Veros Real Estate Solutions

California Disclosures And Privacy Policy

Effective Date

This California Disclosure Privacy Policy was last updated and is effective as of December 23, 2022.

The State of California requires that we provide privacy information for individuals that are residents of California. If you are not a resident California, you can disregard this document.

For California residents, here is a summary of what you will learn from these disclosures and privacy policy:

  1. Personal Information We Collect
    1. What is Personal Information
    2. Categories of Personal Information Collected
    3. How We Obtain Your Personal Information
    4. How We Use Your Personal Information
    5. How Long We Retain Your Personal Information
    6. How We Disclose Your Personal Information
    7. Sale of Personal Information
    8. Sharing of Personal Information
  2. Your Rights Under the California Consumer Privacy Act of 2018
    1. Right to Know
    2. Right to Delete
    3. Right to Correct
    4. Right to Limit Use of Sensitive Personal Information
    5. Right to Opt-Out
    6. Right to Non-Discrimination
    7. Employees / Former Employees / Applicants
  3. Submitting a Request to Know or Request to Delete
    1. How to Submit a Request Yourself
    2.  Authorized Agents
    3. Response Timing and Delivery Method
  4. Changes to this California Privacy Policy
  5. How to Contact Us

Below is the legal information we are required to share:

These California Disclosures and Privacy Policy supplement the information contained in the Privacy Policy of Veros Real Estate Solutions, LLC (“we,” “us,” or “our”) and applies solely to visitors, users, and others who are residents of the State of California (“consumers” or “you”). We adopt these California Disclosures and Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this privacy policy.

  1. PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).

1.1. What is Personal Information

Personal information does not include:

  • Publicly available information from government records
  • De-identified or aggregated consumer information
  • Information excluded from the CCPA, including:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

AS A COURTESY, SOME OF THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.

1.2. Categories of Personal Information We Collect

We collected the following categories of personal information:

  • Sensitive Personal Information” such as Social Security numbers, Driver’s license, financial account or card numbers, Precise geolocation, Racial and ethnic characteristics, Religious and philosophical beliefs, Union membership, Contents of mail, email and text messages, Genetic and biometric data;
  • Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
  • Other Personal Information” such as name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, home value, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories;
  • Internet or Network Activity” such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement; and
  • Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait.

1.3. How We Obtain Your Personal Information:

We obtain personal information directly and indirectly from you based on activity on our website or visiting our office. For example, from submissions through our website, website usage details collected automatically, our business to business transactions and communication, or security footage.

1.4. How We Use Your Personal Information:
We may collect, use, retain, or disclose the personal information we collect for one or more of the following purposes:

  1. For advertising or marketing services, or receiving analytic services. This includes:
      a. to fulfill or meet the reason for which the information is provided;
    1. b. to provide you with information, products, or services that you request from us;
    1. c. to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
    1. d. to carry out our obligations and enforce our rights arising from any contracts entered into by us
  1. Undertaking internal research for technological development and demonstration
  2. Debugging to identify and repair errors that impair existing intended functionality
  3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  4. Auditing related to a current interaction with a consumer or our customers, and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
  5. Undertaking activities to verify or maintain the quality or safety or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
  6. For short-term, transient use, including disclosure to third parties to build a profile about consumers or to alter consumer’s online experience outside the current interaction.
  7. To comply with our legal or regulatory obligations

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 notice.

1.5. How Long We Retain Your Personal Information

Based on contractual requirements in our role as service provider and/or legal requirements, such as a legal hold, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements. Additional information such as emails and vendor agreements are maintained for business purposes.

1.6. How We Disclose Your Personal Information

We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal information to a service provider or contractor, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise allowed under the CCPA. We disclose personal information to third parties as follows:

With customer service platforms, word processing, and communication applications we disclose Identifiers, Other Personal Information, Protected Characteristics, and Internet or Network Activity.

With shipping providers we disclose Identifiers and Other Personal Information.

With our data analytics, network monitoring services, and incident response providers, we disclose Identifiers, Other Personal Information, and Internet or Network Activity.

With our advisors such as lawyers, and consultants, we disclose Identifiers, Other Personal Information, Internet or Network Activity, and Biometric Information.

With our governmental and regulatory agencies, we disclose Identifiers, Other Personal Information, Protected Characteristics, Internet or Network Activity, and Biometric Information.

With law enforcement, government entities, courts, and pursuant to legal process where required by law, we disclose Identifiers, Other Personal Information, Internet or Network Activity, and Biometric Information.

1.7.  Sale of Personal Information:

We do not sell your personal information. We do not sell the personal information of minors under 16 years of age.

1.8.  Sharing of Personal Information:

We do not share your personal information. Our site is not intended for or directed to minors. We do not knowingly share the personal information of minors under 16 years of age. (“Sharing” means the disclosure of personal information for cross-contextual behavioral advertising.)

  1. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018
The CCPA provides consumers (California residents) with specific rights regarding their personal information—the Right to Know, the Right to Delete, the Right to Opt-Out, and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights, if applicable.

2.1. Right to Know:

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months (“Right to Know”). Once we receive and verify your request, unless an exemption applies, we will disclose to you:

  • Categories of Personal Information Collected and Shared
    • The categories of personal information we collected about you
    • The sources for 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
    • If we disclosed your personal information for a business purpose, the categories of personal information shared with each category of third-party recipients
  • Specific Information
    • The specific pieces of personal information we collected about you

2.2.  Right to Delete:

You have the right to request that we delete any of your personal information that we collected and retained (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information (and direct our service providers to do the same), unless an exemption or exception applies.

We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:

  • complete the transaction for which the personal information was collected;
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • debug to identify and repair errors that impair existing intended functionality;
  • exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; or
  • comply with legal or regulatory obligations

2.3.  Right to Correct:

You have the right to request that we correct your personal information if it is inaccurate (“Right to Correct”). Once we verify your identity and confirm that your personal information is inaccurate, we will correct your personal information (and direct our service providers to do the same).

2.4.  Right to Limit the Use of Sensitive Personal Information

You have the right to direct a business that collects your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.

2.5.  Right to Opt-Out and Submitting an Opt-Out Request:

The CCPA gives consumers the right to opt-out of 1) the sale of their personal information, 2) the sharing of their personal information for cross-context behavior advertising, or 2) for use in automated decision making.

2.5.1. Sale of Personal Information

We do not sell your personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

2.5.2. Sharing Personal Information for Cross-Contextual Behavioral Advertising

We do not share your personal information. Our site is not intended for or directed to minors. We do not knowingly share the personal information of minors under 16 years of age.

2.5.3. Automated Decision-making

The CCPA gives consumers the right to opt-out of the use of automated decision-making technology in connection with decisions about the consumer’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. However, we do not use automated decision-making technology for personal information that is not covered by GLBA and CalFIPA, or that is outside our capacity as a service provider.

2.6.  Right to Non-Discrimination:

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.

2.7.  Employees / Former Employees / Applicants:

If you are an employee, former employee, owner, officer, director, or job applicant with VRES, please contact us at privacy@veros.com for a copy of our California Employee Privacy Policy for information on your rights and how to exercise those rights. This information was previously provided to you in relation to your employment or application for employment.

  1. SUBMITTING A REQUEST TO KNOW OR REQUEST TO DELETE


3.1.  How to submit a request:

To make a Request to Know, Request to Delete, or Request to Correct, please contact us by either:

Only (1) you, (2) a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a Request to Know twice within a 12-month period.

A Request to Know, Request to Delete, or Request to Correct must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • If you are submitting a Request to Know specific pieces of personal information, you will need to submit a declaration under the penalty of perjury confirming you are only correcting information about yourself.

3.2.  Authorized Agents:

Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent, we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at privacy@veros.com and provide the following information:

  1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
    • signed permission from the California resident, or
    • a valid power of attorney
  1. To verify your identity, please attach copies of the following to your request email:
    • valid Government Issued ID (not expired) AND
    • a Utility Bill, Bank Statement, or similar documentation to verify your name and address.
  1. To verify the identity of the consumer for whom you are submitting the request, please submit the required information by calling us at 866.458.3767 (option 6) or emailing us at privacy@veros.com. We will need:
    • name,
    • address,
    • email address,
    • phone number,
    • type of data subject (business contact, website visitor, or other ),
    • type of request (Request to Know categories and specific information, Request to Delete, or Request to Correct), and
    • if making a Request to Correct, then identify the inaccurate piece of information and reasons for correction.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

3.3.  Response Timing and Delivery Method:

We will acknowledge receipt of your request within 10 business days of its receipt. We will respond to a request within 45 days of its receipt. If we require more time (up to 45 additional days for a total of 90 days from receipt of the request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  1. CHANGES TO THESE CALIFORNIA DISCLOSURES AND PRIVACY POLICY

We reserve the right to amend these California Disclosures and Privacy Policy at our discretion and at any time. If we make material changes to this privacy policy, we will post the new version on our website, www.veros.com.

  1. HOW TO CONTACT US

If you have any questions or comments about these California Disclosures and Privacy Policy, the ways in which we collect and use your personal information, or your rights regarding such use, or you wish to exercise your rights under California law, please do not hesitate to contact us at:

Privacy Support E-Mail:
Toll-Free Number:
Postal Address:

privacy@veros.com
866.458.3767 (option 6)
Veros Real Estate Solutions
Attn: Privacy
2333 N. Broadway, Suite 350
Santa Ana, CA 92706