Effective Date: November 17, 2020
You can access the Sites in many ways, including from a computer or mobile device, and this Policy will apply regardless of the means of access. To the extent we provide you notice through the Sites of different or additional privacy policies or practices (e.g.
, at the point of collection), those additional terms shall govern such data collection and use.
Please read this policy carefully. If you do not want us to collect, use or disclosure your Personal Information in the ways described in this Policy, please do not use the Sites or otherwise provide us with your Personal Information or authorize a third party to make your Personal Information available to us. By using the Sites or otherwise providing us with your Personal Information, or otherwise making your Personal Information available to us, you consent to the collection and use of your Personal Information as described in this Policy. Please note, as described in this Policy, we may receive your Personal Information from third parties that have not expressly advised you that they will disclose your Personal Information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process Personal Information, including whether we have received your Personal Information from a third party, please contact us at the email address or mailing address provided at the end of this Policy.
- PERSONAL INFORMATION WE COLLECT
Our primary goals in collecting Personal Information are to provide and improve our Sites, to conduct our Operations, to communicate with you and to enable visitors to our Sites to enjoy and easily navigate them. This section describes what Personal Information we collect and the different was we collect it. When we refer to “Personal Information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “Personal Information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
- Categories of Personal Information We Collect. Generally, we may collect and disclose the categories of Personal Information in the table below in connection with our Operations. Please note, the examples of Personal Information identified 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 in connection with our Operations. Thus, some categories of Personal Information may not be collected from or about a specific individual.
||Examples of Types of Personal Information Within the Category
||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.
|Personal information categories covered by certain laws (including 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.
|Protected classification characteristics under certain laws
||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).
||Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
|Internet or other similar network activity
||Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.
||Physical location or movements.
|Professional or employment-related information
||Current or past job history or performance evaluations.
|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.
|Inferences drawn from other personal information
||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
- How We Collect Personal Information
- Personal Information We Collect from You.
- When you use our Sites or otherwise engage with us in connection with our Operations, such as requesting more information about our organization, communicating with us or otherwise interacting with us, you may be required or otherwise choose to provide certain Personal Information directly to us. The Personal Information we may collect includes your first and last name, email address, phone number, geographic location and, if you apply for a job, information about your prior work experience and other relevant historical information.
- We may, now or in the future, allow you to register for an account on our Sites. When you register for an account, we may access and collect the Personal Information you provide as part of your account creation, which may include your first and last name, contact information, email address, date of birth, phone number, username and password. We will also collect and maintain information about your use of your account and interactions with our sites.
- Personal Information We Collect from Third Parties. We may obtain Personal Information about you from third parties through or in connection with our Operations. These third parties may include our parent companies, our affiliates, our business partners, social media sites, ad networks, analytics providers and other third parties that you authorized to share your Personal Information with us or otherwise inform you that they will share your Personal Information with third parties, which may include us. We may also collect Personal Information about you from others that refer you to us.
- Personal Information We Automatically Collect.
- When you use portions of our Sites some information is automatically collected. For example, when you visit our sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and the websites you visited before visiting our Sites are logged automatically (“Usage Information”). We also collect information about your usage and activity on our Sites.
- We may collect information using web beacons, clear gifs, pixel tags or other similar technologies. These technologies are electronic images that may be used on our Sites or in emails we send. We use these technologies to deliver cookies, count visits, understand usage and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
- Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
- Personal Information Collected by Third Parties.
- Our sites may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or mobile device, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third party sites or services to which links or access are provided through our Sites. We encourage you to read the privacy policies or statements of the other websites you visit.
- We may also use third party tracking solutions on our Sites such as those outlined below:
- Facebook Pixel, a cookie placed by Facebook, enables us to measure the effectiveness of advertising campaigns served on Facebook. The information collected by that cookie will be transmitted to and stored by Facebook. For more information about Facebook’s privacy practices, please refer to https://www.facebook.com/about/privacy/. To opt-out, please see https://www.facebook.com/ads/preferences.
- LinkedIn Insight Tag, a cookie placed by LinkedIn, enables us to measure the effectiveness of advertising campaigns served on LinkedIn. The information collected by that cookie will be transmitted to and stored by LinkedIn. For more information about LinkedIn’s privacy practices, please refer to https://www.linkedin.com/legal/privacy-policy. To opt-out you can update your advertising preference through your LinkedIn account. If you do not have a LinkedIn account, LinkedIn allows you to opt-out of targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
- HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We use the Personal Information we collect for various purposes to conduct and improve our Operations. This section describes the primary purposes for which we use the Personal Information we collect.
- Marketing Purposes. We may use the Personal Information we collect for our own marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and e-mail address) with non-personal information (including information automatically collected as described in this Policy) and use such linked information for our own marketing purposes. If you do not want us to use your Personal Information for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Information” section below.
- Non-Marketing Purposes. We may use the Personal Information we collect for non-marketing purposes, including: (1) validating your identity; (2) sending you emails to provide you with alerts and updates about your engagement with our Operations; (3) conducting statistical or demographic analysis; (4) complying with legal and regulatory requirements; (5) customizing your experience with our Operations; (6) protecting and defending BLDG Management and its affiliates against legal actions or claims; (7) preventing fraud; (8) satisfying contractual obligations; (9) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (10) for other business purposes permitted under applicable law.
- Other Purposes. We may also use information in the aggregate to conduct research studies and for other purposes. We will not collect additional categories of Personal Information or use the Personal Information we collect in connection with our Operations for materially different, unrelated or incompatible purposes without providing you notice.
- WHO WE SHARE PERSONAL INFORMATION WITH
For business purposes, we may share certain Personal Information we collect in connection with our Operations from and about you, and about your relationship with us, with our parent companies or other affiliates and certain third parties. Doing so allows us to conduct our Operations. This section describes the categories of third parties we may share your Personal Information with and the purposes for that sharing.
- Categories of Personal Information Disclosed to Third Parties. Generally, in the past 12 months, we have disclosed the following categories of Personal Information to third parties for business purposes:
- Personal information categories covered by certain laws (including the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics under certain laws
- Commercial information
- Internet or other similar network activity
- Geolocation data
- 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
- Categories of Third Parties to Whom we Disclose Personal Information.
- Affiliated Companies. We may share your Personal Information with our parent companies or other affiliates to enable us or them to use your Personal Information for the purposes described in this Policy and as otherwise described to you, including, but not limited to, in such third parties’ applicable privacy policies.
- Third Party Service Providers. Your Personal Information may be shared with or collected by third party service providers who provide us with services, including, but not limited to, marketing, data hosting or processing. We require these third party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.
- Compliance with Laws and Law Enforcement. 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 legal claims, for legal process (including subpoenas), to protect the our property and rights or those of a third party, to protect us 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 Operations and any equipment used to make the Sites available, or to comply with applicable law.
- As Directed by You. Upon your consent and/or pursuant to your instructions, we will share your Personal Information, including your authorization to disclosure such Personal Information, with others.
- Anonymous Information. We may provide anonymized information to third parties. Any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.
- Selling Your Personal Information. We do not sell your Personal Information and have not done so in the past 12 months.
- MANAGING YOUR PERSONAL INFORMATION
We offer you several choices with respect to how we use your Personal Information. This section describes the mechanisms available to you to control the Personal Information we use about you in connection with our Operations.
- Updating Your Personal Information. If you want to update any Personal Information you have provided us, you can send us a request to update your Personal Information at firstname.lastname@example.org. If you have an account through the Sites or otherwise in connection with our Operations, we may, now or in the future, provide certain functionalities that enable you to update your Personal Information directly.
- Communications Opt-Out.
- From time to time (and with your consent when required), you may receive periodic mailings or emails from us with news or other information about our Operations and other efforts. If at any time you wish to stop receiving mailings or emails from us, please send us an email to email@example.com with the phrase “Privacy Opt Out: BLDG Management Mailings” in the subject line, or write to us at the address provided below, and we will remove you from our mailing list.
- Alternatively, for email communications, you may opt-out of receiving such communications by following the unsubscribe instructions set forth in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails from us. Please note, opting out of email communications will only apply to marketing and other promotional emails and will not apply to any email or other communication sent for non-marketing purposes, including, but not limited to, emails and other communications about your account or your use of the Sites.
- Targeted Advertising. If you do not want us to use Personal Information that we collect, or that you provide, to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email with your request to firstname.lastname@example.org. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org/.
- SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information that we collect and use in connection with our Operations. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us without your consent. We cannot guarantee the security of any information you disclose online, and you do so at your own risk.
- CHILDREN’S PRIVACY
We do not knowingly collect or allow the collection of Personal Information via the Sites or in connection with our Operations from persons under the age of 13. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at email@example.com
and ask us to remove your child’s personal information from our systems.
- INTERNATIONAL TRANSFERS
Personal Information collected through our Operations may be stored and processed in any country in which we or our parent companies or other affiliates, suppliers, service providers or agents maintain facilities. By using the Sites, or otherwise engaging with us or our Operations, you expressly consent to any transfer of Personal Information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our parent companies or other affiliates, suppliers, service providers and agents comply with our standards of privacy regardless of their location.
- CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have certain rights regarding your Personal Information under California’s Shine the Light Law and the California Consumer Privacy Act (“CCPA”). This section describes your rights under those laws.
- Shine the Light Law. Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the other rights described in this Policy. Under California’s Shine the Light Law, you have the right to send us a request at the designated email address provided below to receive the following information:
- the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services they market.
This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is firstname.lastname@example.org
- Please note, the rights described in this section only apply to Personal Information covered by the CCPA. Among other types of Personal Information, the CCPA does not cover information that is publicly available from government records, deidentified or aggregated consumer information, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act (CMIA) or clinical trial data and 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.
- Access Requests. Under the CCPA, you have the right to request that we 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 (information on how to submit requests is provided below), 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 Requests. Under the CCPA, you have the right to request that we delete any of your Personal Information that we collected from or about you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (information on how to submit requests is provided below), 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 your Personal Information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, 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 the Personal Information that are compatible with the context in which you provided it.
- How to Submit a Request.
- To submit an access, data portability or deletion request, 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 information 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.
- When submitting a verifiable consumer request you 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; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
- We cannot respond to your requests 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.
- We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Responses to Requests.
- We attempt to respond to verifiable consumer requests within 45 days. 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. 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.
- Rights Regarding the Sale of Personal Information. At this time, we do not sell any Personal Information in connection with our Operations. The CCPA does grant consumers rights with respect to the sale of their Personal Information, and if we decide to sell Personal Information in the future in connection with our Operations we will update this Policy and our Sites to make those rights available to you.
- Non-Discrimination for Submitting Requests. 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.
- UPDATES TO THIS POLICY
You agree that your use of the Sites and otherwise providing us with Personal Information in connection with our Operations constitutes your agreement with this Policy. We reserve the right to change this Policy at any time. If we decide to change this Policy, we will post those changes on this page so that you are always aware of what Personal Information we collect, how we use it and under what circumstances we disclose it. As we may make changes to this Policy from time to time, with or without notifying you, we suggest that you periodically consult this Policy for any changes. Your continued use of the Sites or other engagement with our Operations after the effective date of any modification to this Policy will be deemed to be your agreement to the changed terms.
- CONTACT US
We welcome your questions, comments and concerns about privacy. Please email us at email@example.com
with your feedback pertaining to privacy. You may also write to us at:
Attention: Chief Financial Officer
205 Detroit Street, Suite 400
Denver, CO 80206