Privacy Policy

The Lombardi Privacy Policy


Effective Date: April 2024

The following Privacy Notice applies to RMA Development, LLC, a New York limited liability company, and 38 Roslyn Associates, Inc a New York limited liability company (“RMA”) in connection with your use of other specific websites managed by RMA (collectively our “Properties”). The terms “we”, “us”, or “our” refer to RMA, and the terms “you” and “your” refer to you, a rental customer or other visitor accessing our Properties.

The purpose of this Privacy Notice is to inform you of the types of information we may collect, how such information is used, with whom information may be shared, your choices regarding the control of communications and the security procedures we use to protect your information. If you want to exercise any of your rights included in this Privacy Notice, contact us at

  1. Categories of Information We Collect

At different occasions, when you enter into agreements with us, use our Properties, send us communications, or otherwise engage with us (including visiting our job application website), you may provide RMA with the following information:

  • Contact Information: We may request and collect, without limitation, your name, address, email address, home telephone number, work telephone number and cell phone number.
  • Additional Information About You: We may request and collect, without limitation, information about the home you are renting including the community, mailing address, and anticipated move-in date.
  • When you make inquiries concerning career opportunities, we will request a copy of your resume, your highest level of education and information about the type of job you are seeking.
  • Access to Camera and Photos: Our Property Mobile Applications may request access to your mobile device’s camera and photos. We’ll access your camera and photos only after you give us permission.
  • Comments to Our Blog Posts: When you post a comment to our blog, we collect your comment, name, and email address.
  • You may also provide us similar information regarding your household members and pets

Additionally, we may collect nonpublic personal information about you from the following sources:

  • Information we receive from you on applications or other forms, such as your name, address, social security number, assets, and income.
  • Information we receive from a consumer reporting agency, such as your creditworthiness and credit history; and
  • Information about your transactions with us.
  • Information we receive from criminal reporting agencies, including sex offender and prior felony charges against you.

We may collect the following contact information that you provide, confirm, or update while using the Properties:

  • The services that you desire to order and your preferences regarding service information (services information).
  • You may provide credit card information to our selected and vetted payment processor to pay for services that are ordered (credit card information), but please note such information is processed directly by the applicable third-party vendor or payment processor (and isn’t accessible by RMA).
  • The email addresses of friends and family to receive a notification regarding your move (friends and family contact information).

Certain units in our properties are equipped with smart home devices to enable smart features related to security, heating, cooling, and lighting. If you use these features, the devices will collect certain data about you, your use of the device, and device statistics, subject to the privacy policies of the device manufacturers. You are responsible for removing any personal data from such smart devices when you vacate the property.

In connection with use of the Properties, we collect certain web analytics information, including, among other information, the number of visitors to the Properties, city and county of origin, session time and navigation history, operating system type and browser type, and version (technical information). Technical information is not collected in a manner in which it can be tied to a specific user (except as described above regarding IP addresses). When you access the Properties, some of our services are provided to or through service provider websites. Personal information that you provide to those sites may be sent to the Properties in order to deliver a service. Information processed by a service provider will be processed in accordance with the service provider’s own privacy policy. In some cases, we may combine information we collect through our Properties with information collected from other online and offline sources.

  1. Use of Information You Provide to RMA Development

Except as otherwise specifically provided in this Privacy Notice or as specifically required by law, any communication or material you provide to us, whether received online, electronically, in person or otherwise collected by or submitted to us, including any data, questions, comments, suggestions or the like, is, and will be treated as, non-proprietary. Anything you submit, transmit or post may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, market research, development of prospect lists, project planning, broadcast, posting and marketing, among other things, as permitted by law and except as otherwise provided in this Privacy Notice.

We may also use information provided by you or transmitted to us through the Properties to send you emails and mobile notifications about a property in one of our communities. Your use of our Properties constitutes your permission to do so unless you specify otherwise pursuant to applicable law, as discussed below. We comply with the US Federal CAN-SPAM Act, and make every effort to ensure that our messages are not considered Spam. Of course, you may unsubscribe from any messages we send at any time and you will not receive further promotional electronic messages from us after following the instructions included within the message. Please note that you may continue to receive non-promotional emails from us regarding operational issues surrounding your apartment, your lease, and/or your community. Additionally, we may always email you in response to your correspondence or in connection with any other transactions you have with us.

  1. Categories of Information We Disclose

Except as otherwise provided in this Privacy Notice, we may use, share, or disclose all of the information that we collect from you as a prospective, current or former customer:

  • In connection with the fulfilment of the services that you request through the Properties.
  • To respond to your requests, comments, and questions. To enforce the Terms and Conditions applicable to the use of the Properties
  • As required by law or valid legal process.
  • In response to appropriate governmental requests.
  • As we deem reasonably necessary to investigate, prevent or take other appropriate action in connection with potential illegal or fraudulent activities or potential risk to the personal safety of any individual or the security of your information.
  • To manage our business.
  • To protect our interests.
  • To support direct marketing and other opportunities of RMA and third parties as described herein.
  • To assist you in finding Properties that may be of interest to you.

  1. Parties to Whom We Disclose

We may disclose nonpublic personal information about you to the following types of select third parties:

  • We may share your contact information and apartment home information with utility providers who assist RMA in providing utilities services required in order to reside at the property.
  • We may share your contact information and new apartment home information with carefully selected amenity providers that agree with RMA to offer products or services to users of the Properties. These amenity providers may use the personal information we provide for their own direct marketing. We may receive a commission or other payment if you make a purchase from an amenity provider to whom we provided your personal information.
  • We contract with business service providers to provide business functions on our behalf, such as credit card processing, payment and billing processing, IT systems management, third party hosted applications, customer service, email marketing and website analytics, and marketing research. We require service providers with access to personal information to use and protect personal information in accordance with the standards of this Privacy Notice.
  • In the event that RMA, an RMA-owned property, or a portion of its business is acquired by another company, including in bankruptcy, your information may be transferred to the successor company.

  1. Information Sharing with Companies that Perform Services on our Behalf

We may disclose any or all of the information we collect, as described above, to companies that perform services on our behalf. The categories of third parties with whom we have contracted may include, among others:

  • Financial service providers, such as our insurance agencies ; and
  • Other service providers, such as our package locker vendors, our print vendors, and our software programmers.

  1. Service Provider & Third Party Policies

Each of the service provider or other third parties identified in the Properties has its own privacy notice or policy that will differ from RMA’s Privacy Notice. By requesting products and services from RMA, your information may be provided to the applicable service provider or other third parties as discussed in this Privacy Notice. You may access the privacy policy of each service provider by visiting the provider’s website. We do not have any control over, or responsibility for, the content or operation of the website of any service provider or third party. Each such website may collect information about you and your usage of the website and have information sharing policies that differ from those of RMA. The use of such websites is at your own risk.

  1. Safeguarding Your Information

Information transmitted over the Internet may find its way to recipients to whom it is not intended or persons you may not want to have such information. Under certain circumstances, this may be beyond the control of RMA, and you are advised that such transmission may not be secure. However, RMA complies with applicable law regarding the safeguarding of your personal information, and we employ reasonable administrative, technical and physical safeguards to protect the security, confidentiality, and integrity of your information, as required by law. Further, we restrict access to nonpublic personal information about you to those associates who need to know that information in order to provide products or services to you.

  1. Your Right to Control Communications

We may provide you with an “opt-in” or “opt-out” mechanism depending on where you are located when we collect your personal data. An “opt-in” mechanism will provide you the opportunity to positively indicate that you would like or do not object to our use of your personal data for the designated purposes (such as sending you such further communications) and we will not make such use of your personal data unless you have “opted-in.” An “opt-out” mechanism will provide you the opportunity to indicate that you do not want us to use your personal data in certain ways (such as to send you such further communications), and if you “opt-out” we will not make such use of your personal data. Either way, opting-in or opting-out will be up to you and, in addition, if you do not want us to use your personal data for a particular purpose or disclose it to a third party, you may “opt-out” at any time by contacting us as provided below.

  1. Cookies and Interest-Based Advertising

We may use cookies and other devices on our Properties. Using cookies on our sites provides benefits to you. The use of cookies also allows us to measure site activity to provide a better user experience. Cookies and other devices may also be used to tell us additional information about the use of the Properties, including, without limitation, the time and length of your visit, browser type, OS type, and the pages you look at on our site. We may use third parties, such as Google Analytics, to collect such data. To learn more about how Google collects and processes data and the choices Google may offer to control these activities, you may visit Each service provider identified on, or accessed from, the Properties has its own policies on the collection and use of technical information and the use of cookies.

The Properties do not currently support “do not track” browser settings.

We use third-party advertising companies to serve ads when you visit our Properties. These companies may collect information about your visits to our Properties and other websites and/or apps in order to provide advertisements about goods and services of interest to you. We may also partner with ad networks and other companies that serve ads on behalf of us and others on non-affiliated digital properties. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information these ad networks collect about your visits to our Properties and other non-affiliated websites or apps over time.

You may visit to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:

DAA AppChoices iOS

DAA AppChoices Android

You can control the use of cookies by using your mobile device settings or the “Manage Cookies” tool at the bottom of the Properties’ web pages. By adjusting your device settings or clicking on the tool you can accept or refuse the use of defined categories of cookies. If you refuse certain categories of cookies, the Properties will remain usable, but some services functionalities may be blocked or may not work.

You may also be able to limit data collection by third parties by using your mobile device settings. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, please note that if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices.

  1. Your Privacy Rights

In connection with the accessing and browsing of the Properties, you are entitled to the following rights:

  • Right to Be Informed: you have the right to be informed about the personal information that we collect from you and how we process them.
  • Right to Rectification: if your personal information is inaccurate, you have the right to have the data rectified without undue delay.
  • Right to Access: you may request to view the categories of all personal information being processed about you.
  • Right to Erasure (Right to Be Forgotten): the right to request the removal or deletion of your personal information if there is no compelling reason for us to continue processing them. In considering a request to delete personal information we will take into account our business 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, is reasonably used for an ongoing business relationship, is retained for legal purposes, or is used in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Restrict Processing: you have the right to ‘block’ or restrict the processing of your personal information. When your personal information are restricted, we are permitted to store your data, but not to process them further.
  • Right to Data Portability: you have the right to request a copy of your personal information that you provided to us and use them for your own purposes.
  • Right to File a Complaint with Authorities: You have the right to file a complaint with supervisory authorities if your personal information has not been processed in compliance with the applicable law. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

Consumers (including applicants, employees and independent contractors) in certain states have the right to request any of the following information from RMA regarding personal information collected about you during the preceding 12 months:

  • The categories of personal information collected about you.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • For personal information disclosed to a third party for a business purpose: categories of personal information and categories third parties.
  • The specific personal information collected about you.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your state of residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

We will not discriminate against you if you choose to exercise any of these rights. residents of certain states may exercise the rights described above by contacting us as follows:

By email:

By Phone: (914) 459-1400

Please note that in order for a request to be verifiable, you may be required to confirm information that we have on file for you; including email address, phone numbers, full names, addresses and other information. We reserve the right to deny a consumer request if the identity of the requesting party cannot be confirmed.

  1. Privacy Rights in Other Jurisdictions

You may have rights, under applicable data privacy laws, to request information about or access to the personal information that we hold about you, to require that information to be corrected it is inaccurate or, in some circumstances, to object to our processing of your personal information. If you wish to exercise those rights, please send a written request to

  1. Notice to Employment Applicants and Employees

This is notice that, in connection with your application for employment and, if you are extended an offer, pre-employment and/or employment onboarding, as applicable, we collect information about applicants, employees and independent contractors, including the following categories of personal information:

Categories of Personal Information Collected

Disclosed for a Business Purpose?

Categories of Third Parties to Whom the Information was Disclosed

Name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers


Service providers who perform services on the Company’s behalf, such as helping manage the recruitment and onboarding process, providing applicant tracking systems and recruiting software and conducting background checks (“Employment Service Providers”)

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


Employment Service Providers

Characteristics of protected classifications under state or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, and gender identity)


Employment Service Providers

Biometric information to enable employees to participate in company health contests (e.g., walking sprees)


Employment Service Providers

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding interaction with an internet web site, application, or advertisement


Employment Service Providers

Professional or employment-related information


Employment Service Providers

Education information


Employment Service Providers

Inferences drawn from any personal information to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes


Employment Service Providers

We collect the following categories of sensitive personal information regarding applicants, employees and their emergency contacts and beneficiaries, and independent contractors:

Categories of Sensitive Personal Information Collected

Disclosed for a Business Purpose?

Categories of Third Parties to Whom the Information was Disclosed

Personal information that reveals social security, driver’s license, state identification card, or passport number


Employment Service Providers

Personal information that may be included in an employee’s workspace that is examined by the Company while the employee is on video call to monitor compliance with Company privacy and security and safety protocols related to remote work


Employment Service Providers

Personal information collected and analyzed concerning an employee’s health (including results of pre-employment drug screenings)


Employment Service Providers

We do not use or disclose the above sensitive personal information for any purpose other than those permitted under applicable local law.

The personal information and sensitive personal information described above are collected directly from you when you (1) apply for employment or through third-party recruiters, or (2) provide such information in relation to your employment with us. Such information is not sold or shared as such terms are defined under applicable local law, and the Company does not have actual knowledge that it sells or shares the personal information of anyone under 16 years of age.

We collect, use and disclose the personal information, including sensitive personal information, described above only for business purposes related to your application for employment and/or any post-offer, onboarding, or employment activities, as applicable. Those purposes may include:

  • To evaluate an applicant's qualifications and suitability for employment;
  • To administer pre-employment tests and training activity;
  • To complete the onboarding process;
  • To conduct criminal and other background checks;
  • To manage the terms and conditions of employment, such as payment of wages/salary, direct deposit authorization, the provision and administration of benefits and leaves of absence and maintenance of emergency contact information;
  • To prepare and maintain legally required records, such as I-9 forms, EEO-1 forms and affirmative action plans;
  • To provide a safe work environment;
  • To manage employee timekeeping;
  • To maintain information regarding training, disciplinary action, injuries and other employment history;
  • To ensure compliance with our company policies (including privacy and security and safety protocols related to remote work) and legal requirements;
  • To meet tax obligations;
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible; and
  • To achieve other operational purposes for which the personal information was collected that are compatible with the context in which the personal information was collected and our employment or independent contractor relationship for that activity.

We will retain the personal information, including sensitive personal information, described above as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

  1. Children’s Information

The Properties are not directed at or intended to be used by children, and we will not intentionally collect or maintain personal information about anyone under the age of 13, except for information provided by the relevant parent(s) or guardian(s). If we discover that we have collected any other personal information about anyone under the age of 13, we will take reasonable steps to promptly delete such information from our systems.

  1. Revisions of Terms

RMA may at any time revise the Privacy Notice or Terms and Conditions by updating the posting. You are bound by any such revision and should therefore periodically visit the Properties to review the then current terms and conditions, privacy notice and legal disclaimers to which you are bound.

Thank you for taking the time to read all of this important information.

  1. Effective Date

This Privacy Notice is effective as of date set forth at the top of this Privacy Notice and is incorporated into and subject to the Terms and Conditions for use of these Properties.