Privacy Policy for California

In addition to the information contained in our General Privacy Notice (available here), under the California Consumer Privacy Act (“CCPA”), California residents have specific rights regarding their personal information. This Notice describes these CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

California residents have the right to request that we disclose certain information about our collection and use of their personal information over the past 12 months. Once we receive and confirm a verifiable consumer request we will disclose:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for business-to-business (“B2B”) personal information.

Deletion Request Rights

California residents have the right to request that we delete any of their personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) the 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 that the consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract with the consumer.
  • 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.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s 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.

We do not provide these deletion rights for B2B personal information.

How to Submit a Request for Access, Portability, or Deletion

To exercise the access, data portability, and deletion rights described above, if you are a California resident, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized 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. The request must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

What Happens After You Submit a Request for Access, Portability, or Deletion

Following a request to exercise your rights, we must first verify your identity. We will take commercially reasonable steps to verify your identity, which may include requiring you to provide us with a copy of state-issued identification and, in some cases, an affidavit. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in connection with a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 preceding the verifiable 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 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 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.

Personal Information Collected and Used within the Past 12 Months

California residents have the right to know what categories of personal information we have collected, where that information came from, and the business or commercial purpose for the collection, all within the past 12 months from the effective date at the bottom of this notice. Below you will find a chart that sets this out in general terms. Please note that these are categories of personal information as they are set forth under California law. We did not necessarily collect all of the specific pieces of personal information listed for any given person. Personal information does not include information excluded from the CCPA’s scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), or California Financial Information Privacy Act (FIPA).

What Personal Information We Collect

Where We Get It

Why We Collect It

(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name

Customer provided information from forms or direct interactions.

Customer interactions with a website, including page clicks, time spent, or other automatically collected meta-data. Internet cookies

To fulfill or meet the reason you provided the information. To provide, support, personalize, and develop our Website, products, and services. To create, maintain, customize, and secure your account with us. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses

(B) Any categories of personal information described in the California Consumer Records statute (Section 1798.80(e)).

Customer provided information from forms or direct interactions.

Customer interactions with a website, including page clicks, time spent, or other automatically collected meta-data

To fulfill or meet the reason you provided the information. To provide, support, personalize, and develop our Website, products, and services. To create, maintain, customize, and secure your account with us. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses

(C) Characteristics of protected classifications under California or federal law.

Not collected

Not Applicable

(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Not collected

Not applicable

(E) Biometric Information

Not collected

Not applicable

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

Customer interactions with a website, including page clicks, time spent, or other automatically collected meta-data. Internet cookies

To provide, support, personalize, and develop our Website, products, and services.

(G) Geolocation Data

Not Collected

Not applicable

(H) Audio, electronic, visual, thermal, olfactory, or similar information.

Not Collected

Not applicable

(I) Professional or employment-related information.

Customer provided information from forms or direct interactions.

To fulfill or meet the reason you provided the information. To provide, support, personalize, and develop our Website, products, and services. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses

(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Not Collected

Not applicable

(K) Inferences drawn from any of the information identified in this chart to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Not Collected

Not applicable

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose (such as auditing, debugging, and fraud prevention). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: Affiliates.

California residents have the right to know what categories of personal information we have disclosed about consumers for business or commercial purposes within the past 12 months from the effective date at the bottom of this notice. Below you will find a chart that sets this out for you in general terms. Please note that these are categories of personal information as they are set forth under California law. We did not necessarily disclose all of the specific pieces of personal information listed for any given person.

What Personal Information We Disclose

(A) Identifiers such as a 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.

(B) Any categories of personal information described in the California Consumer Records statute (Section 1798.80(e)).

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

(I) Professional or employment-related information.

We have not sold personal information within the past twelve months from the effective date at the bottom of this notice.

Shine the Light Law

Residents of the State of California, under California Civil Code §1798.83 (Shine the Light Law) have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

Contact for More Information or Questions

If you have any questions about this California Privacy Policy or about exercising your rights described above, you can contact us by:

Email: legaldepartment@trimontrea.com

Mail:

Trimont Real Estate Advisors, LLC
One Alliance Center
3500 Lenox Road NE, Suite G1
Atlanta, Georgia 30326 USA

Attn: Legal Department

Effective Date

This California Privacy Policy is effective as of 1-January-2020, and was last revised on 1-January-2020.