Privacy Policy
Privacy Policy
Effective: February 2026
Introduction
NewCastle Management Group, with its affiliated companies (“NewCastle Affiliates” and, together referred to as “NewCastle,” “we,” “us,” “our”), has been building apartment communities since 2012. This Privacy Policy describes how personal information is collected, used, disclosed, and processed by NewCastle Management Group and the NewCastle Affiliates that post this Privacy Policy. We use the terms “you” and “your”) to refer to individuals who visit us online or in person, are home buying or prospective home buying customers, communicate or do business with us, or whose personal information we receive in other ways
This Privacy Policy applies to NewCastle and any NewCastle Affiliate that posts this Privacy Policy including: all Sites.
NewCastle operates NewCastleDG.com, our public website, the NewCastle tenant platform, which provides NewCastle tenants with secured access to their individual experience account (“NewCastle Tenant Site”), and any other NewCastle website, application, social media account, or online platform with a link to this Privacy Policy (each a “Site” and together our “Sites”). Your use of our Sites may also be subject to their own “terms and conditions” or “legal disclosures.”_
The following NewCastle Affiliates maintain their own separate websites and applications and each posts its own privacy policy or statement that supersedes this Privacy Policy: __________.
Your Consent
Please review this Privacy Policy carefully. By using our Sites or interacting with us through channels and at locations where this Privacy Policy is posted or published, you are agreeing to the collection, use, disclosure, and other processing of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Sites or services and do not provide your personal information to us.
We make changes in this Privacy Policy regularly, so you should reread it from time to time. Changes to this Privacy Policy will be posted on our Sites and will be effective when posted. Your continued use of our Sites or communications with us following the publishing of any changes constitutes your acceptance of our Privacy Policy as revised.
If you are a California resident, please also see “California Residents: Your California Privacy Rights.” If you are a Texas resident, please also see “Texas Residents: Your Texas Privacy Rights.”
Personal Information We Collect
What is Personal Information?
We use the term “personal information” in this Privacy Policy to refer to information that identifies, relates to, describes, or is reasonably capable of being associated or linked, directly or indirectly, with you (or your household if you are a resident of California). Personal information also includes any information that can be combined with other information to identify, contact, or profile you.
This Privacy Policy does not apply to information that is: publicly available; aggregated, deidentified or anonymized; collected by third-party websites or social media platforms you reach by navigating from links on our Sites; or information about NewCastle’s current and former employees or job applicants.
How We Collect Personal Information
We may collect your personal information in the following ways:
- Directly from you when you provide information to us or a NewCastle Affiliate (with consent for marketing, as required);
- Your communications with us by phone call, text message, e-mail, postal mail, via chat function or in-person at one of our properties;
- Your transactions with us or a NewCastle Affiliate;
- Information you provide via the NewCastle Tenant Site;
- From real estate, home products and services vendors, and other third-party companies with which we collaborate in apartment building, community development and other related services (“Business Partners”);
- From your visits to and interactions with our Sites collected via cookies and similar technologies placed by digital advertising networks, data analytics services, and social media platforms (“Advertising Platforms”);
- From Advertising Platforms that collect and share information about the marketing communications and advertisements you have seen or clicked on;
- From other third party sources that provide consumer data, including internet browsing data, such as information about your interests, demographic information, and marketing inferences.
Categories of Information We Collect
The categories of personal information we collected and used for our business and commercial purposes during the past 12 months included the following:
- Identifiers, such as name, postal address, email address, social security number, driver’s license number, passport number, internet protocol address, device identifier, online account name and other online identifiers.
- Protected demographic data, such as age, marital status, sex and gender identity, national origin, disability and genetic information, and military/veteran status (all information collected is used, or not used, in conformity with the Fair Housing Act).
- Consumer information, such as signature, telephone number, credit card, debit card, bank account and other financial information,.
- Commercial information, such as credit reports, NewCastle and NewCastle Affiliate transaction history.
- Internet activity, including browsing history, search history, and a user’s interaction with a website, application, or advertisement (“Internet Usage Data”).
- Audio/visual data collected on NewCastle-owned properties for security purposes. We may record customer service calls for quality assurance and training, but not for identification purposes.
- Professional and employment-related information, where part of the application for a home purchase or other transaction.
- Inferences drawn from the above information categories, used for customer and prospective customer profile records that combine information and draw inferences from various sources about, for example, your transactions, home preferences, communications such as the content of emails, text messages, interactions with automated customer service features (such as a chatbot), and history of experiences with us.
Sensitive Information
Some of the personal information we collect is classified as sensitive information under the privacy laws of some states (“Sensitive Information”). For example, we may collect credit information to process your request to purchase a home, passport or visa information to establish citizenship or immigration status for legal purposes, or information for a personal accommodation related to your home design. When we request Sensitive Information, we will use it only for the purpose disclosed to you at or before the time the Sensitive Information was collected a purpose we reasonably believe is compatible with and expected by you based on the original disclosed purpose, or as required or authorized by law. Unless we request Sensitive Information for a specific purpose, we ask that you not send or disclose any Sensitive Information to NewCastle. The types of Sensitive Information we may collect for business purposes include social security numbers, driver’s license, passport, and other government identification numbers; citizenship or immigration status; very limited medical information, and precise geolocation data.
Specific Types of Personal Information Collected from You
Depending on the purpose of your communication or interaction with us, we may ask you to provide the following types of personal information:
- Contact Information If you chat with the chat-bot on our Sites or submit an online request for information about our products and services, we will collect and retain the information you provide including name, address, email address, telephone number, NewCastle communities of interest to you and other information we need to fulfill your request.
- NewCastle Tenant Site. New homebuying shoppers and homeowners are asked to create a secured customer account via the NewCastle Tenant Site (or computer at our web-based Sites). To set up an account, we request your name, email address, new account password, phone number, state and county of residence, and location where you are looking for a home or the location of the home you purchased. The NewCastle Tenant Site is the preferred method for buyers of NewCastle homes to make warranty service claims. We also obtain additional information that you may provide at your option, including your mailing address, NewCastle communities you are interested in, proposed date to close on the purchase of your new home, information about desired features for your home, and your interests in the range of services provided by NewCastle, NewCastle Affiliates and our Business Partners.
- Transaction information. When you are ready to move forward with the purchase of a home, we will ask you to submit an application and enter into contracts containing identification, financial and other personal information. If you apply for a mortgage, title insurance, or other insurance, similar information may be collected by and shared with NewCastle or NewCastle Affiliates. Some transactions require your Sensitive Information to provide specific services you request, such as your signature, social security number, driver’s license, passport number and information about income, assets and liabilities. The disclosure of some of this information may be protected by the Fair Credit Reporting Act and other laws.
- Payment card and bank account information. If you enter into a contract to buy or finance a home or for other services, your credit card, debit card or bank account information will be processed by a third-party payment processor. NewCastle does not store this information.
- Communications. Your communications with us, such as emails, text messages, phone calls, interactions with live and automated (chatbot) customer service, may contain personal information. We will not ask for, and request that you not provide, any Sensitive Information in any unsecured form of communications.
- Photos. You may share with us or give us permission to take photos or videos of your home, family, or yourself. With your permission, we may use these on our Sites or for marketing purposes.
- Your comments. If you post or allow us to post a comment on our Sites, blog, or "leave a comment" online or on third-party or social media sites, we collect or receive your comment, name and email address.
- Audio/visual. We may use security cameras at our Welcome Home Centers, models and other properties. We record customer service calls for quality assurance and training. This information is not used or retained for any other purpose.
- Friends and family. You may provide contact information for friends and family to receive a notification regarding your move or for other stated purposes.
- Business representatives’ contact information. If you are a real estate agent, developer, landowner, or vendor doing business with NewCastle or receiving information about NewCastle properties, we will collect your name, your company’s name, your position and business contact information.
- Other information you may choose to provide. In the course of doing business with NewCastle, you may provide information about your employment, education, family, age, gender, interests and preferences for home location and features, and other personal matters.
Automated Online Data Collection
When you visit our Sites, we and our third-party providers, including Advertising Platforms, automatically collect data about your interaction with our Sites transmitted by cookies and similar tracking technologies placed on your device or web browser. Examples of the types of data collected this way may include the following:
- Time and duration of your visits to the Sites;
- Pages viewed and functions used on the Sites;
- IP address or mobile device identifier;
- Randomly generated unique ID number;
- Device type, browser type, and operating system;
- Browsing and search history;
- Internet location from which you navigated to our Sites and the location you went to when leaving our Sites;
- Interactions with our advertisements and content placed on other Sites and social media platforms (subject to your restrictions on targeted advertising).
- Approximate geographic location (as determined, for example, using satellite, cell phone tower and Wi-Fi signals).
For more information about how we use these technologies and how you can restrict their use, see the sections below titled “How We Use Cookies and Other Tracking Technologies,” and “How You Can Restrict Cookies and Targeted Advertising.”
Information from NewCastle Affiliates
- Transaction information. We may receive, collect and share personal information about your transactions with NewCastle Affiliates (subject to your consent to share certain credit and other financial information with NewCastle Affiliates in accordance with the Fair Credit Reporting Act and other applicable laws). This information may include your payment history, the status of a loan or other application submitted to a NewCastle Affiliates, or other information about your transactions. Some NewCastle Affiliates have posted their own privacy policies on their websites that explain how they collect, use and disclose personal information.
- Credit and commercial activity information. In connection with home purchases, mortgage applications and other transactions, NewCastle Affiliates may obtain and, with your prior consent, may share with NewCastle your credit information from consumer reporting agencies, including your creditworthiness and credit history.
Information from Business Partners, Advertising Platforms, and Other Sources
- Business Partners. We may receive personal information from and provide personal information to Business Partners and third parties not owned or controlled by NewCastle for marketing programs and prospective customer lead generation, subject to your ability to opt-opt or opt-in where required by law.
- Social media platforms. If you choose to link your social media account or other third-party accounts to our Sites (such as Instagram, X, Facebook, YouTube, and LinkedIn), you may be authorizing those third parties to send us certain information about you and you are authorizing us to collect, store and use the information they transmit to us in accordance with this Privacy Policy.
- Advertising Platforms and consumer information services. We use third-party services to combine information gathered on our Sites with information collected from other online and offline sources. For example, these services may aggregate information from multiple sources to correlate IP addresses with zip codes that help us to target and assess the performance of marketing campaigns.
- Smart-Home technology. We may receive personal information or household information from certain smart home technology devices installed in your home.
- Publicly available and commercial databases. We may source personal information from marketing research and data analytics resources. We may, for example, receive demographic information (age, sex, household income, job industry and job title) from these sources.
How We Use Personal Information
Depending on how you use our Sites and services, your interactions with us, and the permissions you give us, the purposes for which we use your personal information may include to:
- Work with you throughout the design, sales, contracting, financing, construction and completion phases of your new home.
- Provide customer service, fulfill requests for information, verify customer information and process payments for transactions (payment information is handled by authorized third-party payment processors).
- Connect you with NewCastle Affiliates that offer mortgage financing, title insurance or other related services (with your permission).
- Connect you with Business Partners that offer household products and services in your area.
- Send and track your responses to marketing messages and display targeted advertising to you, subject to your options and preferences.
- Maintain and improve our Sites and the NewCastle Tenant Site.
- Monitor usage of our Sites for market research and Site improvement purposes.
- Personalize the Sites to show you content we think you will be most interested in based on your browsing activity, your account information, and your purchase history.
- Develop and train artificial intelligence (AI) models, develop, provide, and personalize our services, and gain insights about you, with the help of AI-powered chatbots, and make certain inferences that make our services more relevant and useful to you and others.
- Display your photos and comments on our Sites and in marketing materials (with your permission).
- Build long-term customer relationships by learning about your experience with us and keeping records of your needs, preferences and interests.
- Conduct internal activities we believe are reasonably aligned and compatible with your expectations about how we will use your personal information based on your relationship with NewCastle and the context in which you provided the information (such as quality assurance, strategic marketing and product development).
- Secure our Sites, systems, locations, and business, detect and investigate fraud and protect ourselves and others when necessary.
- Manage our contractual relations and protect our business interests.
- Comply with legal process and respond to appropriate governmental requests.
- Create anonymized information for market research and other lawful purposes.
Information Sharing and Disclosure
The operation of our business and Sites involves sharing or allowing third parties to have access to certain personal information collected by NewCastle consistent with the purposes for which we collected the information. The categories of those third parties are identified below.
Business Partners. We may share your personal information, such as contact details, NewCastle property location, and closing date with Business Partners that offer products and services we believe may be of interest to you based on the customer profile we have for you and your NewCastle community or geographic area. Business Partners may use the personal information we provide to market their products and services directly to you. Please note, however, that SMS (or text message) consents are not applicable to, or shared with, Business Partners. We may receive a commission or other payment if you make a purchase from a Business Partner to whom we provided your personal information.
NewCastle does not have any responsibility for how Business Partners use or share your personal information, and you should review that company’s privacy policy by visiting its website or requesting a copy. At any time, you can opt out of sharing your information with Business Partners by using the “Do Not Sell or Share My Personal Information” option accessible from the link located in the footer on the Sites You can also contact us as explained in “How to Contact Us.”
Advertising Platforms. We authorize Advertising Platforms (advertising exchanges, social media platforms, and other third-party advertising networks) to collect and analyze data collected automatically during visits to our Sites. These companies use cookies, pixels, web beacons, tags, software development kits (SDK), and other tracking technologies (commonly referred to as “cookies”) to collect information about your online and mobile device activities over time and across different websites and apps. They use this information to build a profile may target advertisements to you based on your interests as suggested by the history of your visits to our Sites and other websites. For more information, see “How We Use Cookies and Other Tracking Technologies” and “How You Can Restrict Cookies.”
Site Analytics Providers. We authorize website analytics services (such as Facebook and Google) to collect usage data on our Sites using cookies, and other tracking technologies to measure and evaluate access to and traffic on the Sites. The reports from these services help us analyze how our Sites are used, obtain demographic, interest and preference information about Site users, and assist with targeted advertising and assessment of the effectiveness of marketing campaigns. These services may use your information collected on our Sites for their own business and commercial purposes including data aggregation, and machine learning to improve their products and services. For more information, see “How We Use Cookies and Other Tracking Technologies” and “How You Can Restrict Cookies.”
NewCastle Affiliates. With your opt-in consent, NewCastle may share your personal information, including Sensitive Information, with NewCastle Affiliates that offer home mortgage, title insurance and other products that may be of interest to you. The shared information may include your contact information, public real estate and lien records, NewCastle transaction history, and information necessary to close a home transaction. The NewCastle Affiliates may use your information for their business and commercial purposes, including to:
- Assess if you qualify for a mortgage or other transaction.
- Send you marketing communications about their products and services, with your opt-in consent. Please note, however, that SMS (or text message) consents are not applicable to, or shared with, NewCastle Affiliates or Business Partners.
- Complete a transaction with you.
When required, we will provide a link for you to opt in or give consent before sharing your personal information with any NewCastle Affiliate. You may change your selection at any time by visiting our preferences page accessible from the footer on our Sites or by contacting us as explained in “How to Contact Us.” You should review the separate privacy policies and notices of those NewCastle Affiliates that publish their own privacy policies or notices on their websites.
Service Providers. Service providers and vendors who support our operations (“Service Providers”) may have access to your personal information when reasonably necessary to provide the specific products and services for which we engage them. We do not permit Service Providers to use this personal information for their own direct marketing or other commercial purposes. Examples of Service Providers we use are:
- Construction services including contractors and tradespeople, companies that provide appliances, wiring for security systems and solar panels.
- Site features and operations, including hosting and maintenance services for our Sites and to provide features on our Sites such as the chat bot functionality.
- Administrative operations including credit reporting and background checking and identity verification services, e-mail and other marketing services, software and data cloud hosting, IT security, storage and backup, and accounting and payment processing.
Hosted Site Features. We use third-party software and hosting services to provide certain interactive functionalities for our Sites. These third parties are responsible for personal information they collect and use for purposes other than providing services on behalf of NewCastle and for explaining their privacy practices to you. See the section titled “Links to Third-Party Features, Websites, and Social Media.”
Legal Matters. We may also disclose personal information under appropriate circumstances to:
- Law enforcement, government authorities, and investigators to comply with laws or legal processes or to investigate or take other action in connection with potential illegal or fraudulent activities or risk to any individual or the security of personal information.
- Parties to a dispute or claim.
- Parties involved in negotiations for a major corporate, financing, restructuring, or bankruptcy transaction, subject to appropriate confidentiality protections.
Personal Information Shared in the Past 12 Months. The chart below summarizes the categories of personal information we may have disclosed, sold, or shared for targeted advertising purposes in the past 12 months with NewCastle Affiliates, Business Partners, Advertising Platforms (which include ad networks, social media platforms, analytics services), and Service Providers. Note that personal information in any of the categories listed below may be disclosed or accessible to Service Providers in connection with the services they provide.
|
Categories of information and categories of third parties |
Disclosed for business purposes |
Can you limit disclosure for business purposes? |
Disclosed for marketing purposes |
Can you limit disclosure for marketing purposes? |
Sold or shared for targeted advertising |
Can you limit sale or sharing for targeted advertising? |
|
Personal Identifiers: name, postal, e-mail and IP address, telephone number, device identifier. internet protocol address, device identifier, online account name and other online identifiers |
||||||
|
NewCastle Affiliates |
Yes |
No |
Yes |
Yes |
No |
N/A |
|
Business Partners |
Yes |
Yes |
Yes |
Yes |
Yes |
Yes |
|
Sensitive Identifiers: Social security number, driver’s license number, passport number |
||||||
|
NewCastle Affiliates |
Yes |
No |
No |
N/A |
No |
N/A |
|
Business Partners |
No |
No |
No |
N/A |
No |
N/A |
|
Protected demographic information: |
||||||
|
NewCastle Affiliates |
Yes |
No |
No |
N/A |
No |
N/A |
|
Business Partners |
No |
No |
No |
N/A |
No |
N/A |
|
Consumer information: signature, credit card, debit card, bank account and other financial information, audio/visual recordings and images. |
||||||
|
NewCastle Affiliates |
Yes |
No |
No |
N/A |
No |
N/A |
|
Business Partners |
Yes |
No |
No |
N/A |
No |
N/A |
|
Commercial Information: credit report information, NewCastle transaction history |
||||||
|
NewCastle Affiliates |
Yes |
No |
Yes, for transaction history only |
Yes |
No |
N/A |
|
Business Partners |
No |
N/A |
No |
N/A |
No |
N/A |
|
Internet Usage Data: browsing history, interactions with Sites and NewCastle ads |
||||||
|
NewCastle Affiliates |
Yes |
No |
Yes |
Yes |
Yes |
Yes |
|
Business Partners |
Yes |
No |
Yes |
Yes |
Yes |
Yes |
|
Advertising Platforms |
Yes |
Yes, by cookie preference selections |
Yes |
Yes, by cookie preference selections |
Yes (subject to opt-out) |
Yes (subject to opt-out) |
|
Customer Profile Information: contact, demographic, property, and occupancy information, chatbot interactions |
||||||
|
NewCastle Affiliates |
Yes |
No |
Yes |
Yes |
Yes |
Yes |
|
Business Partners |
Yes |
No |
Yes |
Yes |
Yes |
Yes |
|
Advertising Platforms |
Yes |
Yes, by cookie preference selections |
Yes |
Yes, by cookie preference selections |
Yes |
Yes |
How We Use Cookies and Other Tracking Technologies
Cookies and Similar Technologies. Internet tracking and data storage technologies, commonly referred to as “cookies,” are placed on your device and stored on your browser when you visit our Sites. These technologies may include, for example, cookies, pixels, local device storage, web beacons, scripts, and device identifiers. They can be classified by:
- Time span. A session cookie is temporary and will expire when you close your browser; a persistent cookie will remain on your device until it automatically expires after a specified time period (or sooner if you delete it);
- Source. Either the operator of the website you are visiting (first-party cookie), or an authorized third-party service or platform (third-party cookie) can place the cookie; and
- Purpose. As described below, we use cookies for the proper functioning of our website, to learn about usage of our Sites, and for advertising and marketing purposes.
Third-Party Cookies. The types of data collected by third-party cookies generally do not directly identify an individual user and the analytics data we receive about our Sites is aggregated and anonymous. However, the third-party platforms we use for analytics and advertising purposes are able to track browsing activity on a device by a unique identifier and combine data collected from cookies on our Sites with data they collect from other sources to build a user profile that may be linkable to an identifiable person. For information about setting your cookie preferences and restricting cookies, see the section titled “How You Can Restrict Cookies and Targeted Advertising.”
The Advertising Platforms and other third parties placing cookies on our Sites are responsible for personal information they use for purposes other than providing services for us. They are also responsible for explaining their privacy practices to you. Some information about commonly used third-party cookies may be found at:
- https://policies.google.com/technologies/partner-sites for how Google processes data from websites for advertising and data analytics purposes
- https://policies.google.com/privacy for information about controls Google offers to manage the collection and use of your personal information
- https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0 for information about how Meta and Facebook use cookies
Categories of Cookies. The cookies we (or our authorized third‑party providers) place on our Sites can be categorized as described below. You may restrict data collection using any type of cookies placed on your device or browser except for cookies that are strictly necessary as explained in “How to Restrict Cookies and Targeted Advertising.”
Strictly necessary cookies are required for the basic operation and performance of our Sites and cannot be switched off. These are session cookies that are erased when you close your browser.
Performance cookies are used to identify and verify your device when you log in to access our Sites by storing, for example, your password, device identifier, browser type, operating system, Internet Service Provider (“ISP”) and Internet Protocol (“IP”) addresses. These cookies allow us to count visits and traffic so we can collect insights like which pages are the most popular and see how visitors move around the site. You can restrict or delete these cookies as explained in “How to Restrict Cookies and Targeted Advertising.”
Functional cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third party providers. If you do not allow these cookies then some or all of these services may not function properly.
Analytics cookies let us know how you and other visitors interact with our Sites and which other websites you browse before and after visiting our Sites. These cookies allow us to count visits and traffic so we can identify which pages are the most popular and see how visitors move around the Sites. Google, Salesforce, Facebook, Hotjar, TikTok and other services provide website and advertising performance analysis by collecting data across many users’ devices and tracking users’ activities on our Sites and other websites and platforms. These cookies qualify as persistent cookies because they remain on your device or browser after you close the current session. You can restrict or delete these cookies as explained in “How to Restrict Cookies and Targeted Advertising.”
Targeted advertising cookies may be placed on your device or browser by us or our authorized Advertising Platforms, including (among others) the Google, Facebook, and Microsoft. The Internet Usage Data transmitted by these third-party cookies enables the Advertising Platforms to build a profile of your preferences and interests and show you advertisements based on your internet activities over time and across many nonaffiliated websites, applications, and platforms you visit. The data may also be linked across the different devices you use. Targeted advertising cookies do not store directly identifying personal information, but they store data that may uniquely identify your browser and device. You can restrict or delete these cookies as explained in “How to Restrict Cookies and Targeted Advertising.”
Social media cookies, including the Meta (Facebook) pixel, are placed by social media networks and collect data for advertising and other data analytics purposes. They enable you to share content from our Sites through social media networks and help us to analyze the effectiveness of content and marketing we post on social media. These cookies collect, for example, web activity, IP address, device and browser characteristics, and timestamps of visits. These cookies help us to analyze the effectiveness of advertisements we post on social media. The social media networks also collect data about your activities on our Sites. For information about how social media networks use the data collected by cookies, and how to restrict their data collection, see the privacy and cookie policies issued by the social media platforms you use.
E-mail cookies may be used to give us information such as how you interact with our e-mail communications, including whether and when you opened it, what links you clicked within the e-mail, and if it was forwarded.
How You Can Restrict Cookies and Targeted Advertising
As explained in “How We Use Cookies and Other Tracking Technologies,” we may allow third-party analytics services, advertising companies and ad networks (including Google Analytics, Google Ads and Facebook Ads) to track visitor interactions with our Sites. They may combine the data collected from our Sites with information collected about your activities on other websites and platforms and use algorithmic tools to help us assess whether our online advertising campaigns are successful and to direct our advertisements to you and other potentially interested users on other websites and social media.
Listed below are some of the ways you can select certain opt-outs and other privacy preferences and restrict how non-essential cookies are used on the Sites. Note that you may need to exercise some these opt-out options on each browser and device you use.
- Visit our Cookie Preferences link located in the footer to our Site pages and select your preferred settings for some types of cookies;
- Select your cookie and other privacy preferences using your browser settings;
- Block the sharing of your mobile device and/or advertising ID if your device has a setting you can select to reject incoming requests for the ID associated with your device;
- Configure a global opt-out preference signal on your browser, if available, to direct us not to share your personal information for targeted advertising, which we will follow as required by applicable law;
- Configure your advertisement and privacy settings for your social media and other advertising platforms where you have an account (such as Facebook and Google);
- Install the Google Analytics opt-out browser add-on, which is described at the Google Analytics Opt-out Browser Add-on page at https://tools.google.com/dlpage/gaoptout;
- Download a utility from an independent software provider that you install on your computer browsers to limit tracking of browsing activity;
- Learn more about opting out of personalized advertising by participating advertisers at:
https://youradchoices.com/control
https://optout.networkadvertising.org/?c=1
Additional information about how some Advertising Platforms companies we authorize to place cookies on our Sites handle personal information privacy, and the tools they offer for managing data collection may be available at these locations:
- Google:
https://policies.google.com/privacy
https://policies.google.com/technologies/partner-sites?hl=en-US - Facebook:
https://www.facebook.com/privacy/explanation
You can restrict the use of mobile device advertising identifiers by adjusting your advertising preferences on mobile devices through your device settings:
- iOS Devices: Go to Settings > Privacy & Security > Apple Advertising > Personalized Ads
- Android Devices: Go to Google Settings > Privacy > Advanced > Ads > Opt Out of Ads Personalization
Do Not Track (“DNT”) is an optional browser setting that is used by some website operators and third parties. Our Sites do not respond to DNT signals.
How We Use Artificial Intelligence and Chatbot Technology on our Sites
NewCastle may use AI features, including machine learning and natural language processing, in connection with our Sites and NewCastle’s social media pages. The contents of chatbot communications may be shared with other NewCastle applications and retained by NewCastle and the chatbot service provider for marketing, quality assurance, and service improvement purposes.
We may use chatbots and other generative AI features to assist users with inquiries and provide information about NewCastle companies and properties. It is important for users to understand that the chatbot technologies we use are designed only to facilitate real-time access to basic and preliminary information about NewCastle’s services and communities. These AI features should not be used for questions about specific transactions or information that requires professional knowledge and experience. Users should always verify with a NewCastle associate any specific information obtained through AI-based feature before relying on it. Users should never enter Sensitive Information (such as social security number, other identification numbers, or health or financial information) into a chatbot or similar feature.
Your Marketing Communications Choices
E-mail marketing. You can opt out of receiving e-mail marketing and promotional communications from us by following the “unsubscribe” instructions included in each of our e-mail marketing communications. You can also unsubscribe by at our Communications Preferences page where available at a link located in the footer on our Site pages, emailing us at info@newcastlemg.com, or contacting us as explained in the section “How to Contact Us.” We will need to know the email address that you want us to remove from our marketing database and add them to our ‘Do Not Contact’ list. It may take up to ten days to process your request to unsubscribe from e-mail marketing messages. If you unsubscribe from marketing messages, we may still send e-mails to you that involve your orders or responses to your questions.
Text messages. We will only send recurring automated promotional and personalized SMS (text) marketing communications to you if you previously gave us permission to do so. You may withdraw your previously granted consent at any time by replying STOP to our text message. It may take up to seven days to process your request to STOP text marketing messages.
Protection of Personal Information
NewCastle maintains commercially reasonable administrative, technical and physical safeguards to secure the confidentiality, integrity and availability of your personal information appropriate to the nature of the personal information we collect. While the measures we implement are intended to reduce the likelihood of security problems, we cannot guarantee that these measures will prevent unauthorized access to your personal information because no method of transmission over the Internet or method of electronic data storage is fully secure.
Our Sites permit you to create an account on the NewCastle Tenant Site accounts protected by a password you create. You are responsible for maintaining the confidentiality of your password and you are responsible for any access to or use of your account by anyone else who has obtained your password through you, even if you did not authorize that person. You should notify us of any unauthorized use of your password or account. If you suspect any unauthorized use of your account, you should immediately reset your password. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem.
Retention of Personal Information
We retain personal information for as long as we reasonably require it for legal or business purposes. When we no longer have a legitimate business interest in keeping your personal information, we will delete, destroy, or de-identify (anonymize) the information. In determining retention periods, NewCastle takes into consideration warranty periods, other contractual obligations, applicable laws and what we reasonably believe are your expectations and requirements. For example, if you purchase a home, we will retain your information as required by contracts, by law, and to protect our rights. If you submit a request for information about our products or services, we will retain your contact and preferences information and consider our relationship to remain active for marketing purposes after fulfilling your request and until we take note that you no longer show interest in our products or services, or you direct us not to continue sending communications to you.
Links to Other Websites and Social Network Access
Our Sites may provide links to the websites of our Business Partners and other companies that offer products and services we believe may be of interest to you. The use of these links is at your own risk. If you click on any of these links, you will leave our Site and be transferred to an internet location operated by the third party. The information you provide on that third-party website, or is collected automatically from your usage, will be available to the third-party operator. The third-party operator may collect your IP address or device identifier and other internet browsing data and may set a cookie to enable their features to function and track your usage.
NewCastle does not have any control over or responsibility for the privacy practices or website content of any Business Partner or other third-party company (except for Service Providers we engage to collect or process information on our behalf). Any personal information you provide or is collected automatically on a third-party website will be subject to the privacy policy or practices of the third party and will not be subject to this Privacy Policy. We recommend that you review the privacy and cookie statements and practices of these third parties to learn how they collect and use personal information before sharing your information with them.
Some of our Sites may allow you to sign into and associate your social network accounts including, but not limited to, Facebook, LinkedIn, YouTube, Instagram, and X with your NewCastle account. By using this functionality, you give NewCastle permission to access all elements of your social network profile information that you have made available publicly, and to use that information in accordance with the social network's terms of use and this Privacy Policy. Please refer to the privacy settings in your social network for information about what data is shared with us and other connected websites and applications and how to manage the data shared through your account, including information about your activities using our Sites. If you would like to disconnect a social media account from NewCastle, refer to the settings of the social media platform.
Requests About Your Personal Information
All Consumer Requests
Regardless of where you live, NewCastle will honor the following requests about your personal information(“Consumer Requests”):
- Confirm if we have collected your personal information and describe the personal information we collected about you in the past twelve months;
- Correct inaccurate or update information we may have about you;
- Stop sending you e-mail or text messages for promotional purposes by using the unsubscribe feature in our e-mails or text STOP in response to a text message or contacting us or on our Communications Preferences page;
- Withdraw any consent you previously granted to use, disclose, or sell your personal information
- Opt-out from sharing your personal information for targeted advertising, which you can do on our Cookie Preferences page accessible from the link located in the footer on the Sites, by contacting us as explained in “How to Contact Us,” or in other ways as described in “How to Restrict Cookies and Targeted Advertising.”
- Opt-out from selling or sharing your personal information, which you can do by selecting “Do Not Sell or Share My Personal Information” on our Communication Preferences page or contacting us as explained in “How to Contact Us.”
- Restrict other uses of data collected by cookies on our Sites by making or changing your selections on our Cookie Preferences page accessible from the link located in the footer on the Sites,.
Specific State Law Consumer Requests
If you reside in a state which has specific data privacy laws that apply to NewCastle, we will honor Consumer Requests from residents of those states to exercise their privacy rights within any timeframes set by such applicable laws. Although there are differences among state laws, some of the Consumer Requests provided in state laws are summarized below.
Request to Know and Access What Personal Information We Collected about You. You can request to know and receive the following information regarding the last twelve (12) months:
- Categories of personal information we collected.
- Categories of sources from which personal information is collected.
- Business or commercial purpose for collecting or selling personal information.
- Categories of personal information sold or exchanged for value with a third-party and categories of such third parties.
- Categories of personal information disclosed to a third-party for a business purpose and categories of such third parties.
- Specific pieces of personal information collected about you (except for very sensitive personally identifiable information, which we will describe but not transmit).
Request to Change or Correct Your Personal Information. You can ask us to correct inaccurate information, and we may consider relevant circumstances to confirm the accuracy of the changes you request:
- The nature of the personal information (e.g., whether it is objective, subjective, unstructured, sensitive, etc.).
- How we obtained the information.
- Any documentation relating to the accuracy of the information.
You can update or correct the information contained in your NewCastle Tenant Site account by logging into your account on our Sites.
Request to Delete Personal Information. In considering a request to delete personal information we will take into account our reasons for keeping that information and the statutory standards and exclusions that apply to deletion requests. We will not delete personal information if it is necessary to complete a transaction, reasonably used for an ongoing business relationship, retained for legal purposes, or is used in a lawful manner that is compatible with the context in which you provided the information.
Once we receive and verify your request, we will separately confirm your request and follow appropriate procedures to verify the identity and authority of the person submitting the request. If your request to delete information is confirmed and verified, we will delete (and direct our service providers and contractors to delete) all or part of the requested personal information from our (and their) records, unless an exclusion applies.
If we are unable to fulfill all or part of your request, we will let you know why (for example, if we have a permitted reason to retain certain information or if the identity of the requesting person cannot be verified). For technical reasons and to maintain anonymous business statistics, we may de-identify personal information rather than erase it completely from our systems. We do not delete or de-identify job applicant information except where required by law.
How to Submit and How We Verify a Consumer Request
You may submit a Consumer Request using any of the ways explained in the “How to Contact Us” section.
Please note that to verify certain requests, we may need to verify your identity by confirming information we have on file for you, including email address, phone number, full name, address and other personal information. If you make a request on behalf of someone else, we will need to verify your authority to make that request. We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete information related to your personal information. We may require written proof of the agent’s permission to make a request on your behalf, and we may need to verify your identity directly.
How We Respond to Consumer Requests
We will confirm receipt of your Request to Know, Request to Delete, or Request to Correct within ten (10) business days and may request additional information necessary to verify that you are authorized to make the request. We will respond to any verifiable consumer request within forty-five (45) calendar days of receiving it, subject to delays and exclusions as permitted by law. If we require more time to respond, we will let you know the reason and the extension period in writing. If you have an account on the NewCastle Tenant Site, we may respond via that account. Otherwise, we will use the email address or U.S. Postal address you provided to us when making the request.
If we cannot comply with all or part of your request, we will explain the reasons why. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information readily from one entity to another entity.
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. We will not discriminate against you if you make a request about your personal information.
Personal Information of Minors
The Sites are not intended for, and NewCastle does not knowingly collect or process personal information from children under 16 years of age without appropriate parent or other consent. If we learn that personal information from individuals under 16 years of age has been collected without appropriate consent, we will take reasonable measures to promptly delete that information from our records. If you become aware of any personal information that we have received from children under age 16, please contact us as explained in “How to Contact Us.”
For Canadian, European Economic Area, United Kingdom and Other International Residents
NewCastle builds apartment communities in the United States, and we follow the privacy and consumer protection laws of the United States and its individual states. If you reside or are located in a different country, the data protection laws of that country may differ as to how your personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain your information through our Sites or other communications with us, you are giving us your express consent to transfer your personal information to, and process your personal information in, the United States, subject to U.S. laws and the terms of this Privacy Policy. Please direct your requests and questions about our privacy practices as explained in “How to Contact Us.” We may require verification of your identity before acting on a request.
How to Contact Us
To make a Consumer Request as described in “Requests about Your Personal Information,” if you have any questions about this Privacy Policy, or want to obtain more information about NewCastle’s privacy practices, you can contact us:
- Online Privacy Request: info@newcastlemg.com
- By U.S. postal mail:
100 Tenth Street NE, Suite 300, Charlottesville, VA 22902
- By telephone: 434-270-7590
- By email: info@newcastlemg.com
To make or change your preference settings for privacy purposes, you can use the following webforms or contact us by e-mail, postal mail or phone as shown above.
Click the “Do Not Sell or Share My Personal Information” link in the footer on our Site pages:
- To opt out from selling or sharing your personal information (except for permitted business purposes as described in this Privacy Policy).
Click the “Cookie Preferences” link in the footer on our Site pages:
- To opt out from sharing your personal information for targeted advertising
- To make or change your other selections about cookies.
Click the “Communications Preferences” link in the footer on our Site pages:
- To opt in to sharing your personal information with NewCastle Affiliates for marketing purposes
- To make or change your communications choices for e-mail, text messages and telephone call marketing.
Changes to Our Privacy Policy
We reserve the right to amend this Privacy Policy at any time in order to address future developments in our operations, use of technology, or legal requirements and will post the revised Privacy Policy on the Sites. You can determine when this Privacy Policy was last revised by referring to the "Effective Date" legend on the top of this Privacy Notice.
By continuing to use our Sites following such changes, you will be deemed to have agreed to such changes. If you do not agree with our Privacy Policy as in effect at any time, you should not continue to use our Sites.
NewCastle also at any time may revise our Legal Disclaimers or Terms and Conditions by updating those documents as posted on our Sites. You are bound by any such revisions and should therefore periodically visit our Sites to review the current Terms and Conditions and Legal Disclaimers to which you are bound.
Texas Residents Privacy Rights
In addition to the Consumer Requests listed in the section “Requests about Your Personal Information,” residents of Texas have additional rights under the Texas Data Privacy and Security Act of 2024 (“TDPSA”). This section applies only to personal information collected by NewCastle about consumers who are Texas residents.
- Opt-Out of Targeted Advertising: Texas residents may opt out of having their information used to provide targeted advertising. See the section on “How You Can Restrict Cookies and Targeted Advertising” to learn more.
- Opt-Out of Profiling. Texas residents have the right to opt out of the processing of their personal information for the purpose of profiling in furtherance of a decision that produces a legal or similarly significant effect. Under the TDPSA, “profiling” means automated decision-making that uses your personal information to analyze or predict your economic situation, health, personal preferences, and other behaviors. If a situation arises in which NewCastle or a NewCastle Affiliate expects to use profiling in a way that would have a legal or other significant effect, an opportunity to opt out will be provided in advance.
- Request to Transmit Data. Texas residents have the right to request, if technically feasible, to have their data transferred to a portable and readily-usable format so that you may transmit the data to someone else.
- Designate an Authorized Agent. Texas residents can use a global setting such as the Global Privacy Center, an Internet browser setting, or other authorized agent or process to exercise a right to opt-out or submit a personal information request. We may require the agent to provide verification of their authority.
- Consent to use or disclosure of Sensitive Information. We will only use your Sensitive Information for the purpose disclosed to you. We will request your express consent before using your Sensitive Information for any other purpose.
- Exercising your TDPSA Rights. To learn more about how to exercise your TDPSA rights, please see the section “Requests About Your Personal Information- How to Submit and How We Verify a Consumer Request.” We are legally required to verify your identity before we can fulfill your or your authorized agent’s request. We reserve the right to decline to consider repeated requests from a consumer in accordance with TDPSA.
- Right to Appeal. If we deny all or part of your request, you may appeal by contacting us as described in “How to Contact Us.” We will review and respond to your appeal within 60 days from the day we receive the request for appeal, explaining the reason for the decision on appeal. If your request is denied on appeal, you have the right to pursue recourse with the Texas Attorney General’s Office here.
California Residents Privacy Rights
In addition to the Consumer Requests listed in the section “Requests about Your Personal Information,” California residents have additional rights under the California Consumer Privacy Rights Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”). This section applies to personal information collected by NewCastle about California residents and their households. This Privacy Policy and this section also apply to personal information collected by NewCastle in a business context including business contact and position information about the representatives of other companies with which we engage in business transactions and discussions..
This section does not apply to our current or former NewCastle associates or job applicants whose personal information is covered in a separate privacy policy.
Collection of Personal Information The categories and sources of personal information collected by NewCastle in the preceding twelve (12) months are described in these sections of this Privacy Policy:
-
Personal Information We Collect
- What is Personal Information?
- Categories of Personal Information We Collect
- Specific Types of Personal Information You May Provide
- Sensitive Information
- Usage Information
- Information from NewCastle Affiliates
- Information from Business Partners and Other Sources
- How We Use Your Personal Information
- Information Sharing and Disclosure
The business or commercial purposes for which we use personal information are described in the section of our Privacy Policy called “How We Use Personal Information.” The categories of third parties to whom we may disclose consumers' personal information are identified in these sections of our Privacy Policy:
-
Information Sharing and Disclosure
- Business Partners
- Advertising Partners (site analytics, ad networks, social media and targeted advertising services)
- NewCastle Affiliates
- Service Providers
- Other Third Parties
Your Rights under the CCPA. California residents have the rights under the CCPA summarized below. You may exercise any of these rights by making a Consumer Request as explained in the section called “Requests about Your Personal Information.” We will respond as explained in the section called “Requests about Your Personal Information—How We Respond to Consumer Requests.”
- Right to know and access your personal information collected by us: You have the right to request us to disclose to you the categories of personal information we collect about you; the categories of sources from which we collect your personal information from; the business or commercial purpose for which we collect your personal information; the categories of third parties to whom we disclose your personal information; and the specific pieces of personal information we collected about you.
- Right to correct inaccurate personal information: You have the right to request we correct any inaccurate personal information we maintain of you, subject to the exceptions provided in the CCPA.
- Right to deletion of your personal information: You have the right to request we delete any of your personal information that we collected from you, subject to the exceptions provided in the CCPA.
- Right to know your personal information we sold or shared for targeted advertising or shared personal information for targeted advertising.
- Right to opt-out of the sale of your personal information or sharing of your personal information for targeted advertising: You have the right, at any time, to direct us not to sell your personal information or share your personal information for targeted advertising purposes.
- Right to limit use and disclosure of Sensitive Information: You have the right to limit how we use your Sensitive Information. We will only use your Sensitive Information for the purpose disclosed to you at the time we asked you to provide it. We will request your express consent before using your Sensitive Information for any other purpose.
- Right to not be discriminated against following exercising any right to opt-out or exercise other rights: We will not retaliate against you for exercising any of your rights.
Exercising your CCPA Rights. To learn more about how to exercise any of your CCPA rights, please see “Requests About Your Personal Information- How to Submit and How We Verify a Consumer Request.” Please note that you may only submit a request to know twice within a twelve (12) month period. 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. We are legally required to verify your identity before we can fulfill your or your authorized agent’s request to know what personal information we collected about you, or what personal information we sold or shared with our Business Partners. We also must verify your identity to fulfill your request to delete or correct your personal information.
Financial Incentive Programs. We may offer you certain financial incentives permitted by California law to encourage consumers to provide personal information. These incentives may result in different prices, rates, or quality levels of products or services if reasonably related to the value of your personal information and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Rights under “Shine the Light” Law. California residents may request a list of the types of customer information we provided to third parties for their direct marketing purposes and the names and addresses of all third parties with which we have shared such information during the past calendar year. We will provide the information to you free of charge within 30 days of your request. To request that we provide you with such information, please send a written request to privacyinfo@NewCastle.com. Within thirty (30) days of receiving your request, we will provide you with the information at the address you designate in your request, which may be an email address or physical address.
Effective Date
This Privacy Policy is effective as of March 2026.
Copyright © 2026 NewCastle Management Group. All rights reserved.