Privacy
Policy
Effective
Date: January 1, 2023
Demmon
Partners, LLC (collectively, “Demmon Partners,” “we,” “us”
and “our”) respects the privacy of its customers, business partners, job
applicants and Websites visitors (“You” and “your”). Protecting your private
information is our priority. In
providing our services, we may collect information that identifies, relates to,
describes, is reasonably capable of being associated with, or could reasonably
be linked to, directly or indirectly, you (“Personal Information”).
This Privacy Policy (the “Policy”) describes how we treat data and your Personal
Information that Demmon Partners collects and receives through this website,
and other Demmon Partners websites that link to this Privacy Policy
(collectively, “Websites” and individually “Site”), and other aspects of Demmon
Partners’ business, whether online or offline.
This Policy does not apply to the practices of companies that Demmon
Partners neither owns nor control.
By using and accessing any of the Websites, you agree to the terms
and conditions of this Policy. This Policy may change from time to time and
your continued use of the Websites after we make changes is deemed to be
acceptance of those changes. Please check the Policy periodically for updates. If
you have any questions or concerns about our use of your Personal Information,
please contact us using the contact details provided at the bottom of this
Policy.
1. Personal Information Collection
We may collect Personal Information from you. Under the California
Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California
Privacy Rights Act of 2020 (“CPRA”), to
“collect” means to buy, rent, gather, obtain receive, or access any Personal
Information of a California resident. While we may not retain Personal
Information from you, we may nonetheless “collect” Personal Information when
using that definition. The types of Personal Information we collect will
depend on much you engage with our Websites and their services.
To provide services offered by Demmon
Partners, we must process information about you, including Personal
Information, whether or not you are registered or logged in. However, we
do not use your data for automated decision making.
Here is a summary of categories of Personal Information
we may have collected from you over the past 12 months, depending on how you
use our services, as well as how we use it and with whom we may have shared it.
This Section does not apply to
California-based job applicants, contractors or similar individuals. For California-based job applicants,
contractors or similar individuals, please see privacy
policy for the Personal Information collected.
Category
|
Examples
|
Collected
|
Identifiers.
|
Name, postal address, unique personal identifier, online
identifier, Internet Protocol (“IP”) address, email address, Social Security
number, or other similar identifiers.
Note: Personal Information does not
include publicly available information from government records
|
Yes
|
Personal
Information referenced in the California Customer Records statute (Cal. Civ.
Code § 1798.80(e)).
|
A name, signature,
address, telephone number, passport number, driver’s license or state
identification card number, insurance policy number, employment history
Notes: Some Personal
Information included in this category may overlap with other categories. Personal Information does not include publicly
available information from government records
|
Yes
|
Protected
classification characteristics under California or federal law.
|
Age (40 years or
older), race, color, ancestry, national origin, citizenship, religion or
creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or childbirth
and related medical conditions), sexual orientation, veteran or military
status, genetic information (including familial genetic information).
|
Yes
|
Commercial
information.
|
Records of personal property, products or services
purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies.
|
Yes
|
Biometric
information.
|
Physiological,
biological, or behavioral, characteristics (including DNA) that can be used
to establish individual identity, such as fingerprints and eyes, or
behavioral characteristics
|
No
|
Internet or
other electronic network activity.
|
Browsing history, search
history, information on a consumer’s interaction with an internet website,
application, or advertisement.
|
Yes
|
Geolocation
data.
|
Physical location
or movements.
|
Yes
|
Sensory data.
|
Audio, electronic,
visual, thermal, olfactory, or similar information.
|
Yes
|
Professional or
employment-related information.
|
Current or past job
history
|
Yes
|
Non-public
education information (per the Family Educational Rights and Privacy Act (20
U.S.C. Sec. 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
|
Inferences drawn
from other Personal Information to create a profile about a consumer.
|
Profile reflecting
a consumer’s preferences, characteristics, behavior, attitudes, intelligence,
abilities, and aptitudes.
|
Yes
|
Sensitive
Personal Information.
|
Any private
information that divulges any of the following such as personal
identification numbers, including social security, driver's license,
passport, or state ID card numbers
|
Yes
|
2. How is This Information
Collected?
· Directly from you when you provide
it to us.
· Indirectly through one of our
third parties that either store the details you provided to process billings
information or send email campaigns.
· Information we receive from you
when you contact our main office or other Demmon Partners offices for any inquiries.
· Information that you provide by
filling in forms on our Websites. We may also ask you for information when you
enter a contest, fundraiser, or promotion sponsored by us, and when you report
a problem with our Websites.
· Your responses to surveys that we
might ask you to complete for research purposes.
·
Information
through cookies and similar technologies.
We may automatically collect
Personal Information as you navigate through the Websites. Information
collected automatically by us or companies acting on our behalf may include,
but is not limited to, log and usage data, IP addresses, cookies, pixel tags,
web beacons, device data, location data, and other tracking technologies.
You may stop or restrict the placement of technologies on your device or
remove them by adjusting your preferences as your browser or device permits.
o Log and Usage Data. Log and usage data is service-related,
diagnostic usage and performance information our servers automatically collect
when you access or use our Websites and which we, or a third party acting on
our behalf, record in log files. Depending on how you interact with us, this
log data may include your IP address, device information, browser type and
settings and information about your activity in the Websites (such as the
date/time stamps associated with your usage, pages and files viewed, searches
and other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called ‘crash
dumps’) and hardware settings).
o Cookies. Cookies are small text files placed in visitors’
device browsers to store their preferences. Most browsers allow you to block
and delete cookies. However, if you do that, the services may not work
properly. These cookies and other related technology allow third party
companies to help us improve your experience on our Websites, understand how the
Websites are being used, and measure the number of visitors to the Websites. We
also work with third parties who may place cookies on your web browser to
enable us to serve you with advertising based on your search activity.
Your web browser may tell you how to be notified
when you receive certain types of cookies and how to restrict, reject or
disable certain cookies. For more information about removing cookies for your
specific web browser, visit allaboutcookies.org/manage-cookies/clear-cookies-installed.html.
o
Pixel
Tags/Web Beacons. A pixel
tag (also known as a web beacon) is a piece of code embedded on the Websites
that collects information about users’ engagement on that web page. The use of
a pixel allows us to record, for example, that a user has visited a particular
web page or clicked on a particular advertisement.
o Device Data. We, or a third party acting on our behalf,
may collect device data such as information about your computer, phone, tablet
or other device you use to access the Website. Depending on the device used,
this device data may include information such as your IP address (or proxy
server), device application identification numbers, location, browser type,
hardware model Internet service provider and/or mobile carrier, operating
system configuration information.
·
Information collected from other sources.
To
enhance our ability to provide relevant marketing, offers and services to you
and update our records, we may obtain information about you from other sources,
such as public databases, analytics providers (such as Google Analytics,
Facebook Insight, and Geotargeted), data providers, social media platforms, service
providers as well as from other third parties. If you interact with us on a
social media platform using your social media account (e.g. Facebook or
Twitter), we receive Personal Information about you such as your name, email
address, and gender. Any Personal Information that we collect from your social
media account depends on your social media account’s privacy settings.
3. Use of Personal Information
We may use any of
the Personal Information we collect for the following business-related purposes:
- To enable
user-to-user communications. We may use your Personal Information
to enable user-to-user communications with each user’s consent.
- To respond to user inquiries/offer support to users. We
may use your information to respond to your inquiries and solve any
potential issues you might have with the use of our services.
- To manage user accounts. We may use your
information for the purposes of managing our account and keeping it in
working order.
- To allow you to access amenities,
Site features and request service. We
may use your information to assist you in maintenance requests, access to
property amenities, and other services.
- To resolve bugs, troubleshoot
problems, security incidents, and improve Site operation. We
may use your information as part of our efforts to keep our Websites
safe and secure (including to protect against malicious, deceptive,
fraudulent, or illegal activity, and prosecute those responsible for that
activity).
- To improve, upgrade or enhance our Websites and services.
- To fulfill and manage your lease applications. We
may use your information to fulfill and manage your lease applications,
payments, returns, and exchanges made through the Websites.
- To administer prize draws and competitions. We
may use your information to administer prize draws and competitions when
you elect to participate in our competitions.
- To send administrative information to you. We
may use your Personal Information to send you service, updated, and new
feature information and/or information about changes to our terms,
conditions, and policies.
- To send you marketing and promotional communications. We
may deliver targeted advertising, coupons, newsletters, and other
information regarding promotions, the Site and properties we manage to
you.
- To compile anonymous statistical data
and analysis for use internally or with third parties. We may monitor
and analyze usage and trends to improve your experience with the Site.
- To request feedback. We may use
your Personal Information to request feedback and to contact you about
your use of our Websites.
- To operate our Websites and provide our services in accordance with
our agreements you may have with us.
- To carry out
other purposes that are disclosed to you and/or to which you consent.
- To pursue our
legitimate interests where your rights and freedoms do not outweigh these
interests.
- To respond to legal requests and
prevent harm. If
we receive a subpoena or other legal request, we may need to inspect the
data we hold to determine how to respond.
4. Personal Information Sharing
No “Selling” or “Sharing” of Personal Information: Demmon Partners does not sell your Personal
Information or share your Personal Information for the purpose of behavioral
advertising and we do not allow any Personal Information to be used by third
parties for their own marketing purposes. We do not exchange your Personal Information with others for monetary or
other valuable consideration. We
may process or share your Personal Information that we hold based on the
following legal basis:
- Consent: We may process your data if you
have given us specific consent or authorization to use your Personal
Information in a specific purpose.
- Performance of a Contract: Where we have entered into a contract
with you, we may process your Personal Information to fulfill the terms of
our contract.
- Vendors, Consultants and Other
Third-Party Service Providers. We may share your data with utility billing providers, cable
companies, third-party vendors, service providers, contractors or agents
who perform services for us or on our behalf and require access to such
information to do that work. Examples include: payment processing, data
analysis (such as Google Analytics, Facebook Insight, and Geotargeted),
email delivery, hosting services, customer service and marketing efforts.
We may allow selected third parties to use tracking technology on
the Websites, which will enable them to collect data on our behalf
about how you interact with our Websites over time. This
information may be used to, among other things, analyze and track data,
determine the popularity of certain content, pages or features, and better
understand online activity. Unless described in this notice, we do not
share, sell, rent or trade any of your information with third parties for
their promotional purposes.
- Third-Party Advertisers. We may use third-party
advertising companies to serve ads when you visit or use the Websites.
These companies may use information about your visits to our Websites and
other websites that are contained in web cookies and other tracking
technologies to provide advertisements about goods and services of
interest to you.
- Business Partners. We may share your Personal Information with our business partners to offer
you certain products, services or promotions.
- Other Users. If you interact with other users
of our Website and register for our Website through a
social network (such as Facebook), your contacts on the social network
will see your name, profile photo, and descriptions of your
activity. Similarly, other users will be able to view descriptions of
your activity, communicate with you within our Website, and view your
profile.
- Legal Obligations: We may disclose your Personal Information where we are legally required to do so
to comply with applicable law, governmental requests, a judicial
proceeding, court order, or legal process, such as in response to a court
order or a subpoena (including in response to public authorities to meet
national security or law enforcement requirements).
- Vital Interests: We may disclose your Personal Information where we believe it is necessary to
investigate, prevent, or take action regarding potential violations of our
policies, suspected fraud, situations involving potential threats to the
safety of any person and illegal activities, or as evidence in litigation
in which we are involved.
- Business Transfers. We may share or transfer your Personal Information in connection with, or during negotiations
of, any merger, sale of company assets, financing, or acquisition of all
or a portion of our business to another company.
- Legitimate Interests: We may process your data when it
is reasonably necessary to achieve our legitimate business interests.
5. Unaffiliated Third-Party Links/Websites
Our Websites may contain links to
other websites or services that Demmon Partners neither owns nor operates. Websites
hosted by third party service providers, such as RENTCafe.com, may appear as if
you are still on a Site. To tell whether
you are on one of the Websites or viewing third party content, please check the
URL address in your browser’s address window.
We encourage you to read the
privacy statements of each and every third party website and service provider
before providing any personally information to them. We are not responsible for
the privacy practices of third parties. If you choose to visit or use any third
party websites, including those offered by our third party service providers or
other partners, please be aware that this Policy will not apply to information
that you disclose to third parties.
6. Opt-Out and
Do-Not-Track Signals
Do Not Track (DNT) is a web browser setting that
requests that a website or web application disable its tracking of a user’s
browsing data. Various web browsers (including Internet Explorer, Google
Chrome, Firefox, and Safari) offer a “do not track” option, which sends a
signal to websites visited by the user about his or her browser DNT preference
setting.
We do not directly respond to “Do Not Track” signals
and no common industry standard for DNT has been adopted. We do not permit
third parties other than our analytics and other service providers to track the
users’ activity on the Websites. We do not track your online activity on other
online services over time.
Third parties like Google Analytics that have content
embedded on Demmon Partners’s websites may set cookies on a user’s browser
and/or obtain information about the fact that a web browser visited a specific Demmon
Partners website from a certain IP address. Third parties cannot collect any
other Personal Information from Demmon Partners websites unless you provide it
to them directly.
You may opt-out of data collection from certain
companies:
·
We
use Google Analytics to collect and analyze information about the use of our
Websites. This information helps us measure the effectiveness of our marketing
campaigns. If you have an account with Google, you can manage your advertising settings,
otherwise you can manage these settings through your web browser.
·
You may also opt-out of Google Analytics by installing Google’s
opt-out browser add-on here.
Please review Google’s terms of service and privacy policy before installing. You can learn about Google’s practices by clicking here.
·
We
also use Facebook Insights to collect and analyze information about the use of
our Websites. For more information about Facebook’s collection and use of this
data and your rights and choices about protecting your privacy, please refer to
Facebook’s Privacy
Policy. For logged-in users’ deactivation, please check http://www.facebook.com/settings/.
To do this you must be logged in on Facebook or Instagram.
·
You
may also opt out of the automated collection of information by certain third-party
ad networks for the purpose of delivering advertisements tailored to your
interests, by visiting the consumer opt-out
page for the Self-Regulatory Principles for Online Behavioral Advertising.
Because those opt-out pages are specific to your browser used to
visit it and because we do not have control over those unaffiliated third party
websites, we are unable to perform the opt-outs on your behalf.
7. Notice at Collection for Job Applicants, Contractors,
Or Similar Individuals
Pursuant to the CCPA, this section is a Privacy Notice pertaining
only to Personal Information Demmon Partners may collect about a California
resident in the course of such person acting as a job applicant to, contractor
to, or similar individuals of Demmon Partners. During the course of your
application for work with us, we may collect certain information about you. The
categories of information we may collect, and the purposes for collecting them,
include:
Category of Information
|
Why We Collect it
|
Identifiers. This category includes 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
|
•
Collect and process employment applications,
including confirming eligibility for employment, background and related
checks, and onboarding
|
Personal information, as defined in California Civil
Code section 1798.80. This category includes contact information, name,
signature, social security number, passport number, driver’s license or state
identification card number, insurance policy number, education, employment,
employment history, bank account number, credit or debit card number, other
financial information, medical information, health insurance information
|
•
Collect and process employment applications,
including confirming eligibility for employment, background and related
checks, and onboarding
|
Protected
classification information. This category includes characteristics of
protected classifications under California or federal law
|
•
Comply with applicable state and federal Equal
Employment Opportunity laws
|
Internet
or other electronic network activity information. This category includes without
limitation Internet or other electronic network activity information such as
browsing history, search history, and information regarding your interaction
with internet web sites and applications
|
•
Facilitate the efficient and secure use of the
company’s information systems, ensure compliance with company policies and
procedures, and investigate complaints and any suspected violations of
company policy.
|
Geolocation.
This category includes physical location or movements such as GPS location
data
|
•
Improve safety of employees, customers and the public
with regard to use of Demmon Partners property and equipment
•
Prevent unauthorized access, use, or loss of Demmon
Partners property
|
Professional or
employment-related information. This category includes without limitation
work history, prior employer, references, qualifications, skills and
experience, human resources data, emergency contact information, and data
necessary for benefits and related administrative services
|
•
Collect and process employment applications,
including confirming eligibility for employment, background and related
checks, and onboarding
|
Education Information. This category includes
education history
|
• Process,
evaluate, and communicate with an individual about his or her application and
assess his or her eligibility and fit for the role for which the individual
applied
|
Inferences
drawn from any of the Personal Information listed above
|
• Assess
qualifications for certain positions to create a profile reflecting his or
her preferences, characteristics, behavior, attitudes, intelligence,
abilities, and aptitudes
|
Sensitive
Personal Information. This
category includes any private information that divulges any of the following
such as personal identification numbers, including social security, driver's
license, passport, or state ID card numbers
|
•
Collect and process employment applications,
including confirming eligibility for employment, background and related
checks, and onboarding
|
8. Security of Personal Information
We use appropriate technical and
organizational security measures to protect the security of your Personal
Information both online and offline including the implementation of access
controls, firewalls, network intrusion detection, and use of anti-virus
software. These measures vary based on the sensitivity of the Personal
Information we collect, process, and store, and the current state of
technology. We or a third party acting on our behalf will store the data
necessary for the encryption, especially the public and private keys (the
private keys are stored encrypted, for us it is not possible to decrypt any
private key). However, as technology continues to develop overtime, there is no
storage, or transmission of data over the Internet that is guaranteed to be
completely secure. We therefore cannot guarantee to providing absolute
security. Although we will do our best
to protect your Personal Information, transmission of Personal Information to
and from our Websites is at your own risk. You should only access the Websites
within a secure environment.
9. Retention of Your Personal Information
Demmon Partners will retain your Personal
Information, including sensitive Personal Information, only for as long as is
necessary for the purposes set out in this Policy. We will retain and use your Personal
Information to the extent necessary to comply with our legal obligations (for
example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
Demmon Partners will also retain
Usage Data (i.e., data collected automatically, either generated by the use of
the service or from the service infrastructure itself, such as the duration of
a page visit) for internal analysis purposes. Usage Data is generally retained
for a shorter period of time, except when this data is used to strengthen the
security or to improve the functionality of our service, or we are legally
obligated to retain this data for longer time periods.
10. CCPA: Your Rights and Choices (California
Residents Only)
Under
the California Consumer Privacy Act (“CCPA”), if you are
a California resident, you are entitled to additional efforts to protect their
privacy, these rights include:
·
Right
to Access/Know where you may request any or all of the following information
relating to your Personal Information we have collected and disclosed in the
last 12 months, upon verification of your identity:
o
The
specific pieces of Personal Information we have collected about you;
o
The
categories of Personal Information we have collected about you;
o
The
categories of sources of the Personal Information;
o
The
categories of Personal Information that we have disclosed to third parties for
a business purpose, and the categories of recipients to whom this information
was disclosed;
o
The
categories of Personal Information we have sold about you (if any), and the
categories of third parties to whom the information was sold; and
o
The
business or commercial purposes for collecting or, if applicable, selling the
Personal Information.
·
Right
to Request Deletion of Personal Information that Demmon Partners has collected
of you
·
Right
to “opt-out” of the sale or sharing of Personal Information
·
Right
to No Retaliation for the Exercise of a Consumer’s Privacy Rights – a consumer
(including employees, job applicants, or independent contractors) has a right
not to receive discriminatory or retaliatory treatment by Demmon Partners for
the valid exercise of privacy rights conferred by the CCPA/CPRA.
·
Right
to request that you limit a California consumer’s use and disclosure of your
sensitive Personal Information
·
Right
to correct any inaccurate Personal Information
We may deny your deletion request if retaining the
information is reasonably necessary for the business or 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 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 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.
To exercise any of your rights described above, please submit a request
to us by either:
Mailing Address: Demmon
Partners LLC
601
University Avenue, Suite 110
Sacramento, CA
95825
Email Address: optout@demmonpartners.com
You may only make a request for access or data portability 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. We reserve the right to confirm
your California residency. Government identification may be required.
· If you wish to designate an authorized agent
to make a request on your behalf, we will need to verify both your and your
agent’s identities, which may require submission of government identification.
Your agent must also provide other proof of authority acceptable to us in our
sole discretion.
· 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 authority to make the request
and confirm the Personal Information relates to you. In certain cases, we may
be permitted by law to deny your request.
Making a request does not require you to create an account with us. We
will only use Personal Information provided in a request to verify the
requestor’s identity or authority to make the request.
11. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA
rights. You have the right not to receive discriminatory treatment by Demmon
Partners for the exercise of privacy rights conferred by the CCPA/CPRA,
including an employee’s, applicant’s, or independent contractor’s right not to
be retaliated against for the exercise of their CCPA rights. Unless permitted
by the CCPA/CPRA, 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.
·
We
provide these tools for your benefit and we will never discriminate against you
for using them. But if you choose to delete your data or close your account, we
won’t be able to offer you services that require us to use your data.
12. Minors
Demmon Partners recognize the
privacy interests of children and we encourage parents and guardians to take an
active role in their children’s online activities and interests. Neither the
Site nor our services are not directed to children under 13 (or other age as
defined by local law). We do not target our services or the Websites to
children. We also do not knowingly collect Personally Information from
children. If we learn that we have collected any Personal Information from a
child in violation of applicable law, we will immediately take steps to delete
such information. If you learn that your child has provided us with Personal
Information without your consent, please contact us using the contact
information provided below.
13. Disclaimer
Although our Site is accessible
throughout the world, our Site is designed for and targets U.S. audiences, and
is governed by and operated in accordance with the laws of the United States.
We make no representation that our Site is operated in accordance with the laws
or regulations of, or governed by, other nations, and we do not warrant or
imply that our Site or content/materials on our Site are appropriate for use
outside of the United States.
14. Changes to this Privacy Policy
We reserve the right to change this Policy
at any time. If we make any material changes to this Policy, we will update the
“Effective Date” at the top of this page and update our notices on the Websites.
You are responsible for ensuring we have an up-to-date active and deliverable
email address for you, and for periodically visiting our Site and this Policy
to check for any changes.
15. Contact Us
If you have
any questions about our privacy practices or this Policy, please contact us at:
Mailing Address: Demmon
Partners LLC
601
University Avenue, Suite 110
Sacramento, CA
95825
Email Address: optout@demmonpartners.com