This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA. Our California Applicant/Employee/Contractor Privacy Notice contains disclosures for job applicants, employees and contractors.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

  • Lawfully made available from government records.
  • Deidentified or aggregated.
  • Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of third parties with whom we shared Personal Information. Not all categories may apply to your Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category We Collect We Disclose We Sell Categories of Third Parties with Whom We Share Personal Information

A. Identifiers

 

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

Yes Yes Yes, only to the extent use of Facebook Pixel and Google Analytics, Google Ads, and Google Tag Manager is considered a “sale” under CCPA. ALL

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

 

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

Yes Yes No ALL

C. Characteristics of Protected Classifications under California or Federal Law

 

Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

Yes Yes No IV, VII, VIII, IX, X, XI, XII

D. Commercial Information

 

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes Yes Yes, only to the extent use of Facebook Pixel and Google Analytics, Google Ads, and Google Tag Manager is considered a “sale” under CCPA. ALL

E. Biometric Information

 

Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No N/A N/A N/A

F. Internet or Other Electronic Network Activity Information

 

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

Yes Yes Yes, only to the extent use of Facebook Pixel and Google Analytics, Google Ads, and Google Tag Manager is considered a “sale” under CCPA. ALL

G. Geolocation Data

 

Example: Precise physical location.

No N/A N/A N/A

H. Sensory Information

 

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Yes Yes No ALL

I. Professional or employment-related information

 

Examples: Job application or resume information, past and current job history, and job performance information.

Yes Yes N/A IV, VII, VIII, IX, X, XI, XII

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

 

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.  

No N/A N/A N/A

K. Inferences Drawn from Personal Information

 

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes Yes Yes, only to the extent use of Facebook Pixel and Google Analytics, Google Ads, and Google Tag Manager is considered a “sale” under CCPA. ALL

 

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

  1. Providing Services: Providing our services.
  2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
  3. Social Network Support: Updating your status on social networks, sending messages on your behalf to your social networks, and providing other features and services to you.
  4. Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks.
  5. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
  6. Personalization: Personalizing your experience on our services such as presenting tailored content.
  7. Sending Messages: Sending you email and text messages.
  8. Facilitating Payments: Facilitating transactions and payments.
  9. Deidentification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.
  10. Job Applications: Processing your job application.
  11. Safety Issues: Responding to trust and safety issues that may arise.
  12. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  13. Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  14. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  15. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
  16. Transient Use: Short-term, transient use.
  17. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
  18. Research: Undertaking internal research for technological development and demonstration.
  19. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
  20. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
  21. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

  1. You/Your Devices: You or your devices directly.
  2. Users: Other users of our services.
  3. Affiliates.
  4. Advertising Networks
  5. ISPs: Internet Service Providers.
  6. Analytics Providers.
  7. Government: Government entities.
  8. OS/Platform Provider: Operating systems and platforms.
  9. Social Networks.
  10. Resellers: Consumer data brokers.
  11. Partners: Business partners.
  12. Public: Publicly accessible sources.

Disclosure of Personal Information

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties:

  1. Advertising Providers: Advertising technology companies, such as advertising networks.
  2. ISPs: Internet service providers.
  3. Analytics Providers.
  4. Government: Government entities.
  5. OS/Platform Provider: Operating systems and platforms.
  6. Social Networks.
  7. Affiliates.
  8. Vendors: Vendors and service providers.
  9. Integrated Third Parties: Third parties integrated into our services.
  10. Third Parties as Legally Required: Third parties as required by law and similar disclosures.
  11. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
  12. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, we may require you authenticate your account by logging into your account, and/or provide us with your name, address, email address, phone number, and other identifying information or documents, as needed.

Right to Opt Out. The CCPA defines “sale” very broadly to cover common industry practices, including providing you with a customized experience on our websites and apps. In some circumstances, you may opt out of the sharing activities that meet the CCPA’s definition of “sale.” We do not currently sell your Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please call our toll-free number 1 (877) 953-9948, send an email via our Contact Information section, or visit our CCPA page on our website.

Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.

Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact us

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at privacyoffice@altusgroup.com or write to us at:

Altus Group Limited
33 Yonge Street, Suite 500
Toronto, ON M5E 1G4 Canada

Last Reviewed and Updated: July 1, 2020

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