Privacy Policy

Golden Valley Property Management Corporation (“Heritage PMR,” “we,” “our,” or “us”) is a licensed property management company that manages multifamily apartment communities in California. This Privacy Policy describes our data practices regarding information that could be used to identify you or that is associated with information that identifies you (“Personal Information”). This Privacy Policy applies to Personal Information that we gather or collect via the Web Site, as well as to Personal Information collected offline by Heritage PMR. It does not apply to any Personal Information collected by third-party web sites not operated directly by Heritage PMR. Except as set forth in this Privacy Policy, Heritage PMR will not share, sell, or rent individual Personal Information with anyone without your advance permission or unless ordered by a court of law.

WHAT INFORMATION DOES HERITAGE PMR GATHER ABOUT ME?

Personal Information You Provide

General

We collect certain Personal Information you voluntarily provide in order to deliver services. For example, you may be asked to provide Personal Information such as name, email address, and phone number when requesting a tour of an Heritage PMR apartment community. If you do not provide this Personal Information, we may not be able to assist you in scheduling a tour of an Heritage PMR apartment community. We may collect your email address so that we can send you information you have requested. We may use your email address to inform you about current events or to send you updates regarding information that was previously sent to you.

Heritage PMR works with third-party web site operators to provide services such as online rental applications, resident services, and investor relations information (“Portal Sites”). When you input Personal Information to one of Heritage PMR’s Portal Sites, you are providing that information to a third party. Heritage PMR’s Portal Sites may utilize framing techniques to make it appear that the user is still on the Web Site when the user is actually on a Portal Site. For example, if you are on a page that has the look and feel of www.gvluxury.com or www.heritagepmr.com, but the URL listed in your browser is a different URL than www.gvluxury.com or www.heritagepmr.com, then know that any information you provide is being collected by this third party and not governed by this Privacy Policy.

When you leave the Web Site and are transferred to a Portal Site, you may be notified that you are no longer on the Heritage PMR Web Site. You should carefully review the privacy policy and terms of use for any Portal Site before using and providing Personal Information through a Portal Site. The operators of such Portal Sites may share the information you enter with Heritage PMR. You should carefully review this Privacy Policy to see how Heritage PMR uses information you enter through the Web Site or through any Portal Sites.

AppFolio

In order to submit a rental application online for one of Heritage PMR’s apartment communities, you will be redirected to a Portal Site operated by AppFolio. AppFolio will request certain Personal Information from you in order to process your rental application. This information may include your name, mailing address, email address, date of birth, social security number, and other identifying information. AppFolio collects this information to process your rental application and communicate to you regarding your rental application. You should review AppFolio’s data collection and sharing practices prior to providing any Personal Information to AppFolio.

AppFolio

Heritage PMR uses a third party to process applications for employment, AppFolio. AppFolio collects Personal Information when you fill out an application for employment at Heritage PMR. This information may include your name, address, email address, phone number, date of birth, employment history, educational history, and other Personal Information that is or may be relevant to the position to which you are applying. AppFolio collects this information to and shares this information with Heritage PMR so that Heritage PMR can evaluate your application for employment and communicate with you about the position or positions you are seeking.

Automatically Collected Data

When you visit our Web Site or Portal Sites, we or our third-party Portal Site operators, may collect information to administer the Web Site and analyze its usage.

Examples of this information include:

Your IP address.
The kind of browser or computer you use.
Number of links you click within the site.
State or country from which you accessed the site.
Date and time of your visit.
Name of your Internet service provider.
Web page you linked to our site from.
Pages you viewed on the site.

This information is collected to help us administer and operate the Web Site, better understand how users interact with and access the Web Site and Portal Sites, and understand the types of users that access the Web Site and Portal Sites.

HOW DOES HERITAGE PMR USE PERSONAL INFORMATION?

Business Purposes

We collect and use Personal Information for the following business purposes:

(1) to provide you with services or process transactions that you have requested;

(2) to communicate with you regarding information, features or offers that we believe will be of interest to you;

(3) to respond to your questions or other requests;

(4) to contact you with regard to the Web Site or Portal Sites;

(5) to process any applications, payments or changes to your account information;

(6) to process other information or Personal Information that you submit through the Web Site or Portal Sites;

(7) to conduct user surveys;

(8) to contact you regarding a sweepstakes, contest or promotion in which you have participated,

(9) to evaluate your application for employment; and

(10) to fulfill other purposes disclosed at the time you provide your Personal Information.

We may also use the information you provide to improve the Web Site or Heritage PMR’s services, to customize your experience on the Web Site or Portal Sites, to serve you specific content, or for other business purposes.

We may use the contact information you provide to communicate with you through email and other means, including mobile text messages, telephone calls, and push notifications. If you provide your telephone number, you agree that we may contact that number even if it is registered on a corporate, state, or national Do Not Call Registry.

If you are purchasing a service, we will request financial information. Any financial information we collect is used only to bill you for the services you purchased. If you purchase by credit card, this information may be forwarded to your credit card provider. For other types of registrations, we will ask for the relevant information. You may also be asked to disclose Personal Information to us so that we may provide online technical support and troubleshooting.

Sharing with Third Parties

We may share your Personal Information with third parties who perform services on our behalf or on behalf of the owner of one of our properties and who may use this information for their own purposes, including sending advertising to you. This includes, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renter's insurance, provide credit checks, resident screening, or collection services, manage package deliveries, provide marketing and advertising services, including marketing analytics, to Heritage PMR, or create, host and/or provide customer service on our behalf. These third parties may have access to certain Personal Information in order to provide these services to us or on our behalf. We also may share Personal Information with our business partners in order to provide services and offerings to you, and certain aggregated demographic information that does not identify you personally with our business partners regarding the users of our websites.

For more information about a third-party service provider, please contact us via email at managers@heritagepmr.com.

Heritage PMR may also disclose Personal Information we collect from you to third parties in order to:

Fulfill your service requests for services,
Protect ourselves from liability,
Protect the safety and security of Heritage PMR and its users,
Respond to legal process or comply with law, or
Provide information in connection with a merger, acquisition, or liquidation of our company.

Affiliated and Subsidiary Companies

We may share Personal Information with our affiliated or subsidiary companies who use Personal Information for business purposes related to your tenancy or to process any application, request, inquiry, or other information or Personal Information you submit via the Web Site. This includes the owner of any community where you submit an application or where you lease, as well as the management company for such community.

A cookie is a small text file that is saved in a user’s browser when you access our Web Site. We may link the information we store in cookies to any Personal Information you submit while on our Web Site. We use both “session” cookies and “persistent” cookies. We use session cookies to make it easier for you to navigate our Web Site. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s help file. We set a persistent cookie to store your passwords, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Web Site and other Web sites.

If you reject cookies, you may still use our Web Site, but your ability to use some areas of our Web Site, such as saving properties, will be limited. Some of our business partners (e.g., advertisers) may use cookies on our Web Site. For example, on occasion an advertiser may run a banner campaign on our Web Site. We have no access to or control over these cookies. This privacy statement covers the use of cookies by this Web Site only and does not cover the use of cookies by any business partners or advertisers on our Web Site or other Heritage PMR web sites. See the “Third-Party Advertisers” and “Links to Other Sites” sections of this Privacy Policy below for more information. We use Google Analytics, Google AdWords, Google Tag Manager, Crazy Egg, and New Relic on the Web Site to collect non-personally identifiable data, such as your IP address, your internet service provider, the web page you linked to our Web Site from, and other clicking and browsing behavior, to analyze how users use the Web Site, and to provide targeted advertisements to you on our Web Site. You may opt out of some of these tracking services.

CLEAR GIFS (WEB BEACONS)

We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Web Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

THIRD-PARTY ADVERTISERS

The ads appearing on this Web Site or other Heritage PMR web sites, if any, may be delivered to users by third-party advertising companies. Third-party advertising companies may use cookies and clear gifs on this Web Site, which allow it to recognize a user’s cookie when a user visits this Web Site and other Web sites. The companies serve their ads from their own web sites, independently from Heritage PMR. These companies may use non-personally identifiable information (e.g., click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Web Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. The information that the third-party advertising companies collect and share through this technology is governed by the privacy policies of those third parties. We encourage you to read the privacy statements of each and every web site that you visit that collects personally identifiable information.

HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

Our systems do not respond to browser “Do Not Track” signals, but several of our business partners who utilize cookies, Web Beacons, or other tracking technologies on the Web Site may enable you to opt out of certain of their cookies, Web Beacons, and other tracking technologies and the tailoring of advertisements to your interests. We also provide you with additional tools to opt out of certain communications from us. You can learn about this in the “Your Choices” section of this Privacy Policy.

LINKS TO OTHER SITES

This privacy statement applies only to Personal Information collected by this Web Site. This Web Site contains links to other sites that are not owned or controlled by Heritage PMR. Please be aware that Heritage PMR is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every web site that collects personally identifiable information.

SHARE THIS

When you use “Share This” to bookmark and share our products and Web Site, you will be taken to a third-party site. These third-party sites’ privacy policies govern the collection and use of the information collected on those sites.

CHILD PROTECTION AND PRIVACY

Heritage PMR does not knowingly seek to collect or maintain Personal Information or other information from children under the age of 13. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 13. Use of the Web Site by children under the age of 13 is not permitted. If you become aware that a child has provided Personal Information through our Web Site, please email us at managers@heritagepmr.com.

YOUR CHOICES

In general, you may browse the Web Site or a Portal Site without providing Personal Information. However, if you choose not to provide certain Personal Information through this Web Site or a Portal Site, Heritage PMR may not be able to provide certain services or process certain of your requests. You may not be able to submit an application for employment, may not be able to access resident services online, or otherwise use all of the features and products that Heritage PMR offers through this Web Site or a Portal Site. Depending on the functionality associated with the Web Site feature or Portal Site you are using, you may be able to update certain aspects of your Personal Information on the Web Site. If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “unsubscribe” link included in those emails. Please see the “Contact Us” section of this Privacy Policy for information about how to contact us with questions.

LEGAL REQUIREMENTS AND LAW ENFORCEMENT

We may disclose Personal Information when we believe in good faith that the law requires it; at the request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Web Site and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Web Site, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

SWEEPSTAKES AND PROMOTIONS

If you choose to enter a sweepstakes, contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

SECURITY

Heritage PMR will take reasonable steps to secure the Personal Information you agree to provide via the Web Site. Please note that no transmission of Personal Information over the Internet or the subsequent electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Web Site, please be aware of these inherent risks and know that you do so at your own risk.

INFORMATION RETENTION

Please note that in accordance with our routine corporate record-keeping practices, we may store, transfer or delete records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Web Site. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the Personal Information we collect.

JURISDICTION

The Web Site is operated in the United States of America (U.S.) and is only intended for use by individuals accessing it from the U.S. If you are located in another jurisdiction, then please be aware that any Personal Information you elect to supply will be transferred from your current location to the U.S. – to our servers, offices, and/or to the third parties described above (see “How Does Heritage PMR Use Personal Information?”), and be subject to U.S. laws regarding data privacy and collection, which may be less stringent than or otherwise different from the laws in effect in the country in which you are located. By using this Web Site or by voluntarily providing us with your Personal Information, you acknowledge and agree with your Personal Information being processed and transferred as described above.

If you have any questions regarding our Privacy Policy, please contact us at managers@heritagepmr.com.

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 are not yet 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.

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to Heritage PMR’s (“Company” “us” “we” our”) other privacy policies or notices. In the event of a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any privacy policy or notice of general applicability posted or referenced on our websites, leases, community handbooks and properties including, without limitation, www.Heritage PMRapartmenthomes.com.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (or “PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA This Notice also covers rights California Consumers have under the CCPA, as well other notices to Californians required by other laws. The description of our data practices in this Notice, as required by the CCPA, covers only calendar year 2019 and will be updated annually. Our practices in calendar year 2020 may change, however, if materially different such that we think a Consumer would reasonably expect notice we will provide notice in connection with the applicable collection, which may include reference to other applicable privacy policies and notices.

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. 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.

Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

PI WE COLLECT

We collect PI about California Consumers, including the following, which reflects our 2019 data practices:

Category of PI

Examples of PI

Sources of PI

Business or Commercial Purposes for PI Collection

Identifiers

This may include but is not limited to: name, driver’s license or state ID number, postal address, Internet Protocol address, Social Security number or national identification number and details, passport number, email address, prior address, signature, or other similar identifiers.

You
Your email and social media accounts;
Your devices;
From other individuals, such as friends or family;
Publicly-available information;
Consumer reporting agencies;
Third parties (e.g., data brokers, background check services);
Vendors.

Delivering products or services;
Analytics;
Marketing;
Security and fraud prevention;
Debugging;
Research and development;
Quality assurance.

Personal Records

This may include information such as: account number and password, application and claims history, financial account information, resident names, contact information, payment card number, credit history, criminal history, date of birth, driving citations, emergency contact details, insurance policy information, or social media account details, status as victim of domestic violence, assault, or stalking.

You;
Business partners;
Your email and social media accounts;
Chat logs;
From other individuals, such as friends or family;
Publicly-available information;
Consumer reporting agencies; Contractors or consultants;
Third parties (e.g., data brokers, background check services);
Vendors.

Delivering products or services;
Analytics;
Marketing;
Security and fraud prevention;
Debugging.

Consumer Characteristics

This may include, but is not limited to: age, citizenship status, disability or medical condition, gender, gender identity and gender expression, marital status, military or veteran status.

You;
Business partners (non-vendors);
Contractors or consultants;
Publicly-available government data;
Third parties (e.g., data brokers, background check services);
Vendors.

Delivering products or services;
Analytics;
Marketing;
Security and fraud prevention;
Legal Compliance;
Debugging.

Customer Account Details / Commercial Information

This may include, but is not limited to: account profiles, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

You.

Delivering products or services;
Analytics;
Marketing;
Research and development.

Internet Usage Information

This may include, but is not limited to: website history, browsing time, and information regarding your interaction with an Internet Web site, application, or advertisement.

You;
Your email and social media accounts;
Chat logs;
Vendors.

Delivering products or services;
Debugging;
Security and fraud prevention;
Analytics;
Marketing.

Geolocation Data

This may include, but is not limited to: precise physical location

You;
Your devices;
Your email or social media accounts.

Delivering products or services;
Analytics;
Marketing.

Sensory Data

This may include, but is not limited to: voice or video recordings.

You;
Created by us;

Your email account or social media accounts;
Chat logs;
From other individuals, such as friends or family

Delivering products or services;
Quality assurance.

Professional or Employment Information

This may include, but is not limited to: benefits and entitlements data, bonus payments, business unit / division, company / entity, compensation data, contract type - fixed term / temporary / permanent etc., corporate credit or debit card numbers, hours of work, job application details (e.g. application form, interview notes, references), job title / role, line / reporting manager, office location, personnel number, previous work history, qualifications / certifications, reference or background checks, salary / wage, salary / wage expectation, start date.

You;
Consumer reporting agencies;
Your email or social media accounts;
Chat logs;
Publicly-available government data;
Third parties (e.g., data brokers, background check services)

Delivering products or services;
Analytics;
Advertising;
Quality assurance.

Inferences from PI Collected

This may include, but is not limited to: inferences about abilities, attitudes, behavior, characteristics, predispositions, preferences.

You;
Your email and social media accounts;
Chat logs;
From other individuals, such as friends or family.

Delivering products or services;
Analytics;

Marketing;
Quality assurance;
Research and development.

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. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests.

Sources of PI

We may collect your PI directly from you, your devices, your email or social media accounts, or from business partners (non-vendors), consumer reporting agencies, contractors or consultants, other individuals, such as friends or family, third parties (e.g., data brokers, background check services), and vendors, as well as public sources of data such as government databases. For more specifics tied to each category of PI, see the chart above.

Collection and Use of PI

Generally, we collect, use and disclose your PI to provide you services and as otherwise related to the operation of our business. For more specific detail on our disclosures of PI, see the next section, Sharing of PI. We may collect, use and disclose the PI we collect for one or more of the following business purposes:

Providing Products or Services;
Processing Interactions and Transactions;
Managing Interactions and Transactions;
Research and Development;
Quality Assurance;
Security; 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.

We may collect, use and disclose your PI for additional purposes such as for interest-based advertising. In addition, we may collect, use and disclose your PI as required or permitted by applicable law. For more specifics tied to each category of PI, see the chart above.

SHARING OF PI.

We may share PI with our service providers, and others, including without limitation during calendar year 2019 as follows:

Category of PI

Categories of Third Parties

Business or Commercial Purpose for Disclosure

Identifiers

Legal counsel;
Public authorities / government bodies;
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Legal compliance;
Quality assurance.

Personal Records

Legal counsel;
Public authorities / government bodies;
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Legal compliance;
Quality assurance.

Consumer Characteristics

Legal counsel;
Public authorities / government bodies;
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Legal compliance.

Internet Usage Information

Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics.

Geolocation Data

Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Quality assurance.

Sensory Data

Legal counsel;
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Legal compliance;
Quality assurance.

Professional or Employment Information

Public authorities / government bodies;
Legal counsel;
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Quality assurance
Research and Development;
Marketing.

Inferences from PI Collected

Legal Counsel
Service Providers

Delivering products or services (to perform services on behalf of Heritage PMR);
Marketing;
Analytics;
Quality assurance.

Notwithstanding anything to the contrary in our other privacy notices, we typically restrict use of your PI that is governed by the CCPA’s Consumer rights provisions and is shared with our vendors for business purposes.

Sale

We do not believe that in 2019 we sold PI as defined under the CCPA. However, there is not yet a consensus on what the term “sell” means under the CCPA and we may revisit this conclusion as the law evolves. If you direct us to share PI we may, and that is not a sale. We do not treat disclosures required by applicable law to be made, such as to the government, to be sales. Also, disclosures amongst the entities that constitute Company as defined above are not a sale. For more information on how we interpret the term “sale” under the CCPA, including regarding cookies on our web site, see the Do Not Sell section in the California Privacy Rights notice below. In addition, for more information about cookies and ways you can exercise preferences with respect to cookies, including certain types of interest-based advertising, see the Cookies section of our Privacy Policy above.

CALIFORNIA PRIVACY RIGHTS.

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”), which will be further explained as part of the request process. 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 Portal 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 leasing 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. You are not required to create an account with us to make a Verifiable Consumer Request, but you may use your account to do so. 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, an account password, or security questions or answers 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:

The Right to Know:

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.
The specific pieces of PI we have collected about you.
A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI, by categories of PI sold for each third party.

If you are disabled and need reasonable accommodations to facilitate your request, please let us know. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process. We will verify your identity based on matching information you provided with data we have maintained on you in our systems. This data could include, but is not limited to, email address, mailing address, phone number, date of birth, address of Heritage PMR apartment in which you live, had lived or desired to live, apartment number, lease start date, and date on which you first contacted Heritage PMR. If we are not satisfied that we have sufficiently verified your identity, we may direct you to this Notice for information on our PI practices generally. 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 date.

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 and are maintaining in the period that is 12 months prior to the request date. To make a request, click here or call us at (833) 591-5938. If you are disabled and need reasonable accommodations to facilitate your request, please let us know. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process. We will verify identity based on matching information you provided with data we have maintained on you in our systems and we require that at least three of the data elements you provide match to data we already maintain on you. This data could include, but is not limited to, email address, mailing address, phone number, date of birth, address of Heritage PMR apartment for which you live, had lived or desired to live, apartment number, lease start date, and date for which you first contacted Heritage PMR. If we are not satisfied that we have sufficiently verified your identity, we may direct you to this Notice for information on our PI practices generally.

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.

Do Not Sell:

We do not believe that we sell your PI as defined under the CCPA, and until such time as we change this policy by updating this Privacy Notice, will treat PI collected under that policy as subject to a do not sell request. How we do so will depend on how the law evolves regarding what is and is not a “sale” under the CCPA. For instance, while there is not yet a consensus and although we think otherwise, data practices of third-party cookies and tracking devices associated with our websites and mobile apps may potentially be determined to constitute a “sale” of your PI as defined by the CCPA.

We do not currently provide a “do not sell” optout for cookies, but you can exercise control over browser-based cookies by adjusting the settings on your browser. In addition, third party tools enable you to search for and opt-out of some of these devices, such as the Ghostery browser plug-in available at https://www.ghostery.com/. Further, you can learn more about your choices regarding certain kinds of online interest-based advertising in our general Privacy Policy above. We do not represent that these third-party tools, programs or statements are complete or accurate. For more information on cookies and other tracking technologies that may be associated with our web sites, and ways you may exercise preferences regarding them, see our Privacy Policy above.

We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share your PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

Delete:

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, click here or call us at (833) 591-5938. If you are disabled and need reasonable accommodations to facilitate your request, please let us know. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process. We will verify identity based on matching information you provided with data we have maintained on you in our systems and we require that at least three of the data elements you provide match to data we already maintain on you. This data could include, but is not limited to, email address, mailing address, phone number, date of birth, address of Heritage PMR apartment in which you live, had lived or desired to live, apartment number, lease start date, and date on which you first contacted Heritage PMR. If we are not satisfied that we have sufficiently verified your identity, we may direct you to this Notice for information on our PI practices generally.

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.

Authorized Agents:

You may designate an agent to exercise your CCPA rights on your behalf. To exercise your rights via an agent, your agent must (1) show proof of power of attorney; or (2) submit a written authorization of his or her authority to act on your behalf.

Limitation on 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.

ADDITIONAL CALIFORNIA NOTICES.

In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

Third Party Marketing and Your California Privacy Rights:

We do not sell any information to any party. 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 provide qualifying California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, for such third parties’ own direct marketing purposes. California residents may exercise that opt-out, and/or request information about our compliance with the Shine the Light law, and obtain a disclosure of third parties we have shared information with in accordance with the law for their direct marketing purposes absent your choice and the categories of information shared, by contacting us managers@heritagepmr.com. 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.

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.

Online Privacy Practices:

For more information on our online practices and your California rights specific to our online services see our online Privacy Policy above. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

(i)Tracking and Targeting:

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our online Privacy Policy, above.

(ii) California Minors:

Any California residents under the age of eighteen (18) who have registered to use our online services and who posted information on the service can request removal by contacting us at managers@heritagepmr.com, detailing where the information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the information 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 more information on your California privacy rights, please visit https://oag.ca.gov/consumers

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