpose of registering on the Site, creating an account or processing application forms;
When you send other personal information to us through other forms found on the Site or its Related Uses, such as the “Contact” tab; or
When you participate in surveys or contests, submit orders or requests, or register for or use our services; or
When you otherwise contact us through the Site or its Related Uses, by mail, email, telephone or other means.

Data Processing when using the Site or any Related Use.

The following information is automatically stored every time you access the Site or any Related Use:

The date and time of access
The name of the requested file
The web page from which the file was requested
The access status (file transferred, file not found, etc.)
The IP address of the requesting device

Information collected from third-party data sources.

UNPACK LABS INC. may leverage external data sources in order to provide context and background on the users of its services in order to improve customer experience, mitigate fraud or malicious activity or comply with internal company and external regulatory requirements. These may include social media through which you have disclosed personal information, real estate professionals that you have authorized to process your information, and from public records, such as real estate registries.

Information about Site usage and electronic messages we send.

UNPACK LABS INC. and engaged third-party service providers use “cookies,” web beacons, server logs, and related technologies to collect information about how visitors interact with the Website, Sites, Related Uses and with messages we send to individuals (e.g., which pages visitors view or emails individuals open, which URL the website used before visiting the Site), Site usage preferences (e.g., language), and the technical characteristics of their Internet browsers and connection (e.g., IP Address, browser type, device identifiers, operating system version). We use this information to improve how the Site and the Related Uses function. The Site and its Related Uses also uses cookies to store information necessary for users logging into certain portions of the Site or its Related Uses, and to remember users and their preferences. Most web browsers provide you with the ability to accept or decline cookies, as well as be warned each time a cookie is sent. If you choose to decline cookies, you may not be able to fully use UNPACK LABS INC.’s Site or the Related Uses.

This website uses Google AdWords & other remarketing services to advertise on third party websites to previous visitors to the Site. Third-party vendors, including Google & Facebook, use cookies to serve ads based on past visits to the Site. Of course, any data collected will be used in accordance with our own privacy policy, as well as Google & Facebook privacy policies.

You can opt-out of remarketing by visiting Google and Facebook

How we may share and use your personal information.

UNPACK LABS INC. does not sell your personal information to any unrelated third parties.

However, we may share your personal information with non-affiliated third parties, but only as disclosed in this Policy, and we have done so for a business or commercial purpose in the preceding 12 months. We also may share your personal information with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes.

UNPACK LABS INC. may also anonymize and aggregate any information collected through the Site or its Related Uses in a manner that renders your information no longer identifiable to your personal information. We may use and share this anonymized and aggregated and information for any purpose, including without limitation, for internal management, research, promotional and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

We may also disclose your personal information for any other purpose disclosed at the time of data collection or sharing.

We may transfer your personal information to:

Worldwide UNPACK LABS INC. affiliates and non-affiliated partners and joint-venture companies to assist us in providing, maintaining, and operating our services or marketing. These companies are required to comply with the principles set out in this Policy, and only use such information for the purposes for which it was provided to them;
A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession, or sale at bankruptcy), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Policy or our products and services, in the manner described in this Policy. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees or with the newly-acquired business.

We may also use your personal information to:

Administer and perform our services, including to carry out our obligations arising from any agreements entered between you and us;
Respond to requests for information and to ensure the content of the Site and its Related Uses is presented in the most effective manner for you and your device;
Provide you with details about new services or products. We will always include an option for you to opt-out of such communications;
Better understand you and our clients’ services and business requirements and to better understand our business and develop our products, services and offerings;
Respond to your expressed interest in any employment or rental opportunities; Fulfill our legal and regulatory or risk management obligations or to protect the rights of our company, business partners, service providers, clients and other website users;
Notify you about changes to the Site, its Related Uses, services or this Privacy Policy;
Request information or otherwise contact you regarding the business, products, services or Site;
Respond to your comments, questions, requests,
Provide and deliver the information you request, process contributions and send confirmations, technical notices, updates, security alerts, support and administrative messages;
Prevent illegal activities and otherwise protect our rights and the rights of other site users, third party business partners, clients or service providers.
Enter in or perform our contract with you or your company;
Enable us to perform our obligations and offer our services and provide communication with our clients, third party business partners and/or service providers.
Provide marketing information, improve the Site’s performance, analyze Site usage, improve the Site’s content, customize the Site’s layout and content and for other customer service purposes.

Compliance with Terms of Use and legal requirements.

In addition, UNPACK LABS INC. may disclose your personal information to law enforcement or to service providers that are engaged by us for the purposes of:

Complying with the law and/or legal process in which a formal request has been made (e.g., a request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
Defending our rights and/or property or the rights and property of others;
Enforcing our Terms of Use and/or this Policy;
Responding to claims that the content(s) of a communication violates the rights of another;
Detecting, preventing or otherwise addressing fraud, security, or technical issues.

In the event of any violation of the Site’s Terms of Use, we would use and disclose any information to investigate and respond to such violations. You authorize us to disclose any information about you as required by law, including disclosure to law enforcement agencies and government officials, as we, in our sole discretion, believe appropriate or necessary.

We may also disclose your personal information for any other purpose disclosed at the time of data collection or sharing.

Email List Privacy and Unsubscribe Policy

Individuals may sign up or ask to join our mailing lists using the forms provided on the Site, its Related Uses or other means expressly sanctioned by UNPACK LABS INC..

If you no longer wish to receive future e-mails from us, simply click the UNSUBSCRIBE link at the bottom of any email sent to you by UNPACK LABS INC..

Security

We comply with all consumer privacy laws and use reasonable administrative, technical and physical safeguards and security measures to protect the information you provide to us from unauthorized access, use or disclosure. However, while we may use all commercially reasonable steps to protect the information you provide, we cannot guarantee that third parties will not unlawfully intercept or access internet data transmissions.

Links

The Site may contain links to other sites that are operated or owned by third parties. Please note that when you click on one of these links, you are navigating to another site with separate terms of use and privacy policies. We encourage you to read the terms of use and privacy policies of these linked sites as their policies may differ from ours. We are not responsible or liable for the privacy policies or the content of any third-party web site and do not make any representations or warranties as to how third parties may use your information.

Age Restriction

We do not intend to collect information from anyone under the age of eighteen. If you are under eighteen, please ask your parent or guardian for permission to use the Site or any of its Related Uses. Do not submit any information if you are under the age of eighteen.

Rights of California Residents

Under certain circumstances, and as required by law if you are considered a “Consumer” under the California Consumer Privacy Act (“CCPA”) and/or the California Privacy Rights Act (“CPRA”) once in effect, and if we are subject to the CCPA and/or CPRA once in effect, you may have the following rights:

Consumer right of disclosure and access.

California Consumers have the right to request disclosure of their personal information and to receive additional details regarding their personal information collected, our purposes for such collection, and the categories of third parties with whom we have shared or sold their personal information. Consumers may only request twice a year such disclosures regarding their personal information that we collect and only for a 12 month look-back. Please see the next section for information on requesting your personal information.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights, including requests to delete your personal information). Identity verification is a necessary security measure to ensure personal information is not disclosed to any person who has no right to receive it. In addition, you may designate an authorized agent to make a request pursuant to your rights by contacting our Privacy Office.

Consumer data request process.

If we receive a verifiable request from you, we will promptly take steps to deliver a copy of the personal information that we have collected about the consumer. The information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows the consumer to easily transmit this information to another entity. Unless otherwise required by applicable law, the required information will be delivered within 45 days to California residents after the date of receiving the request from the Consumer, unless we provide notice and a reason why more time is needed, in which case we will deliver the requested information no later than 90 days after the initial request by a California Consumer.

Consumer right to delete personal information.

Consumers have the right to deletion of their personal information collected by us subject to the following exceptions:

Information necessary to complete transactions or perform contract;
Information used to detect data security incidents and protect against malicious, fraudulent or illegal activity;
Information used to protect against illegal activity and/or comply with legal obligations and or applicable laws; or
Information used to enable internal purposes that are reasonably aligned with the expectations of the consumer based upon the consumer’s relationship with us.

In addition, upon its effective date of January 1, 2023, the CPRA adds the following rights for California consumers:

The right to correct inaccurate information;
The right to have personal information collected subject to data minimization and purpose limitations;
The right to receive notice from businesses planning on using sensitive personal information and ask them to stop;
The right to access any personal information a business has collected on the consumer, not limited to the current 12-month look-back;
The right to opt out of sharing your information with third parties, in addition to information being sold;
The right to sue businesses if they expose usernames or passwords.

California Consumers interested in exercising any of these rights can contact the UNPACK LABS INC. Privacy Office in writing by any means described in the “How to contact us with requests concerning your personal information” in Part 10, below. All California Consumers have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA and CPRA.

Notice to Connecticut Residents

We protect the confidentiality of Social Security numbers in our possession from improper disclosure and misuse by maintaining and enforcing policies and physical and electronic safeguards to prevent the improper disclosure and misuse of information. We do not permit disclosure of Social Security numbers, except to personnel who require access to this information to perform their job responsibilities.

Notice to Virginia Residents

Under certain circumstances, and as required by law if you are considered a “Consumer” under the Virginia Consumer Data Protection Act (“VCDPA”) and we are subject to the VCDPA once in effect as of January 1, 2023, you may have the following rights:

Consumer Right to Opt Out

A Virginia consumer has the right to opt out of the processing personal data concerning the consumer for purposes of:

Targeted advertising;
The sale of personal data;
Profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Consumer right of disclosure and access.

Virginia Consumers have the right to request disclosure of their personal information and to receive additional details regarding their personal information collected, our purposes for such collection, and the categories of third parties with whom we have shared or sold their personal information. In addition, you have the right to receive notice of data processing activity affecting your personal data. Consumers may only request twice a year such disclosures regarding their personal information that we collect. Please see the next section for information on requesting your personal information.

Consumer data request process.

If we receive a verifiable request from you, we will promptly take steps to deliver a copy of the personal information that we have collected about the consumer. The information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows the consumer to easily transmit this information to another entity. Unless otherwise required by applicable law, the required information will be delivered within 45 days to Virginia residents after the date of receiving the request from the Consumer, unless we provide notice and a reason why more time is needed, in which case we will deliver the requested information no later than 90 days after the initial request by a Virginia Consumer.

Consumer right to delete or correct personal information.

Consumers have the right to deletion of their personal information collected by us subject to the following exceptions:

Information necessary to complete transactions or perform contract;
Information used to detect data security incidents and protect against malicious, fraudulent or illegal activity;
Information used to protect against illegal activity and/or comply with legal obligations and or applicable laws; or
Information used to enable internal purposes that are reasonably aligned with the expectations of the consumer based upon the consumer’s relationship with us.

In addition, Consumers have the right to request that inaccuracies in their personal data be corrected, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data.

Virginia Consumers interested in exercising any of these rights can contact the UNPACK LABS INC. Privacy Office in writing by any means described in the “How to contact us with requests concerning your personal information” in Part 10, below. All Virginia Consumers have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the VCDPA.

Notice to Residents of the European Union or European Economic Area

We provide services exclusively within the United States (“U.S.”) and do not own or manage property outside the U.S., have a presence outside the U.S., including in the EU, any EU–Member State, or any state belonging to the European Economic Area, or intentionally market our services outside the U.S. We do not market our services to individuals in the EU, including EU residents. If an EU resident visits or uses the Site, its Related Uses and our services, that person consents to the practices described in this Privacy Policy and agrees to its terms.

Where EU data protection laws apply, the provisions below will apply in addition to the terms and conditions set forth above.

Pursuant to EU data protection laws, TF Cornerstone, Inc. is the controller of your personal information collected and processed via the Site and can be contacted as set forth below.

We may hold your personal information as determined using the following criteria:

For the intended purposes and to provide the services as mentioned above.
For as long as is necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose.
To comply with laws or regulations for which we must retain your personal information.

Under certain circumstances, and as required by law, you may have the right to:

Request information regarding your personal information that we hold and obtain access to it;
Request correction of any incomplete or inaccurate personal information that we hold about you;
Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below);
Object to processing of your personal information or withdraw your consent to processing (note: we may still be entitled to process your personal information if we have a legitimate reason for doing so, such as to comply with a legal obligation;
Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it; or
Receive some personal information in a structured, commonly used and machine-readable format, and/or request the transfer of your personal information to another party.

If you want to exercise any of these rights, please contact the UNPACK LABS INC. Privacy Office in writing per the “How to contact us with requests concerning your personal information” section in Part 10, below. Valid requests will be honored within 30 calendar days of request.

If you are located in the European Union (EU), you have the right to lodge a complaint with the EU Supervisory Authority in your country of residence. However, if you have a complaint regarding the processing of your personal information, we request that you first contact the UNPACK LABS INC. Privacy Office, and we will reply on a timely basis.

How to contact us with requests concerning your personal information.

If you have any questions about this Privacy Policy, the Terms of Use of the Site, or any of the Related Uses, wish to request action with respect to your rights, or require other information, please contact us by postal mail, email, telephone or online at:

Postal Mail:

Privacy Office
Unpack Labs Inc,

C/O TF CORNERSTONE INC.
387 Park Ave South
New York, NY 10016

Email: info [at] helloportico.com

Telephone: 212-672-1000

Or use our “Contact” tab on the Website.

You have a right not to receive discriminatory treatment by UNPACK LABS INC. for the exercise of the privacy rights contained in this Privacy Notice and as required by law.

Privacy Policy

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