Updated: August 7, 2020
The California Consumer Privacy Act of 2018 (“CCPA”), including amendments, requires certain disclosures and gives certain rights to California residents regarding their Personal Information. While the CCPA applies only to California residents, we believe it is important to provide the same privacy rights to everyone regardless of where you live. Thus, the rights described in this policy and the tools referenced below may be used by anyone with whom we interact or about whom we collect Personal Information. Your rights can be summarized as follows:
· You can ask us what Personal Information we have about you, including a list of categories of your Personal Information that we have sold and a list of categories of your Personal Information that we have shared.
· You can ask us to delete your Personal Information.
· You can ask us to stop selling your Personal Information.
More information on each of these requests and how to make them is provided below.
1. Personal Information Defined
Not all information we collect is Personal Information under this definition. For example, Personal Information does not include publicly available information collected from government records or information that has been de-identified or aggregated in a way that no longer allows identification of a particular person. We use both of these types of non-Personal Information to provide the Services.
2. Disclosures Regarding Personal Information
Personal Information We Collect
How we collect and store information depends on the services you use. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone who uses the Services or interacts with the Sites or Application. We are providing a full list here to comply with disclosure obligations because some of the information may have been collected about some consumers.
Identifiers; name, alias, gender, postal address, phone number, mobile number, email address, birth year. Any personal data described in subdivision (e) of Section 1798.80 of the California Consumer Privacy Act. Characteristics of protected classifications under California or federal law. Commercial, biometric, geolocation, sensory, and/or education data. Internet or other electronic network activity data.
Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via an SNS, on message boards, in chat areas or in advertising or notices you post, that information can be viewed publicly and may be collected and used by third parties without our knowledge (or our consent) and may result in data collection by or unsolicited messages from other individuals or third parties.
Sources of Personal Information We Collect
We collect the categories of Personal Information listed above from various sources. This section lists and describes those sources.
Directly from you. You may be asked to provide Personal Information when you use the Services or request information from us. This information may include:
· Registration Information. When you sign up for the Services, you are required to provide information such as your name, email address, company, password and location(s) of investment interest.
· Profile Information. You may choose to provide us with profile information, such as a photograph, personal bio, list of interests, phone number, physical address, alternate email address, and links to your profile on other social media sites or company website biographies.
· Additional Information. Additional information that you provide to us, including when you complete certain forms through the Services, post or comment through the Services, upload or submit any material through the Services, request information or contact us with inquiries, or when you use other aspects of our Services, may be collected and stored.
Indirectly from you. We may automatically collect Personal Information from you when you use the Services or interact with the Sites or Application through the use of tracking technologies or by other passive means. This “passively collected” information helps us to improve our Services and allows us to ensure the Sites and Application work as designed and in a way that meets your expectations. Some examples of the sources of this passively collected Personal Information include:
· Log Information. When you access the Services, our servers automatically record information that your browser or mobile device sends whenever you visit the Sites or Application. These server logs may include information such as your web request, IP address, browser type, browser language, your computer operating system, email patterns, your mobile device and mobile operating system, the name of your internet service provider or your mobile carrier, the date and time of your request, and one or more cookies (discussed below) that may uniquely identify your browser.
· Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Services and to recognize users by accessing our cookies. We may employ web beacons to facilitate Services administration and navigation, to track the actions of users of the Services, to compile aggregate statistics about Services usage and response rates, and to provide an enhanced online experience for visitors to the Services. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
Directly from publicly available sources. We may collect information directly from public available sources, such as county property and tax record databases.
Use and Disclosure (or “Sale”) of User’s Personal Information You
Our business is all about helping our users make connections. Connections between buyers and sellers of real estate, connections with local real estate investments clubs, connections between real estate investors and the lenders they need to make those investments a realty. The list of possible connections goes on, but you get the picture. What is important about these connections is that you intentionally use the Services to make them. The Personal Information you provide to us and that we share with other users through the Services directly facilitates those connections. While sharing your Personal Information in this way does not seem like a “sale” to us, out of an abundance of caution and in light of a very broad definition of “sale” in CCPA, we are disclosing this information to you.
Outside of this core function of Offmarket, we use both Personal Information and non-Personal Information to deliver the Services to you, to help improve your interaction with our Sites and Application, and to support our business or commercial purposes. Some examples of ways in which we use or disclose Personal Information include:
· To identify you when you sign on to your account
· To create and maintain your account and online profile
· To respond to your questions or inquiries
· To ask you to participate in surveys, or otherwise provide feedback
· To notify you of new investment opportunities
· To improve, upgrade or enhance our Sites or the Application and our Services
· To develop new products and services
· To create de-identified or aggregated lists of information for any the uses stated above
· To carry out other purposes that are disclosed to you and/or to which you consent
The categories of Personal Information that we may have disclosed for a business or commercial purpose within the past 12 months include any of the categories of Personal Information shown in the table at the beginning of this section.
We may disclose your Personal Information to the following categories of other parties for a business or commercial purpose:
· Other users of the Services
· Advertising and marketing partners
· Technical service providers
· Data analytics providers
· Subsidiaries and affiliates
· Affiliated and non-affiliated third-parties with whom we have business relationships, such as title companies or insurance agencies, so that they may provide products and services in which our users may be interested
· Entities involved in the sale or purchase of all or a portion of the our business
Additionally, we will cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In doing so, we may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas or other lawful government request for data); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; (iii) to detect or prevent fraud or security concerns; and (iv) to stop activity that we consider illegal, unethical or legally actionable.
De-Identified and Aggregated Information
3. Consumer Rights Regarding Personal Information
Right to Know the Personal Information Collected or Disclosed
When you request that we provide you with the information we collect or disclose we will provide you with an individualized response about our collection and use of your Personal Information over the past 12 months. That response will include:
· Specific pieces of Personal Information we have collected about you
· The categories of Personal Information we have collected (for reference see the table above for categories and examples of Personal Information that we may collect)
· The sources from which we have collected your Personal Information
· Our business or commercial purpose for collecting or selling Personal Information
· The categories of third parties to whom we have disclosed or sold Personal Information
· Whether we have disclosed or sold your Personal Information for a business or commercial purpose.
You may only exercise this right twice within a 12-month period.
Right to Request Deletion of Personal Information
When you request that we delete your Personal Information, we will delete Personal Information we maintain about you from our records as of the date of your request subject to certain limitations. We will also request that any service providers that we know maintain your data on our behalf also delete your Personal Information. In some cases, deletion may be accomplished through de-identification of the information.
Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection. We will also keep information needed to provide the Services you have purchased. For example, if you ask us to delete your data, but have purchased access to the PiN program, we will keep the information we need to continue providing you with investment opportunities that are consistent with your indicated preferences.
Additionally, we cannot control whether other users of our Services have stored a copy of or Personal Information from the profile you created that would allow them to contact you even after we have deleted the Personal Information from our records.
Exercising Your Right to Know or Delete
We cannot respond to your right to know or deletion if we cannot verify your identity or the authority of your agent to make the request and confirm that the Personal Information we maintain relates to you. When you make a request, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., telephone number and email address).
You must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If we have questions regarding your request you must make an effort to respond to our inquiries. If we do not understand your request we may not be able to comply.
Response Timing and Format. Where possible, we will respond to a verified right to know or delete request within 45 days of receipt. If we require more time, we will inform you of the reason and the need for an extension.
Any disclosures we provide will only cover the 12-month period preceding the verified consumer request’s receipt. The response we provide will also explain 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 to another entity.
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.
You may designate an authorized agent to make requests on your behalf. We will require verification that you did in fact give that person your authorization. Unless the law requires otherwise, your authorized agent must provide contact details for you. We will contact you to confirm that you authorized the agent to act on your behalf. Once you confirm, we will promptly respond to the rights request.
Right to Opt-Out of Sale of Personal Information
As discussed above, we share your Personal Information for various reasons, including with other investors and asset-based lenders to facilitate your real estate investment goals; with our technical service providers to improve our ability to serve you; with our advertising partners to keep you aware of the Services; and with affiliated and non-affiliated third parties so that they may provide products and services in which our users may be interested. Because each of these types of disclosures may be classified as “sales” under CCPA we are giving all consumers the right to direct us not to disclose Personal Information for these or any other purpose (unless permitted by law after receiving an opt-out request).
We will not discriminate against you for exercising any of the rights listed in this section. Specifically, we will not:
· Deny you Services, except to the extent that not having Personal Information prevents us from providing the Services.
· Provide you a different level or quality of Services, except to the extent that not having Personal Information limits our ability to provide the Services.
· Charge or suggest that we will charge you different prices or rates for the Services, including through granting discounts or other benefits, or imposing penalties.
4. Other Privacy Choices
In addition to the rights discussed above, there are various other ways you can choose to access, update, or limit the Personal Information you provide to us.
If you are an account holder with us you can make various changes to your account that will limit the Personal Information that is shared or disclosed to others, including:
· Changing your account settings to limit what information can be viewed by other users of the Services.
· Log-in to your account to edit or delete information you have provided to us so that other users do not see it when they view your profile.
· Log-in to your account to delete it. Note, however, that when you delete your account without specifically telling us to delete your Personal Information, we will not make additional efforts to remove such information from cached or archived pages.
Mobile Application Users
You may also choose to uninstall our Application from your mobile device regardless of whether you are an account holder or not.
Unsubscribe from Emails
You may opt-out of receiving Emails from us by following the “unsubscribe” instructions included in certain emails we send you.
We use the Google Analytics service to gather and provide us with statistical data about how our Website is used. This Google service uses a cookie that can be recognized by Google when you visit other websites. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
5. Information Storage and Security
We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your Personal Information. These security measures include Secure Socket Layer (SSL) technology data transmission. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect the Personal Information we collect about you, we cannot guarantee the security of any information we collect through the Sites or Application or in connection with the Services. If you have reason to believe that your Personal Information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
6. Other Important Information
No Children Under 13 (or 16). The Services are not directed at or intended for use by children under 13 years old. We do not knowingly collect or retain Personal Information from children under 13 through the Sites and Application. If you are under the age of 13 you should not be visiting the Sites and Application. If you are under the age of 13 and are visiting or otherwise using the Sites or Application please discontinue such use immediately and do not disclose or provide any personally information to us. If you are a parent who learns that your child has provided us with Personal Information without your consent, please contact us as provided in the Contact Us section below with sufficient detail to enable us to delete that information from our records. We will act promptly on your request to delete such information.
Users Outside the United States
The Services are not directed at or intended for users outside the United States. Please be advised that if you are located in the European Union or another region with laws related to data collection and use that may differ from U.S. law, your Personal Information submitted through the Websites or Application and transferred to the United States may not have the same legal data protection as in your jurisdiction. Accessing the Services is prohibited from territories where the Sites or Application or any content thereon is illegal. If you access the Services from other locations, you do so at your own initiative and are responsible for compliance with local laws.
Links to Third Party Sites or Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Sites or Application. These other websites and applications are not controlled by us. We are not responsible for the privacy practices or the content of those third-party websites. We encourage our users to be aware when they leave our Sites or Application and to read the privacy policies of each website and application with which they interact. Connected Investors does not endorse, screen or approve, and is not responsible for the privacy practices or content of such other websites or applications.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
8. Contact Us
For general inquiries:
· Email us at firstname.lastname@example.org;
· call us at 888-204-7501;
· Chat with us via this Site; or
· write to us at 254 N. Front, Suite 100, Wilmington, NC 28401
To submit a request to know what data we collect, click https://connectedinvestors.com/consumer-protection,
call us at 888-204-7501 ext. 144 (CCPA Support), email us at email@example.com, or chat with us via the Site.
To complete a request for deletion, click https://connectedinvestors.com/consumer-protection, call us at 888-204-7501 ext. 144 (CCPA Support), email us at firstname.lastname@example.org, or chat with us via the Site.
To access our “Do Not Sell My Personal Information” page, click https://connectedinvestors.com/content/do-not-sell
You may also make this request by calling us at 888-204-7501 ext. 144 (CCPA Support), emailing us at email@example.com, or chatting with us via the Site.