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Privacy Policy

Our privacy policy and terms of use.

Privacy Policy

Revised as of January 21, 2022

Ludlow Street Development, LLC (hereinafter referred to as “Company”, “we,” “us” or “our”) have created this Privacy Policy (the “Privacy Policy”) to describe the information that we collect, how we use it, and to whom and under what circumstances we may disclose it.

This Privacy Policy applies to all personal information we collect or may collect from and about you, including on our website located at (the “Website”), through use of our Mobile Application (if/when one is offered by us), in our building or facilities, by phone, by mail, by email or otherwise when you visit the Website, use our Mobile Application, or purchase, use or inquire about services or goods offered by us (the “Services”). Except as explicitly provided herein, this Privacy Policy does not apply to the practices of entities that we do not own or control, or to people that we do not employ or manage.

By using this Website, our Mobile Application, or any of the Company’s services, you are consenting to the practices described in this Privacy Policy. This Privacy Policy applies to your use of this Website, our Mobile Application and the Services. Any dispute over privacy is subject to this Privacy Policy and any Supplemental Terms. If you do not agree with any part of this Privacy Policy, please do not use the Website or the Services.

The Company may change or revise this Privacy Policy at any time, for any or no reason, at our sole discretion, without notice, simply by posting such changes or revisions on this page. Any such change will be effective immediately upon posting. Your continued use of the Website, Mobile Application or the Services signifies your acceptance of any such change or revision. For this reason, please visit this page on a regular basis to ensure that you are familiar with the most recent version of this Privacy Policy. The Company’s use of information is subject to the Privacy Policy in effect at the time that it uses such information.

Your privacy is important to us and this Privacy Policy notifies you of:

  1. What personally identifiable information of yours we collect;
  2. How we collect such information;
  3. How such information is used;
  4. With whom we may share your information;
  5. How we protect your personally identifiable information; and,
  6. What choices you have regarding collection, use and distribution of your information.

Questions regarding this Privacy Policy should be directed to the Company by emailing

Information We Collect

We collect the following categories of information in order to provide products and services to you, to communicate with you, to enhance our products, services and operations, and/or for other operational, legal and compliance purposes:

  • Information you provide to us: We receive and store any information you provide in relation to the Services. You can choose not to provide certain information, but then you might not be able to take advantage of some of our Services.

The information you provide to us may include:

  • Point of sale information: We may collect information from you when you make a purchase, sign up for Services at one of our locations, fill out a form and submit it to us in any manner, complete a survey for us, participate in a contest or other promotion sponsored by us or on our behalf.
  • Profile information: We collect data when users create or update their accounts. This may include the users name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes user settings.
  • Identity verification and credit check: We collect identity verification and credit check information. This may include information such as driver license information, passport information, birthdate, social security numbers, and credit card information. This information may be collected by an authorized vendor on our behalf. This information may also be used to verify or otherwise check the status of anyone claiming to be protected under the Service Members Civil Relief Act.
  • Secondary contacts: In some instances, we may ask for contact information for people other than yourself, including, for example, Authorized Users (if applicable), In Case of Emergency contact information, an e-mail address of a friend to whom you send a link to the Website or Mobile Application, or the mailing address or phone number of someone you wish us to notify about the Services.
  • Demographic data: We may collect demographic data about users, including through user surveys.
  • User content: We collect the information users submit when they contact us or otherwise provide feedback or comment on us or the Services. This may include video footage, photographs or other recordings.

  • Automatic Information: We may automatically collect and store certain types of information about your use of our Website, Mobile Application, or the Services. We may use “cookies” or other unique identifiers, and we obtain certain types of information when you access our Website, Mobile Application or our Services.

This information may include:

  • Non-identifying Website usage data, such as the number of visits to our Website or use of Mobile Application.
  • Information about the Internet protocol (IP) address used to connect your computer or device to the Internet.
  • Connection information such as browser type and version, operating system and platform, content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads, and network details for streaming and download quality, including information about your internet service provider, and the precise or approximate location of your computer or device, if enabled by the user to do so.
  • Device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures.
  • The Company Service metrics (e.g., the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information, location of your device running an application, information about uploaded images and files such as the file name, dates, times and location of your images).
  • Other software and hardware information.
  • Information about your browsing behavior, such as the date/time you visit the Website, the Website pages that you visit, the time you spend visiting the Website or viewing a page, the number of times you return to the Website, and other click-stream data.
  • We may also use third party website analytics tools (such as Omniture, Google or JavaScript) that collect information about visitor traffic on our Website and any mobile applications.
  • Phone numbers used to call our customer service number and recordings of the calls.
  • Audio, video or electronic information, such as audio or video recording of the conversations for quality control, training, security and analytic purposes when you call our customer service centers or other phone support lines. We may also use video monitoring, audio monitoring, and other tracking technologies at our facilities to enhance security, protect against theft and other crimes and to monitor facility traffic patterns, customer counts and interests, and perform similar analytics. However, we may or may not be able to associate such information with you.

We treat all Automatic Information as non-personal, unless required by applicable law to do otherwise. Additionally, any unsolicited information that you provide to us shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose and distribute such unsolicited information to others without limitation or attribution.

  • Information from Other Sources: We might receive information about you from other sources.

This information may include:

  • Your contact information from affiliates, acquired businesses, public sources or other individuals, such as through referral programs or if someone purchases a service or product and lists you in some manner.
  • Customers or others providing information in connection with claims or disputes.
  • Feedback, such as ratings, reviews, or compliments.
  • Your commercial information, such as your purchase history, from affiliates, acquired businesses or business partners.
  • Inferences or preference information about you from business partners, such as data analytics, marketing service providers, or survey vendors. We may use such information to conduct aggregated analyses of our customer composition, and we may collect your interest and preference information to recommend products or services that may interest you. We may also learn about your preferences from public sources, such as information you submit in a public forum.
  • Vendors who may help us verify users’ identity, background information, or eligibility for protection under certain laws.
  • Credit history information from credit bureaus, which we may use for purposes such as to help prevent and detect fraud and to offer certain credit services to some customers.
  • Publicly available sources.

Please note that when you delete your account information on the Website, Mobile Application, or terminate your use of the Services, we may retain your information for a reasonable period of time afterward for the purpose of recordkeeping, account management and fraud prevention activities.

What Do We Use Your Information For?

We use your personal information to operate, provide, develop, and improve the Services and products that we offer our customers, including to:

  • Respond to your requests for Services and to keep you informed of updates about your account.
  • Deliver services, process payments, process transactions, and communicate with you about Services and products, and promotional offers.
  • Communicate with you in relation to Services by different channels (e.g., by phone, e-mail).
  • Personalize your experience with the Website, Mobile Application, or the Services.
  • Provide you with targeted offers, promotions and advertisements that might be of interest to you, identify your preferences, and personalize your experience.
  • Send periodic emails
  • Improve the Website, Mobile Application, and the Services.
  • Improve customer service and customer interfaces.
  • Display interest-based ads for features, products, and services that might be of interest to you.
  • Protect your rights, our rights and the rights of others including efforts to prevent and detect fraud.
  • Verify users’ identity, background information, or eligibility for protection under certain laws.

Once you create an account with us, you are automatically included in our mailing list, and will receive updates, newsletters, correspondence and other materials of this type. If you do not want to receive these communications, follow the instructions provided in the “Opting Out” section.

Cookies and Other Tracking Technologies

The Company and its partners may use cookies (which are small files that a site or its service provider transfers to your computer/hard drive through your web browser that enables the site’s or service provider’s system to recognize your browser and capture and remember certain information) and other tracking technologies on our websites, Mobile Applications, emails, and online ads for purposes such as:

  • Improving and personalizing the Website and Mobile Application, as permitted under applicable law.
  • Authenticating users.
  • Remembering user preferences and settings.
  • Determining the popularity of content.
  • Delivering and measuring the effectiveness of advertising campaigns.
  • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with the Website, Mobile Application or use our Services.

We also may work with third parties that may use cookies or other tracking technologies to collect information about your visits to the Website, other websites, and use of the Mobile Application, to serve advertisements to you based on that information, serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements.

The majority of web browsers accept cookies, but the “help” menu on your browser should give you options for preventing, accepting, or receiving notice of cookies should you wish to do so. Please be aware that if you block cookies, some Website or Mobile Application functionality may not be available to you.

Do We Share Your Personal Information with Outside Parties?

We may share your personal information with third parties that assist us in operating the Website, Mobile Application, providing the Services, conducting our business, or servicing you, or to our affiliates or agents. We may share your personal information with third parties that provide various services to us in areas, that include: reservations, customer support, information technology, marketing, customer service, data analytics, research, enhancement, fraud prevention, legal, compliance and risk management. These companies may need access to information about you in order to perform their functions but are generally not authorized to use the information we disclose to them for any other purpose.

At times, we may disclose information about you to a third party who may also use the information for their own purposes. For instance, we may provide your information with a vendor who is assisting us with providing or promoting a product or service to you, or with a social media or online advertising technology company to serve tailored commercial information to you.

We may disclose information about you (1) if we believe such action is appropriate to enforce our terms and conditions of use, Supplemental Terms, or other policies of our Website, Mobile Application, or Services, including any investigation of potential violations thereof; (2) when such action is deemed to be necessary, in our sole discretion, to detect, prevent, or otherwise address fraud, security or technical issues associated with the Website, Mobile Application, or the Services; (3) if we believe we are required to do so by law, regulation or legal process, such as a court order or subpoena; (4) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement authorities or tax authorities; (5) when we believe disclosure is appropriate or necessary to protect the rights, property or safety of the Company, our customers or others, including to prevent physical, financial or other harm, injury or loss or to collect a debt you owe; or (6) in connection with an investigation of suspected or actual unlawful activity.

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution or liquidation).

Information from Outside Parties

Examples of information we may receive from other sources include account information; purchase or redemption information; page-view information from some merchants with which we operate co-branded businesses; and information from search results and links, including paid listings (such as Sponsored Links from Google). Content and information that you submit through Facebook, Twitter, Pinterest, Instagram or other online platforms may appear on our Website or Mobile Application through feeds from those platforms. We are not responsible for the dissemination of content or information from, or the privacy practices of, any such platform.

How We Protect Your Information

We maintain administrative, technical, physical, electronic, and procedural safeguards designed and intended to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers’ database, only to be accessible by those authorized with special access rights to such systems, who are required to keep the information confidential.

It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications. Be sure to sign off when finished using a shared computer or device.

Unfortunately, no transmission of data over the Internet or by other means, and no system for storage of data, is guaranteed to be completely secure. It may be possible for hackers or other third parties not under the control of the Company to intercept or access private communications unlawfully. While we strive to protect your personal information, the Company cannot ensure or warrant the security of any information you transmit or otherwise provide to us. Any transmission or other provision of information is done at your own risk.

Information we collect and use may be transferred, stored and accessed from various locations to support our operations. We retain information for as long as it is needed or useful to provide and improve our products and services, comply with our legal obligations, resolve disputes and enforce our agreements.

It is important to note that the Website or Mobile Application may contain links to other websites and that those sites may not follow the same privacy policies as the Company. These sites may send their own cookies to you, and may collect data and make uses of it that the Company would not. If you use these links, you will leave the Website or Mobile Application. These third parties and their websites are not under our control. We do not examine or evaluate these websites and we are not responsible for their content, privacy practices, or operation. By providing links to these websites, we do not approve, warrant or endorse, or otherwise make any representation about them, their owners or operators, or the goods or services that they offer and/or sell, and we do not assume any responsibility or liability relating to any of the foregoing. You should exercise your own judgment in evaluating and using these websites. When you link to these websites, you become subject to their terms and conditions of use and privacy policies. You understand, acknowledge and agree that all access to and use of any such third party website by you shall be at your own risk.

“Opting Out” of Receiving Communications from Us

We offer you certain choices in connection with the personal information we obtain about you. If you no longer want to receive our e-mails, offers, updates on Services, or other communications, please send an email to or follow the “unsubscribe” instructions at the bottom of each email or communication. Please note that you cannot unsubscribe from certain correspondence from us, including certain messages relating to your use of the Services.

You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance, the Network Advertising Initiative, and TrustArc.

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). The Website and Mobile Applications are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Website and Mobile Applications. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.

Additional Information

This Privacy Policy is personal between you and us, and no one else shall be deemed a third party beneficiary through you, of this Privacy Policy.

How to Contact Us

If you have any questions regarding this Privacy Policy or the use of your personal information under this Privacy Policy, you can contact us at the following postal or email address: Privacy Director, Ludlow Street Development, LLC, 110 Edison Place, Suite 300 , Newark, NJ 07102. E-mail: