Privacy Policy

Privacy Policy

About This Policy

Hunt Companies, Inc. and its subsidiaries and affiliates that principally operate within the real estate, infrastructure, and financial services spaces in the United States (collectively, “we,” “our,” or “the Company”) recognize and respect that privacy is important to you. We created this Privacy Policy to help you understand how our business units collect Personal Information, what types of Personal Information we collect, how we use it, the steps we take to safeguard it, and the choices you have regarding how it may be used and disclosed. By “Personal Information,” we mean information about you that identifies, describes, or is reasonably capable of being associated with you or your household.

This Privacy Policy outlines our practices with respect to the use and handling of Personal Information collected from users who access certain websites owned and/or operated by the Company (collectively, “Site” or “Sites”), or who share Personal Information with us by other means (collectively, “Users”). If you have arrived at this Privacy Policy through one of our businesses’ Sites, then this Privacy Policy governs your use of the Site, any current or future mobile application (the “Mobile Application”), all interactive features, applications, widgets, social networks and social network “tabs”, and other online or wireless offerings that post a link to this Privacy Policy (collectively, the “Services” and, together with the Sites and the Mobile Application, the “System”).

When we refer to “you,” or “your,” we mean Users and persons accessing this Privacy Policy. If the person accessing this Privacy Policy through a Site acts on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

When you use one or more of the Sites, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy. Capitalized terms used herein without definition shall have the meanings given such terms in our Terms of Use.

We encourage you to carefully read this Privacy Policy and use it to make informed decisions. In the event that you have any questions or concerns about this Privacy Policy or our uses of your Personal Information, please contact us at privacy@huntcompanies.com.

Note that if you are an investor or potential investor in one of our funds, you may also receive separate notices regarding our privacy practices concerning non-public Personal Information that we collect from you as an investor in us or in any funds that we sponsor or manage. The privacy practices contained in those notices to investors or potential investors are summarized below.

What Information Do We Collect?

The following is a description of (1) the categories of Personal Information we may have collected in the preceding 12 months; (2) the sources from which we may have collected it; (3) the business purposes for which we may have collected it; and (4) with whom we share the personal information we collect.

    1. Personal Information That You Provide to Us Directly.
      We collect from you directly Personal Information, which identifies, relates, describes, or is reasonably capable of being associated with, a particular individual or household. We may collect Personal Information from you when you:

      • Voluntarily provide us your personal details in order to register on our Site;
      • Open an investment management account with us;
      • Apply for a loan with us;
      • Enter into an agreement with us or request other financial services; and
      • Submit an application for housing.

      Although not all are applicable to each User or a Site, the categories of Personal Information that we may collect include:

      • Client login or Site registration information: We collect information from you (or about you) when you provide it to us directly. When you register on our Site or fill out a contact form, you will be asked to provide us certain details such as: full name; email or physical address; telephone number; site registration user name and password; occupation and in some cases, salary, social security number, driver’s license information, and other information.
      • Financial services information: We may collect the following from you: name, mailing address, email address, phone number, date of birth, social security number or tax identification number; driver’s license or state identification information; passport information; salary range and net worth; financial account information; and certain “bad actor” disqualification and disclosure information, and tax status. For institutional investors, we may also collect the individual’s title and position with their company.
      • Housing application information: If you complete an application for housing, you may also be asked to provide us with information such as your name, physical address, date of birth, mailing address, telephone number, email address, social security number; driver’s license, passport information, military ID or state identification information; vehicle registration; marital status; criminal history; dependent verification; financial account information, credit report; military service records; photo ID; military orders and employment information, including pay level and employment history.

 

    1. Information Collected Through Your Use Of The Site.IP AddressWe also collect Personal Information from your device when you access the Site, including:
      • Geolocation data;
      • IP address;
      • Unique identifiers (e.g., MAC address and UUID); and
      • Other information which relates to your activity through the Site.

      Cookies
      We and our service providers use cookies and other technologies in our related services, including when you visit our Site or access our services. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences, and making the interaction between you and our Services quicker and easier.

      Cookies do not contain any information that personally identifies you. Nevertheless, you may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of our Site may not operate properly, and your online experience may be limited. For more information on how to modify your browser settings or how to block, manage, or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

      Analytics Information
      We may also use a third-party tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

      For more information on Google Analytics cookies, visit www.google.com/policies. According to its own policy, Google does not collect any personal data with this process. Nevertheless, to opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

 

  1. Information Provided To Us By Others.
    We may receive your Personal Information from third parties that you ask to share your information with us.

Generally speaking, we may collect two types of data and information:

Personal Information: The first type is personal information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual or a household. Although not all of the following are applicable to each User, the categories and types of Personal Information that we may collect either online or off-line include:

  • We collect Personal Information from you (or about you) when you provide it to us directly. For example, when you register for or login to our Site or you fill out a “contact us” form, you will be asked to provide certain details such as: first and last name, alias, mailing address, email address, telephone number, site registration user name and password, and other Site registration information.
  • We collect Personal Information from your device when you access the Site. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), and other information that relates to your activity throughout the Site.
  • If you establish an investor or financial services account with us, we may collect the following information from you: first and last name, physical address, mailing address, telephone number, email address, social security or tax identification number, drivers license information, passport information, birth date, bank account name and number, information about your income and net worth, certain “bad actor” disqualification and disclosure information, and tax status. For institutional investors, we may also collect the individual’s title and position with their company.
  • If you complete and submit a loan application to us, we may collect the following information from you: first and last name, physical address, mailing address, telephone number, email address, date of birth, Social Security Number, and, if you enroll in auto-payments, banking information (bank name, routing number, and account number).
  • If you complete and submit a housing application to us, we may collect the following information from you: first and last name, physical address, mailing address, telephone number, email address, social security or tax identification number, drivers license information, passport information, birth date, bank account name and number, and employment information, including pay level and employment history.

Non-personal Information: The second type is non-personal information that is un-identified and non-identifiable information pertaining to Users that may be made available or gathered by your use of the Site. Non-personal Information may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g., pages viewed, clicks, actions, etc.). We do not know the identity of a User from which Non-personal Information is collected.

How Do We Use Your Personal Information?

We may use Personal Information that we collect from or about you for any of the following business purposes:

  • To communicate with you, such as sending you notices regarding our products and services, providing you with technical information, and responding to any inquiries or customer service issues you may have;
  • To run background checks;
  • To audit files for compliance with regulations;
  • To process applications;
  • To provide you with requested products or services and to perform our contractual obligations to you;
  • To process and fulfill your requested transactions;
  • To market our websites, products, and services (see more under “Company Promotional Correspondence” below);
  • To conduct statistical, diagnostic, and analytical purposes, intended to improve the Site and our services;
  • To better provide you with services and enhance the use of our Sites; and
  • To ensure compliance with any Company policies and any applicable law, regulation or order.

We will not use Sensitive Personal Information that we collect from or about you for any other business purpose other than described above.

What Personal Information Do We Share And Why?

We do not sell, disclose, or share our Users’ Personal Information with any third parties for their own use, and have not done so for the preceding 12 months.

We will not use disclose, share, or transfer your Personal Information with or to any other person or entity, except as follows:

  • We may share your Personal Information with third parties that you or your agents authorize us in advance to disclose to or allow to use.
  • We may share your Personal Information with our service providers, who may be located in different jurisdictions across the world, to assist us with any of the following business purposes:
    • Processing and evaluating housing applications;
    • Hosting and operating our Sites;
    • Providing you with our products or services, including providing a personalized display of our Sites;
    • Responding to your customer service inquiries or requests;
    • Responding to requests for housing maintenance or complaint resolution;
    • Storing and processing Personal Information on our behalf;
    • Providing you with marketing offers and promotional materials related to our Site, products and services; and
    • Performing internal research, technical diagnostics, security assessments, or analytics.
  • We may disclose Personal Information if we believe that disclosure is reasonably necessary to:
    • Comply with any applicable law, regulation, legal process or governmental request;
    • Enforce or investigate potential violations of our policies (including our Terms of Service);
    • Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
    • Establish or exercise our rights to prosecute or defend against legal claims;
    • Prevent harm to the rights, property or safety of the Company, our Users, or others;
    • Cooperate with law enforcement agencies and/or to enforce legal rights; or
    • Further any other purposes permitted by law.
  • We may also share aggregated demographic and statistical information that is not personally identifiable with third parties, including, without limitation, our corporate partners.

Corporate Transaction

In the event of a sale, assignment, or transfer of our assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from individuals, or that we otherwise collect in connection with the Site, to unaffiliated third-party purchasers.

Job Applicants

Any Personal Information you provide us, such as identifiers or employment history, when applying for a career position with the Company will be used solely to consider and act upon your application. We may retain your Personal Information for a period of time, but only for as long as necessary for such purposes, please see Data Retention and Rectification section below. We may disclose your Personal Information to our service providers for the purpose of evaluating your qualifications for the particular position you applied for, or other available positions.

Company Promotional Correspondence

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or through our service providers for the purpose of providing you with promotional materials concerning our products or services that we believe may interest you. We provided within such marketing materials a means by which to decline receiving further promotional materials from us. If you unsubscribe from these materials, we will remove your email address or telephone number from our marketing distribution lists.

How Can I Opt-Out Of Receiving Promotional Correspondence?

You may receive emails from the Company for a variety of other reasons. If you have an account with the Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Alternatively, you may contact us at privacy@huntcompanies.com with the word “UNSUBSCRIBE” or “REMOVE” in the subject line. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.

Accessing, Reviewing, And Changing Your Personal Information

If you have an account on the Site, you can see, review, and change most of your Personal Information by logging into your account on the Site and editing your Account Profile or by contacting us at the addresses in “How To Contact Us.” NOTE: California Residents who wish to make a consumer rights Request to Know, Request to Delete, Request to Access, or Request to Correct their data should follow the instructions in the “California Residents” sections of this Policy, below.

Data Retention And Rectification

We will retain your Personal Information for as long as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our policies, as outlined in the below Retention Schedule. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications, and anything else as required by applicable laws and regulations. We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion.

Personal Information Collected Retention Period
Device Information (e.g., IP addresses, geolocation data, unique identifiers) 2 years
Housing Application Information and supporting data from client 10 years
Low income housing tenant application and related documentation Permanent
Financial Services Information 5 years
Client Login and Site Registration 5 years
Job Applications for hired employees 10 years
Job Applications for non-hires 5 years

 

Our Privacy Policy only addresses the use and disclosure of Personal Information we collect from or about you. This Privacy Policy does not apply to any website owned and/or operated by or on behalf of any third party, even if we provide a link to such website on one of our Sites. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the Terms and Conditions and Privacy Policy of each third party that you choose to disclose information to.

Social Media Platforms and Websites

Anything that you submit to any of our pages contained on a social media platform or website by email, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform, and we are therefore not responsible for any submissions contained on a social media platform or website. By visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable Privacy Policy and Terms of Use of such website or social media platform, and that you will abide by all such provisions contained therein.

How Do We Safeguard Your Information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any service provider to comply with similar security requirements, in accordance with this Privacy Policy. We restrict access to non-public information about you to those employees who need to know that information to provide products and services to our clients, our tenants, and our funds and their investors. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied, or otherwise, that we will prevent such access.

Minors And Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. You must be at least eighteen (18) years of age to use our Site and the Company’s services. If you are not at least 18 years of age, please do not provide any Personal Information through this Site. Under no circumstances shall we allow the use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors or children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us, below.

Updates Or Amendments To This Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy Policy. The latest revision will be reflected by the “Last Updated” date first shown above. Your continued use of the Site, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy, and your agreement to be bound by the terms of such amendments.

How To Contact Us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at privacy@huntcompanies.com, at 1-866-566-9438, or at the following address:

Hunt Companies, Inc.
Attention: Chief Compliance Officer
1330 Avenue of the Americas 28th Floor
New York, NY 10019
USA

FUND INVESTORS: GLBA Notice To Investors Regarding Privacy Of Financial Information

Pursuant to the Gramm-Leach-Bliley Act (“GLBA”), Pub. L. No. 106-102, the rule issued by the Securities and Exchange Commission regarding the Privacy of Consumer Financial Information (Regulation S-P) 17 C.F.R. Part 248, and/or the rule issued by the Federal Trade Commission regarding the Privacy of Consumer Financial Information, 16 C.F.R. Part 313, institutions that provide certain financial products or services to individuals to be used for personal, family, or household purposes are required to provide written notices to their customers regarding disclosure of nonpublic personal information. This notice is being provided to you to comply with this requirement.

We understand that it is our obligation to maintain the confidentiality of non-public personal information with regard to our investors. As a consequence, we do not disclose any non-public personal information about our investors or former investors to anyone other than our affiliates and service providers, except as permitted by law. Affiliates are companies related by common ownership or control and can be financial or nonfinancial companies. Service providers include businesses such as our attorneys, accountants, and entities that assist us with the distribution of stock to our investors.

Furthermore, consistent with industry practice, we will continue to distribute certain non-public personal information, such as the schedule of investors to the fund agreement and capital account information for all investors in each specific fund, to any regulatory authority having jurisdiction over us or any of our funds; or in connection with any litigation or other dispute or otherwise as necessary or appropriate to enforce the terms of our agreements with you.

In order to accurately and efficiently conduct the fund’s investment program, we must collect and maintain certain non-public personal information about you and the fund’s other investors and former investors. We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, and entities that assist us with the distribution of stock to our investors) on a “need to know” basis, certain non-public personal information about you from the following sources:

  • Information we receive from you as set forth in your subscription agreement, investor questionnaire or similar forms, such as your name, address, and social security or tax identification number; and
  • Information about your transactions with us, our affiliates and service providers, or others, such as your participation in each of our funds such as your capital account balance, contributions, and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.

To the extent authorized by law, we also may disclose non-public personal information to other nonaffiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus.

We restrict access to non-public personal information about you to those employees who need to know that information to provide services to the fund and its investors. We maintain physical, electronic, and procedural safeguards to guard your non-public personal information. In addition, we will continue to assess new technology for protecting information with regard to our investors. If we have your consent and it has not been revoked, we may also share your non-public personal information with entities other than our affiliates and service providers. We will provide notice of our GLBA Privacy Policy annually, as long as you maintain an investment with us. This policy may change from time to time, but you can always review our current policy by contacting us for a copy. To make such a request, please send an email to privacy@huntcompanies.com or call 1-866-566-9438.

CALIFORNIA RESIDENTS: Shine The Light Law

The State of California enacted the Shine the Light law (CA Civil Code § 1798.83) that permits customers who are California residents to request certain information regarding our disclosure of personal information during the past year for marketing purposes. To make such a request, please send an email to privacy@huntcompanies.com or call 1-866-566-9438.

CALIFORNIA RESIDENTS: Summary Of Rights Under The California Consumer Privacy Act (“CCPA”)

A. Overview

The California Consumer Privacy Act of 2018, Cal. Civ. Code §1798.100 et seq., (“CCPA”) took effect on January 1, 2020 and grants new privacy rights to California consumers. The California Privacy Rights Act of 2020 (“CPRA”), is a California ballot proposition that voters approved, which expands and builds on the CCPA and went into effect on January 1, 2023. Together, the CCPA and the CPRA provide California consumer rights, including:

  • The right to know what Personal Information is collected, used, shared, or sold, both as to the categories and specific pieces of Personal Information;
  • The right to access Personal Information;
  • The right to data portability (i.e., easy, portable access to all pieces of personal data held by the company);
  • The right to delete Personal Information held by businesses and, by extension, a business’s service provider;
  • The right to opt out of (1) the sale or sharing of Personal Information and (2) targeted/cross-contextual behavioral advertising. Consumers are able to direct a business that sells or shares Personal Information to stop selling or sharing that information. Children under the age of 16 must provide opt-in consent, with a parent or guardian consenting for children under 13;
  • The right to correct inaccurate Personal Information, considering the nature of the Personal Information and purpose of the processing;
  • The right to opt out of the disclosure of sensitive Personal Information, which includes racial origin, religious beliefs, union membership, email, geolocation, account, debit or credit card numbers with passwords, and social security numbers; and
  • The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under the CCPA.

A business subject to the CCPA that collects a California consumer’s Personal Information must, at or before the point of collection, inform the consumer as to the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.

A covered business must disclose and deliver the Personal Information the business collected about the consumer in response to a verifiable consumer request

For purposes of the CCPA, “Personal Information” does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

A further summary of consumer rights provided by the CCPA follows.

B. Right to Know.

A business subject to the CCPA must disclose in its Privacy Policy the Personal Information about consumers that the business has collected, sold, or disclosed for a business purpose in the past 12 months.

A business that collects Personal Information must also disclose, in response to a verifiable consumer request, the following:

  • The categories of Personal Information the business has collected about the consumer;
  • The categories of sources from which that Personal Information is collected;
  • The business or commercial purpose for collecting or selling Personal Information collected from consumers;
  • The categories of third parties with which the business shares Personal Information; and
  • The specific pieces of Personal Information the business has collected about the consumer making the request.

A business that sells or shares a consumer’s Personal Information or discloses a consumer’s Personal Information for a business purpose must disclose the following in response to a verifiable consumer request:

  • The categories of Personal Information the business has collected about the individual consumer;
  • The categories of Personal Information the business has sold about the consumer and categories of third parties to which the Personal Information was sold by category or categories of Personal Information for each third party to which the Personal Information was sold. Or, if the business has not sold any consumer Personal Information, it must state that fact); and
  • The categories of Personal Information the business has disclosed about the consumer for a business purpose. Or, if the business has not disclosed any consumer Personal Information for a business purpose, it must state that fact.

C. Right to Correct Inaccurate Personal Information.

California consumers have the right to request that a business that maintains inaccurate Personal Information about the consumer correct that inaccurate Personal Information, considering the nature of the Personal Information and the purposes of the processing of the Personal Information. A business must use commercially reasonable efforts to correct inaccurate Personal Information as directed by the consumer.

D. Right to Deletion.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

However, the CCPA provides for certain exceptions to the Right to Deletion. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  3. Debug products to identify and repair errors that impair existing intended functionality;
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent;
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  8. Comply with a legal obligation; and/or
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

E. Right to Portability.

California consumers may obtain a copy of their Personal Information that the consumer previously provided to a business in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hinderance.

F. Right to Non-Discrimination.

A business must not discriminate against a consumer who exercises any of the consumer’s rights under the CCPA. However, a business may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer’s data and may offer financial incentives to a consumer for the collection, sale, or deletion of Personal Information on a prior opt-in consent basis.

G. Right to Opt-Out.

If a business sells consumers’ Personal Information to third parties, then the business needs to provide notice to consumers thereof and that consumers have the right to opt out of the sale of their Personal Information. Such a business must provide a “Do Not Sell My Personal Information” link on its Internet homepage that links to an Internet webpage that enables a consumer to opt out of the sale of the consumer’s Personal Information.

A business must not sell the Personal Information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s Personal Information.

H. Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to limit the Company’s use and disclosure of sensitive Personal Information to that which is necessary for providing products or services to you. You can click on the link titled “Limit the Use of My Sensitive Personal Information” which will take you to a form that enables you to limit the use of sensitive Personal Information to only that which is essential for providing goods or services.

Sensitive Personal Information includes any private information that divulges any of the following:

  • Personal identification numbers, including social security, driver’s license, passport, or state ID;
  • Account, debit, or credit card numbers;
  • Account login along with password or required credentials;
  • Personal mail, email, or text message contents when the recipient is not the business accessing it;
  • A consumer’s exact geolocation;
  • A consumer’s racial origin, religious beliefs, or union membership;
  • Information concerning a consumer’s health;
  • A consumer’s genetic data; and
  • A consumer’s sex life or sexual orientation.

Publicly available information is not sensitive Personal Information under the CCPA.

I. Privacy Policy Requirements.

A business must describe in its online privacy policy or in any California-specific description of consumer privacy rights the following, which must be updated at least once every 12 months:

  • Consumers’ rights under the CCPA, including the consumer right to opt out of any sale of the consumer’s Personal Information and, if there are sales, a separate link to the “Do Not Sell My Personal Information” Internet Web page;
  • The methods for submitting and verifying consumer requests;
  • Duration of retention Period for personal information; and
  • A list of the categories of Personal Information that the business has collected about consumers, sold about consumers, and disclosed about consumers for a business purpose in the preceding 12 months.

CALIFORNIA RESIDENTS: How To Make A CCPA Consumer Rights Request.

A. Instructions for Submitting a CCPA Consumer Rights Request to Us.

If you wish to exercise any of the CCPA consumer rights summarized above, such as a Request to Know or a Request to Delete Personal Information, you can do so in one of the following ways:

Upon receiving a verifiable Request to Know or a Request to Delete, we will confirm receipt of the request within ten (10) business days and provide some information about how we will verify and handle the request, and by when you should expect to receive a response.

Please note that you may only make a verifiable consumer Request to Know or Request to Access your data under the CCPA two times within any 12-month period.

B. Verification Of The Person Making A Consumer Rights Request.

Of course, we need to be reasonably sure that the person making the request is actually you! So, we may need some information from you to verify that you are the person whose Personal Information you are asking to know about or to delete. Accordingly, the verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Requests to delete or to know specific household Personal Information will not be granted unless each member of the household is verified.

C. Designating An Authorized Agent to Make A Request for You.

Only you or a person registered with the California Secretary of State that you designate and authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. For your protection, we will need some proof that someone seeking to act on your behalf is actually authorized by you to do so. You may also make a verifiable consumer request on behalf of your minor child.

D. Response Timing and Format.

We will try to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we need more time (up to a total of 90 calendar days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

If you are making a Request to Delete your Personal Information, we may re-confirm with you that you really want your information deleted after verifying your request.

If we cannot respond to or comply with your Request to Know or Request to Delete, for instance, because we cannot verify your identity or because an exception applies, we will explain the reasons we cannot comply with your request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.