California Consumer Privacy Act (CCPA) Website Visitor Disclosure
California Consumer Privacy Act (CCPA) Website Visitor Disclosure
This CCPA Website Visitor Disclosure applies to HPL Holding, L.L.C., a Delaware limited liability company and each of its affiliates listed below (collectively referred to as “Hometown America”). The affiliates include: HPL Management, L.P.*, HPL Management GP, L.L.C., BRD Development, L.L.C., GTS Development, L.L.C. and GTS Development II, L.L.C.
Respecting the privacy of individuals interested in High Point Living is an essential part of our privacy program. We are committed to the proper handling of the Personal Information collected or processed in connection with your inquiry of us. This disclosure describes categories of Personal Information we collect and the purposes for which we process that information in accordance with section 1798.100 (b) of the California Consumer Privacy Act (CCPA). The CCPA defines Personal Information as categories of information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to a particular California resident or household.
Personal information does not include (a) publicly available information from government records, (b) deidentified or aggregated consumer information, and (c) 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
| Definitions of Categories of Personal Information Under the CCPA | |
| Category A Identifiers |
Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
| Category B Personal Information |
Personal information, as defined in the CCPA and consumer records law, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, credit card number, debit card number, any other financial information, medical information, health insurance information, contact information, insurance policy number, education, employment, employment history, financial information, medical information and health information. |
| Category C Characteristics |
Characteristics of protected classifications under California or federal law. |
| Category D Commercial Information |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| Category E Biometrics |
Biometric information means an individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
| Category F Internet Activity |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. |
| Category G Geolocation |
Geolocation data, such as device or personal location. |
| Category H Sensory Data |
Audio, electronic, visual, thermal, olfactory, or similar information, such as images and audio, video or call recordings created in connection with our business activities. |
| Category I Professional Information |
Professional or employment-related information, such as work history and prior employer, human resources data and data necessary for benefits and related administrative services. |
| Category J Education |
Education information subject to the federal Family Educational Rights and Privacy Act, such as student records. |
| Category K Inferences |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Categories of Personal Information Collected by High Point Living
High Point Living collects Personal Information from Categories A, B, C, D, F and I from resident applicants. High Point Living collects Personal Information from Categories A, B and D from residents.
Purposes for Collecting Personal Information
Personal Information is collected for the following purposes:
- To comply with state and federal law and regulations;
- To induce individuals to lease, rent, or buy real property;
- To perform background, credit, and other inquiries to determine suitability for leasing, renting, or purchasing a home;
- To process rents, fees or other charges; and,
- To ensure compliance with lease documents, including associated documents such as Community Rules and Regulations.
Contact
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
- Phone: Please call 1-877-763-7543 and request that our Chief Privacy Officer contact you.
- Website: Please review High Point Living’s privacy policy via the link at the bottom of the website homepage, www.HighPointLiving.com. This page also lists High Point Living’s Chief Privacy Officer’s contact information.
- Email: Please send an e-mail to our Chief Privacy Officer at Privacy@HighPointLiving.com.
- Postal Address: High Point Living, 110 N. Wacker Dr., Suite 4500, Chicago, IL 60606, Attention: Chief Privacy Officer.
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