California Residents
SUPPLEMENTAL PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Effective: July 1, 2023
This Supplemental Privacy Policy for California Residents (“Supplemental Privacy Policy”) supplements and is expressly made part of the information contained in Griffis Residential’s (“Griffis”) Privacy Policy, available at https://griffisresidential.com/privacy-policy/, and applies solely to visitors to our websites, our customers and others who reside in the State of California (“consumers” or “you”). We adopt this Supplemental Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”).
1. Personal Information We Collect
For the purposes of this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the particular service, product or functionality if that information is necessary to provide you with such service, product or functionality or if we are legally required to collect it.
Generally, we may collect and disclose the categories of Personal Information in the table below. Please note, the examples of Personal Information are for informational purposes only and any reference to a specific type of Personal Information is not a representation that we actually collect that specific type of Personal Information. Additionally, the categories identified below cover all categories of Personal Information that we collect, use and disclose, including both Personal Information collected through this Site and off-line. Thus, some categories of Personal Information may not be collected from or about a specific individual.
Categories with Examples
1. Identifiers
A real name, alias, postal address, email address, business contact information, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers.
2. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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.
Note: Some personal information included in this category may overlap with other categories.
3. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
4. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
5. Professional or employment-related information
Current or past job history or performance evaluations.
6. Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)
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.
7. Inferences drawn from other personal information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Personal Information does not include:
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Publicly available information from government records or information made publicly available by you or with your permission.
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Deidentified or aggregated consumer information.
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Information outside CCPA’s scope, such as:
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Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; or
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Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“FIPA”) and the Driver’s Privacy Protection Act of 1994.
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Note on inferring characteristics: Griffis does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about you.
2. How We Collect Personal Information
We may collect personal information from the following categories of sources:
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You, for example, when you submit a “Contact” form, use the “Live Chat” feature on our Site, and any information you provide during the course of leasing you an apartment.
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Automated technologies on our Site, for example, to track logins and activity on our Site.
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Government or administrative agencies, for example, law enforcement or public health authorities.
3. How We Use Personal Information
We may use the Personal Information we collect about you as described in our Privacy Policy. We may also use your Personal Information for one or more business purposes, such as:
Griffis will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice.
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To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our properties, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to submit a rental application, we will use that information to process your rental application.
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To provide, support, personalize and develop our websites and services.
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To create, maintain, customize and secure your account with us.
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To process your requests, transactions and payments and prevent transactional fraud.
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To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
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To personalize your experience on our websites and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites and via email or text message (with your consent, where required by law).
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To help maintain the safety, security and integrity of our websites, products and services, databases and other technology assets and our business.
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For testing, research, analysis and product development, including to develop and improve our websites, products and services.
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To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
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As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
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To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Griffis’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Griffis about users of our websites, our customers and other individuals is among the assets transferred.
Griffis will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. How We Disclose Personal Information
Griffis may disclose your Personal Information, to the categories of third parties as described in our Privacy Policy and for certain other business purposes. In that event, Griffis discloses your personal information, identified above, only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CCPA and other applicable laws.
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Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, analytics and digital marketing, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
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Law Enforcement Agencies. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Griffis or a third party, to protect Griffis against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security or integrity of our websites and services and any equipment used to make the websites and services available, or to comply with the law.
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Third Parties Involved in Business Transfers. Griffis may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets or similar transaction, or in the event of insolvency or bankruptcy you will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Supplemental Privacy Policy or our Privacy Policy.
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Other Third Parties. We may share Personal Information with our affiliates and business partners to whom it is reasonably necessary or desirable for us to disclose your Personal Information for the purposes described in our Privacy Policy and this Supplemental Privacy Policy.
5. Disclosures of Personal Information for a Business Purpose
In the past 12 months, Griffis has disclosed the following categories of Personal Information, listed below, to the following categories of third parties for the following business purposes (as defined by the CCPA):
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Service providers: Griffis may disclose to service providers any of the categories of personal information listed above, for the business purpose of performing services on our behalf and, in particular, for the specific purposes described above, regarding how we use personal information.
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Auditors, lawyers, consultants, and accountants engaged by Griffis: Griffis may disclose the categories of personal information to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.
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Affiliated companies: Griffis may disclose any of the categories of personal information listed above to our affiliates for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.
Categories of Personal Information Disclosed:
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Identifiers
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Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))
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Protected classification characteristics under California or federal law
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Commercial information
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Internet or other similar network activity
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Professional or employment-related information
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Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
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Inferences drawn from other personal information
6. Sales of Personal Information
In the past 12 months, Griffis has not sold Personal Information. Griffis also has not disclosed Personal Information to a third party for cross-context behavioral advertising (“sharing”). In addition, Griffis has no actual knowledge that it sells or shares the personal information of children under age 16.
7. How Long We Keep Personal Information
We retain your personal information for the course of your relationship with us and for 7 years thereafter unless a shorter or longer retention period is required by applicable law.
8. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information subject to certain exceptions. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Pieces of Personal Information
You have the right to request specific pieces of your Personal Information and information about Griffis’ collection, use, and disclosure of your Personal Information. Specifically, consumers have the right to know:
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The categories of Personal Information we collected about you.
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The categories of sources for the Personal Information we collected about you (but not the individual sources).
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Our business and/or commercial purposes for collecting or disclosing that Personal Information.
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The categories of third parties with whom we disclosed that Personal Information (but not the individual third parties).
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The specific pieces of Personal Information we collected about you. Please note that the right to obtain “specific pieces” does not grant a right to the whole of any document that contains Personal Information, but only to discrete items of Personal Information.
Deletion Request Rights
You have the right to request that Griffis delete your Personal Information that we collected from you and retained, subject to certain exceptions.
Right to Correct
You have the right to request Griffis to correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
How to Exercise Your Rights
To exercise your rights described above, please submit a verifiable consumer request to us by either:
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Calling us at 888-895-1174; or
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Emailing us at ccparequests@griffisresidential.com.
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You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting us at ccparequests@griffisresidential.com.
In the alternative, you can provide a power of attorney compliant with the California Probate Code.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person.
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Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot respond to your request to exercise your rights if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
If you submit your request other than through a password-protected account, we will match Personal Information that you provide us against Personal Information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of Personal Information), the more items of Personal Information we may request to verify you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Non-Discrimination
We will not discriminate or retaliate against you for exercising any of your rights under the CCPA.
Other California Privacy Rights
California Civil Code Section 1798.83, you have the right to request us to disclose the identity of any third parties to whom we have disclosed Personal Information within the previous calendar year, along with the type of Personal Information we disclosed, for the third parties’ direct marketing purposes. Please note that we are only required to respond to a customer request once during any calendar year, and only if we are covered by such California Civil Code section. If you are a California resident and would like to make such a request, contact us at ccparequests@griffisresidential.com. Please be aware that not all information sharing is covered by this California law and only information sharing that is covered will be included in our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
9. Changes to this Supplemental Privacy Policy
Griffis reserves the right to amend this Supplemental Privacy Policy at our discretion at any time. When we make changes to this Supplemental Privacy Policy, we will post the Supplemental Privacy Policy on the Sites and update the Supplemental Privacy Policy’s effective date. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal data, we will provide a prominent notice of such changes and the effective date of the changes before making them.
10. For More Information
We welcome your questions, comments and concerns about privacy. Please contact us at webmaster@griffisresidential.com with your feedback pertaining to privacy.
