National Real Estate Development, LLC Privacy Notice Under The California Consumer Privacy Act (“CCPA”)
Last Updated: October 2023
The California Consumer Privacy Act (CCPA) imposes certain obligations on National Real Estate Development, LLC (“National Development,” “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose and share personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
The privacy of your personal information is important to us at National Real Estate Development, LLC (“National Development”). We are committed to protecting the privacy of that information. Furthermore, the privacy of your personal information may be protected by various government laws or regulations.
At the same time, in order to provide you with services you may request, it is necessary for us to possess some of your personal information. Similarly, without some of that information, we cannot inform you about the services we have available or that you may request (though if you are currently receiving information or marketing communications from us, you may opt-out of receiving further communications at any time).
This privacy statement explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of personal information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.
The CCPA and Your Personal Data Rights
The CCPA as amended by the California Privacy Rights Act (the “CPRA”) is a sweeping piece of legislation that grants California residents increased control over their personal data. The CCPA allows consumers to find out what personal information of theirs has been gathered, to request that businesses delete their data, to opt out of having their information sold, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to assure that their vendors comply as well.
This privacy notice provides the details you need to understand your rights under the CCPA, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
Data Privacy Information
Defining Personally Identifiable Information
Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories.
At National, we have chosen to adopt the broader approach to what information must be protected and kept as private as possible. In this notice, “Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more.
National Development does not and will not sell or share your PII.
Types of Collected PII
National Development collects some of your personally identifiable information. This section describes the categories of PII that are collected, as well as the categories of sources for obtaining that PII, and the purpose for collecting it.
The PII we collect from you consists of the following categories:
- Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government ID numbers
- Personal Information, as defined in the California customer records law, such as name, contact information, signature, government ID numbers, financial account information, and education and employment information
- Protected classification characteristics under California or federal law, such as age, ethnicity, citizenship, religion or creed, marital status, gender
- Commercial information, such as records of personal property
- Professional or employment-related information, such as occupation, employer information
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
Some of the information we collect, such as social security numbers, may be considered sensitive personal information under applicable law. We will not use or disclose your sensitive personal information for purposes other than those permitted by law and set forth in this notice.
The categories of sources of the PII we collect about you are:
- Information you provide when you visit one of our properties in California
- You or your representative when interacting with us or our website or when otherwise communicating with us
- Publicly available information
- Another person or other persons (typically people who know you) who provide referral information about you to us or who use the capabilities we offer on our website to forward an article or other information to you
- Third parties that provide products and services to you through your relationship with us
- Third parties that perform services for us or on our behalf
The purposes for which we use the Personal Information that we collect depend on our relationship or interaction with a specific California resident. Nonetheless, National Development does collect your PII for a variety of purposes including:
- Managing job applications
- Contacting you or your designated representative by phone, email, fax, or mail
- Marketing and advertising
- Research and analysis
- Fulfilling our legal and regulatory obligations, including legally required record retention
The length of time that National Development holds your personal data will vary. The retention period will be determined by the following criteria:
- The purpose for which National Development is using your personal data – We will need to keep the data for as long as is necessary for that purpose.
- Legal obligations – Laws or regulation may set a minimum period for which National Development has to keep your personal data.
Our Website and Your PII
Visiting and navigating our website will likely involve some form of usage of your PII. This section details the methods and permissions involved.
Consent to Use Your PII
By visiting our website or completing any of our online forms, you consent to our storing and using your PII for the reasons provided in this notice. You also consent to our using it to reply to your request as well as to contact you in the future, whether or not at your request, to provide you with additional information.
Note that we might also be required to comply with all applicable privacy laws and regulations to record and maintain certain PII from you by monitoring email and other network traffic.
Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt out of receiving further communications at any time.
Cookies are small pieces of data stored on your device (computer or mobile device) when you visit certain websites. They are widely used to enhance your online experience and collect information about your browsing behavior on the Website.
Disclosing Your PII
Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that transfer of your PII.
Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect identity information which we use to help prevent and detect fraud.
Disclosing PII to Third Parties
We may disclose your PII to our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We also disclose personal information for a variety of additional purposes including, but not limited to:
- Within National Development and among our affiliates and subsidiaries for (data processing or storage purpose)
- With business partners and suppliers to provide services and help facilitate transactions (including event registrations, data storage, and marketing communications)
- In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements
- For any purposes other than the purposes for which the PII was collected (and other than for the exceptions listed here) only after we have provided you notice and received your consent to disclose the information for that purpose)
We do not offer financial services and products to minors and do not intend to collect personal information from children under the age of 13. We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.
Your PII Rights
The CCPA provides you with certain rights in regard to what we do with your personally identifiable information. This section details those rights, how to exercise them, and what National Development will do in response.
You have the right to request that we disclose to you, free of charge, the categories and specifics of the PII we collect or disclose about you to a third party for business purposes. We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a PII disclosure.
Your request for disclosure can apply to any such PII mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the PII we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII we collect about you:
- The categories of personal information we have collected about you
- The categories of sources from which that personal information is collected
- The business or commercial purpose for collecting that personal information
- The categories of personal information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such personal information, as applicable
- The specific pieces of personal information we collected about you
Deletion of PII
You have the right to request that we delete the PII we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
We may deny your deletion request if retaining the personal information is necessary for us or our service suppliers to:
- Complete a transaction for which we collected the personal information, provide a good or service that you requested, 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
- Enable solely internal uses that are reasonably aligned with your expectations based on your 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
Correction of PII
You have the right to request that we correct any inaccurate PII we have collected from you. Following our verification of your request, we will comply with your request and make corrections to any PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
Contacting Us to Exercise Your PII Rights
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number (1-844-621-0428) or visiting our website (www.natadvisors.com).