Your California Privacy Rights
Your Choices and Your CA and NV Privacy Rights
You have certain choices regarding information collection and communications options explained here, including:
- California residents have certain privacy rights detailed here;
- Nevada residents have certain privacy rights detailed here;
- Although Landmark Properties does not look for or respond to “do not track” signals, you can find information on tracking technologies here
- About Ads and Tracking: Learn about certain choice options regarding Tracking Technologies, including certain sharing of activities, location and/or cross-device usage for interest-based advertising here;
- Your options regarding accessing and changing certain of your Personally Identifiable Information are available here;
- Your options regarding promotional communications are explained here; and
- Children’s and minors’ privacy rights, and notice to parents of these rights, are explained here.
Your Choices and Your CA and NV Privacy Rights
- Landmark Properties may ask you to provide Personally Identifiable Information (e.g., name, address, e-mail, phone number, etc.), as well as other information (e.g., gender, interests, etc.), which may be required to access certain content, features, and functionality. More
- Landmark Properties and third parties may collect information from you automatically as you access the Service (e.g., information about the devices you use to access the Service and your usage activities). More
- The information Landmark Properties receives via the Service may be combined with information Landmark Properties receives from third parties and sources outside of the Service. More
- Landmark Properties’ policies and practices regarding Personally Identifiable Information collected from children are explained here.
Use of Information
Sharing of Information
- to deliver and improve Landmark Properties’ services;
- for Landmark Properties’ Affiliates’ (defined below) marketing and other purposes;
- in connection with corporate transactions (e.g., merger or sale);
- to display your posts or send your messages (More);
- in connection with your use of third-party services (More); and
- in connection with sweepstakes, contests and promotions (More).
- Landmark Properties does not knowingly sharing Personally Identifiable Information with third parties (other than Landmark Property Affiliates) for their own direct marketing purposes.
- Landmark Properties may share your non-Personally Identifiable Information, aggregate and/or de-identified information about you except as prohibited by applicable law.
Questions and How to Contact Landmark Properties
Table of Contents
Information we collect
Landmark Properties, and/or its Service Providers (defined below), may collect information you provide directly to Landmark Properties and/or its Service Providers via the Service. For example, Landmark Properties collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
Information Collected Automatically. Landmark Properties, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Landmark Properties with Landmark Properties-Collected PII, Landmark Properties does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Landmark Properties-Collected PII. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
- A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com settings manager. The Service may associate some or all of these types of cookies with your devices.
- Web Beacons (“Tracking Pixels”)
- Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts
- An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Landmark Properties’ web server, or from a third party with which Landmark Properties works and is active only while you are connected to the Service and deleted or deactivated thereafter.
- Location-identifying Technologies
- GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content , including third party ads, based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties.
- Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.
- Device Recognition Technologies.
- Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
- In-App Tracking Methods
- There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.
- Device and Activity Monitoring
- Technologies that monitor, and nay record, certain of your interactions with the Service, including without limitation, keystrokes, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.
Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services and used by Landmark Properties and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain third-party services. See Section 11 regarding certain choices regarding these activities.
Landmark Properties is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
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HOW WE USE THE INFORMATION WE OBTAIN
- Allow you to participate in the features we offer on the Service;
- Facilitate, manage, personalize, and improve your online experience;
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
- Landmark Properties Affiliates’ marketing and other purposes;
- Improve the Service and for any other internal business purposes;
- Tailor our content, advertisements, and offers;
- Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
- Determine your location and manage digital content rights (e.g., territory restrictions); and
- Prevent and address fraud, breach of policies or terms, and threats or harm.
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Sweepstakes, Contests, and Promotions
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Information You Disclose Publicly or to Others
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Landmark Properties relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Landmark Properties for any other marketing purpose unless Landmark Properties obtains consent from that person. Your contact information and message may be included in the communication.
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Third-Party Content, Third-Party Services, Social Features, Advertising And Analytics
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps, plug-ins, application programming interfaces (“API”), and software development kits (“SDK”)), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Landmark Properties’ content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Landmark Properties or Landmark Properties Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Landmark Properties and Landmark Properties Affiliates. Also, both Landmark Properties and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Landmark Properties may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).
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Data Security and Monitoring
Landmark Properties takes reasonable measures to protect Landmark Properties-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Landmark Properties does not guarantee the security of your information collected through the Service.
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The Service is intended for a general audience and not directed to children less than 13 years of age.
Landmark Properties does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Landmark Properties here, detailing where the content or information is posted and attesting that you posted it. Landmark Properties will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Landmark Properties does not control.
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Accessing and Changing Information
Landmark Properties may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Landmark Properties-Collected PII, and potentially certain other information about you (e.g., profile and account information). Landmark Properties will make good faith efforts to make requested changes in Landmark Properties’ then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Landmark Properties’ databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
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Choices: Tracking and Communications Options
Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website helpx.adobe.com/. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. &nnbsp;Like many online services, Landmark Properties currently does not alter Landmark Properties’ practices when Landmark Properties receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com, but Landmark Properties is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Landmark Properties is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit aboutads.info/choices, and aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Landmark Properties supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Landmark Properties directly engages to serve you Interest-based Advertising will do so as well, though Landmark Properties cannot guaranty their compliance. Landmark Properties is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
Mobile Apps. With respect to Landmark Properties’ mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:
- For Android 6.0 and above:
- For earlier versions of Android:
Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from Landmark Properties at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from Landmark Properties to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Landmark Properties may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Landmark Properties’ ongoing business relations.
Cross-Device Data. To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the section above regarding the DAA’s Interest-based Advertising choices.
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Nevada Residents. Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us here and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.
California Residents. California residents can learn more about their privacy rights in our California Consumer Privacy Notice here.
Connecticut Privacy Notice. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
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Landmark Properties California Privacy Notice
Effective Date: January 1, 2020
This notice reflects our good faith understanding of the law and our data practices as of the date posted (set forth above), but the CCPA’s implementing regulations recently became final and there remain differing interpretations of the law. Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. However, our Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department here. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.
To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available at Title 1.81.5 of the California Civil Code, Sections 1798.100 – .199 for your review, and in some places in this Notice we cite and/or link to specific CCPA sections for your reference. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
You can click on the following links to navigate to the different sections in this Notice.
PI WE COLLECT
Based on our 2019 data practices through the Effective Date, we give you notice that we collect the following types of PI about California Consumers, and use and share it as set forth below. This notice will be updated annually, and our current privacy notices at the point of collection, and general privacy policies, may reflect more current practices.
|Category of PI
||Examples of PI
||This may include but is not limited to: a real name, alias, postal address, prior address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, state ID number, passport number, or other similar identifiers.
||This may include information such as: physical characteristics or description, signature, telephone number, date of birth, education, employment, and criminal history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
|Personal Characteristics or Traits
||This may include, but is not limited to: age, citizenship, sex, marital status, religion, veteran status, familial status, race, disability, gender identity, and creed.
|Customer Account Details / Commercial Information
||This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This may include, for example, the location and type of apartment, home, or building you are interested in, desired budget, lease term, and move-in date, whether you have pets, and any additional details you wish to provide.
||This may include but is not limited to: genetic, physiological, behavioral, and biological characteristics, that can be used to establish individual identity, including but not limited to fingerprints, voiceprints, retina scans from which an identifier template can be extracted, and other physical patterns, and sleep, health, or exercise data, that contain identifying info.
|Internet Usage Information
||This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
||This may include, but is not limited to: precise physical location or movements and travel patterns.
||This may include, but is not limited to: audio and/or visual recordings of customer care calls, electronic, visual, thermal, olfactory, or similar information (e.g., security cameras).
|Professional or Employment Information
||This may include, but is not limited to: professional, educational, or employment-related information, including personal or professional references.
|Non-public Education Records
||This may include but is not limited to: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|Inferences from PI Collected
||This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The chart above reflects that categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.
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Sources of PI
We may collect your PI directly from you or from service providers, vendors and suppliers, credit reporting agencies, our affiliates, or other individuals and businesses, as well as public sources of data such as government databases.
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Use of PI
Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures and sale of PI, see the next section Sharing of PI.
We may collect, use and share the PI we collect for one or more of the following business purposes:
- Processing Interactions and Transactions
- Managing Interactions and Transactions
- Performing Services
- Research and Development
- Quality Assurance
- and Debugging
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.
We may collect and use your PI for commercial purposes such as for interest based advertising.
In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.
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CALIFORNIA PRIVACY RIGHTS
The CCPA is a new law and there remain differing interpretations of it and the regulations that implement it. Accordingly, we may from time-to-time update information in our notices regarding our data practices and your rights, modify our methods for you to make and for us to respond to your requests, and/or supplement our response(s) to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make. You may also obtain information on how to make, and may submit, a request by asking a manager at any of our management offices.
Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your social security number, driver’s license number or other government-issued id number, financial account number, any health or medical identification number, an account password, security questions or answers, or unique biometric data generated from measurements or technical analysis of human characteristics in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.
Your California Consumer privacy rights are as follows:
A. The Right to Know:
i. Information Rights:
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.
To make a request, follow the instructions at our Consumer Rights Request page here email us here or call us at 1 (888) 914-9661 PIN 493149 and indicate that you are making a right to know categories request. In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. We are required to verify a consumer’s request to know categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by the consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the consumer. If you fail to do so we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
For your specific pieces of information, as required by the CCPA, we will apply the heightened verification standards set forth in subsection (ii) below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
ii. Obtaining Copies of PI
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. To make a request, follow the instructions at our Consumer Rights Request page here email us here or call us at 1 (888) 914-9661 PIN 493149 and indicate that you are requesting to know the specific pieces of PI that we have collected about you. In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. We are required to verify a consumer’s request to know specific pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by the consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the consumer together with a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
B. Do Not Sell
We do not believe that we sell your PI as “sell” is defined under the CCPA, and until such time as we change this policy by updating this Privacy Notice, and provide a method to opt-out of sale, we will treat PI collected under that policy as subject to a do not sell request.
There may be cookies and other tracking technologies associated with our online services that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. While there is not yet a consensus, we do not believe that data practices of third-party cookies and tracking devices associated with our online services constitute a sale of PI by us and therefore we do not currently treat these activities as a “sale.” Currently, a do not sale request to us will not affect these third-party activities. However, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices. In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available at https://www.ghostery.com/. You can learn more about how to exercise certain choices regarding cookies and interest-based advertising at http://www.aboutads.info/choices/, http://www.aboutads.info/appchoices, and http://www.networkadvertising.org/choices/.
For easy access, here are links on how to manage cookies from some of the more popular browsers:
We do not represent that these third-party tools, programs or statements are complete or accurate. Clearing cookies or changing settings may affect your choices and you may have to opt-out separately via each browser and other device you use. Cookie-enabled opt-outs signals may no longer be effective if you delete, block or clear cookies. We are not responsible for the completeness, accuracy or effectiveness of any third-party notices or choices.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. Further, there is not currently a consensus as to how various user-enabled privacy or “do not track” signals or settings should be treated or what they mean, so we will not look for or respond to any that are not expressly listed here as programs in which we participate or otherwise accept, which may change as programs evolve. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
We do not knowingly sell the PI of Consumers under 16.
We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Landmark Properties as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.
To make a request,follow the instructions at our Consumer Rights Request page here email us here or call us at 1 (888) 914-9661 PIN 493149and indicate that you are making a request to delete your PI. In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. We are required to verify a consumer’s request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the consumer posted by unauthorized deletion. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
However, you may alternatively exercise a more limited control of your PI by instead exercising one of the following more limited opt-out, such as op exercising a more limited opt-out, such as opting out of marketing communications.
D. Non-Discrimination and Financial Incentive Programs:
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. We do not currently offer financial incentive programs or charge a different price or rate, or offer a different level or quality of good or service that relates to your data. If this policy changes, the material aspects of that policy will be explained and described in its program terms in accordance with the CCPA.
F. Limitation of Rights:
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
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ADDITIONAL CALIFORNIA NOTICES
In addition to CCPA rights, certain Californians are entitled to certain other notices, including:
A. Third Party Marketing and Your California Privacy Rights:
Separate from your CCPA “Do Not Sell” rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:
We do not share personal information as defined by California Civil Code § 1798.83 (the “Shine the Light law”) with third parties, other than Landmark Property affiliates, for their direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by request information about our compliance with the Shine the Light law, by emailing us here or by sending a letter to us at 315 Oconee Street, Athens, Georgia, 30606, (Attention: Legal Counsel). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
B. Online Privacy Practices:
Tracking and Targeting:
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Although our online service(s) are intended for an audience over the age of 18, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us here, detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
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