Last Updated: September 10, 2021

This California Consumer Privacy Act (CCPA) privacy notice (this “CCPA Notice”) is included in our Privacy Policy and applies to our processing of “personal information” of California “consumers” in relation to the Website (as the terms “personal information” and “consumer” are defined under the CCPA) (collectively, “Consumers, “you,” or “your”). Any capitalized terms or other terms not defined herein shall have the meaning given to them elsewhere in our Privacy Policy or, if not defined herein or elsewhere in our Privacy Policy, the CCPA.

To the extent of any conflict between this CCPA Notice and the rest of our Privacy Policy, this CCPA Notice shall control only with respect to Consumers and their personal information. If you are located elsewhere, please see our Privacy Policy here.

  1. General

This CCPA Notice provides further detail regarding (a) how we have processed Consumers’ personal information within the past twelve (12) months and (b) your rights under the CCPA.

  1. Personal Information We Collect
  2. Collection: We collect the categories of personal information listed below:
  3. Identifiers – Examples include name, email address, physical address, company name, and title.
  4. Commercial Information – Examples include products or services purchased, obtained, or considered and demographics/interests.
  5. Internet or Network Activity – Examples include page views, clickthroughs, referral and exiting URLs, time spent on pages, latency, and IP address.
  6. Geolocation (precise or generalized location of device)
  7. Professional or Employment Information – Examples include cover letter, and CV/Resume (including job experience, education).
  8. Characteristics of Protected Classifications under California or Federal Law – Examples include race, ancestry, gender, disability, sexual orientation, and military or veteran status.

Note that we may not collect each category of personal information above (or each example contained therein) in relation to every Consumer, depending on how Consumers interact with us through our Website.

  1. Sources: The above categories of personal information are collected from you directly or, in the context of Internet or Network Activity or Geolocation, from server logs or 1st/3rd-party cookies, pixels, or similar technologies.
  2. Business Purposes: We use the above categories of personal information for the following business purposes:
  • Responding to inquiries and other messages
  • Providing marketing materials and emails
  • Audience measurement and analytics (e.g., understanding of how the Website is used, the locations where Consumers engage with the Website, engagement with social media and other marketing channels such as email, measuring clickthroughs from URLs)
  • Providing location-specific services (e.g., finding a distributor, store, or event near you)
  • Processing job applications
  • Cybersecurity and fraud detection
  • Compliance with applicable law
  • Responding to lawful requests by public authorities
  • Establishing, exercising, or defending legal claims
  • Optimizing the Website and related services
  • A merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets (including, in each case, any due diligence relating thereto)
  • Internal purposes aligned with Consumer expectations
  • As otherwise either disclosed to you (e.g., via “just-in-time” notices) or pursuant to Consumer consent.

Note that each business purpose listed herein may not use every category of personal information described above. For example, “Protected Classifications” under California or Federal law are a designation primarily relevant to the employment context (and associated legal compliance). However, all information may be transferred in the context of a merger, sale, or similar event, as such are further described above.

  1. Disclosures: For the above business purposes, we disclose each of the categories of personal information above to third parties and service providers such as cloud storage and web hosting providers, distributors, technical assistance and security vendors, database management/back-up services, analytics services, email clients, digital marketing services (e.g., marketing automation), customer relationship management/CRM platforms, and customer service vendors. For clarity, we do not use professional or employment information or characteristics of protected classifications for marketing purposes.

III. Your CCPA Rights

  1. Access: You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice per every twelve (12) months.
  2. Deletion: You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations, as discussed below.
  3. “Do Not Sell” Requests: We do not “sell” your personal information, as such term is defined under the CCPA, nor do we have actual knowledge of any “sales” of personal information of minors under the age of sixteen (16).
  4. Exercising Your Rights: To exercise the access and deletion rights described above, please submit a request to us by either:
  • Filling out this form
  • Calling us at 1-877-218-2434

Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA. Please note that a record of your requests, including how we responded and any correspondence or documentation related thereto, may be kept pursuant to our legal obligations.

  1. Verifying Your Rights Requests

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verified before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., name, email address).

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

  1. How to Contact Us

If you have any questions regarding our privacy practices as it relates to this CCPA Notice, please contact us via email at ajacobson@onlreit.com with the subject line, “CCPA Notice.”