For California Residents
This notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real 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 (“personal information”). Personal information does not include de-identified, aggregated or anonymized information, publicly-available information, and certain other information that is regulated by other applicable laws such as the Gramm-Leach-Bliley Act.
Right to Know
You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
The categories of personal information we have collected about you;
The categories of sources from which we have collected your personal information;
Our business or commercial purpose(s) for collecting or selling your personal information;
The categories of third parties with whom we have shared your personal information; and
The specific pieces of personal information we have collected about you.
You have the right to request that we disclose certain information to you about our disclosures and sales of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
The categories of personal information we have collected from you;
The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold (please note, however, that we do not sell your personal information); and
The categories of personal information that we disclosed about you for a business purpose.
Right to Opt-Out
We do not sell your personal information now and have no plans to start, however, we are required to let you know that you have the right to opt-out of the sale of your personal information at any time if we ever engage in such activity.
Right to Delete
You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable law.
Right to Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different service level to you. However, we may charge a different price or provide a different service level only if the price or difference is directly related to the value provided to you by your personal information.
How to Contact us to Exercise Your Rights
To submit a request to exercise your “Right to Know” or “Right to Delete” rights provided in this notice, please email us at email@example.com, or submit your request by phone by calling us toll-free at 833-230-8102. We will evaluate the request and take action where required to do so.
We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We endeavor to respond to your request as soon as we can, within the timeframes permitted under the CCPA. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).
Verification of Requests and Authorized Agents
We may have to verify your identity when you contact us to exercise your “Right to Know” or your “Right to Delete.” Our verification process may vary depending on the nature of your request. However, generally, we will verify your request by asking you to:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or are an authorized agent.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request, and confirm that the personal information relates to you.
You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that the authorized agent has been authorized by you to act on your behalf
Your authorized agent may make a request on your behalf by contacting us at firstname.lastname@example.org.
Please note that in most cases we are not able to respond to more than two “Right to Know” requests from a consumer in any 12-month period.
Information We Collect
We have collected the following categories of personal information from consumers in the last twelve (12) months:
Identifiers (such as email address, first name and last name, phone number, IP addresses, and device identifiers)
Commercial information (such as services you have used or considered, or other purchasing or consuming information)
Internet or other electronic network activity (such as your browser type, frequency and time and date of visits to our Site, operating system, the site from which you linked to us, the name of the website you chose to visit immediately after ours, information about other websites you have recently visited, and site activity)
Geolocation data (such as your approximate location based on IP address)
Professional or employment-related information (such as employment information necessary to confirm your eligibility for certain tenant services )
Inferences from the above information (we may draw inferences drawn from any of the information identified above to create profiles of users and those that interact with us)
Our sources for this information:
We collect personal information that you voluntarily provide to us when you use our Site, our services, inquire about our properties, our business or our services, or when you interact with us. For example, when you use our Shift website services, you will provide us with your email address, first name and last name, phone number, employer name, and job title in order for you to use the services.
When you visit our Site, certain personal information is automatically collected from you, your browser, or your device.
We also collect information offline, as well as information provided to us by third parties. For example, if you use our Shift website services, you may provide information to us at our events, and we may receive information about you from your employer in order to determine your eligibility for certain Shift services.
Our business purposes for collecting this information:
We generally use personal information for the purposes for which we collect it. The specific personal information we collect, and how we use that information, will depend on the nature of our relationship with you. We collect personal information so that we can provide services to you and provide information that you request from us. This includes responding to inquiries and questions, communicating with you, providing services such as tenant services associated with our Shift website, verifying your identity and employment, and providing information about our properties and our business. If you use our Shift website services, in addition to the above, we may also use personal information to suggest certain events and amenities tailored to you.
We may also use personal information to: (i) analyze, operate and improve the Site, our services, and our business; (ii) customize the content you see when you use the Site, or the services that we offer to you; (iii) conduct market analysis, traffic flow analysis and related reporting to third parties; and (iv) for any other purposes disclosed to you at the time we collect your personal information.
We may also use personal information as we believe may be necessary or appropriate for certain essential purposes, such as: (i) to comply with applicable law and legal process; (ii) to respond to requests from public and governing authorities; (iii) to detect, prevent, or investigate potential security incidents or fraud; (iv) to enforce our Terms of Service or any other contract; (v) to protect our operations or those of our affiliates; (vi) to protect our rights, privacy, safety or property, security and/or that of third parties; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Third parties we share this information with:
We share your personal information with our third-party service providers who provide services such as website hosting, data analysis, analytics, marketing, IT services, email delivery services, and other services, to enable them to provide their services to us. These third party service providers are not authorized to retain, share, store or use the personal information for any purposes other than to provide the services they have been hired to provide.
We may also transfer personal information to third parties under the following circumstances: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of BEACON CAPITAL; (iv) when we believe it is necessary to protect the rights, property, or safety of BEACON CAPITAL or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of BEACON CAPITAL.
Date of last update: 3/17/2022