California Privacy Notice
This Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at Hines Securities. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.
SOURCES OF PERSONAL INFORMATION
We collect this Personal Information from you, such as when you visit our website, register for an account, or undertake a transaction with us, and from other categories of sources: entities with which we do business that have a pre-existing relationship with you, joint marketing partners, public databases, and social media platforms.
CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED
The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
Categories of Personal Information
Disclosed to Which Categories of Third Parties for Operational Business Purposes
|Identifiers, such as name, contact information, IP address, online identifiers, drivers’ license numbers, social security numbers, and other government-issued ID numbers||Our affiliated companies; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Personal information, as defined in the California customer records law, such as name, contact information, signature, and financial information||Our affiliated companies; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Characteristics of protected classifications under California or federal law, such as gender, citizenship, and immigration status||Our affiliated companies; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Commercial information, such as transaction information and payment history|
|Internet or network activity information, such as interactions with our online services, including our website|
|Geolocation data, such as approximate location derived from IP address|
|Audio, electronic, visual and similar information, such as video or call recordings created in connection with our business activities|
|Sensitive Personal Information: Personal Information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in information; citizenship and immigration status|
USE OF PERSONAL INFORMATION
We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; carry out corporate transactions, such as mergers, joint ventures or acquisitions; and exercise and defend legal claims.
We do not “sell” Personal Information (including Sensitive Personal Information), and we do not “share” Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Notice was last updated. Without limiting the foregoing, we do not sell or share Personal Information (including Sensitive Personal Information) of minors under 16 years of age.
PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
We collect, use, and disclose Sensitive Personal Information only as permitted under applicable law, for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.
We retain Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was obtained, including to satisfy any legal, compliance, accounting, or reporting requirements, and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide our products and services to you, for example, for as long as you continue to use our Website or other services;
- Whether there is a legal obligation to which we are subject, for example, to keep records of your transactions for a certain period of time; or
- Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.
INDIVIDUAL RIGHTS AND REQUESTS
If you are a California resident, you may request that we:
- Disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we disclosed, and the categories of third parties to which we disclosed such Personal Information.
- Correct inaccuracies in your Personal Information.
- Delete Personal Information we collected from you.
To make a request for the disclosures, correction or deletion described above, please contact us at 888−220−6121 or firstname.lastname@example.org. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as the last four digits of your Social Security number and your Hines account number, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.
CHANGES TO THIS NOTICE
We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new “Last Updated” date.
If you have any questions regarding this Notice, please contact us at email@example.com.