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Privacy Policy

COOK PROPERTIES PRIVACY POLICY

Last Updated: September 17, 2026

Highland Holdings LLC, doing business as Cook Properties (“Cook Properties,” “we,” “us,” or “our”), respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy describes how we collect, use, disclose, retain, and safeguard personal information when you:

  • Visit CookProperties.com, cookproperties.com, Cook.Properties, the Highland Holdings Tenant Portal, or any other Cook Properties website or online service that links to this Privacy Policy;
  • Apply to rent, purchase, finance, or inquire about a home, property, storage unit, commercial space, or other service;
  • Communicate with us by telephone, email, SMS/text message, social media, online forms, or other means;
  • Use our resident, applicant, payment, property management, or other online portals; or
  • Otherwise interact with Cook Properties.

By accessing or using our websites or services, you acknowledge the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

Information You Provide to Us

We may collect personal information that you voluntarily provide to us, including:

  • Name;
  • Mailing or physical address;
  • Email address;
  • Telephone or mobile phone number;
  • Employment and income information;
  • Payment and billing information;
  • Rental, housing, storage, or property preferences;
  • Emergency contact information;
  • Government-issued identification information;
  • Rental, purchase, financing, or other application information; and
  • Communications, correspondence, inquiries, and other information you provide to us.

If you apply to rent, purchase, or finance a home or property, we or our authorized service providers may collect additional information reasonably necessary to verify your identity, process your application, conduct authorized screenings, evaluate eligibility, process payments, prevent fraud, and comply with applicable legal obligations.

Sensitive Personal Information

In limited circumstances involving applications, financing, payment processing, identity verification, employment, fraud prevention, or legal compliance, Cook Properties or its authorized service providers may process sensitive information, including:

  • Social Security numbers;
  • Driver’s license, state identification, or other government identification information;
  • Financial account or payment information;
  • Credit information or history;
  • Background or screening information; and
  • Other sensitive information required or permitted by applicable law.

We seek to collect and use sensitive information only when reasonably necessary for legitimate business purposes, to provide requested services, or to satisfy legal and regulatory obligations.

Information Automatically Collected

When you access our websites or online services, we and our service providers may automatically collect certain information, including:

  • Internet Protocol (IP) address;
  • Browser type and version;
  • Operating system;
  • Device type and identifiers;
  • Referring and exit URLs;
  • Pages viewed;
  • Links, buttons, and other website interactions;
  • Date and time of visits;
  • Approximate geographic location derived from an IP address;
  • Advertising or analytics identifiers; and
  • Diagnostic, performance, and error information.

We may use this information to operate and secure our websites, understand how visitors use our services, diagnose technical issues, measure marketing effectiveness, and improve the user experience.

2. HOW WE USE INFORMATION

We may use personal information to:

  • Provide, operate, maintain, and improve our services;
  • Respond to inquiries regarding homes, communities, commercial properties, self-storage, or other services;
  • Process rental, housing, purchase, financing, employment, or other applications;
  • Communicate with applicants, residents, customers, prospective customers, vendors, and other individuals;
  • Send account, transaction, maintenance, service, or operational notifications;
  • Respond to customer service or maintenance requests;
  • Schedule appointments and communicate regarding properties or services;
  • Process transactions and payments;
  • Maintain resident, applicant, customer, and business records;
  • Conduct analytics and reporting;
  • Improve and personalize our websites and services;
  • Conduct advertising and marketing activities where permitted by law;
  • Maintain the security of our systems, properties, and services;
  • Detect, investigate, and prevent fraud, abuse, security incidents, or unlawful activity;
  • Establish, exercise, or defend legal rights;
  • Comply with applicable laws, regulations, court orders, and other legal obligations; and
  • Enforce our contracts, agreements, terms, and policies.

We may also use information for another purpose disclosed when the information is collected or with your consent where required.

3. COOKIES AND TRACKING TECHNOLOGIES

Cook Properties and its service providers may use cookies, pixels, tags, web beacons, analytics technologies, and similar technologies when you visit our websites.

These technologies may be used to:

  • Maintain website functionality;
  • Remember preferences;
  • Maintain website and account security;
  • Analyze website traffic and performance;
  • Understand how visitors interact with our websites;
  • Diagnose technical problems;
  • Improve website functionality and user experience;
  • Measure the effectiveness of advertising and marketing campaigns; and
  • Provide or personalize advertising and content where permitted by law.

Depending on the services currently deployed on our websites, these technologies may be provided by third parties such as Google, Meta/Facebook, LinkedIn, Microsoft, HubSpot, advertising providers, analytics providers, and similar technology vendors.

These third parties may collect information according to their own privacy policies and practices.

Most web browsers allow users to block, restrict, or delete cookies. Disabling certain cookies may affect the availability or functionality of portions of our websites.

Where required by applicable law, Cook Properties will provide additional choices regarding non-essential cookies or tracking technologies.

4. SMS, TELEPHONE, AND MOBILE COMMUNICATIONS

If you provide Cook Properties with a telephone or mobile number, we may use that number to communicate with you regarding matters such as:

  • Property or leasing inquiries;
  • Application status or updates;
  • Account notifications;
  • Maintenance requests;
  • Appointments;
  • Resident communications;
  • Payment or service notifications;
  • Property-related information; and
  • Marketing or promotional communications where permitted by law and, where required, with your consent.

Message frequency may vary. Message and data rates may apply.

You may opt out of marketing text messages by replying STOP to an applicable message or by contacting Cook Properties directly. You may continue to receive non-marketing communications when permitted or required by law, such as communications concerning an existing account, tenancy, transaction, maintenance request, or other ongoing business relationship.

Consent to receive marketing text messages is not a condition of purchasing or renting a property or obtaining other services from Cook Properties.

Cook Properties does not sell mobile telephone numbers or SMS consent information to third parties for their independent marketing purposes.

5. RENTAL APPLICATIONS, CREDIT, AND SCREENING

If you apply to rent, purchase, or finance a home or property, Cook Properties and its authorized service providers may process information necessary to:

  • Verify your identity;
  • Process and evaluate your application;
  • Conduct authorized background or tenant screenings;
  • Obtain or evaluate credit information where permitted;
  • Verify employment, income, rental history, or other application information;
  • Evaluate rental, purchase, or financing eligibility;
  • Prevent fraud;
  • Comply with applicable fair housing, consumer reporting, and other laws; and
  • Meet legal or regulatory requirements.

Certain screening, credit reporting, financing, payment, or verification services may be provided by independent third parties. Information processed directly by those parties may also be subject to their respective privacy policies and legal obligations.

Nothing in this Privacy Policy modifies any rights you may have under the Fair Credit Reporting Act or other applicable consumer protection laws.

6. AUTOMATED TOOLS AND ARTIFICIAL INTELLIGENCE

Cook Properties may use automated systems, artificial intelligence (“AI”) technologies, customer relationship management platforms, chat or communication services, analytics platforms, and other software tools to support our operations.

These technologies may assist with activities including:

  • Customer service;
  • Website functionality;
  • Lead and inquiry management;
  • Communications;
  • Analytics and reporting;
  • Marketing;
  • Document or information processing;
  • Application administration;
  • Fraud or security detection; and
  • General operational efficiency.

Cook Properties does not rely solely on automated systems to make final housing, credit, employment, or other legally significant decisions where such use would be prohibited by applicable law.

Information processed through third-party technology or AI providers may be subject to contractual, security, confidentiality, and privacy protections appropriate to the nature of the service.

7. WHEN WE SHARE INFORMATION

Cook Properties does not disclose personal information indiscriminately. We may disclose personal information in the following circumstances:

Service Providers

We may provide information to vendors, contractors, professional advisers, and other service providers that perform services for us, including:

  • Property management services;
  • Applicant and tenant screening;
  • Payment processing;
  • Website hosting and development;
  • Information technology;
  • Cybersecurity;
  • Communications;
  • Customer relationship management;
  • Analytics;
  • Advertising and marketing;
  • Accounting and financial services;
  • Legal services;
  • Document management; and
  • Other operational support.

Service providers may receive information as reasonably necessary to perform services for Cook Properties and are subject to applicable contractual or legal obligations.

Affiliates

We may share information with subsidiaries, affiliates, or companies under common ownership or control when reasonably necessary for legitimate business operations.

Business Transactions

Information may be transferred or disclosed in connection with a proposed or completed merger, acquisition, financing, reorganization, sale of assets, property transaction, corporate restructuring, bankruptcy, or similar business transaction.

Legal and Safety Purposes

We may disclose information when we reasonably believe disclosure is necessary or appropriate to:

  • Comply with applicable laws or regulations;
  • Respond to a subpoena, court order, warrant, or other lawful governmental request;
  • Protect or enforce our legal rights, contracts, or property;
  • Investigate suspected fraud, misconduct, or security incidents;
  • Protect the safety or security of residents, customers, employees, users, or others; or
  • Establish, exercise, or defend legal claims.

8. DATA RETENTION

Cook Properties retains personal information for only as long as reasonably necessary for the purposes for which it was collected and for legitimate legal and business purposes.

These purposes may include:

  • Providing requested services;
  • Maintaining resident, applicant, customer, employment, or transaction records;
  • Meeting legal, tax, accounting, insurance, or regulatory requirements;
  • Resolving disputes;
  • Enforcing contracts or agreements;
  • Preventing fraud or abuse;
  • Maintaining cybersecurity and system records; and
  • Establishing, exercising, or defending legal claims.

Retention periods may vary depending upon the nature of the information, our relationship with the individual, and applicable legal requirements.

When information is no longer reasonably required, Cook Properties may securely delete, destroy, de-identify, or archive it in accordance with applicable law and our records-management practices.

9. DATA SECURITY

Cook Properties maintains reasonable administrative, technical, and physical safeguards designed to protect personal and private information against unauthorized access, acquisition, disclosure, alteration, misuse, loss, or destruction.

Depending on the nature of the information and system involved, these measures may include:

  • Encryption;
  • Firewalls and network security;
  • Identity and access controls;
  • Multi-factor authentication;
  • Security monitoring;
  • Endpoint and system protections;
  • Vendor security oversight;
  • Employee cybersecurity and privacy training;
  • Risk assessments; and
  • Incident response procedures.

Although Cook Properties takes reasonable measures to protect information, no method of electronic transmission, network communication, or data storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information.

10. REQUESTS REGARDING YOUR PERSONAL INFORMATION

Depending upon applicable law and the circumstances of our relationship with you, you may be entitled to certain rights or may request that Cook Properties:

  • Provide information regarding personal information we maintain about you;
  • Correct inaccurate or outdated personal information;
  • Delete certain personal information;
  • Stop or limit certain marketing communications; or
  • Withdraw consent where processing is based upon consent.

To submit a privacy request, contact Cook Properties using the contact information provided in Section 17 below.

For security purposes, we may take reasonable steps to verify your identity before providing, modifying, or deleting personal information.

Cook Properties may deny or limit a request where permitted by law, including when information must be retained to comply with legal or regulatory requirements, complete a transaction, maintain required business records, prevent or investigate fraud, resolve disputes, enforce agreements, protect legal rights, maintain security, or fulfill another legitimate business purpose.

We will respond to verified requests as required by applicable law.

11. NEW YORK PRIVACY AND DATA SECURITY

Cook Properties is headquartered in New York and maintains administrative, technical, and physical safeguards designed to protect private information in accordance with applicable New York law, including the New York SHIELD Act.

Our safeguards are designed to protect the security, confidentiality, and integrity of private information and may include appropriate access controls, cybersecurity protections, employee training, vendor oversight, risk assessments, monitoring, and secure information disposal practices.

If Cook Properties discovers a breach involving private information, we will investigate the incident and provide notifications to affected individuals, government agencies, consumer reporting agencies, or other parties when required by applicable New York law.

Cook Properties may also voluntarily honor reasonable requests regarding personal information when practicable and when doing so does not conflict with our legal, contractual, security, record-retention, fraud-prevention, or legitimate business obligations.

12. GEOGRAPHIC SCOPE AND CALIFORNIA PRIVACY

Cook Properties is a New York-based business. Our properties, communities, facilities, and primary business operations are located within the State of New York, and our property-related services are intended primarily for individuals and businesses seeking housing, commercial property, self-storage, or related services within New York.

Cook Properties does not own, operate, or manage properties in the State of California, does not specifically market its properties or services to California residents, and does not intentionally solicit or conduct property-related business in California.

Our websites are publicly accessible and therefore may be viewed by individuals located outside New York, including individuals located in California. Such accessibility does not reflect an intention by Cook Properties to market or provide its property-related services in California.

Based on our current operations and business practices, Cook Properties does not consider itself a business subject to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Nothing in this Privacy Policy is intended to waive, restrict, or eliminate any right or obligation that applies under applicable law.

If Cook Properties expands its operations, begins conducting business in additional jurisdictions, or becomes subject to additional privacy requirements, we may update our privacy practices and this Privacy Policy as appropriate.

13. THIRD-PARTY WEBSITES AND SERVICES

Our websites and services may contain links to or integrate with websites, payment platforms, resident portals, applicant portals, social media platforms, maps, embedded content, or other services operated by third parties.

Cook Properties does not control the privacy, security, or information-handling practices of independent third parties.

Information you provide directly to a third-party service may be governed by that provider’s privacy policy, terms of service, and security practices.

We encourage you to review the applicable privacy policies before providing personal information to third-party services.

14. CHILDREN’S PRIVACY

Cook Properties’ websites and services are intended for adults and are not directed toward children under the age of 18.

We do not knowingly solicit personal information directly from children under 18 through our general websites or marketing services.

Information regarding minors may, however, be provided by a parent, guardian, applicant, resident, or other authorized individual when reasonably necessary for legitimate housing, residency, emergency contact, legal, or administrative purposes.

If we become aware that personal information was collected directly from a child in a manner inconsistent with applicable law, we will take reasonable steps to address or delete the information as appropriate.  

You can request we remove the personally identifiable information of a minor by completing Cook Properties Data Subject Access Request (DSAR) form. 

15. ACCESSIBILITY

Cook Properties is committed to providing accessible and usable online services.

If you experience difficulty accessing content, features, or functionality on a Cook Properties website, please contact us at (585) 434-3032 or Contact@CookProperties.com.

We will make reasonable efforts to provide the requested information or assistance through an accessible alternative where appropriate.

16. CHANGES TO THIS PRIVACY POLICY

Cook Properties may update this Privacy Policy periodically to reflect changes in:

  • Our business operations;
  • Information collection or processing practices;
  • Technologies or service providers;
  • Websites or online services;
  • Legal or regulatory requirements; or
  • Security and privacy practices.

When we make changes, the revised Privacy Policy will be posted on our website and the “Last Updated” date at the top of the policy will be updated.

We encourage visitors to periodically review this Privacy Policy for changes.

17. CONTACT INFORMATION

If you have questions regarding this Privacy Policy, our privacy practices, or personal information maintained by Cook Properties, or if you would like to submit a privacy-related request, please contact:

Cook Properties
Highland Holdings LLC d/b/a Cook Properties
Attn: IT Department
90 Airpark Drive, Suite 400
Rochester, NY 14624

Phone: (585) 434-3032
Email: Contact@CookProperties.com

When submitting a privacy request, please provide sufficient information for us to understand the request and reasonably identify the relevant records. For security purposes, Cook Properties may request additional information necessary to verify your identity before fulfilling certain requests

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To request to review, update, or delete your personal information, please fill out and submit the Cook Properties Data Subject Access Request (DSAR) form.