Last Updated: June 4, 2021
The Information We Collect
When you visit our Service we may collect information regarding your visit from your computer. Such information helps us to determine information about how you found our Service, the date that you visited our Service and search engines that may have led you to our Service. We collect this information in order to continually improve and enhance the functionality of the Service. Generally, you may provide us with two types of information, User Content, which may include Personally Identifiable Information, and Website Usage Information, both of which are discussed in greater detail below.
- Personal Information You Choose to Provide.
- Sign-Up Information.We will ask you to provide certain information if you are authorized to register as a Member on the Service by CAM, including your name, email address, address, telephone number, and other information (collectively “Personally Identifiable Information”).
Do not supply to us or disclose on the Service any Personally Identifiable Information of any person under 13 years of age, as we do not intend to collect information from anyone under 13 or invite to them to participate in the Service.
- Questionnaires and Surveys. We may occasionally ask users of our Service to complete online surveys, questionnaires, and opinion polls about their activities, attitudes, and interests. These surveys help us to better serve you and improve the usefulness and features of the Service. In requesting your participation in these surveys we may ask you to provide your name and email address to us.
- Contact Us. If you email us through the email address listed on our Service, firstname.lastname@example.org, we may ask you for information such as your name and email address so we can respond to your questions and comments. If you choose to correspond with us via email, we may retain the content of your email messages, your email address and our response to you. In certain cases, and with your permission, we may post content from your emails to us on the Service.
- Website Usage Information.
- Clear GIFs/Beacons. When visiting our Website, we may also use “Clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies in our Website and/or in our communications with you. A Clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message, which helps us to verify an individual’s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Website and may enable us to relate such information to other information, including your Personally Identifiable Information. We use information provided from Clear GIFs to enable more accurate reporting, improve the effectiveness of our marketing, and make our Service better for our users.
- IP Address and Clickstream Data. Our servers automatically collect data about your Internet Protocol address when you visit the Website. When you request pages from our Website, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on the Website; the website you visit after this Website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers, to analyze general usage patterns, and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet Service Provider. CAM may aggregate user information in a non-personally identifiable manner to share with advertisers and to enhance the Website with new features.
- Website Usage Information.
Any or all of these activities with regard to the above-described Website Usage Information may be performed on our behalf by our third-party service providers.
How We Use Your Information
- Personal Information. If you submit information to us through the Service, including registration information, then we use this information to operate, maintain, and provide the features and functionality of the Service. CAM will use your email address to complete the signup process. By providing CAM your email address you consent to our using the email address to send you Service-related notices, including among other things notices required by law, in lieu of postal mail. You may not opt out of Service-related e-mails. We may also use your email address to send you other messages, including changes to Service features and special offers.
Rights to Opt-in / Opt-out. You have the right to “opt in” and/or “opt out” of certain of our uses of your Personally Identifiable Information. For example, you may have the opportunity to elect whether you would like to receive correspondence from us and/or third party service providers. Your personal information will not be shared with third party service providers unless consent is given by you. You will have the opportunity to opt out of CAM’s promotional e-mails by clicking the “opt out” or “unsubscribe” link in the e-mail you receive. You can also request this by sending an e-mail to email@example.com, specifying whether: (i) you would like to opt out of receiving promotional correspondence from CAM in general, or just via e-mail, postal mail and/or by phone, and/or whether (ii) you would like to opt out of only certain of CAM’s e-newsletters or correspondence. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
- Website Usage Information. We use non-Personally Identifiable Information, such as anonymous Website use data and IP addresses, to improve the quality and design of the Website and to create new features and services by storing, tracking, and analyzing your preferences and trends. We may use such information to: (a) remember information so that you will not have to re-enter it during your current or subsequent visits to the Website; (b) provide customized content and information; (c) monitor the effectiveness of our marketing campaigns and aggregate metrics such as total number of visitors and traffic; (d) diagnose or fix technology problems; (e) access your information after you sign in; (f) market our Website to advertisers and other third parties; (g) aggregate general User statistics including demographic and geographic information; and (h) other purposes for which your personal identity is not revealed.
- Location-Based Services. We collect location-based information in order to provide specific location-based services which you may request. You understand that certain location-based services require a location to function properly, and your use of Service on your mobile device with such features enabled signifies your agreement to use your location for the purposes of the Service.
When We Share Information
CAM will not share your email address with advertisers or unaffiliated third parties without first obtaining your express permission.
If you are a Member (i.e. an investor in one or more of our commercial real estate properties or a tenant at one or more of our commercial real estate properties) we may provide information, including personal information, to our contracted software providers who provide the areas of our Service limited to Members in order for you to access and utilize such features.
We may share non-Personally Identifiable Information (such as anonymous Website use data) with third-parties to assist them in understanding our Website, including Users’ use of our Website and the services we provide and the success of advertisements and promotions.
We may share non-personally identifiable aggregated user data, such as aggregated gender, age, height, weight, and usage data (without the inclusion of a user’s name or other identifying information) to advertisers and other third parties for their marketing and promotional purposes.
We may share location-based information with third parties for their marketing and promotional purposes if you have allowed location-based services as described above.
Our Commitment to Children’s Privacy
Protecting the privacy of young children is especially important and is mandated by U.S. law. For these reasons, CAM does not knowingly collect Personally Identifiable Information on the Service from persons under 13 years of age, and no part of our Service is directed to persons under 13. If you are under 13 years of age, then you must not use or access the Service at any time or in any manner or provide any information to the Service. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on our Service, we will delete the information from our records.
Rights to Control Your Data
You can control your personal data. You have many choices about how your data is collected, used and shared.
For personal data that we have about you, you can:
∙ Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you).
∙ Change or Correct Data: You can edit some or your personal data by asking us to change, update or fix your data in certain cases, particularly if it is inaccurate.
∙ Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal data (e.g., if CAM has no legal right to keep using it) or to limit our use of it (e.g., if your data is inaccurate or unlawfully held).
∙ Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of the personal data you provided to us in machine-readable form.
You may contact us at firstname.lastname@example.org, and we will consider your requests in accordance with applicable laws.
Residents in Designated Countries may have additional rights under the laws of those countries.
The Website is hosted in the United States and is intended for and directed to Users in the United States. The Website and Service are void where prohibited. If you are accessing the Website from outside the United States, your use of the Website is governed by U.S. law, you are transferring your personal information to the United States, and you consent to that transfer.
We have lawful bases to collect, use and share data about you. You have choices about the use of your data. We will only collect and process Personally Identifiable Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the CAM services you have requested)) and our legitimate interests, provided that such processing shall not outweigh your rights and freedoms. CAM will seek to obtain your additional consent where required by applicable law. At any time, you can withdraw the consent you have provided by contacting us by email at email@example.com or postal mail at Privacy, Cohen Asset Management, Inc., 1900 Avenue of the Stars, Third Floor, Los Angeles, CA 90067.
You may, of course, decline to submit Personally Identifiable Information to the Website, in which case you may not be able to register or CAM may not be able to provide certain services to you.
You may access, update or correct your personal information by contacting CAM at firstname.lastname@example.org. You may also request that CAM correct, update, or remove your information from the current Website by contacting us at email@example.com. We will respond to your request within 30 days. However, before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and provide other details to help us to respond to your request.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your account information at all times.
You may decline to utilize location-based services on your mobile device. If you do not want us to use location-based information, please refrain from using a location-based service or click “Don’t Allow” when your mobile device requests your location-based information.
Online Tracking Disclosures
You may be accessing the Website via a browser that has a “Do Not Track” setting. If you have turned this setting in your browser on, or if you are using a browser with the default setting of “Do Not Track”, please be advised that all features of the Website may not function in such setting. As detailed above, we collect a variety of functional and analytic cookies in order for you to completely engage with our services.
If you wish to opt-out of the collection of tracking information you may do so according to your browser settings; however, please be advised that such an election may limit the functionality of the Website available to you.
Our Commitment To Data Security
We have implemented commercially reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. Such measures include, but are not limited to, the utilization of Secure Sockets Layer (SSL) encryption to transmit sensitive information through the Website. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes. You acknowledge that you provide your Personally Identifiable Information at your own risk.
While CAM strives to protect the security and integrity of Personally Identifiable Information on its Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that your information, during transmission through the Internet or while otherwise in our care, will be safe from intrusion of others. You should also be aware that if you contact us by email or a “contact us” or similar feature on the Website, your transmission might not be secure. An unaffiliated third party could view information you send by these methods in transit. You should also be aware that if you are accessing the Service via a mobile device, your transmissions may not be secure due to the inherent nature of mobile data carrier networks. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
Compromise of Personal Information
In the event the breach involves your online account credentials, we will provide notification in electronic form and direct you to promptly take other appropriate steps to protect the online account. You consent to our use of e-mail as a means of such notification. If you would prefer us to use another method to notify you in this situation, please e-mail us at firstname.lastname@example.org with the alternative and/or additional contact information you would like us to use.
California Privacy Rights: Privacy Notice for California Residents
Information We Collect
Our Service, including restricted areas of the Service which a third party provides on our behalf pursuant to an enterprise software license, collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In accordance with the CCPA, please find the following particular categories of Personal Information which the Website has collected from Consumers within the last twelve (12) months, as well as those categories which the Website has not collected:
|A. Identifiers.||A real name, alias, postal address, online identifier, Internet Protocol (IP) address, email address, account name, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, first initial and last name, signature, address, telephone number, passport number, occupation, bank account number, credit card number, debit card number, a user name or email address in combination with a password or security question and answer that would permit access to an online account. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, national origin, citizenship, marital status, religion, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).||NO|
|D. Commercial information.||Records of personal property, records of products or services purchased, obtained, or considered.||YES|
|E. Biometric information.||Genetic (DNA), physiological, behavioral, and biological characteristics, or activity patterns that can be used singly or in combination with each other or with other identifying information to establish identity; activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, handprints, vein patterns, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns; and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or physical movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information to any of the foregoing.||NO|
|I. Professional or employment-related information.||Current job history.||NO|
|J. Non-public education information (per the Family Educational 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.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
|L. Information from Children under the age of 16||Information from minors under 13 years of age (solely as submitted via their parents or legal guardians), Information from minors between 13 and 16 years of age (solely as submitted via their parents or legal guardians).||NO|
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope due to the primacy of other federal regulations:
- Health Information: Protected or health information that is collected by a covered entity governed by the privacy, security, and breach notification rules issued by the federal Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Availability Act of 1996 (“HIPAA”).
- Personal information reported in, or used to generate, a consumer report as defined by subdivision (d) of Section 1681a of Title 15 of the United States Code, where use of that information is limited by the federal Fair Credit Reporting Act (15 U.S.C. Sec. 1681 et seq.).
- Personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.
- Personal information collected, processed, sold or disclosed pursuant to the federal Driver’s Privacy Protection Act of 1994 (18 U.S.C. Sec. 2721 et. seq.).
- Information excluded from the CCPA’s scope due to other California regulations which may supersede the CCPA:
- Health Information: Protected or health information that is collected by a covered entity governed by the California Confidentiality of Medical Information Act (Part 2.6 (commencing with Section 56 of Division 1)).
- Personal financial information governed by the California Financial Information Privacy Act (FIPA).
How we collect Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you or your agents. For example, from forms you complete on the Website, from information which is provided from you by phone and inputted into our systems, or from email messages you transmit to us, including via the “Contact Us” section of our Website.
- Indirectly from you or your agents. For example, from observing your actions on the Website or interactions with our advertisers, or from personal preferences to facilitate customer service, or from existing consumers of ours who may recommend our Services to you.
Use of Personal Information
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information in connection with a potential investment in one of the commercial properties owned or managed by us, we will utilize that information in connection with our customary due diligence concerning the potential transaction. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment. We may also save your Personal Information to facilitate new or recurring orders of products and services, or to remit distributions to you.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose. 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 such contract.
We share your Personal Information with the following categories of third parties: vendors and service providers who may provide certain services in connection with our real estate development and management services. These include software provider Yardi Systems, Inc., which provides our restricted access investor and tenant portals enabling investors in our properties and tenants leasing space at our properties the ability to access information particular to their individual relationship with us. We also share information with on site managers of our properties). These managers may ask you for additional Personal Information beyond what we share to them in connection with their job responsibilities and the services they furnish, which you may elect to then provide or not at your discretion.
Disclosures of Personal Information for a Business Purpose
- In the preceding twelve (12) months, CAM has disclosed Personal Information for a business purpose.
Sales of Personal Information
- In the preceding twelve (12) months, CAM has not sold Personal Information.
Your Rights and Choices as a California Resident
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources of the Personal Information we collected about you.
- Our business or commercial purpose for collecting 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 disclosed your Personal Information for a business purpose, a separate list identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that CAM delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 the information is necessary for us or our service provider(s) to:
- Complete the 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.
- 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 that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights: Submitting a Verifiable Consumer Request
Who Can Submit a Verifiable Consumer Request: 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 consumer request on behalf of your minor child.
How to Submit a Verifiable Consumer Request: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
- Sending us a message on our Service; or
- By emailing us at email@example.com.
What Your Verifiable Consumer Request Must Contain: The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or are an authorized representative of such person.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request or if we cannot confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Frequency of Submitting a Verifiable Consumer Request: You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to a total of 90 days), we will inform you of the reason and extension period in writing.
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 date of our receipt of the verifiable consumer request. 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, specifically by electronic mail communication.
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 your request is excessive, repetitive, or manifestly unfounded, we may either: (a) tell you why we made that decision and refuse to respond to your request, or (b) provide you with a cost estimate of reasonable fees reflecting administrative costs involved before completing your request, and if you still wish to proceed, collect such fees from you prior to carrying out such request.
Personal Information Sales Opt-Out and Opt-In Rights
CAM does not sell your Personal Information. Accordingly, the rights granted under the CCPA enabling users 16 years of age or older to opt-out of sales of Personal Information, and for users between 13 and 16 years of age to specifically opt-in to sales of Personal Information, are not applicable to CAM’s information processing activities.
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.
Shine the Light
Under California’s “Shine the Light” law (California Civil Code §1798.83), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled once per calendar year to request and obtain from us information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2021 will receive details concerning 2020 sharing activities).
To obtain this information, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information – Shine the Light” on the subject line and in the body of your message. We will in turn provide the requested information on covered sharing to you at your e-mail address.
- Via our Service by contacting us here.
- Write to us by physical mail at:
Cohen Asset Management, Inc.
1900 Avenue of the Stars 3rd Floor Los Angeles, CA 90067
- Write to us by email at: email@example.com