Effective: January 1, 2020
- Personal Information We Collect
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. Thus, some categories of Personal Information may not be collected from or about a specific individual.
||A real name, alias, postal address, email address, 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:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information outside CCPA’s scope, like:
- 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;
- 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.
- How We Collect Personal Information
- How We Use Personal Information
- 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.
- To provide, support, personalize and develop our websites and services.
- To create, maintain, customize and secure your account with us.
- To process your requests, transactions and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- 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).
- To help maintain the safety, security and integrity of our websites, products and services, databases and other technology assets and our business.
- For testing, research, analysis and product development, including to develop and improve our websites, products and services.
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- 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.
- How We Share Personal Information
We share your Personal Information with the following categories of third parties:
- 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 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.
- 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.
- Disclosures of Personal Information for a Business Purpose
In the past 12 months, Griffis has disclosed the following categories of Personal Information for a business purpose:
- Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics under California or federal law.
- Professional or employment-related information
- Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)
- Inferences drawn from other personal information.
- Sales of Personal Information
In the past 12 months, Griffis has not sold Personal Information.
- Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Griffis disclose certain information to you about our collection and use of Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will disclose to you, based on what you request:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business and/or commercial purposes for collecting or selling that Personal Information.
- The categories of third parties with whom we shared that Personal Information.
- The specific pieces of Personal Information we collected about you (also known as a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Griffis delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
How to Exercise Your Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person.
- 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 access, data portability and/or deletion 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.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period prior to the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
At this time, Griffis does not sell any Personal Information. The CCPA does grant consumers rights with respect to the sale of their Personal Information. If you are 16 years of age or older, you have the right to direct companies not to sell your Personal Information at any time. If you are between 13 and 16 years of age, your Personal Information can only be sold by companies that you provide affirmatively authorize to sell your Personal Information. If you are less than 13 years of age, your Personal Information can only be sold by companies that your parent or legal guardian affirmatively authorizes to sell your Personal Information. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
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 email@example.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.
We welcome your questions, comments and concerns about privacy. Please contact us at firstname.lastname@example.org with your feedback pertaining to privacy.