terms & policies

This website (the “Site”), is owned and operated by wpg (also referred to herein as “we”, “us”, “our”). This Privacy Policy (the “Policy”) has been instituted to explain to Site users and visitors (“you”, “your”) how we collect, use, disclose, and protect the Personal Information of users and visitors to the Site. The term “Personal Information” as used in this Policy refers to information that identifies you personally, alone or in combination with other information available to us. Examples of Personal Information include, but are limited to, your name, home address, e-mail address, mobile phone number, and credit card information.

This Policy applies only to the collection, use, disclosure, and protection of data or information collected through the Site and does not apply to any other data or information collected by us online or offline except to the extent this Policy is expressly incorporated by us, such as by internet link on a website or presentation or display to users in the course of providing services. Users and visitors to the Site are subject to the terms, conditions, and provisions stated in this Policy and any other relevant terms, conditions, policies, or notices posted or included on the Site. By visiting or using the Site, you agree to the terms of this Policy and, if you provide us your Personal Information, you consent to the collection, use and disclosure of your information as described in this Policy. If you do not agree with this Policy, please do not provide us any Personal Information and do not use the Site.

This Policy is Part of Our Terms of Use

This Policy is part of the Terms of Use that govern your use of this Site. A link to our Website Terms of Use is provided at the bottom of each page of this Site.

Privacy Notices

This Policy may be supplemented or amended from time to time by “Privacy Notices” posted on this Site. These Privacy Notices provide a level of detail that we cannot provide in this more general description of our privacy practices. For example, certain pages of this Site may contain Privacy Notices providing details about the Personal Information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.

Do Not Track Signals

Certain browsers may allow you to request that websites not track your activities over time and across third party websites or other online services by sending “do not track” signals to commercial websites like the Site. We do follow the “do not track” directions provided by your browser. This Privacy Policy provides the details regarding the types of tracking mechanisms in place on the Site, the types of information collected by such tracking mechanisms, whether you have the option to control how and when such tracking mechanisms are used, whether and how third parties use tracking mechanisms on the Site, and whether those third party tracking mechanisms are activated before or after you leave the Site.

Types of Information We Collect

Information You Volunteer. wpg collects the Personal Information you and others knowingly and voluntarily provide when you use this Site. For example, we collect the Personal Information you submit when you sign up for our news alerts, submit an application, or contact us with questions. In addition, you may provide Personal Information in order to use, or participate in, certain optional features of the Site. The manner in which we will use this Personal Information, if any, will be disclosed on the page through which you sign up for, or otherwise provide information to use, or participate in, the applicable feature. For the avoidance of doubt, we will not share or use your mobile number for any other purpose than to send you mobile SMS alerts, in accordance with carrier and Mobile Marketing Association (MMA) guidelines.

When you complete forms online or otherwise provide us Personal Information in connection with a program, you agree to provide accurate, complete and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If we, in our sole discretion, believe that any such information is untrue, inaccurate or incomplete, we may prohibit you from further participation in the applicable program and pursue any appropriate legal remedies.

Except as expressly set out in this Privacy Policy, or as disclosed when you sign up for, or otherwise provide Personal Information to use, or participate in, an optional feature on the Site, we will not disclose any Personal Information to a third party without your express prior authorization, nor will we use that information for any purpose other than to provide the applicable feature. However, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.

Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your web browser. This information typically includes, but is not limited to, your internet protocol (“IP”) address, the identity of your Internet service provider (ISP), the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. Please check your browser if you want to learn what information your browser sends or how to change your settings.

Information from your mobile device. If you access the mobile version of this Site, we may automatically collect certain information from or about your mobile device. The types of information we may collect includes, but is not limited to, the type of device you use, your device’s unique identification number, the IP address of your device, your device’s operating system, the type of mobile Internet browser(s) you use, and information about the way you use our mobile application(s) on this Site.

More About IP Addresses. An “IP address” is a unique number that is automatically assigned to your computer when you connect to the Internet. It is used to identify your computer’s “location” in cyberspace, so that the information you request can be delivered to you. IP addresses do not include your name, e-mail address, or other information that identifies you personally, but in some cases, they can be used to identify you. For example, if you have registered with this Site, we may link your IP address to account information that identifies you personally. We may also provide your IP address to our third-party service providers who can use it to identify your state and zip code. In addition, if, we suspect inappropriate or criminal activity or a threat to the security of this Site, we may share our server logs—which contain users’ IP addresses—with the appropriate investigative authorities, who could use that information to trace and identify individuals.

Cookies and Similar Technologies. We use “cookies” and other web technologies to collect information and support certain features of this Site and provide other services (collectively, the “Services”). Our use of cookies is subject to our Cookie Notice, which is fully incorporated herein.

How We Use Personal Information Collected Through This Site

Generally, we use the Personal Information we collect through this Site: (A) to provide the information and services you request; (B) to better understand your needs and interests; (C) to provide you with a personalized experience when you use this Site; (D) to provide you with effective customer service; (E) to improve the content, functionality and usability of this Site; (F) to contact you with information and notices related to your use of this Site; (H) to contact you with special offers and other information we believe will be of interest to you; (I) to invite you to participate in surveys and provide feedback to us (with “feedback” meaning the content you post on or through this Site that is specifically about how we can improve this Site and the products and services we make available through this Site); (J) to improve our services; (K) to improve our marketing and promotional efforts; (L) for security, credit, or fraud prevention purposes; and (M) for any other purpose identified in any other notice or agreement between you and us.

We may occasionally use third-party advertising companies and advertising networks to serve advertisements to you on our behalf when you visit the Site. These companies may use Personal Information about your visits to the Site and other web sites in order to provide advertisements about goods and services that may be of interest to you. If you would like more information about this practice and how to opt-out of receiving communications from these third-party advertising companies, visit http://www.networkadvertising.org/choices.

We can and will use IP addresses and/or MAC addresses to identify a user when we feel it is necessary to enforce compliance with our Terms of Use or to protect the Site, users, or other individuals. We also reserve the right to use or disclose non- Personal Information in any manner we see fit in order to improve the Site.
Please see below for information about the choices you have about the ways we use your Personal Information.

Use of Aggregated and De-Identified Information

We may use information gathered through this Site to create a compiled, aggregate view of its audience and visitors’ usage patterns. We use aggregated and/or de-identified information to operate our services and to better understand our audience as we develop new services and compile information for your use. We may also share aggregated and/or de-identified information with our third-party service providers and/or investors. Aggregate and de-identified information is not personally identifiable, but in some cases, it can be used to identify you as provided elsewhere in this Privacy Policy.

Your Choices

In General. We respect your right to make choices about the ways we collect, use, and disclose your Personal Information. Discussed above are choices you have about delivery of cookies through this Site and about our collection of location information. In addition, we may ask you to indicate certain choices at the time we collect your Personal Information. For example, at the time you give us your contact information, we may provide to you an opportunity to choose (via “opt out” or “opt in”) whether you receive certain communications from our business partners.

Previously Expressed Preferences. You may change previously expressed preferences regarding how we use your Personal Information. If you have registered with this Site, you may be able to change certain privacy preferences through your account settings. Otherwise, if at any time you wish to be taken off our mailing lists, please contact us using the information provided above. Once we have the information we need, we will remove you from our mailing lists as you have requested. Please give us a reasonable amount of time to honor your request.

How to Access, Update or Correct Your Personal Information

If you wish to access, update, or correct your Personal Information, please contact us using the information provided in this Policy. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.

Steps We Take to Safeguard your Personal Information

We maintain reasonable administrative, physical, and technological measures to protect the confidentiality and security of Personal Information you submit on or through this Site. Unfortunately, no Web site, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your Personal Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. In addition, wpg may use a third-party service provider or providers to process credit card transactions and fulfill online orders, which service provider(s) may share information and credit card numbers with a ticket agent, a credit card processing company, an issuing bank, the card network issuer and/or a shipping/fulfillment company in order to complete an order. We urge you to take every precaution to protect your Personal Information when you are on the internet. If a password is used to help protect that information, it is your responsibility to keep your password confidential. If you are sharing a computer with anyone, we suggest you log out before leaving a site or service in order to protect subsequent users from gaining access to your information and decline to have your Internet browser remember your password. Due to the fact that no physical or electronic security is impenetrable, by using the Site, you agree to assume all risk in connection with your Personal Information.

How We Share Your Personal Information With Others

Third–Party Vendors. We may share Personal Information collected through this Site with other third-party vendors who act for or on behalf of wpg. For example, we may share Personal Information with companies that provide web hosting or email services for our newsletters, emails, and other communications. This may include serving you relevant advertisements embedded in these communications. These third-party vendors may need information about you to perform their functions.

User-Generated Content. We may offer you the ability to submit User-Generated Content on or through this Site. “User-Generated Content” refers to all of the content that you post on or through this Site using the social networking tools we make available to you and that does not constitute feedback. One way that User-Generated Content differs from other information you provide to us is that, once submitted, User-Generated Content is made available instantaneously to others. Examples of User-Generated Content include comments posted to discussion boards. User-Generated Content is available to others who visit this Site. In addition, we may repurpose User-Generated Content you submit on or through this Site for use in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your further consent before using User-Generated Content for such purposes. Therefore, you should have no expectation of privacy with respect to User-Generated Content you submit on or through this Site. You should not submit any User-Generated Content you do not wish to make available to the general public, and you must take special care to make sure your submissions comply with our Terms of Use and Legal Restrictions (the “Terms of Use”). In particular, your submissions must not violate the privacy or other rights of others.

Business Negotiations. We may contemplate, for strategic or other reasons, selling, buying, merging, or otherwise reorganizing one or more of our businesses. In negotiating with a third party about entering into such an arrangement, we may need to disclose your Personal Information. In such cases, we will take reasonable measures to protect the Personal Information we disclose, for example, by requiring a prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the Personal Information.

Business Transfers. Your Personal Information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization. If such a transfer occurs, the successor organization’s use of your Personal Information will still be subject to this Policy and the privacy preferences you have expressed to us.

Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose your Personal Information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. These disclosures may also include exchanging information with other companies and organizations for fraud protection and credit risk reduction, to report any suspected illegal activity to law enforcement for investigation or prosecution and/or in connection with legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) rights or property of wpg and/or the rights or property of any third party. We reserve the right to release information concerning any user of the Site when that user is in violation of our Terms of Use or other published guidelines or partakes (or is reasonably suspected of partaking) in any illegal activity.

As Described in a Privacy Notice. We reserve the right to disclose your Personal Information as described in any Privacy Notice posted on the Web page where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that Privacy Notice.

Children Under the Age of Thirteen

This Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted Personal Information on or through this Site without the consent and supervision of a parent or guardian, please contact us using the information provided below. The use of this Site in any way which is not in compliance with this provision constitutes a violation of our Terms of Use.

Your California Privacy Rights

Pursuant to California Business and Professions Code Section 1798.83 et sec (“Shine the Light”), as amended, residents of California have the right to request from a business with whom the California resident has an established business relationship certain information with respect to the types of Personal Information the business shares with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

In addition, an operator of a commercial website subject to California Business and Professions Code Section 22581 et sec, as amended, must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. If this applies to you and you wish to make such a request, your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Pursuant to California Business and Professions Code Section 1798.100 et sec (the “California Consumer Privacy Act” or “CCPA”), as amended, California residents meeting the definition of consumers qualify for certain additional rights. For more information please visit our Supplemental Privacy Notice for California Consumers.

To exercise your rights, please contact us using one of the options provided below under the heading “To Contact Us.”

Visiting the Site From Outside of the United States

wpg is a United States company focused on managing a real-estate portfolio of shopping centers located in the United States. Although the Site may be accessible in some locations outside of the U.S., it is not our intention to offer goods or service to individuals outside of the U.S. Also, the information we collect may be stored and processed in the U.S. The laws of the U.S. may offer less protection than the laws of your place of residence if you are located outside of the U.S. We will keep this information only as long as we need it for the purposes described above.

In the event we offer services that are subject to the General Data Protection Regulation (GDPR), we will comply with requests which could include the right to access information we hold about you, have inaccurate or unnecessary information rectified or deleted or to ask us to stop using your information in a certain way. In the unlikely event your use of the Services is subject to GDPR, you would also have a right to lodge a complaint with your local EU regulator.

Links to Other Sites

This Site may contain links to websites operated by other organizations, including websites operated by our third-party service providers and other third parties. This Policy does not apply to Personal Information collected on any of these third-party websites. When you access third-party websites through a link on this Site, please take a few minutes to review the privacy policy posted on that site.

This Policy May Change

This Policy describes wpg’s current policies and practices with regard to the Personal Information we collect through this Site. We are continually improving and adding to the features and functionality of this Site and the services we offer through this Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. For your convenience, whenever this Policy is changed, we will alert you by posting a notice on our home page. We will also update the “effective date” at the bottom of this Policy. If we have your email address, we may also attempt to email you with notice that the Policy has changed. You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of this Site.

To Contact Us

If you have any questions about this Policy or our privacy practices you may contact us by electronic mail at [email protected] or call us toll free at 1-844-943-0270.

Effective Date of this Policy: March 1, 2023

I. Policy Introduction & Overview. This website (the “Site”), is owned and operated by wpg (also referred to herein as (“we,” “us,” or “our”). These Terms of Use govern your use of this Site and each website or service in which it is expressly incorporated, such as by internet link on a website or presentation or display to Site users in the course of providing services.

II. Your Acceptance of These Terms of Use. These Terms of Use apply to all users of this Site. By using this Site you are agreeing to comply with and be bound by these Terms of Use. If you do not agree to these Terms of Use, you may not access or use this Site.

III. Your Acceptance of Our Privacy Policy. By agreeing to these Terms of Use, you agree to the terms of our Privacy Policy, which is expressly incorporated herein. Before using this Site, please carefully review our Privacy Policy. All Personal Information (as defined in the Privacy Policy) provided to us as a result of your use of this Site will be handled in accordance with our Privacy Policy.

IV. Your Consent to Other Agreements. Certain aspects of the Site may be provided by one or more third parties. Such third parties may have their own policies and end user license agreements (collectively, “Third Party Policies and EULAs”) that apply to your use of the Site. Nothing in this Terms of Use is intended to modify or limit such Third Party Policies and EULAs. This Terms of Use only applies to the Site to the extent actually developed, distributed, licensed and supported by or on behalf of wpg. We may also require you to follow additional rules, guidelines or other conditions to sign up to use various special features or password-protected areas of this Site, to participate in certain programs, promotions or activities available through this Site, or for other reasons. In such cases, you may be asked to expressly consent to these additional terms, for example, by checking a box or clicking on a button marked “I agree.” This type of agreement is known as a “click-through” agreement. If any of the terms of a click-through agreement are different than the terms of these Terms of Use, the terms of the click-through agreement will supplement or amend these Terms of Use, but only with respect to the matters governed by the click-through agreement.

V. Ownership of this Site and its Content This Site, including all its content, are protected under applicable intellectual property and other laws, including without limitation the laws of the United States and other countries. The word “content” as used in these Terms of Use refers to all of the software and code comprising or used to operate this Site, and all of the text, photographs, images, illustrations, graphics, sound recordings, video and audio-video clips, and other materials available on this Site, including user-generated content. All content and intellectual property rights therein are the property of wpg or the material is included with the permission of the rights owner and is protected pursuant to applicable copyright and trademark laws. The presence of any content on this Site does not constitute a waiver of any right in such content. You do not acquire ownership rights to any such content viewed through this Site. Except as otherwise provided herein, none of this content may be used, copied, reproduced, distributed, republished, downloaded, modified, displayed, posted or transmitted in any form or by any means, including, but not limited to, electronic, mechanical, photocopying, recording, or otherwise, without the express prior written permission of wpg. Permission is hereby granted to the extent necessary to lawfully access and use this Site and to display, download, or print portions of this Site on a temporary basis and for your personal, noncommercial use only, provided that you (i) do not modify the content; (ii) you retain any and all copyright and other proprietary notices contained in the content; and (iii) you do not copy or post the content on any network or computer or post or broadcast the content in any media.

VI. Responsibility for User-Generated Content Posted on or Through this Site You are responsible for User-Generated Content that you post. The term “User-Generated Content” refers to all of the Content that you post on or through this Site using the social networking tools we make available to you and that do not constitute Feedback (defined below). One way that User-Generated Content differs from other information you provide to us is that, once submitted, User-Generated Content is made available instantaneously to others. Examples of User-Generated Content include comments posted to discussion boards. Under no circumstances will we be liable in any way for any User-Generated Content.

This means that you, not wpg, are entirely responsible for all User-Generated Content that you post and that you can be held personally liable for comments that are defamatory, obscene, or libelous, or that violate these Terms of Use, an obligation of confidentiality, or the rights of others. If any part of the User-Generated Content you post is not your original work, it is your responsibility to obtain any necessary permission to post it.
Because we do not control the User-Generated Content posted on or through this Site, we cannot and do not warrant or guarantee the truthfulness, integrity, suitability, or quality of that User-Generated Content. You also agree and understand that by accessing this Site, you may encounter User-Generated Content that you may consider to be objectionable. We have no responsibility for any User-Generated Content, including without limitation any errors or omissions therein. We are not liable for any loss or damage of any kind you claim was incurred as a result of the use of any User-Generated Content posted, e-mailed, transmitted or otherwise made available on or through this Site. The User-Generated Content posted on or through this Site expresses the personal opinions of the individuals who posted it and does not necessarily reflect the views of wpg or any person or entity associated with wpg.

You own User-Generated Content, but we may use it. You own the copyright in any original User-Generated Content you post. We do not claim any copyrights in User-Generated Content. However, by using this Site you are granting us and our subsidiaries, affiliates, vendors, successors and assigns, a nonexclusive, fully paid, worldwide, perpetual, irrevocable, royalty-free, transferable license (with the right to sublicense through unlimited levels of sub-licensees) to use, copy, modify, distribute, publicly display and perform, publish, transmit, remove, retain, repurpose, and commercialize User-Generated Content you post in any and all media or form of communication whether now existing or hereafter developed, without obtaining additional consent, without restriction, notification, or attribution, and without compensating you in any way, and to authorize others to do the same. For this reason, we ask that you not post any User-Generated Content that you do not wish to license to us, including any confidential information or product ideas.
We may disclose and/or remove User-Generated Content. wpg reserves certain rights. We reserve the right (but do not assume the obligation) to:

• monitor all User-Generated Content;

• require that you avoid certain subjects, if we believe that doing so will help ensure compliance with applicable laws or these Terms of Use;

• remove or block any User-Generated Content at any time without notice at our sole and absolute discretion;

• disclose any User-Generated Content and the identity of the user who posted it in response to a subpoena, or other legal process, or whenever we believe that disclosure is appropriate to comply with the law or a court order, to prevent or investigate a possible crime or other violation of law, to protect the rights of wpg or others, or to enforce these Terms of Use;

• require that you avoid certain subjects, if we believe that doing so will help ensure compliance with applicable laws or these Terms of Use;

• remove or block any User-Generated Content at any time without notice at our sole and absolute discretion;

• disclose any User-Generated Content and the identity of the user who posted it in response to a subpoena, or other legal process, or whenever we believe that disclosure is appropriate to comply with the law or a court order, to prevent or investigate a possible crime or other violation of law, to protect the rights of wpg or others, or to enforce these Terms of Use; and

• terminate your access to and use of this Site, or to censor, edit, or block your transmissions thereto in our sole discretion.

You agree that our exercise of such discretion shall not render us the owners of User-Generated Content you post, and that you will retain ownership thereof as described above.

Restrictions on User-Generated Content. It is a condition of these Terms of Use that you do not:

• upload, post, transmit or otherwise make available:
o any User-Generated Content that is unlawful, harmful, hateful, threatening, abusive, harassing, libelous, defamatory, obscene, vulgar, pornographic, profane, racially disparaging, indecent, or invasive of another’s privacy;
o any User-Generated Content that constitutes or promotes any illegal activity, including, without limitation, any User-Generated Content constituting or encouraging conduct that would be a criminal offense, give rise to civil liability or otherwise violate any local, state, national or foreign law;
o any User-Generated Content that is false, misleading, or fraudulent;
o any User-Generated Content that you do not have a right to make available under any law or under contractual or fiduciary relationships (such as inside information or proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements);
o any User-Generated Content that violates or infringes upon the rights of others, including User-Generated Content which violates the patent rights, copyrights, trademark rights, privacy rights, publicity rights, trade secret rights, confidentiality rights, contract rights, or any other rights of any individual, living or deceased, or any legal entity;
o any User-Generated Content that contains the image, name or likeness of anyone other than yourself, unless (i) that person is at least eighteen years old and you have first obtained his/her express permission or (ii) that person is under eighteen years old but you are his/her parent or legal guardian;
o any request for or solicitation of any personal or private information from any individual;
o any request for or solicitation of money, goods, or services for private gain;
o any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; or
o any User-Generated Content that contains advertising, promotions or marketing, or which otherwise has a commercial purpose;

• impersonate any person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity; or

• violate any local, state, national or international law, rule or regulation.

By posting User-Generated Content, you represent and warrant that (i) you own or otherwise control all of the rights to the User-Generated Content and have the right to grant the license set forth in these Terms of Use; (ii) the User-Generated Content is accurate, and (iii) you are at least eighteen years old and you have read and understood—and your User-Generated Content fully complies with—these Terms of Use and applicable laws and will not cause injury to any person or entity.

VII. Your Feedback. Although we do not claim ownership of User-Generated Content you post using this Site, the feedback you provide to us through this Site will be and remain our exclusive property. As used in these Terms of Use, the word “feedback” refers to the content you post on or through this Site that is specifically about how we can improve this Site and our services and programs. Your submission of feedback will constitute an assignment to us of all worldwide rights, title and interests in your feedback, including all copyrights and other intellectual property rights in your feedback. We will be entitled to reduce to practice, exploit, make, use, copy, disclose, display or perform publicly, distribute, improve and modify any feedback you submit for any purpose whatsoever, without restriction and without compensating you in any way. For this reason, we ask that you not send us any feedback that you do not wish to assign to us.

VIII. Removal of Content. In general. On certain pages of this Site, we may provide to you a tool to report objectionable User-Generated Content. If that tool is not available, you can report objectionable User-Generated Content and other objectionable content by contacting us using the information provided below. While we do not have any obligation to remove content from this Site merely because of a removal request, we will remove content that we determine should be removed, in our sole discretion and in accordance with these Terms of Use and applicable law. Please be aware, however, that if the content has already been distributed to other websites or published in other media, we will not be able to recapture and delete it. Also, a back-up or residual copy of the content we remove from this Site may remain on back-up servers.

Violation of copyrights. wpg does not knowingly violate or permit others to violate the copyrights of others. We will promptly remove or disable access to material that we know is infringing or if we become aware of circumstances from which infringing activity is apparent. If you are requesting removal of content because of a violation of your copyrights, please note that the Digital Millennium Copyright Act of 1998 (the “DMCA”), as amended and supplemented, provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you believe that your own work, or the work of a third party for whom you are authorized to act, is featured on this Site or has been otherwise copied and made available on this Site in a manner that constitutes copyright infringement, please notify us immediately. Your notice must be in writing and must include:

• an electronic or physical signature of the copyright owner or of the person authorized to act on behalf of the owner of the copyright interest;

• a description of the copyrighted work that you claim has been infringed, including any copyright registration numbers;

• a description of where the material that you claim is infringing is located on this Site (including the URL, title and/or item number if applicable, or other identifying characteristics);

• your full name, address, telephone number, and e-mail address, and, if you are not the owner of the copyright, the name of the owner;

• a written statement by you that you have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and

• a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.

Your statement must be addressed as follows:

By Mail: wpg
180 East Broad Street, 21st Floor
Columbus, Ohio 43215
Attn: General Counsel

By Email: [email protected].

Any notification by a copyright owner or a person authorized to act on its behalf that fails to comply with requirements of the DMCA shall not be considered sufficient notice and shall not be deemed to confer upon us actual knowledge of facts or circumstances from which infringing material or acts are evident.

XI. Trademarks. The wpg names and logos, all product and service names, all custom graphics, all button icons, and all trademarks, service marks and logos appearing within this Site, unless otherwise noted, are trademarks (whether registered or not), service marks and/or trade dress of wpg (the “wpg Marks”). All other trademarks, product names, company names, logos, service marks and/or trade dress mentioned, displayed, cited or otherwise indicated within this Site are the property of their respective owners. You are not authorized to display or use the wpg Marks in any manner without our prior written permission. You are not authorized to display or use trademarks, product names, company names, logos, service marks and/or trade dress of other owners featured within this Site without the prior written permission of such owners. The use or misuse of the wpg Marks or other trademarks, product names, company names, logos, service marks and/or trade dress or any other materials contained herein, except as permitted herein, is expressly prohibited.

X. Your Obligations. In consideration of your use of this Site, you agree that to the extent you provide Personal Information to wpg it will be true, accurate, current, and complete and that you will update all Personal Information as necessary. If you submit a leasing application through the Site, you agree that it and any supporting contents will be true, accurate, current, and complete. You agree to use this Site in a manner consistent with any and all applicable rules and regulations. You agree not to upload or transmit through this Site any computer viruses, trojan horses, malware, worms or anything else designed to interfere with, interrupt or disrupt the normal operating procedures of a computer. Any unauthorized modification, tampering or change of any information, or any interference with the availability of or access to this Site is strictly prohibited. We reserve all rights and remedies available to us.

XI. Disclaimers. WE MAKE NO REPRESENTATIONS OR WARRANTIES WITH RESPECT TO THIS SITE OR ITS CONTENT, OR ANY PRODUCT OR SERVICE AVAILABLE ON OR PROMOTED THROUGH THIS SITE. THIS SITE AND ALL OF ITS CONTENT (INCLUDING USER-GENERATED CONTENT) ARE PROVIDED ON AN “AS IS,” “AS AVAILABLE” BASIS, WITHOUT REPRESENTATIONS OR WARRANTIES OF ANY KIND. TO THE FULLEST EXTENT PERMITTED BY LAW, WPG AND ITS SERVICE PROVIDERS AND LICENSORS DISCLAIM ANY AND ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS, IMPLIED, ARISING BY STATUTE, CUSTOM, COURSE OF DEALING, COURSE OF PERFORMANCE OR IN ANY OTHER WAY, WITH RESPECT TO THIS SITE, ITS CONTENT, AND ANY PRODUCTS OR SERVICES AVAILABLE OR PROMOTED THROUGH THIS SITE. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, WPG AND ITS SERVICE PROVIDERS AND LICENSORS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES (A) OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE; (B) RELATING TO THE SECURITY OF THIS SITE; (C) THAT THE CONTENT OF THIS SITE IS ACCURATE, COMPLETE OR CURRENT; OR (D) THAT THIS SITE WILL OPERATE SECURELY OR WITHOUT INTERRUPTION OR ERROR.
WE DO NOT REPRESENT OR WARRANT THAT THIS SITE, ITS SERVERS, OR ANY TRANSMISSIONS SENT FROM US OR THROUGH THIS SITE WILL BE FREE OF ANY HARMFUL COMPONENTS (INCLUDING VIRUSES).

WPG DOES NOT ENDORSE AND IS NOT RESPONSIBLE FOR STATEMENTS, ADVICE AND OPINIONS MADE BY ANYONE OTHER THAN AUTHORIZED WPGLP SPOKESPERSONS. WE DO NOT ENDORSE AND ARE NOT RESPONSIBLE FOR ANY STATEMENTS, ADVICE OR OPINIONS CONTAINED IN USER-GENERATED CONTENT AND SUCH STATEMENTS, ADVICE AND OPINIONS DO NOT IN ANY WAY REFLECT THE STATEMENTS, ADVICE AND OPINIONS OF WPG. WE DO NOT MAKE ANY REPRESENTATIONS OR WARRANTIES AGAINST THE POSSIBILITY OF DELETION, MISDELIVERY OR FAILURE TO STORE COMMUNICATIONS, PERSONALIZED SETTINGS, OR OTHER DATA. YOU ACCEPT THAT WPG’S OWNERS, OFFICERS, MANAGERS, EMPLOYEES AND OTHER REPRESENTATIVES SHALL HAVE THE BENEFIT OF THIS CLAUSE.

APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OF CERTAIN WARRANTIES, SO ALL OR PART OF THIS DISCLAIMER OF WARRANTIES MAY NOT APPLY TO YOU.

XII. LIMITATION OF LIABILITY. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS WE, ON BEHALF OF OUR MANAGERS, OFFICERS, EMPLOYEES, AGENTS, SUPPLIERS, LICENSORS AND SERVICE PROVIDERS, EXCLUDE AND DISCLAIM LIABILITY FOR ANY LOSSES AND EXPENSES OF WHATEVER NATURE AND HOWSOEVER ARISING INCLUDING, WITHOUT LIMITATION, ANY DIRECT, INDIRECT, GENERAL, SPECIAL, PUNITIVE, INCIDENTAL OR CONSEQUENTIAL DAMAGES; LOSS OF USE; LOSS OF DATA; LOSS CAUSED BY A VIRUS; LOSS OF INCOME OR PROFIT; LOSS OF OR DAMAGE TO PROPERTY; CLAIMS OF THIRD PARTIES; OR OTHER LOSSES OF ANY KIND OR CHARACTER, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, ARISING OUT OF OR IN CONNECTION WITH THE USE OF THIS SITE. YOU ASSUME TOTAL RESPONSIBILITY FOR ESTABLISHING SUCH PROCEDURES FOR DATA BACK UP AND VIRUS CHECKING AS YOU CONSIDER NECESSARY. THIS LIMITATION OF LIABILITY APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR ANY OTHER BASIS. IF ANY PART OF THIS LIMITATION ON LIABILITY IS FOUND TO BE INVALID OR UNENFORCEABLE FOR ANY REASON, THEN THE AGGREGATE LIABILITY OF THE RELEASED PARTIES FOR LIABILITIES THAT OTHERWISE WOULD HAVE BEEN LIMITED SHALL NOT EXCEED TEN DOLLARS ($10.00).

This Site gives you specific legal rights and you may also have other rights which vary from state to state and country to country. Some jurisdictions do not allow certain kinds of limitations or exclusions of liability, so the limitations and exclusions set out in these Terms of Use may not apply to you. Other jurisdictions allow limitations and exclusions subject to certain conditions. In such a case the limitations and exclusions set out in these Terms of Use shall apply to the fullest extent permitted by the laws of such applicable jurisdictions.

XIII. Links to Third-Party Web Sites. This Site may provide links to other Web sites operated by third parties. Because we have no control over third-party Web sites, we are not responsible for the availability of those Web sites and do not endorse and are not responsible or liable for any content, advertising, services, products, or other materials on or available from such Web sites. wpg shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any content, advertising, services, products, or other materials on or available from such Web sites. These Terms of Use do not apply to your use of third-party Web sites; your use of such Web sites is subject to the terms and policies of the owner of such Web sites.

XIV. Modification and Discontinuation. We reserve the right at any time and from time-to-time to modify, edit, delete, suspend or discontinue, temporarily or permanently, this Site (or any portion thereof) and/or the information, materials, products and/or services available through this Site (or any part thereof) with or without notice. You agree that we shall not be liable to you or to any third party for any such modification, editing, deletion, suspension or discontinuance of this Site.

XV. Forward-Looking Statements. This Site may contain certain forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Such statements are based on assumptions and expectations that may not be realized and are inherently subject to risks and uncertainties, many of which cannot be predicted with accuracy. Future events and actual results, financial and otherwise, may differ from the results discussed in the forward-looking statements. Risks and other factors that might cause differences, some of which could be material, include, but are not limited to, economic and market conditions, tenant bankruptcies, bankruptcies of joint venture (JV) partners, rejection of leases by tenants in bankruptcy, financing and development risks, construction and lease-up delays, cost overruns, the level and volatility of interest rates, the rate of revenue increases versus expense increases, the financial stability of tenants within the retail industry, the failure of wpg to make additional investments in regional mall properties and redevelopment of properties, the failure to acquire properties as and when anticipated, the failure to fully recover tenant obligations for common area maintenance (CAM) taxes and other property expenses, failure to comply or remain in compliance with covenants in the Company’s debt instruments, failure or inability to exercise available extension options on debt instruments, failure of wpg to qualify as a real estate investment trust, termination of existing JV arrangements, conflicts of interest with the Company’s existing JV partners, failure to achieve projected returns on development properties, the failure to sell malls and community centers and the failure to sell such properties when anticipated, the failure to achieve estimated sales prices and proceeds from the sale of malls, increases in impairment charges, additional impairment charges, as well as other risks listed in our news releases and other public pronouncements, including, but not limited to information published on the Site.

XVI. Waiver. Our failure at any time to require performance of any provision of these Terms of Use or to exercise any right provided for herein will not be deemed a waiver of such provision or such right. All waivers must be in writing. Unless the written waiver contains an express statement to the contrary, no waiver by wpg of any breach of any provision of these Terms of Use or of any right provided for herein will be construed as a waiver of any continuing or succeeding breach of such provision, a waiver of the provision itself, or a waiver of any right under these Terms of Use.

XVII. Severability. If any provision of these Terms of Use is held by a court of competent jurisdiction to be contrary to law, such provision will be changed and interpreted so as to best accomplish the objectives of the original provision to the fullest extent allowed by law and the remaining provisions of these Terms of Use will remain in full force and effect.

XVIII. Governing Law, Jurisdiction and Venue. These Terms of Use will be governed under the laws of the State of Ohio without regard to its conflicts of law provisions. Subject to Section XIX below, all actions or proceedings arising out of or relating to these Terms of Use will have venue exclusively in state or federal court in Franklin County, Ohio and hereby irrevocably consent and submit to the personal jurisdiction of said courts for all such purposes. However, notwithstanding this Section XVIII and the following Section XIX, we retain the right to bring legal proceedings in any jurisdiction where we believe that infringement of these Terms of Use is taking place or originating. Regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of this Site or these Terms of Service must be filed within one year after that claim or cause of action arose or be forever barred.

XIX. Arbitration. Any claim of damages of any kind by one party against the other party arising out of or relating to the use of this Site, and any dispute or controversy arising out of or relating to such claim or the breach, interpretation or validity of these Terms of Use or any provision thereof in relation to such claim, shall be first addressed by the parties involved in the dispute in good faith direct discussions after written notice by the claimant to the other party. If the issue is not resolved by direct discussions it shall be determined by binding arbitration in Columbus, Ohio, before one arbitrator, and shall be governed by the Commercial Dispute Resolution Procedures and the Supplementary Procedures for Consumer Related Disputes (collectively, “AAA Rules”) of the American Arbitration Association (“AAA”), as modified by this Terms of Use, and will be administered by the AAA. The Award shall be reasoned and in writing. Judgment on the award may be entered and enforced in any court having jurisdiction. The parties shall bear their own costs, fees and expenses in arbitrating any dispute, and shall share equally the fees and costs of the arbitration and the arbitrator. This clause shall not preclude the parties from seeking provisional remedies in aid of arbitration. No demand for arbitration may be made more than one (1) year after the event giving rise to the claim occurred or when sooner barred by the applicable statute of limitations or repose. In no event shall any arbitrator have any authority to modify these Terms of Use, award any types of damages which the parties have waived, released, or agreed not to assert, under these Terms of Use, or award any amount which exceeds any limitations contained in these Terms of Use. The arbitration procedure herein is fully binding, final, and non-appealable, and constitutes the parties’ only recourse for any claim of damages. YOU UNDERSTAND AND AGREE THAT, BY ENTERING INTO THIS TERMS OF USE, YOU ARE WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION. YOU FURTHER UNDERSTAND AND AGREE THAT THE PROCEEDINGS AND ALL INFORMATION DISCLOSED OR PERTAINING TO SUCH DISPUTES SHALL BE STRICTLY CONFIDENTIAL AND MAY NOT BE DISCLOSED BY EITHER PARTY EXCEPT AS REQUIRED BY LAW. NOTWITHSTANDING THE FOREGOING, WPG MAY DISCLOSE SUCH INFORMATION AS NECESSARY TO SECURE, DEFEND, MAINTAIN, OR IMPROVE THE SITE. If any portion of this Section XIX is found to be unenforceable, then the entirety of this Section XIX will be null and void and, in that case, the parties agree that the exclusive jurisdiction and venue described in Section XIX(b) will govern any action arising out of or related to this Terms of Use.

XX. Indemnity. You agree to indemnify and hold wpg, its subsidiaries, and affiliates, and their respective officers, agents, partners and employees, harmless from any loss, liability, claim, or demand, including reasonable attorneys’ fees, made by any third party due to or arising out of your use of this Site in violation of these Terms of Use and/or arising from a breach of these Terms of Use and/or any breach of your representations and warranties set forth above and/or if any material that you post using this Site causes us to be liable to another. We reserve the right to defend any such claim, and you agree to provide us with such reasonable cooperation and information as we may request.

XXI. These Terms of Use May Change. We reserve the right to update or modify these Terms of Use at any time, without prior notice, by posting the revised version of these Terms of Use behind the link marked “Terms of Use” at the bottom of each page of this Site. These changes will be effective as of the date we post the revised version on this Site. Your continued use of this Site after we have posted the revised Terms of Use constitutes your agreement to be bound by the revised Terms of Use. For your convenience, whenever these Terms of Use are changed, we will alert you by posting a notice on our home page. We will also update the “effective date” at the bottom of these Terms of Use. Your continued use of this Site after we have posted the revised Terms of Use constitutes your agreement to be bound by the revised Terms of Use. You may access the current version of these Terms of Use at any time by clicking on the link marked “Terms of Use” at the bottom of each page of this Site.

XXII. Entire Agreement. These Terms of Use (together with our Privacy Policy, including, as applicable, any Supplemental Privacy Notices, and any click-through agreements applicable to you) contain the entire understanding and agreement between you and wpg with respect to this Site and supersede all previous communications, negotiations, and agreements, whether oral, written, or electronic, between you and wpg with respect to this Site and your use of this Site.

XXIII. To Contact Us. If you have any questions about these Terms of Use, please contact us by electronic mail at: [email protected] or call us at 844-943-0270

Effective Date of these Terms of Use: March 1, 2023.

1. About this Cookie Notice
This cookie notice applies when you use any of our Services that refer or link to this notice. This notice may be supplemented by additional cookie notices, or terms provided on certain areas of the Service or during our interactions with you.
With the exception to the cookies that are set by third parties, the company that owns or administers the Service, as identified therein, is the primary controller of your personal information provide to, or collected by or for, the Service.
This Cookie Notice is subject to our Privacy Policy and Terms of Use.

2. What are “Cookies” and Why Do we Use Them?
Cookies are small text files that are placed on your computer by websites that you visit. Cookies are widely used in order to make websites and applications work, or work more efficiently, and help them remember certain information about you, either for the duration of your visit (using a “session” cookie) or for repeat visits (using a “persistent” cookie).
The cookies used on this website are as follows:
Strictly necessary cookies: These cookies do not store any personally identifiable information. However, they are essential in order to enable you to move around the website. They are usually only set in response to actions made by you which amount to a request for service, such as setting your privacy preferences, logging in or filling in forms. For example, authentication and security cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. You can set your browser to block or alert you about these cookies, but without these cookies, services you have asked for cannot be provided. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Functionality cookies: These cookies allow our websites to remember the choices you make and your account preferences and to provide enhanced, more personal features. These are set by us or by our third party providers whose services we have added to our pages. For example, these cookies will remember your log-in details. You can set your browser to block or alert you about these cookies, but without these cookies, services you have asked for cannot be provided. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Performance cookies: These are analytics and research cookies that allow us to count visits and measure traffic, so we can measure and improve the performance of our site. They also help us to know which pages are the most and least popular, and see how visitors move around the site. This helps us to improve the way the website works and improve user experience. All information these cookies collect is aggregated and therefore anonymous. You can set your browser to block or alert you about these cookies. Blocking these cookies will not affect the service provided you. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Targeting cookies: These cookies are set by us and our advertising partners to record your visit to the website, the pages you have visited and the links you have followed. We, and our advertising partners, will use this information to make the website, and, the advertising displayed to you more relevant to your interests. You can set your browser to block or alert you about these cookies. Blocking these cookies will not affect the service provided you, but will limit the targeted advertising that you will see, or limit our ability to tailor the website experience to your needs. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Third Party and Social Media Cookies: These cookies are set by a range of social media services that we have added to our websites that enable you to share our content with your colleagues, friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages that you see on other websites that you visit. If you do not allow these cookies you may not be able to use of see the social media sharing tools. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Tracking Technologies Including Pixels, Script, Web Beacons/Gifs, Page Tags: These files, or, code may be included in our emails and mobile apps to record how you interact with us, to help us better analyze and improve our services to you. Again, you can block the cookies either through your browser or device settings, and these settings will apply to all cookies whether included on websites or in emails. However, in some instances, depending on your email or browser settings, the files may be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.
Tracking Via Mobile Apps: When you use our mobile applications, we may record information unique to you that are associated with your device (such as the device ID and IP address), your activity within the App, and, your network location. This information is used to measure and improve the performance of our App, to help us to know elements are the most and least popular, and, see how visitors move around the App itself. This helps us to improve the way the App works and improve user experience. See below for more information on how to manage the collection of this information, or, refer to your email browser or device instructions.

3. How to refuse the use of cookies
You can prevent your browser from accepting certain cookies, have the browser require your consent before a new cookie is placed in your browser, or block cookies altogether by selecting the appropriate settings on your browser privacy preferences menu.
The links below will help you find the settings for some common browsers (please note that we are not responsible for the content of external websites):


• Manage cookie settings in Chrome and Chrome Android and Chrome iOS
• Manage cookie settings in Safari and Safari iOS
• Manage cookie settings in Firefox
• Manage cookie settings in Internet Explorer
• Manage cookie settings in Opera


For all other browsers, or, for alternative advice, help may be sought by visiting www.allaboutcookies.org, or, via your device user manual, or, online help files. For information on how to opt-out of cookies set by our suppliers, please visit the applicable links listed in the table above.

4. Third Party Web Advertising Services
Our Services may use Google Analytics, particularly within our marketing or free content sites, for the purposes of analyzing visitor / customer site interactions including interactions with our online marketing campaigns. For information about how Google processes the data collected please refer to the Google Privacy Policy.
You may opt-out of third party web advertising services that provide personalized advertising based on your online activity. You can also configure your web browser to delete and / or block the use of cookies for any third party (see b for further information).
The following sites may be used to register your 3rd party opt-out preferences:

• click here or here for the U.S.
• click here for Canada
• click here for the EU

Please note: Clicking the links above will redirect you to the appropriate third party website. We are not responsible for the content of external websites. Opting out of Advertising Cookies will not remove advertising from the pages you visit; instead it means the ads you will see may not be matched to your interests.

5. Changes
We will update this cookie notice from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

6. Contact
If you have any questions, comments, complaints or requests regarding this cookie notice, or our processing of your information, you can contact us at [email protected].
You may also lodge a complaint with the data protection authority in the applicable jurisdiction
Effective Date of this Notice: March 1, 2023

Last Revised: March 1, 2023

This Privacy Notice for California Consumers (our “CCPA Notice”) supplements the information contained in the general Privacy Policy of WPG.   We adopt this CCPA Notice to comply with the California Consumer Privacy Act of (“CCPA”), as amended.  Terms used in this CCPA Notice have the meanings defined in the CCPA or, if not therein defined, as defined herein or in our general Privacy Policy.  This CCPA Notice applies to the extent required by the CCPA.  In particular, this CCPA Notice is limited to our collection and use of personal information of residents of the State of California who are included in the definition of “consumer” under the CCPA (“consumers” or “you”). 

This CCPA Notice applies to our collection of personal information from California consumers online and offline, including websites operated by or for us (each our “Site”) unless an alternative Notice at Collection is provided, which case the Notice at Collection will control.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, as amended and supplemented (HIPAA) and the California Confidentiality of Medical Information Act, as amended and supplemented (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, as amended and supplemented (FCRA), the Gramm-Leach-Bliley Act, as amended and supplemented (GLBA) or California Financial Information Privacy Act, as amended and supplemented (FIPA), and the Driver’s Privacy Protection Act of 1994, as amended and supplemented.

In particular, we have collected the following categories of information from consumers within the last twelve (12) months from one or more of the following: the consumer directly, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers:

Personal Information

 

Category

Examples

Collected

A.    Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B.     Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C.     Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D.    Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E.     Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F.      Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G.    Geolocation data.

Physical location or movements.

YES

H.    Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I.        Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J.       Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K.    Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

    

 

Sensitive Personal Information

Sensitive personal information includes:

  • Government identifiers (social security, driver’s license, state identification card, or passport number)
  • Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password)
  • Precise geolocation
  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Union membership
  • Genetic data
  • Mail, email, or text messages contents not directed to us
  • Unique identifying biometric information; or
  • Health, sex life/preferences, or sexual orientation information

wpg does not collect sensitive personal information for the purpose of inferring a characteristic about a consumer.  Nor does wpg sell or share your sensitive personal information.

wpg may collect, use, or disclose sensitive personal information for the following purposes recognized under the CCPA:

(1) To perform the services or provide the goods reasonably expected by an average

consumer who requests those goods or services. For example, a consumer’s precise

geolocation may be used by a mobile application that is providing the consumer with

directions on how to get to specific location.

(2) To prevent, detect, and investigate security incidents that compromise the availability,

authenticity, integrity, or confidentiality of stored or transmitted personal

information, provided that the use of the consumer’s personal information is

reasonably necessary and proportionate for this purpose. For example, a business may

disclose a consumer’s log-in information to a data security company that it has hired to

investigate and remediate a data breach that involved that consumer’s account.

(3) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business

and to prosecute those responsible for those actions, provided that the use of the

consumer’s personal information is reasonably necessary and proportionate for this

purpose. For example, a business may use information about a consumer’s ethnicity

and/or the contents of email and text messages to investigate claims of racial

discrimination or hate speech.

(4) To ensure the physical safety of natural persons, provided that the use of the

consumer’s personal information is reasonably necessary and proportionate for this

purpose. For example, a business may disclose a consumer’s geolocation information

to law enforcement to investigate an alleged kidnapping.

(5) For short-term, transient use, including, but not limited to, nonpersonalized advertising

shown as part of a consumer’s current interaction with the business, provided that the

sensitive personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the

current interaction with the business.

(6) To perform services on behalf of the business, provided that the use of the consumer’s

personal information is reasonably necessary and proportionate for this purpose. For

example, a business may use information for maintaining or servicing

accounts, providing customer service, processing or fulfilling orders and transactions,

verifying customer information, processing payments, providing financing, providing

analytic services, providing storage, or providing similar services on behalf of the

business.

(7) To verify or maintain the quality or safety of a product, service, or device that is

owned, manufactured, manufactured for, or controlled by the business, and to

improve, upgrade, or enhance the service or device that is owned, manufactured by,

manufactured for, or controlled by the business, provided that the use of the

consumer’s personal information is reasonably necessary and proportionate for this

purpose. For example, a car rental business may use a consumer’s driver’s license for

the purpose of testing that its internal text recognition software accurately captures

license information used in car rental transactions.

(8) For purposes that do not infer characteristics about the consumer. For example, a

business that includes a search box on their website by which consumers can search

for articles related to their health condition may use the information provided by the

consumer for the purpose of providing the search feature without inferring

characteristics about the consumer

In an offline context, wpg may gather sensitive personal information and/or personal information (including name, address, age, gender, phone, applicable health/physical condition, etc.) for the purpose of incident reporting at the properties.  For example, if you are injured, damages property, or witness an injury or property damage.  In such cases, the information we collected is limited to what you provide voluntarily in and we maintain and store within our incident reporting database that is secure, encrypted, and password protected. 

Our Business Purposes for Collecting Your Personal Information

We may collect the personal information above for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Site, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users/consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

More specifically, the tables below identify for each category, our expected retention period, use purposes, and whether we sell the information or share it with third parties for cross-context behavioral advertising.

Sales and Sharing of Personal Information

wpg permits third party advertisers to include tracking cookies in advertisements placed on our site and has used this practice during the past 12 months.  As is common with such forms of advertising, the third party advertisers may collect information directly from your device such as your IP address and browsing history and use this information for the purpose of serving you more relevant advertisements. To the extent that this practice, also known as targeting or cross-contextual advertising, meets the definition of “sell” or “share” under the CCPA, then you have certain rights to “opt-out” by contacting us using the contact information we provide below or by using tools we provide on the Site to allow you to signal your instruction.

In particular, you can choose to opt-out of this form of targeting advertising on wpg’s Site and all other websites by controlling the use of cookies through your browser.  To learn more about cookies and how you may limit and control cookies through your browser, please review our Cookie Notice.

Apart from permitting third party advertisers to use cookies in advertisements on wpg’s Site, wpg has not “sold” and has not “shared” (for targeting advertising) personal information in the past twelve (12) months.

Disclosure of Personal Information

We may disclose your personal information to a third party for a business purpose. Subject to your right to opt-out, we may also sell your personal information to share your sensitive personal information for cross-contextual advertising.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Disclosures of personal information for a Business Purpose

In the preceding twelve (12) months, wpg has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

We make such third parties one or more of the business purposes described above in the section entitled “defined above in the section entitled “Our Business Purposes for Collecting Your Personal Information.”

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. In particular, consumers have the following rights:

(A) The right to know what personal information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer;

(B) The right to delete personal information that the business has collected from the consumer, subject to certain exceptions (discussed below);

(C) The right to correct inaccurate personal information that a business maintains about a consumer;

(D) If the business sells or shares personal information, the right to opt-out of the sale or sharing of their personal information by the business;

(E) If the business uses or discloses sensitive personal information for reasons other than those set forth above in the section titled “Sensitive Personal Information,” then the consumer has the right to limit the use or disclosure of sensitive personal information by the business; and

(F) The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request using the contact information provided at the end of this CCPA Notice.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal information Sales Opt-Out and Opt-In Rights

Please refer to the section above entitled “Sales and Sharing of Personal Information”

Also, if you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us using one of the forms provided below under the heading “Contact Information.”

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

Pursuant to California Business and Professions Code Section 1798.83 et sec (“Shine the Light”),  as amended, residents of California have the right to request from a business with whom the California resident has an established business relationship certain information with respect to the types of Personal Information the business shares with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

In addition, an operator of a commercial website subject to California Business and Professions Code Section 22581 et sec, as amended, must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. If this applies to you and you wish to make such a request, your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Changes to Our Privacy CCPA Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which wpg collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-844 943-0270

Email: [email protected]  

Postal Address:

wpg

180 East Broad Street

Suite 21

Columbus, OH 43215

Attn:  Chief Legal Officer

wpg collects and uses personal information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of personal information that we collect and the purposes for which we intend to use this information:

  • Identifying information, such as your full name, gender, date of birth, and signature.
  • Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
  • Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
  • Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
  • Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on wpg information systems and networks.
  • Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a wpg office location.

wpg collects Personal Information to use or disclose as appropriate to:

  • Determining your eligibility for a position with wpg, including processing your application, assessing your fit with us or for a specific role, conducting interviews, carrying out background and reference checks in accordance with law, and keeping records related to our hiring process;
  • Managing compensation, benefits, and employment-related expenses, including payroll processing, managing salaries and expenses, managing corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs;
  • Managing professional development, performance, and conduct, including responding to complaints of misconduct, managing conflicts of interest, conducting performance appraisals, supporting career development, and managing whistleblower programs;
  • Protecting wpg against illegal activity and other misconduct, including by detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; and
  • Complying with our legal obligations,including those related to tax and anti-discrimination laws.

To view our corporate privacy policies, supplements and applicable notices, please visit https://wpgus.com. For questions or to request deletion of data please contact [email protected].  If you have any questions about this notice or need to access this notice in an alternative format due to having a disability, please contact us at [email protected] or call  us at 844 943-0270.

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