PRIVACY NOTICE AND YOUR PRIVACY RIGHTS

Effective: September 1, 2024 

Notice Last Updated: September 1, 2024    

This Privacy Notice describes how Caruso Management Company, Ltd. and its affiliates (collectively “Caruso,” “we,” “us,” or “our”) collects, uses, stores, and shares information about you, including information collected from your use of our mobile applications and websites (including but not limited to www.caruso.com, www.thegrovela.com, www.americanaatbrand.com, www.shopcommons.com, www.shoplakes.com, www.shoppromenade.com, www.shopwaterside.com, www.8500burton.com, www.encinomarketplace.com, www.252southbrand.com, www.villageatmoorpark.com, www.333lacienega.com, www.palisadesvillageca.com, MiramarSantaPhotos.com, www.MiramarBunnyPhotos.com, www.americanabunnyphotos.com, www.americanasantaphotos.com, www.carusosignature.com, www.grovebunnyphotos.com, www.grovesantaphotos.com, www.palisadessantaphotos.com, www.palisadesbunnyphotos.com, and www.promenadesantaphotos.com and the Caruso mobile app (together referred to as “Websites”)), use of our products or services, including our Loyalty Programs (“Products”), and when you visit a Caruso property (including but not limited to The Grove, Palisades Village, The Residences at Palisades Village, The Americana at Brand, The Americana at Brand Luxury Apartments, The Promenade at Westlake, 8500 Burton Way, The Commons at Calabasas, Encino Marketplace, The Lakes at Thousand Oaks, The Masonic Temple at 234 South Brand Blvd, 252 South Brand Blvd., Village at Moorpark, Waterside at Marina Del Rey, and The Rosewood Miramar Beach, collectively “Properties”), and when you communicate with us in any other way, including but not limited to by email, telephone, and in person.

ACCEPTANCE

We recommend that you read this Privacy Notice carefully before you use our Websites or Products, visit our Properties, call us, or communicate with us in any other manner. The practices described in this Privacy Notice are subject to applicable laws in the places in which we operate.

BY ACCESSING OR INTERACTING WITH OUR WEBSITES OR PRODUCTS, VISITING OUR PROPERTIES, CALLING US, OR COMMUNICATING WITH US IN ANY OTHER MANNER, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY NOTICE, WHICH MAY BE UPDATED AND AMENDED FROM TIME TO TIME.

WHAT INFORMATION DO WE COLLECT FROM OR ABOUT YOU?

Depending on how you communicate with us and whether you visit our Properties, we may collect several types of information concerning you, including:

  • Information that you choose to share with us when you enroll in or use our Loyalty Program (including Caruso Signature) and/or other rewards programs, including your name, account number, mobile phone number, zip code, birthdate, email address, password, and retail purchase data.
  • Information about your internet connection (such as your IP address), the equipment you use to access our Websites or our guest Wi-Fi networks, marketing that led you to our Website, and Website usage details, such as your browser type and version, browser settings, browser plug-in types and versions, website views and navigation, operating systems and versions, device type, mobile carrier, page response time, and Media Access Control (“MAC”) address.
  • Information you may decide to share with us or third parties when you make reservations, such as for events or car services, or order or use valet parking, car wash, concierge, family amenity, or other services, which may include for example your contact information, payment card and billing contact information, date and nature of service, information about your vehicle, or information related to or needed for travel plans that you ask our concierge to assist you with.
  • Information that other websites and services, such as social media platforms, may choose to share with us if you have visited both our Websites and the websites or services of those platforms, such as demographic information that you have chosen to share with those platforms.
  • Information used for the safety, management, or administration of our Properties, such as data collected through the use of security cameras, or Closed Circuit Television Video (“CCTV”), located in parking lots and around our Properties.
  • Information that you may submit in connection with an application to tour or lease a Caruso-affiliated property, such as your contact information; your birth date and names and dates of birth of all occupants; your residence, finance, and employment history or status; proof of funds documents; your automobile; your pets and their vaccination records; insurance information; your social security number; your lease; payment authorization forms; and rental deposit receipts.
  • Information that may be collected from you in connection with your stay at a hotel owned by us, such as contact information, travel preferences, dates of stay, and other guest profile data.
  • Information that may be collected from you when you call Caruso’s call center, such as your name, phone number, email address, other contact information, the nature of your inquiry, and the outcome of your call.

HOW DO WE COLLECT INFORMATION?

We may collect this information from you in several ways:

Directly from you when you communicate with us through our Websites, by phone, or in person.

Examples:

  • Information you provide by filling out forms on our Websites, and information provided at the time of registering for, using or participating in any Product, our Loyalty Program or other rewards programs, or event, posting material or requesting further services or information.
  • Information you provide when you enter a sweepstakes, contest or promotion sponsored or offered by us or our partners.
  • Information you provide when you contact our call center (for example, to report a problem with our Websites).
  • Information you provide (e.g. email, name & zipcode) when you choose to sign in to Caruso’s public Wi-Fi captive portal and/or splash page to receive complimentary Internet Access during your visits to our properties.
  • Records and copies of your correspondence (e.g., email address) if you contact us.
  • Your responses to surveys that we might ask you to complete.
  • Details of transactions you carry out through our Websites and the fulfillment of your orders.
  • Your search queries on the Websites.
  • Through lease applications or other forms that you fill out in connection with a lease of a Caruso-affiliated residential or commercial property or download the Caruso mobile app.

Automatically when you access or interact with our Websites, our call center, or our Products or visit our Properties and, for example, are in proximity to a Wi-Fi network, a Bluetooth Beacon, or a camera.

Examples:

  • Details of your visits to the Websites, our call center, including traffic data, location data, logs and other communication data through the use of cookies, beacons, or pixel tags.
  • Information about your computer and mobile device, and internet connection, including your IP address, device MAC address, operating system, and browser type.
  • We may collect your automobile’s license plate information (please see our Automated License Plate Reader policy for more information).
  • Your image if you pass by a CCTV or security camera.
  • Your phone number and caller ID if you contact our call center.

From third parties, including business partners and affiliates, who choose to share your information with us through our relationship.

Examples:

  • Statistical data relating to your Website interactivity.
  • Information shared with us by referring sites, such as by social media sites. When you visit the sites of third parties, we may work with those third parties to display advertisements that we believe you may like to see. For example, if you navigate to one of our Websites, third-party cookies (such as those of social media platforms) may be downloaded to your device.  When you visit that platform’s service or website, the presence of those third-party cookies on your device may result in you seeing an advertisement related to our Products.
  • Companies that manage and operate hotels owned by us.

We may use cookies, beacons, and other similar technologies from time to time to collect information about your use of the Websites and to support the functionality of our Websites. This technology provides a better experience when you visit the Websites, and allows us to improve our services.

Our service providers, contractors, advertising partners, and ad networks may also use cookies and beacons to collect and share non-personal information about your activities both on our Websites and on other websites. In addition, third-parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Websites. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, you can adjust the settings of your browsers or install plug-ins and add-ins.  Depending on a third party’s purpose for collecting information about you, you also may have a right to opt out of sales or sharing of your data with that third party.  Please see below for more information.

Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers of ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. You may use the tools available on your computer or other device to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Websites. Unless you have adjusted your browser settings to refuse all cookies, we may use cookies when you direct your browser to our Websites.

Flash Cookies. Certain features of our Websites may use locally stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Websites. We also use cookies to provide aggregate reporting. The cookies do not identify you as an individual or track your online behavior. We do not collect personal information from flash cookies and we will not associate them with your personal information.

Beacons. Our Websites and emails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us for example, to count users who have visited those pages or opened an email and for other website-related statistics. Beacons in email marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.

HOW DO WE USE YOUR INFORMATION?

Caruso uses the information described above for multiple purposes, including:

  • Provide the Products you have requested;
  • Manage reservations;
  • Communicate with you regarding Products that you have requested or that we believe you may be interested in;
  • Create, manage, and administer our Loyalty Rewards Program and other rewards programs; 
  • Provide the Websites to you;
  • Operate the Websites, including access management, payment processing, Website administration, internal operations, troubleshooting, data analysis, testing, research, and for statistical purposes;
  • Respond to your requests, feedback, or inquiries;
  • Comply with laws, regulations, and other legal requirements;
  • Comply with relevant industry standards and our policies;
  • Deliver content tailored to your interests;
  • Present content that is optimized to your device;
  • Protect and enforce your rights and the rights of other users against unlawful activity, including identity theft and fraud;
  • Protect and enforce our collective rights arising under any agreements entered into between you and us;
  • Provide certain conveniences and efficiencies to our guests;
  • Estimate our audience size and usage patterns;
  • Provide security for the Properties, or protect our rights;
  • Leasing residential and commercial property.

HOW DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your information in several ways:

  • With your consent. In certain circumstances, we may seek to share your information with a third-party with your consent. In such situations, we may, unless otherwise required by law, obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of use on Websites; orally, either in person or on the phone; or other means.
  • With service providers or contractors. We may share your information with third-party vendors and partners who complete transactions or perform services on our behalf (e.g., data and Website hosting services, credit / debit card processing, billing, shipping, repair, customer service, auditing, accounting, marketing, advertising, electronic document signing, online leasing, credit and background checks, and legal advice). In addition, we may share personal information with third-party advertising programs, such as Facebook, in order for us to improve the relevance of advertisements regarding our products and services that you see.  However, you have the right to opt out of sales and sharing of your personal information for this purpose.  Please see below for more information on that right.
  • With affiliated companies. We may share your information with affiliated companies in an effort to facilitate your use of the Websites, Properties and/or use of the Products.
  • In a business transfer. We may share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be shared with third parties as a business asset in the transaction.
  • For legal process and protection. We may share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
    • Enforce or apply agreements, or initiate, render, bill, and collect for Products;
    • Protect our rights or interests, property or safety or that of others;
    • In connection with claims, disputes, or litigation – in court or elsewhere;
    • Protect users of our Products, Properties and Websites, and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
    • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
    • In case of an emergency.

We do not share mobile information with third parties or affiliates for marketing or promotional purposes.  All other categories above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

LINKS TO THIRD PARTY SITES

Our Websites may contain links to third-party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to the Websites and Products only, and we do not accept any responsibility or liability for the policies or practices of any third-parties.

GLOBAL PRIVACY CONTROL SIGNALS

When you use our Websites, third parties may collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers and browser extensions provide their users with the ability to turn on a Global Privacy Control (“GPC”) signal for all or specific websites.   Caruso responds to GPC signals by opting the user whose browser or browser extension sends the signal out of sales and sharing.  Caruso does not support the “Do Not Track” signal.   

SOCIAL MEDIA INTEGRATION

Our Websites may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, Twitter, Google, Instagram, etc. When you do, we may collect additional information from or about you through the social media platform.

Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We do not have control over the collection, use and sharing practices of social media platforms. However, you do have a right to opt out of Caruso sharing or selling your personal information to these social media platforms for cross-context behavioral advertising.  Please see below for more information.  We encourage you to review these social media platforms’ usage and disclosure policies and practices, including their data security practices, before using the platforms.

CELLULAR CARRIERS

When you visit a Caruso property, third parties, such as cellular carriers, may collect data from you in connection with your use of those carriers’ services.  While carriers may install equipment on Caruso property to improve the quality of cellular service available to you, we do not control what personal information the carriers collect or how they may use your data.  Please review your carrier’s privacy policy for more information about their data practices.

YOUR CHOICE AND CONTROL OVER YOUR PERSONAL INFORMATION

You may update and correct your information at any time by contacting us at info@caruso.com. Other choices you have include:

  • Disabling cookies. You can choose to disable cookies in your devices’ browser settings, although some Website features may not be available to you or may not function properly as a result.
  • Opt-out of promotional or marketing efforts. If you do not wish to receive promotional or marketing offers by email, you may opt out of receiving further offers and emails by clicking on the “unsubscribe” button in the email.

CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and you have publicly posted any information on our Websites, California Business and Professions Code § 22581 gives you the right to request and obtain removal of content or information you have publicly posted. If you wish to make such a request, please send an email with a detailed description of the specific content or information to info@caruso.com.

If you are a California resident, you have additional rights when it comes to your personal information under the California Consumer Privacy Act as amended by California Privacy Rights Act (together, the “CCPA”), including:

Notice of Financial Incentive. Caruso operates a Loyalty Rewards Program to Caruso shopping and entertainment center guests and community residents to earn points redeemable for events and experiences at Caruso properties. 

Material Terms of the Loyalty Program. The Loyalty Rewards Program is a points-based loyalty program through which members are able to earn points. For more details about the program, please see the Caruso Signature Program Terms. In exchange for the points in the Loyalty Rewards Program, Caruso collects California resident personal information, including name, mailing address, location information, zip code, email address and other optional information such as telephone number. Caruso will also collect reward program participation information, and certain transaction information to facilitate the program.  

How The Loyalty Program Points Are Calculated

Our Loyalty Rewards Program provides certain points that may be redeemed for events and experiences at Caruso properties. The financial incentive tied to the points is calculated based upon our reasonable but sole determination of the estimated value of the personal information California residents provide, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law.

Opt-In To The Program

When you sign-up for the Loyalty Rewards Program, you are affirmatively opting in to the program, and agreeing to the Caruso Signature Program Terms. As a member, you may choose to link your eligible credit or debit cards to the Program, which enables you to earn rewards for qualifying purchases.  By registering a payment card in connection with transaction monitoring, you authorize Caruso to share your payment card information with Visa, Mastercard and AMEX (“Payment Networks”) so it knows you enrolled. You authorize Mastercard and Visa to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for the Payment Networks to share such transaction details with Caruso to enable your card-linked offer(s) and target offers that may be of interest to you.  You may opt-out of transaction monitoring and information sharing about your linked cards and qualifying purchases under the Program at any time by de-linking the linked card from your Program account or withdrawing from and canceling your membership in the Program.  

Notwithstanding anything to the contrary in the Terms or Privacy Policy, Caruso, its Service Providers (as Defined by CCPA) and its contractors (including Company’s card-linking API provider) will use transaction information solely as follows:

  • Use transaction data such as transaction amount, transaction time and merchant location to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for rewards
  • Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred. For example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
  • Provide participating merchants or Third Party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and Third Party Service Providers to assess the results of their campaign;
  • Create a record of the transaction data and thereafter maintain and use data in connection with operating the Program;
  • Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

You authorize the sharing, exchange and use of transaction data described above and herein by and among Caruso and Caruso’s Third Party Service Providers, Caruso’s contractors, applicable Payment Card Networks and applicable Merchants.

Right To Withdraw

If you wish to withdraw from the Loyalty Rewards Program at any time, you may submit such a request by visiting the Concierge at any participating Caruso property, opting out of membership via the Caruso Signature App or Website, sending an email to Caruso at info@caruso.com or by calling 1-855-490-5500. You will receive an email from Caruso confirming cancellation of your membership. 

Right of access / disclosure. You have a right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting, selling, or sharing that personal information.
  • The categories of third parties to whom we disclose that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or shared your personal information, the categories of personal information that each category of recipient purchased.
  • If we disclosed your personal information for a business purpose, the categories of personal information that each category of recipient obtained.

To make such a request, you may either call 1-855-490-5500, email info@caruso.com, or submit a request here: www.caruso.com/disclosure. Please note that your request is subject to verification, and that we are not obligated to provide personal information in response to such a request if a consumer makes more than two requests in a 12-month period.  In order to verify that you are the consumer to whom the personal information relates, we may request certain information from you.  To obtain information about categories of personal information, we may request that you submit two data points that match data points that we maintain about you and that we determine are reliable for purposes of verifying your identity.  To obtain specific pieces of information we may have about you, we may request that you submit at least three pieces of personal information that we can match to information we maintain along with a signed declaration under penalty of perjury. 

Right of deletion. You have a right to request that we delete your personal information, and that we direct any service providers, contractors, or, unless impossible or involves disproportionate effort, third parties to whom we sold or shared your personal information to do the same. To make such a request, you may either call toll-free at 1-855-490-5500, email info@caruso.com, or submit a request here: www.caruso.com/disclosure. Please note that your request is subject to verification. The type of verification we may require will depend on the nature of the information that you seek to delete.  We also reserve the right to deny your request if your personal information is required to:

  • Complete the transaction for which the personal information was collected;
  • Provide a Product requested by you;
  • Continue the ongoing business relationship with you within the reasonably anticipated context of that relationship;
  • Perform a contract between you and Caruso;
  • 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 California resident 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;
  • 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;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information;
  • Comply with legal obligations; or

Right to correct. If you are a California resident, you have the right to request that we correct inaccurate personal information about you that we maintain taking into account the nature of the personal information and the purpose of the processing of the personal information. To make such a request, you may either call toll-free at 1-855-490-5500, email info@caruso.com, or submit a request here: www.caruso.com/disclosure. Please note that your request is subject to verification, and our duty to correct the personal information is limited to commercially reasonable efforts. Please note that your request is subject to verification. The type of verification we may require will depend on the nature of the information that you seek to delete.  

Right of non-discrimination. You have a right to exercise your rights under the CCPA without being subject to discrimination, including, but not limited to, by:

  • Denying you goods or services;
  • Charging you different prices or rates for goods or services;
  • Providing you a different level or quality of goods or services; or
  • Suggesting you will receive a different price or rate for goods or services or a different level of quality of goods or services; or
  • Retaliating against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.

This right does not prohibit us from charging a consumer a different price or rate, or from providing a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the consumer’s data.  Further, this right does not prohibit us from offering loyalty, rewards, premium features, discounts, or club card programs consistent with the CCPA.  In certain instances, we may need your information to provide you with a particular service.  For example, if you decide to join a Caruso rewards program, you will need to provide us with certain information about yourself.  To provide you with the benefits of the rewards program, we may need to have that information on file.  If you request that we delete that information, we will honor that request, but we may not be able to provide you with the benefits of the rewards account.

Personal Information Collected (By Categories Set Forth In CCPA).  We may collect, and during the preceding 12 months, we have collected the following categories of personal information about California consumers (including, but not limited to, customers, lease applicants, residential tenants, job applicants and/or employees).  Caruso retains personal information for as long as it is necessary to fulfill the purposes described above, unless a long retention period is required or permitted by law.  Generally, Caruso considers the following criteria in determining how long to retain categories of customer personal information: the amount, nature, and sensitivity of personal information; the potential risk of harm from unauthorized use or disclosure of personal information; the purposes for which we process the personal information; available alternatives for satisfying those purposes; and legal requirements.  We may delete or de-identify personal information sooner if we receive a verifiable deletion request that is not subject to an exemption from the duty to delete.   

  • Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses)
  • “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers)
  • Characteristics of protected classifications under California or federal law (for example, demographic data collected about employees or descriptions of subjects in connection with incident reports)
  • Commercial information (such as records of services provided or reward program points earned)
  • Biometric information defined in the CCPA to include an individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video)
  • Internet or other electronic network activity information (such as MAC address information collected in connection with use of our Wi-Fi network, website usage details, or IP addresses)
  • Geolocation data (for example, a record of your using a service at one of our properties)
  • Audio, electronic, visual, thermal, olfactory, or similar information (such as images recorded on security video)
  • Professional or employment-related information (for example, if you choose to apply for employment with us)
  • Education information (for example, if you choose to apply for employment with us)
  • Inferences drawn from any of the information identified above to create a profile about a consumer or resident reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes (for example, inferences that may be drawn about our property that you prefer to visit)

Sensitive Personal Information (as defined in CCPA). For more information, please see the next section. 

Sensitive Personal Information Collected (By Categories Set Forth In CCPA).  We may collect, and during the preceding 12 months, we have collected the following categories of Sensitive Personal Information about certain types of California consumers: specifically, lease applicants, residential tenants, job applicants, and/or employees:

  • Social Security numbers;
  • Driver’s license numbers;
  • Racial or ethnic origin;
  • Health data; and
  • Sexual orientation.

We collect and/or use these categories of Sensitive Personal Information for various purposes associated with performing our roles as an employer and a landlord, including:

  • Verifying employment eligibility;
  • Performing background checks; 
  • Administering health benefits;
  • Health and safety;
  • Paying applicable employment taxes and making necessary withholdings;
  • The promotion of diversity, equity, and inclusion;
  • Complying with legal obligations, satisfying document retention requirements, or defending against legal claims.

We do not sell or share sensitive personal information.

Personal Information Sold or Shared (By Categories Set Forth In CCPA).  

Our current practice is to not sell your personal information for monetary consideration. During the preceding 12 months, we have not sold personal information for monetary consideration.   

We may share, and during the preceding 12 months, we have shared the following categories of personal information about California consumers for cross-context behavioral advertising (which also may be classified as a “sale” under California law):

  • Category of Personal Information Shared: Internet or other electronic network activity information, such as information regarding a consumer’s interaction with our websites, applications, or advertisements.
  • Categories of Third Parties Shared: Digital advertising platforms, such as those offered by Meta Platforms, Inc. or Google LLC.
  • Purpose of Sharing: To provide advertising that is targeted to the interests of our consumers.

We do not knowingly sell or share the personal information of persons under 16.  As discussed below, the Websites are not intended for children under the age of 16 and if you are under age 16, you must not use or provide any information on the Websites.

To opt out of sales and sharing, you may either call toll-free at 1-855-490-5500, email info@caruso.com, or submit a request here: www.caruso.com/disclosure.

Personal Information Disclosed For A Business Purpose (By Categories Set Forth In CCPA).  During the preceding 12 months, we have disclosed the following categories of personal information about California consumers (including, but not limited to, job applicants and/or employees) for a business purpose (such as to perform services on our or a service provider’s behalf or to detect or protect against illegal or fraudulent activity):

  • Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses)
    Categories of Third Parties Disclosed To: Governmental Entities;
  • “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers)
    Categories of Third Parties Disclosed To: Governmental Entities;
  • Characteristics of protected classifications under California or federal law (for example, demographic data collected about employees or descriptions of subjects in connection with incident reports)
    Categories of Third Parties Disclosed To: Governmental Entities;
  • Biometric information defined in the CCPA to include an individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video)
    Categories of Third Parties Disclosed To: Governmental Entities;
  • Professional or employment-related information (for example, if you choose to apply for employment with us)
    Categories of Third Parties Disclosed To: Governmental Entities;
  • Education information (for example, if you choose to apply for employment with us)
    Categories of Third Parties Disclosed To: Governmental Entities;

Use or Disclosure of Sensitive Personal Information.  Other than the use or disclosure of Sensitive Personal Information to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, to perform the services set forth in California Civil Code § 1798.140(e)(2), (4), (5), or (8), or as otherwise authorized by regulations adopted pursuant to Civil Code § 1798.185(a)(19)(C), we do not use or disclose sensitive personal information.

ARE YOU A NEVADA RESIDENT?

If so, you have the right to request that we not sell for monetary consideration personal information we have collected, or will collect from or about you to any non-affiliated third party for the purpose of that non-affiliated third party licensing or selling your personal information to others. To submit this request, please send an email to info@caruso.com. Please note, we reserve the right to verify any request upon receipt.

HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

We have established reasonable organizational, technical and physical safeguards designed to limit who has access to your personal information, and to protect your personal information from unauthorized alteration, access, loss, theft, use or disclosure. These safeguards include, but are not limited to, access controls that are intended to restrict access to your personal information to authorized employees and contractors only.

We also rely on you to protect your personal information. Where we have provided you, or you have chosen, a password for access to certain parts of our Websites, you are responsible for ensuring that password is kept confidential. We ask that you do not share your password with others.  We may act on any activity undertaken under your password.  We also ask that you be careful about sharing your personal information in public spaces of the Websites like message boards. The information you share in public spaces may be viewed by other Website users or shared in other online locations.

No system can guarantee complete security of your personal information. We therefore cannot ensure or warrant that your personal information is secure from unauthorized third parties. Your use and access of our Websites, Products, and Properties, and your communications with us, are at your own risk.

CHILDREN

The Websites are not intended for children under the age of 16. If you are under age 16, do not use or provide any information on the Websites.

INTERNATIONAL JURISDICTIONS

The Websites are hosted in the United States of America (US), and are subject to US state and federal law. If you access the Websites from other countries, please be advised that you are transferring your personal information into the US, and by using our Websites you consent to that transfer and use of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of the US, including state and federal law and your agreements with us. Any persons accessing our Websites from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Websites in a manner lawful in their jurisdiction. If your use of the Websites would be unlawful in your jurisdiction, you may not use the Websites.

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Notice from time to time. Any and all changes to this Privacy Notice will be reflected on this page and the effective date will be stated at the top of this Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you. You should regularly check this page for any changes to this Privacy Notice.

Your continued use, access, or interaction with our Websites, Products, or Properties or your continued communication with us after the updated Privacy Notice has been posted (or any other indication of your consent) will constitute your acceptance of the updated Privacy Notice.  

CONTACT US

info@caruso.com

1-855-490-5500