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California Privacy Notice

 

 

California Consumer Privacy Notice

Updated as of January 1, 2023

 

FOR CALIFORNIA RESIDENTS ONLY

 

Notice Statement

This Privacy Notice provides you with necessary information about the personal information we collect, how this information may be used by The Randall Group, Inc (the "Company"), your privacy rights and the Company’s obligations in accordance with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act of 2020 ("CPRA").

Scope

This Privacy Notice applies to personal information we collect online and offline, such as when you visit one of our real estate properties or submit a lease application (collectively, the “Services”). This Privacy Notice applies solely to natural persons residing in California ("Consumers"), and does not apply to individuals living elsewhere, businesses or other corporate entities.

Definitions

Consumer: As defined by the CCPA and CPRA, a consumer is a natural person who is a California resident, living in California for other than a temporary or transitory purpose, or individual domiciled in California.

Personal Information: Commonly referred to as Personally Identifiable Information (“PII”), Personal Information (“PI”) may be defined under various privacy laws, but, generally, is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable person.

Sensitive Personal Information: Sensitive Personal Information (“SPI”) is a subset of PI that requires greater security protections and standards of care in handling. SPI, also known as "special categories of information", is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. SPI may include information such as racial and ethnic origin, religion, medical information, financial account information and biometric information.

The Company: For the purposes of this Notice, we will refer to The Randall Group, Inc. and our associated affiliates (CTL Management, Inc. and Focus Commercial, Inc.)  as “the Company”, and collectively as “we”, “our”, or “us”.

 

Procedures

1. CONSUMER RIGHTS

The CPRA affords consumers residing in California the following rights with respect to their personal information, subject to certain exceptions:

1.1. RIGHT TO ACCESS

You have the right to access PI which we may collect or retain about you. If requested, we shall provide you with a copy of your PI which we collect as permitted by the CCPA/CPRA.

You also have the right to receive your PI in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

1.2. RIGHT TO KNOW

You have the right to request that we disclose the following about your PI, as defined by the CCPA/CPRA:

  • The specific PI we may collect;
  • The categories of PI we may collect;
  • The categories of sources from which we may collect your PI;
  • The business purpose(s) for collecting or sharing your PI;
  • The categories of PI we may disclose for business purposes; and
  • The categories of third parties to whom we may share your PI.

1.3. RIGHT TO OPT-OUT / DO NOT SELL OR SHARE MY PERSONAL INFORMATION

The Company does not sell or share your PI to third parties for monetary consideration or for cross-context behavioral advertising.

We do not knowingly sell, share, use for cross-context behavioral advertising or disclose the personal information of children under the age of 16.

1.4. LIMIT THE USE AND DISCLOSURE OF MY SENSITIVE PERSONAL INFORMATION

Under the CPRA, certain types of personal information are considered “sensitive” personal information and require additional data privacy rights and obligations. The Randall Group collects government identification numbers and biometric information as described in the Sensitive Personal Information We Collect section, which may be considered SPI under the CPRA. We only collect this SPI to process your applications and provide management and customer services related to our real estate properties (collectively, the “Permitted Uses”). Because The Randall Group uses this SPI for only the Permitted Uses, there is no need for us to provide a Limit Use and Disclosure of Sensitive Personal Information right under the CPRA.

1.5. RIGHT TO DELETION

In certain circumstances, you have the right to request the erasure of your PI. Upon verifying the validity of a deletion request, we will delete your PI from our records, and instruct any service providers or third parties to delete your information, when applicable.

1.6. RIGHT TO CORRECT/RIGHT TO RECTIFICATION

In certain circumstances, you have the right to request correction of any inaccurate PI. Upon verifying the validity of a verifiable consumer correction request, we will use reasonable efforts to correct your PI as directed, taking into account the nature of the PI and the purposes of maintaining your PI.

1.7. Please note that the above rights are not absolute, and we may be entitled to deny requests, wholly or partly, where exceptions under applicable law apply.

2. EXERCISING YOUR RIGHTS

If you are a California resident, you can exercise any of your rights as described in this Notice by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights.

Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise your legal rights.

However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:

  • Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or
  • Deny your request and notify you why we are denying your request.

3. VERIFYING CONSUMER REQUESTS

When you make a request to us, we will require your name, e-mail, phone number, and address. We will attempt to match our records based on that information. Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension under the CPRA.

AUTHORIZED AGENTS

You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us below.

4. PERSONAL INFORMATION (PI) WE COLLECT

We collect PI as necessary to enable us to provide rental services to you, manage and operate our business, and to comply with our legal and regulatory obligations. If you do not provide the PI we ask for, it may delay or prevent us from providing services to you.

The PI that we may collect in the course of doing business with you may include, but is not limited to, the following:

  • Contact information, such as your name, mailing address, telephone number, and email address
  • Your date of birth;
  • Your signature;
  • Various online identifiers such as Internet Protocol address;
  • Information collected by cookies and similar tracking technologies;
  • Your employment background and other relevant applicant information;
  • Financial, account or billing information, including tax identification number, credit card, or debit card information; and
  • Other PI contained in correspondence and documents which you may provide to us.

5. SENSITIVE PERSONAL INFORMATION (SPI) WE COLLECT

We may also collect or process SPI as necessary to enable us for the Permitted Uses. You may also supply us with, or we may receive, the following SPI:

  • Government identification number, such as your driver’s license number or Social Security number or other state/national government-issued identification;
  • Information required to conduct credit checks or rental history checks; and
  • Biometric data, such as your facial image captured from surveillance footage, in combination with other data to establish individual identity

6. HOW PERSONAL INFORMATION IS COLLECTED

We collect most PI directly from you. However, we may also collect PI from the following:

  • Publicly accessible sources;
  • Directly from a third party for credit checks or rental history checks;
  • A third party, such as a bank, financial institution, or advisor, with your consent;
  • Our website, or through the use of Cookies (Please view our Website Privacy Notice and Cookie Notice for more information);
  • Third-party call centers;
  • Door entry systems and reception logs; and/or
  • CCTV and access control systems.

7. THE PURPOSE FOR WHICH PERSONAL INFORMATION IS COLLECTED

The purposes for which the Company will collect or use your PI include:

  • To provide professional rental services to you as a client or prospective client;
  • To communicate with you about services and events offered by the Company;
  • To send you technical notices, security alerts, and support and administrative messages;
  • To respond to your comments and questions and provide customer service;
  • To Personalize and improve your experience on our website;
  • To comply with our internal business processes and policies;
  • To comply with our legal, regulatory, financial, and professional obligations;
  • For operational reasons, such as improving efficiency, training, and quality control;
  • To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of the Company;
  • For updating client records; and
  • To carry out any other purpose described to you at the time the information was collected.

8. DISCLOSURE OF PERSONAL INFORMATION

The Company shall use a reasonable standard of care to store and protect from disclosure any PI collected. The Company may disclose your PI under the following circumstances or as otherwise described in this Notice:

  • In the event that we sell or purchase any business or assets, or if all or substantially all of the Company's assets are acquired by a third party, in which we may disclose your PI to the prospective seller or buyer of such business or assets, solely for the purpose of permitting the due diligence required to decide whether to proceed with a transaction;
  • If reasonably necessary to protect the vital interests of a person or the Company;
  • If we are subject to disclose or share your information in order to comply with any legal or regulatory obligation;
  • To enforce or apply our terms and conditions or to establish, exercise or defend the rights of the Company, Company Personnel, clients, customers or others; or
  • With your consent or at your direction.

We only disclose your information to the following third parties:

  • Affiliated companies and advisors as necessary to carry out the purposes for which the information was supplied or collected; and/or
  • Service providers that assist with providing rental services to you, including data hosting providers, IT and software providers, marketing database providers and accountants. Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process information for a specified, legitimate business purpose and in accordance with our instructions.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

9. SUMMARY OF PRIOR 12-MONTH PERSONAL INFORMATION HANDLING PRACTICES

We provide in the chart below a summary of our prior 12-month personal information handling practices. You can learn more about the information we collect at or before the point of collection above in the Personal Information We Collect, Sensitive Personal Information We Collect, Purpose for Which Personal Information is Collected, and Disclosure of Personal Information sections. Please note that our prior 12-month practices are the same as our current personal information handling practices.

 

Category of Personal Information

Sources

Disclosure and recipients of Personal Information

Identifiers, such as your name, telephone number, mailing address, and email address

You

Sold

We have not sold your identifiers to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your identifiers with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your identifiers with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your identifiers for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

 

Any personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e), such as your signature, social security number, government identification number, employment history, and financial information.

You

Sold

We have not sold your personal information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your personal information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your personal information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your personal information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Characteristics of protected classifications under California or federal law, such as sex and age.

You

Sold

We have not sold your personal information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your personal information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your personal information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your personal information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Commercial information, such as records of personal property

You

Sold

We have not sold your commercial information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your commercial information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your commercial information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your commercial information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Biometric information, such as your facial image collected from surveillance footage, in combination with other information to help identify you[insert example]

You

Sold

We have not sold your biometric information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your biometric information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your biometric information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your biometric information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Internet or other electronic network activity information, such as your IP address

You/Service Provider

Sold

We have not sold your Internet activity information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your Internet activity information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed your Internet activity information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your Internet activity information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Geolocation data, such as your mailing address

You

Sold

We have not sold your geolocation data to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your geolocation data with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed geolocation data with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed your geolocation data for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

 

Professional or employment-related information, such as your employment history

You

Sold

We have not sold your employment-related information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your employment-related information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed employment-related information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed employment-related information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

Sensitive Personal Information, such as your social security, driver’s license, state identification card, or passport number

You/Service Provider

Sold

We have not sold your Sensitive Personal Information to third parties for monetary consideration.

 

Shared for Cross-Context Behavioral Advertising

We have not shared your Sensitive Personal Information with third party cookie and tracker providers for cross-context behavioral advertising.

 

Service Providers

We may have disclosed Sensitive Personal Information with our service providers who help provide certain services for us, such as data hosting providers, recruitment agencies, IT and software providers, marketing database providers and accountants.

 

Purpose of Processing

We may have used and disclosed Sensitive Personal Information for other reasons, as described in greater detail in the Purpose for Which Personal Information Is Collected and Disclosure of Personal Information sections.

 

10. DATA STORAGE AND SECURITY

The Company shall use a reasonable standard of care to store and protect your PI. We use appropriate physical, technical and organizational security measures and procedures to protect PI from unauthorized use, loss, alteration, destruction or modification.

 

 

11. DATA RETENTION

The Company shall retain your PI until the initial purpose for collecting and retaining such data has been satisfied. If you subsequently agree to a new or additional purpose, your PI may be retained until that additional purpose has been satisfied. Additionally, PI may be retained for a continued period of time to comply with legal and regulatory requirements.

 

12. CHILDREN

These Services are not intended for or directed at children under the age of 16. In addition, we do not knowingly collect personal information from children under the age of 16. We also do not knowingly sell, share, use for targeted advertising or disclose the personal information of children under the age of 16.

 

13. CONTACT INFORMATION

In the event that you have any questions regarding this Notice, or any questions about your rights with respect to your Personal Information, please submit inquiries using the contact information below.


9500 SW Barbur Blvd. Suite 300, Portland, OR 97223

Office: 503.245.1131 | www.randallgroup.com.com

Toll-free: 844-245-1135 | privacy@randallgroup.com

 

Consumer Request Form: Click Here