Here’s a quick summary of what is new:
Date: January 1, 2020
1. Information Collection
A. Information You Provide
If you provide it to us, such as, when you inquire about a rental or set up a property tour or you’re a tenant and have set up an account with us. Identifiers could include your first and last name, email address, postal address, phone number, username, password, password hints, information for authentication and account access, social security number, driver’s license number, passport number, and any messages you choose to send to us (such as messages you choose to send to “contact us” on our website or communications by tenants to building management).
Demographic Data (including information protected by California or federal law)
If you provide it to us, including your age, gender, and country.
If you provide it to us, such as information related to your state, city or neighborhood.
If you provide it to us, for example, to pay your rent or apply for tenancy. Customer records could include your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments. Customer records may also include proof of income, previous addresses, references, employer name, office telephone number, and other information necessary to consider your eligibility for tenancy.
Employment and Education Data,
Including your employment and education history, writing samples, and references as necessary to consider your job application for open positions.
B. Information Collected Automatically.
In addition, we automatically collect information when you use the Service. The categories of information we automatically collect and have collected in the last 12 months includes: p Douglas Emmett also collects or logs other information that cannot identify you personally when you visit our web site. This information includes your Internet Protocol (“IP”) address and your domain name. An IP address is a number that is automatically assigned to your computer by the Internet Service Provider (“ISP”) computer through which you access the web, and a domain name is the name of the ISP computer itself through which you access the web.
Including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
Including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
Including products and services you view and purchase.
Including information about your interests, preferences and favorites.
We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:
Which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
Pixels. (also known as web beacons).
Which are files that record events that occur in connection with your use of the Service.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
C. Information from Other Sources.
We also collect information from other sources. The following are the categories of sources we may? collect information from:
Or users of the Service.
when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
Including data in the public domain.
2. Use of Information.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
We do not sell your information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Analytics and Advertising section as a “sale,” we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the Sharing of Information section for more detail about the parties we have shared information with.
3. Sharing of Inforamtion.
We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support.
We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
We share information with our related entities including our direct and indirect subsidiaries and affiliated companies for business purposes such as customer support, marketing, accounting, legal, and technical operations. We also may share information with affiliates for commercial purposes.
We share information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
Merger or Acquisition.
We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Security and Compelled Disclosure.
We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service.
We share information with notice to you and your consent.
Notwithstanding the above, we, our vendors, and service providers may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
4. Separate Entities Websites and Services
We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:
Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
Liking, Sharing, and Logging-In.
We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
5. Analytics and Advertising.
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics and Interest-based Advertising please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
6. Your Rights and Choices.
A. Account Information
If you have an account with us (such as tenants), you may access, update, or remove certain information that you have provided to us through your own account. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as needed to operate our business, keep accurate customer records and accounts, comply with our accounting, compliance and financial processes and controls, comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technology Choices
Cookies and Pixels.
Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. We Currently do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
C. Analytics and Interest-Based Advertising.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Douglas Emmett’s ongoing business relations.
Text Messages and Calls.
We do not send promotional or automated text messages or phone calls. We will only text or call you if you text or call us and we are returning the text message or phone call.
Please note that your opt out is limited to the email address and device used and will not affect subsequent subscriptions
E. Right to Know and Delete.
If you are a California resident, you have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
To exercise any of these rights, please submit a request through our online form available at https://www.shermanoaksgalleria.com/ccpa-request, call our toll free number at 844-999-0650, or email us at firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
To the extent we sell personal information as the term “sell” is defined under the California Consumer Privacy Act of 2018, California residents have the right to opt-out of the sale of their personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information.You may also submit a request to opt-out by calling our toll-free number at 844-999-0650, or emailing us at email@example.com.
G. Authorized Agent.
California residents can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
H. Right to Non-Discrimination.
California residents have the right not to receive discriminatory treatment by us for the exercise of any of their rights.
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
The Service is intended for a general audience, and is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at firstname.lastname@example.org. We will remove the data to the extent required by applicable laws.
We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization.
If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at email@example.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Data Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
9. International Transfer
11. Contact Us
Attn: General Counsel
1299 Ocean Ave
Santa Monica, CA 90401