Privacy Policy

1. Introduction

Pass Creek Holdings LLC (“Pass Creek,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and safeguard personal information when you visit our website, inquire about properties, use campus facilities, participate in coworking programs, or engage with our services. Pass Creek Holdings LLC is an affiliated entity of Black Hills Consortium and its affiliated entities.

2. Information We Collect

We may collect the following types of information:

• Property inquiry data: Name, email address, phone number, budget range, property preferences, move-in timeline, and other details provided when you inquire about available properties, housing units, or commercial space.
• Investor interest data: Name, email, phone number, investment interests, accreditation status, and communication preferences provided during investor inquiries, campus tours, or information requests related to BHC investment opportunities.
• Facility booking data: Name, email, phone number, event type, group size, date and time preferences, and special requirements provided when booking campus facilities, meeting rooms, or event spaces.
• Coworking membership data: Name, email, phone number, company affiliation, billing information, membership tier, access logs, and usage patterns collected during coworking enrollment and use.
• Tenant data: For current and prospective tenants: application information, employment verification, rental history, and contact details as required by the lease application process.
• Website usage data: IP address, browser type, device information, pages visited, and interaction patterns collected through cookies and analytics tools.
• Communication data: Information provided when you contact us, submit inquiries, request campus tours, or subscribe to property updates.

3. How We Use Your Information

• Responding to property inquiries and facilitating property viewings
• Processing lease applications and managing tenant relationships
• Managing coworking memberships, access credentials, and facility bookings
• Providing investor information and coordinating campus tours
• Sending property availability updates, campus news, and investment updates (with your consent)
• Improving our properties, facilities, and services based on occupant feedback and usage data
• Communicating about offerings from Pass Creek and affiliated BHC entities (with your consent)
• Complying with legal obligations, tax requirements, and applicable landlord-tenant regulations

4. Information Sharing

We do not sell your personal information. We may share your information with:

• BHC affiliated entities: We may share relevant information with other Black Hills Consortium entities (such as Settle the West for relocation services, Grow Campus for coworking coordination, or THE OP for campus amenities) when you interact with services spanning multiple entities.
• Property management partners: Third-party property management vendors, maintenance providers, and facility service contractors who require access to relevant information to provide services under contractual data protection obligations.
• Service providers: Third-party vendors who assist with payment processing, email delivery, property management software, background screening (for lease applicants), and analytics under contractual data protection obligations.
• Legal requirements: When required by law, court order, governmental regulation, or in connection with landlord-tenant proceedings.

5. Investor & Tour Data

Information collected during investor inquiries and campus tours is used to provide relevant investment materials, schedule follow-up communications, and coordinate with BHC entities involved in investment activities. Investor data is treated as confidential and is only shared with authorized BHC representatives involved in investor relations. We do not share investor contact information with third parties for marketing purposes.

6. Cookies & Tracking

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyze website traffic, and understand usage patterns. We use Vercel Analytics and Speed Insights for website performance monitoring. These tools collect anonymized usage data. You may configure your browser to refuse cookies, but some features of our website may not function properly without them.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Tenant application data and financial information are stored in encrypted databases with role-based access controls. Payment processing is handled by PCI-compliant third-party providers. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy. Tenant records are retained for the duration of the lease and for up to 7 years thereafter for legal and accounting compliance. Property inquiry data is retained for up to 24 months. Investor inquiry data is retained for the duration of the investor relationship. You may request deletion of your data at any time by contacting us, subject to legal retention requirements.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access and receive a copy of your personal data
• Request correction of inaccurate or incomplete data
• Request deletion of your personal data (subject to legal retention requirements for tenant records)
• Opt out of marketing communications at any time by clicking “unsubscribe” in any email or contacting us directly
• Object to or restrict certain processing of your personal data

To exercise any of these rights, please contact us at the address below.

10. Children’s Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors through our website or services. If we become aware that we have collected information from a person under 18, we will take steps to delete such information promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be effective immediately upon posting to our website. We encourage you to review this policy periodically. Your continued use of our services following any changes constitutes acceptance of the revised policy.

12. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of South Dakota. Any disputes arising under this policy shall be subject to the exclusive jurisdiction of the state and federal courts located in Custer County, South Dakota.

13. Contact

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at legal@blackhillsconsortium.org.