Last updated: September 1, 2026

This Privacy Policy explains how Provenance Owners Group  (“we,” “us,” or “our”) may collect, use, disclose, retain, and otherwise process information when you visit provenancecommunity.com and any related webpages, forms, or digital services that link to this Privacy Policy (collectively, the “Website”).

The Website provides information about the Provenance housing project and offers opportunities to receive updates, submit questions, express interest, or otherwise engage with the project. The Website does not sell products or provide paid services. This Privacy Policy broadly describes our practices, including information that may be collected through website hosting, analytics, advertising, embedded content, communications, and similar technologies, whether or not any of the technologies or categories described below are active at all times.

Our actual collection, use, retention, and disclosure practices may vary depending on how you interact with the Website and which tools are enabled. We will not collect additional categories of personal information or use personal information for materially different, unrelated, or incompatible purposes without providing any notice required by applicable law.

  1. Information We May Collect

We may collect the following categories of information directly from you, automatically from your device or browser, and from service providers or other third parties:

Contact and submission information: Name, email address, telephone number, mailing address, organization or affiliation, and any information you include in a form, message, petition, survey, sign-up, request, or other submission.

Internet and device activity: Internet Protocol address, device identifiers, browser type and settings, operating system, referring and exit pages, pages or content viewed, links clicked, dates and times of access, session duration, general interaction data, and diagnostic or security information.

Approximate location information: General location inferred from an Internet Protocol address or device settings, such as city, region, or state. We do not intend to collect precise geolocation unless clearly disclosed at or before collection.

Communications and engagement information: Records of emails, text messages, calls, requests, responses, subscription preferences, event or community-engagement participation, and interactions with project communications.

Advertising, analytics, and inference information:  Information about how you use the Website or respond to content or advertisements; identifiers or audience information received from advertising or analytics partners; and inferences about interests, preferences, or likely engagement with the project.

Social media and embedded-content information: Information made available when you interact with social media features, videos, maps, fonts, forms, or other content hosted by third parties.

Other information: Any other information you voluntarily provide or that we describe at the point of collection.

  1. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, web beacons, tags, software development kits, local storage, scripts, session-replay or interaction-measurement tools, and similar technologies to operate and secure the Website; remember preferences; understand website traffic and usage; measure the effectiveness of communications or campaigns; improve content; and support advertising, audience measurement, or outreach.

These technologies may collect information over time and across websites or services. Depending on how a third-party tool is configured and used, disclosing identifiers or Internet activity to an analytics, social-media, or advertising provider may be considered a “sale” or “sharing” under California law, even when no money is exchanged.

You may manage cookies through the Website’s available controls and your browser or device settings. Blocking cookies may affect certain Website features. Where required, we will recognize legally valid opt-out preference signals, such as the Global Privacy Control, as a request to opt out of sale or sharing for the browser or device that sends the signal.

  1. How We May Use Information

We may use personal information to:

  • Operate, host, maintain, secure, troubleshoot, and improve the Website;
  • Provide project information and respond to questions, comments, requests, or submissions;
  • Send requested updates, newsletters, announcements, surveys, event information, advocacy communications, or other project-related messages;
  • Understand website use, audience interests, communications performance, and community engagement;
  • Conduct analytics, research, testing, measurement, and reporting;
  • Deliver, measure, or improve online advertising, outreach, or informational campaigns, where permitted by law;
  • Detect, investigate, and prevent fraud, misuse, security incidents, or other harmful activity;
  • Protect our rights, property, safety, and the rights, property, or safety of others;
  • Comply with law, legal process, regulatory obligations, and enforceable governmental requests; and
  • Carry out other purposes disclosed at the time information is collected, with your consent, or as otherwise permitted by law.
  1. How We May Disclose Information

We may disclose personal information to the following categories of recipients:

  • Service providers and contractors: Website hosts, developers, content management providers, analytics providers, communications platforms, email or text message vendors, survey and form providers, security vendors, consultants, and other vendors that support the Website or project communications.
  • Advertising, social-media, and analytics partners: Providers that help us measure audiences, understand engagement, embed content, or conduct and evaluate outreach or advertising. Certain disclosures to these providers may constitute sale or sharing under California law.
  • Project participants and advisors: The project sponsor, property owner, developer, consultants, public-affairs or community-engagement professionals, legal advisors, and other persons supporting the Provenance project, subject to appropriate restrictions.
  • Governmental, legal, or protective disclosures: Courts, regulators, law enforcement, public agencies, or other parties when we believe disclosure is required or permitted by law or reasonably necessary to protect rights, safety, security, or the integrity of the Website.
  • Business or organizational transactions: Parties involved in a financing, reorganization, merger, sale, transfer, dissolution, or similar transaction involving the Website, project, or relevant assets.

At your direction or with your consent: Other persons when you direct us to disclose information or otherwise consent.

  1. California Privacy Disclosures

This section applies to California residents and is intended to satisfy the California Consumer Privacy Act, as amended (CCPA), to the extent the CCPA applies to us. Other California privacy laws, including the California Online Privacy Protection Act, may also apply.

Categories collected: During the preceding 12 months, we may have collected the following CCPA categories: identifiers; personal information described in California Civil Code section 1798.80; Internet or other electronic network activity; approximate geolocation information; professional or employment-related information if voluntarily provided; audio, electronic, visual, or similar information if submitted or recorded in connection with an event or communication; and inferences drawn from other information. We do not seek to collect government identification numbers, financial account credentials, precise geolocation, health information, racial or ethnic origin, religious beliefs, sexual orientation, or other sensitive personal information through the Website unless specifically disclosed and reasonably necessary for a stated purpose.

Sources: We may obtain personal information directly from you; automatically from your browser or device; from cookies and similar technologies; from service providers, analytics providers, advertising partners, social media platforms, and embedded content providers; and from project participants or other lawful sources.

Purposes: We may collect, use, and disclose these categories for the business and commercial purposes outlined in Sections 3 and 4 above.

Sale or sharing: We do not sell personal information for money. We may use analytics, advertising, social media, or similar technologies that disclose identifiers or Internet activity in ways that may be considered “selling” or “sharing” under the CCPA. If we engage in activities that constitute sale or sharing, California residents may opt out as described below.

Sensitive personal information: We do not use or disclose sensitive personal information for purposes that would require a right to limit under the CCPA unless otherwise stated in a notice at the time of collection.

Retention: We retain each category of personal information only for as long as reasonably necessary and proportionate to the purposes described in this Privacy Policy, including maintaining the Website and project records, responding to requests, conducting communications and analytics, satisfying legal or contractual obligations, resolving disputes, and protecting security. Retention periods vary based on the nature of the information, the purpose for collection, legal requirements, and operational needs.

  1. California Privacy Rights

Subject to legal limitations and verification requirements, California residents may have the right to request that we do the following:

  • Disclose the categories and specific pieces of personal information we collected about them, the sources, purposes, and categories of recipients;
  • Delete personal information we collected from them;
  • Correct inaccurate personal information;
  • Opt out of the sale or sharing of personal information;
  • Limit certain uses or disclosures of sensitive personal information, when applicable; and
  • Not discriminate or retaliate against them for exercising privacy rights.

To submit a request, contact us at [email protected]. We may request information reasonably necessary to verify your identity and authority. An authorized agent may submit a request as permitted by law, but we may require proof of authorization and verification of the consumer.

To opt out of sale or sharing, use the “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” link made available on the Website, if applicable, or contact us using the method above. We will also process legally valid opt-out preference signals as required by applicable law.

  1. Email and Text Communications

You may unsubscribe from promotional or project-update emails by using the unsubscribe link in the message. You may opt out of text messages by replying STOP or by following the instructions in the message. Even after opting out of promotional communications, we may still send non-promotional messages in response to a request or regarding Website security or administration.

  1. Children’s Privacy

The Website is intended for a general audience and is not directed to children under 13. We do not knowingly collect personal information from children under 13. We also do not knowingly sell or share the personal information of consumers under 16 without the affirmative authorization required by California law. If you believe a child has provided personal information through the Website, contact us.

  1. Security

We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information we maintain. No method of Internet transmission or electronic storage is completely secure, so we cannot guarantee absolute security.

  1. Third-Party Websites and Services

The Website may link to or embed content from third-party websites and services. Those third parties may collect information directly from you and are subject to their own privacy policies. We are not responsible for their privacy or security practices.

  1. Do Not Track

Some browsers offer a “Do Not Track” setting. Because there is no uniform industry standard for responding to Do Not Track signals, the Website may not respond to them. We will process opt-out preference signals, including Global Privacy Control, when required by applicable law.

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The revised policy will be posted on this page, and the “Last updated” date will be updated. We will provide additional notice when required by law.

  1. Contact Us

Questions or privacy requests may be directed to: Provenance Owners Group 

Email: [email protected]