PRIVACY POLICY (CONFERENCE CENTER / EVENT SPACE)
Effective Date: January 1, 2026
Last Updated: February 23, 2026
This Privacy Policy describes how Hadson 2 Park Avenue LLC (“Landlord,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with our operation of the Conference Center and Terrace (the “Premises”) located at 2 Park Avenue, New York, NY 10016 (the “Building”), including when our clients lease space for in-person meetings, conferences, and other events (each, an “Event”).
This policy is intended to describe our practices as the Building owner and facility operator; Event organizers/lessees may have their own privacy practices that apply to information they collect.
1. Scope; Role of Landlord vs. Event Organizers
Landlord’s role
We own the Building and operate and secure the Premises and provide building and Conference Center services (for example, Premises management, and certain technology and operational services).
Event Organizers’ role
The company or individual that licenses the Conference Center and/or the Terrace for an Event (the “Organizer”) and any vendor which the Organizer may engage in connection with an Event (each, a “Vendor”), may separately collect information about Event attendees (for example, registration details, ticketing, invitations, marketing lists, and in-room recordings managed by the Organizer).
Those practices are governed by the Organizer’s and each Vendor’s policies, not this Privacy Policy.
Service providers; contractual safeguards
We may engage third-party vendors to support Building and Conference Center operations (including, for example, security services, managed Wi-Fi/IT, access-control systems, and A/V support).
Where such Vendors process information on our behalf, we generally require that they implement and maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the information and the services provided, and that they use the information only to perform services for us and consistent with our instructions.
Scope of contracting requirements
Contractual safeguards are applied where appropriate based on the relationship and the type of information involved, including when a Vendor may have access to computerized data that includes “private information,” consistent with New York requirements applicable to entities that own or license such data.
Vendor selection and oversight
As part of our data security program, we take steps designed to select service providers capable of maintaining appropriate safeguards and, as applicable, to address security requirements in our agreements with them.
2. Information We Collect
Sources of information
We collect information from the following sources, depending on the Event and the services used at the Premises:
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From Organizers (and their authorized representatives): We receive information that Organizers choose to provide to us in connection with booking, administering, and operating an Event, including Organizer information (such as contact details, billing information, and professional credentials) and Attendee Lists submitted for security clearance.
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From attendees and devices through venue systems: When attendees or other users access the Building or Conference Center systems that we operate or support (for example, the facility’s guest Wi-Fi), we may collect digital connectivity data generated through those systems (such as MAC addresses, device types, and connection timestamps).
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From cameras and access-control / security systems: We collect security and surveillance data through security and premises-management systems, such as CCTV cameras located in common areas, elevators, and building perimeters, and other building access or security systems used to manage entry to and safety within the Premises.
3. How We Use Information
We use the categories of information described above for purposes consistent with operating and securing the Building and the Premises and providing Conference Center and Terrace services.
a. Organizer information
We may use Organizer information (such as contact details, billing information, and professional credentials provided during the booking process) to:
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Administer licenses, bookings, and accounts, including invoicing, payments, and contract administration.
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Communicate with Organizers about Event planning, building procedures, requested services, and operational coordination.
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Provide and coordinate services related to the Event, including arranging Building or Conference Center and Terrace services and coordinating with service providers where applicable.
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Legal compliance and protection, including maintaining appropriate business records and addressing disputes or issues related to the booking or Event.
b. Attendee lists
We may use Attendee lists (names and company affiliations provided by the Organizer for security clearance and building access) to:
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Facilitate facility operations and security, including managing access to the Building and the Premises and supporting security clearance and Building entry processes.
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Support Event logistics tied to the Building operations, such as planning for anticipated occupancy as needed for Building operations.
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Legal compliance and protection, including investigating or responding to reported security incidents or other issues involving entry/access to the Building and the Premises and complying with lawful requests.
c. Security & surveillance data
We may use security and surveillance data (video footage from CCTV cameras in common areas, elevators, and Building perimeters) to:
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Protect the safety and security of the Building and the Premises, including monitoring common areas, deterring unlawful activity, and investigating incidents involving the Building and its occupants/visitors.
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Support facility operations, such as addressing operational or safety issues that arise in monitored common areas.
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Legal compliance and protection, including responding to and documenting security incidents and complying with lawful requests.
d. Digital connectivity data
We may use digital connectivity data (such as MAC addresses, device types, and connection timestamps collected in connection with use of the Premise’s Guest Wi-Fi) to:
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Provide connectivity and operational support, including enabling network access, troubleshooting connectivity issues, and maintaining network performance.
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Maintain the security of our systems, including monitoring for misuse, abuse, or threats to the Building's or Premises' systems.
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Support facility operations related to technology services, such as managing and maintaining the systems used to support connectivity at the Premises.
These uses are intended to align with our role as the Building owner and facility operator and our provision of building and Conference Center services; Organizers and their Vendors may separately collect and use information under their own policies.
4. How We Disclose Information
We do not sell your information. We may disclose information in the following circumstances:
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To service providers.
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To Organizers.
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For legal and safety reasons.
5. Data Security; “Reasonable Safeguards”
We maintain reasonable administrative, technical, and physical safeguards designed to protect computerized data that includes “private information,” consistent with New York requirements applicable to entities that own or license such data.
6. Data Breach Notification
If we discover a breach of the security of computerized data that includes “private information” (as that term is defined under applicable law) and we determine that notice is required, we will provide notifications as required by applicable law and in a manner designed to be consistent with law-enforcement needs and any measures necessary to determine the scope of the incident and restore the reasonable integrity of our systems.
Notification timing may vary based on the facts and circumstances of the incident, including the nature of the information involved, the results of a prompt investigation, and any request by law-enforcement to delay notice.
Where New York breach-notification requirements apply, notification generally must be made within the timeframes specified by New York law, which may include an outside time-period in certain circumstances; however, the applicable deadline (if any) and the timing of any notice will depend on the circumstances and any legally permitted delays.
7. Recordings, Streaming, and Microphones; Eavesdropping Considerations
Certain Events may involve recording, streaming, photography, or the use of microphones and A/V technology.
New York law makes it a crime to unlawfully engage in wiretapping, mechanical overhearing, or intercepting or accessing an electronic communication.
Common-area security monitoring
We operate video surveillance (CCTV) in certain common areas of the Building (such as lobbies, hallways, corridors, elevators, and building perimeters) for safety and security purposes.
Such monitoring is not intended to capture the content of private conversations. We do not operate audio recording as part of our CCTV systems unless expressly stated in writing for a specific system or location.
Where appropriate, notice (including signage) may be posted in areas subject to CCTV monitoring.
Organizer-controlled recording inside leased spaces
Recording, streaming, or use of microphones or similar A/V capture conducted by the Organizer (or the Organizer’s Vendors, speakers, exhibitors, sponsors, or attendees) within leased event spaces is controlled by the Organizer and its Vendors, not the Landlord.
Unless we expressly agree otherwise in writing, the Organizer and its Vendors are responsible for providing all required notices and obtaining all required consents and authorizations for such recording/streaming, and for complying with applicable laws and third-party rights (including privacy and publicity rights) in connection with any collection, use, or sharing of recordings.
Landlord support for Building systems
We may operate security systems in common areas and may operate or support certain Building systems as described in this Privacy Policy; however, those activities do not alter the Organizer’s responsibility for Organizer-controlled recording within leased spaces unless expressly agreed otherwise in writing.
8. Data Retention
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Guest Lists: Typically deleted 30 days after the Event concludes, unless required for legal purposes.
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CCTV Footage: Retained on a rolling 60-day cycle and overwritten automatically, barring an active investigation.
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Lease Records: Retained for 7 years to satisfy tax and commercial audit requirements.
9. Organizer Responsibilities
The Organizer is responsible for providing clear, timely notice to attendees regarding the Organizer’s own data practices and the limited information that will be shared with the Landlord for Premises operations and security.
The Organizer is also responsible for ensuring that any Attendee information it provides to the Landlord is collected, used, and transmitted in a secure and legally compliant manner, consistent with the Organizer’s role and this policy’s description of the Landlord as facility operator.
a. Required Attendee Notice (Content and Timing)
The Organizer must ensure that all attendees receive notice (e.g., in invitations, registration materials, ticketing flows, or other Event communications) that:
(a) certain Attendee information will be shared with the Landlord for building access-control, security clearance, and related Building operations; and
(b) the Landlord’s practices are described in this Privacy Policy, while the Organizer’s separate collection (e.g., registration, ticketing, invitations, marketing lists, and in-room recordings managed by the Organizer) is governed by the Organizer’s own policies.
b. Authority to Share; No Over-Collection
By providing any guest list or other Attendee information to the Landlord, the Organizer represents and warrants that it has obtained all permissions and authorizations required to disclose that information to the Landlord for the purposes described in this Privacy Policy, including managing access to the Premises and facility security.
The Organizer must limit guest lists to the minimum information reasonably necessary for those purposes (typically names and company affiliations) and must not include sensitive or special-category information (or other unnecessary data elements) in guest lists unless the Landlord has expressly requested such fields in writing for a defined operational need.
c. Secure Transmission and Handling Requirements
The Organizer must transmit guest lists and related Attendee information to the Landlord using reasonable security measures designed to protect the information during transfer (for example, secure file transfer methods or other protected delivery mechanisms, rather than open/unsecured channels) and must ensure that only authorized personnel or vendors have access to such lists prior to transmission.
If the Organizer uses Vendors to compile, manage, or transmit guest lists or other Attendee information, the Organizer remains responsible for ensuring those Vendors implement appropriate safeguards for the information shared for Building access and security purposes.
d. Accuracy; Updates; Timing of Delivery
The Organizer is responsible for the accuracy of guest lists and for providing updates or corrections reasonably promptly when changes occur (including late additions/removals), to support access management and Building security.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The “Last Updated” date above indicates when it was most recently revised.
11. Contact Us
If you have questions about this Privacy Policy or our privacy practices, contact:
Hadson 2 Park Avenue LLC
Attn: Francesco Rauseo
2 Park Avenue | New York, NY 10016
Email: FrancoR@haddad.com
Phone: 212-630-3133