Here’s a quick summary of what is new:
- We explain the categories of data we hold about you and how we may use this data
- We provide details of when and why we receive and share your personal information.
- We describe the choices you have regarding the personal information we maintain about you.
A. Information You Provide
We collect information that you provide about yourself when you use the Service or interact with us offline, including as a tenant or prospective tenant or as a job applicant, when you access our website content, or for another reason. The categories of information we collect (and may have collected in the last 12 months) include:
- Identifiers, such as 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 you send as a tenant or job applicant).
- Demographic Data (including information protected by California or federal law), such as your age, gender, and country.
- Location Data, if you provide it to us, such as information related to your state, city or neighborhood.
- Customer Data, such as your payment information (such as a credit or debit card or bank account data), proof of income, current and previous addresses, references, current or prior employer names, telephone numbers, and other information necessary to consider your eligibility for tenancy and/or to maintain a relationship with you.
- Employment and Education Data, including your employment and education history, writing samples, references, and other information 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:
- Internet Activity, such as 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.
- Identifiers, such as 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.
- Commercial Information, such as products and services you view and purchase.
- Inferences, such as information about your interests, preferences and favorites.
We use (and may have used during the last 12 months) various tracking technologies to automatically collect information when you use the Service, such as:
- Cookies, 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.
- Log Files, 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, such as:
- Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
- Publicly-available sources, such as data in the public domain.
- Vendors, such as credit check or background check vendors.
- Operating and managing our Service, including your registration and account (if any).
- Performing services for or on your behalf, such as responding to your comments, questions, and requests, and providing other customer services.
- Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Preventing and addressing fraud, breach of policies or terms, and threats or harm.
- Monitoring and analyzing trends, usage, and activities.
- Conducting research, including focus groups and surveys.
- Improving the Service or other Douglas Emmett websites, marketing efforts, products and services.
- Developing and sending you marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
- Conducting our business, such as operating our buildings, maintaining proper customer records for billing, accounting and financial purposes, and complying with our legal obligations.
- Considering tenant applications
- Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.
- Sharing information as described below in "Sharing of Information"
Notwithstanding the above, we may use information (including information that has been aggregated or de-identified) that does not identify you 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.
- Service Providers. We share information with entities that process or use information on our behalf for our business purposes including to assist with our daily operations and manage our Service. For example, service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, technical support, parking, and security.
- Vendors. We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. The categories of personal information we share include identifiers, demographic information, commercial information, internet activity, and inferences. We also share certain categories of information, such as identifiers, demographic information, and commercial information, with vendors such as credit or background check vendors. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information.
- Affiliates. We share information with our related entities including our direct and indirect subsidiaries and affiliated companies for business and commercial purposes such as customer support, marketing, accounting, legal, and technical operations.
- Public Forums. 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.
- Facilitating Requests. 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.
- Consent. We share information with notice to you and your consent.
Notwithstanding the above, we, our vendors, our service providers and our affiliates may share information (including information that has been aggregated or de-identified) that does not identify you 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.
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:
- Links. 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.
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").
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 here, we will comply with applicable law as to such activity.
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.
A. Account Information
If you have an account with us (such as a tenant), 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.
- E-mails. 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 and we will only text or call you if you text or call us and we are returning the text message or phone call. For example, if you call one of our agents to schedule a viewing of an apartment, our agent may follow up with a text message asking you if you will agree to receive additional text messages from our agent in order to schedule viewings and for related purposes. In the future, we may send promotional text messages, in which case we will obtain your prior written express consent to receive such messages. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls.
Please note that your opt out is limited to the email address, phone number, 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:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you
To exercise any of these rights, please submit a request through our online form available at https://douglasemmett.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.
F. Right to Opt-Out.
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 Info.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.
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.
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.
Attn: General Counsel
1299 Ocean Ave
Santa Monica, CA 90401