Liberty Property Management
Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the Liberty Property Management Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. As used throughout this notice Liberty Property Management is referred to as "we," "us," or "our company."

I. Received or Collected Information

California law under the CCPA defines “personal information” broadly. However, there are some exceptions. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

II. Where do we receive information from? 

Our company receives information directly from you 
Our company receives personal information primarily for the purpose of managing properties for owner/landlords and renting properties to tenants. Nearly all of the information which we directly collect about you is received from the physical or electronic documents that are necessary to manage a property you own or to rent a property to you as a tenant. For example, the property management agreement and lease agreement will contain your name, signature, and other personal information. Or, for example, a landlord is required by law and contract to give the buyer various disclosures concerning a range of issues associated with the property, some of which information may constitute personal information. Once these documents come into our possession, we are required to retain them by law.
Cookies and Other Technologies 
Our website and some of our online products and services, email messages and advertisements may use cookies, log files and other technologies to collect information about your use of our website, products and services and third-party websites that have a business relationship with our service providers. A cookie is a small data file that is sent to your browser from a website's servers and stored on your computer's hard drive, and is used to store information such as the name of your Internet service provider, your Internet Protocol (IP) address, the website that referred you, your general geographic location, the pages you request, and the dates and times of those requests. Most internet browsers are initially set to accept cookies. If you prefer, you may set your browser so that it refuses cookies or alerts you when cookies are being created on your hard drive. You should be aware that by not accepting cookies you may impair your ability to use certain portions of our website, products and services. 
Our company receives some information indirectly
City, county, state and other agencies of government. Many aspects of the property management and landlord/tenant business rely on information received from a variety of government sources.
Reporting companies. Reporting companies will access public records for information concerning the property and then provide a summary of the information. This information is not typically considered “personal information.”
Other sources of information. Neighborhood advertising information; real estate brokerages, brokers, and agents and their websites; current and former clients and consumers; neighbors; real property portals such as Realtor.com, Zillow.com, etc. and other websites; Multiple Listing Services (MLS) for the purpose of verifying rental history, social media websites such as Facebook, Instagram, etc.; HOA documents from HOAs; appraisers and appraisals; investigators, inspectors, and contractors, natural hazard disclosure report companies; credit reporting agencies such as Equifax, background reporting agencies, landlord verification requests, and legally and contractually required disclosures generated by landlords are other sources of information from which personal information may be collected or received.

III. Use, Sharing and Sale of Personal Information 

Use of Personal information
Assistance in managing a property and/or renting a property. The primary use of personal information is to manage owner/landlord properties and to effectual the rental relationship between those owners/landlords and tenants.

Web technologies. We use cookies and other technologies to verify user information, to make your use of our website, products and services more convenient and to assist in understanding your use of our website, products and services. We also use cookies to measure website activity and generate statistics that allow us to improve the services we provide online. 

Additional Uses. We may use the personal information we collect for the following additional business purposes:

• To create, maintain, customize and secure the communications between you and us.
• To assist in preventing transaction fraud.
• To provide, support, personalize, and develop our website, products, and services.
• To personalize your online experience with us and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• 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.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by our company is among the assets. 

Sharing of personal information and chart

Sharing information to facilitate the management of properties and/or the renting or properties. The sharing of information is integral to the process of managing and renting properties. First and foremost, we will share information with potential tenants who, in turn, share information through us with potential landlords. It is only through the sharing of information that we can match up those landlords with tenants and manage those properties. 

Third parties we commonly share information with. As a property management company, we may typically share your personal information with the following third parties:

·         Property owners, landlords, and tenants

·         Various websites that facilitate the management and rental of properties

·         Service providers such as inspectors, contractors, maintenance vendors, appraisers, or reporting companies

·         Real estate brokerages, brokers, and/or agents in the event that you are contemplating selling a property

·         Law enforcement or government agencies for the purpose of detecting criminal activity, other background checks and investigations

·         Insurance agencies to assist tenants in obtaining insurance

·         Other third parties as necessary to facilitate the management and rental of properties 

Sale of personal information and chart
Referrals. With your consent, our company may share your personal information, your name and phone number with real estate brokerages, brokers, and agents for purposes of referring you to them in the event that you are contemplating selling your property. For this we often negotiate a referral fee in line with the traditional model of brokerage referral relationships. Such a fee does constitute a sale. 
Other referrals. Referrals other than to real estate brokerages, brokers, and agents do not typically involve a referral fee. If such a referral fee is legally permitted, our agents will always disclose and obtain your consent before receiving one.

IV. Your Rights and Choices

If you are a California resident, you have certain rights regarding your personal information under the CCPA. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information 

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. You must make a verifiable consumer request as described below. 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 from which we collected your personal information.
• Our business or commercial purpose for collecting or selling your personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we collected about you. 
• If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing the following:
• The categories of personal information that we disclosed about you for a business purpose. 
• The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category of personal information for each third party to whom the personal information was sold.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily useable format that allows you to transmit it to another entity without hindrance. 

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. You must make a verifiable consumer request as described below. 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. However, we will not direct third parties to delete your personal information. For that, you must contact the third party directly. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Retain transaction files or comply with any other legal obligation.  Real property managers are required to hold all files under California law.   
• Complete a transaction or agreement for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. For example, we will not delete your personal information while we are representing you as a landlord or renting property to you as a tenant. 
• 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.
• 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 of our information is likely to render impossible or seriously impair the achievement of such research, so long as you have provided informed consent. 
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided it.

How to Exercise Your Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

·         Calling us at 1-800-526-2144

·         Visiting https://www.libertypropertymanagement.com/contact-us/?topic=Rights

You may also make a request on behalf of your minor child. You may only make a request for access to or disclosure of your personal information twice within a 12-month period. The request 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.

We cannot respond to your request or provide you with personal information if we are unable to verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create a user account with us to make a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you provide us with personal information in your request, we will only use it to verify the requestor’s identity or authority to make the request. 

Response Timing and Format

We will try to respond to your request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. But the extension period will be no more than an additional 45 days. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily useable format that allows you to transmit it from another entity without hindrance. 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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link:

Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submitting a requesting by visiting the following link:

Opt-In to Personal Information Sales

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. 
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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, deny discounts or other benefits, or impose penalties.

·         Provide a different level or quality of goods or services to you.

·         Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. To make such a request, please contact us via one of the methods found in the “Contact Information” section below.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
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Contact Information 

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

Phone:

1-800-526-2144
Website:

https://www.libertypropertymanagement.com/contact-us/?topic=Rights
Email:

privacy@libertypropertymanagement.com
Postal Address:
Liberty Property Management

Attn: Privacy/General Counsel

1120 Scenic Drive

Modesto, CA 95350