Privacy Notice and Your Privacy Rights

Effective: December 19, 2019

Notice Last Updated: December 19, 2019

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.carusorewards.com, www.grovebunnyphotos.com, www.grovesantaphotos.com, www.palisadessantaphotos.com, www.palisadesbunnyphotos.com, and www.promenadesantaphotos.com  (together referred to as “Websites”)), use of our products or services (“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, or communicate with us in any 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, OR COMMUNICATING WITH US IN ANY 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 Caruso Rewards, including your name, mobile phone number, zip code, birthdate, email address, password, and retail purchase receipts.
  • 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.

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, including information provided at the time of registering for any Product, Rewards Program, 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 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.

Automatically when you access or interact with our Websites or 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, 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.

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, 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.

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. We associate cookies with personal information only if you authorize us to do so. We do not otherwise collect personal information from browser cookies and we do not associate browser cookies with your personal information. 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 your Caruso Rewards account;
  • 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. 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). For example, we may share the fact of your membership in Caruso Rewards and associated personal information with third-party advertising platforms, such as Facebook, in order for us to improve the relevance of advertisements regarding our products and services that you see.
  • 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.

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.

Third Party Tracking / Do Not Track

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 support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Websites are not currently set up to respond to “Do Not Track” signals and do not currently change the way they operate based upon detection of a “Do Not Track” or similar 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. We encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platform.

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. You may also change your preferences regarding such emails by editing your Caruso Rewards account profile.

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, effective January 1, 2020, you have additional rights when it comes to your personal information under the California Consumer Privacy Act (“CCPA”), including:

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 or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold 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 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.

Right of deletion. You have a right to request that we delete your personal information, and that we direct any service providers to do the same. To make such a request, you may either call toll-free at 1-855-490-5500 or submit a request here: www.caruso.com/disclosure. Please note that your request is subject to verification. 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 the expectations of you based on your relationship with us;
  • Comply with legal obligations;
  • Otherwise to be used internally in a lawful manner that is compatible with the context in which you provided the personal information; or
  • Provide employment and related benefits.

Right to opt out. If you are a California resident, you have the right to opt out of having your personal information sold to third-parties. If you are under the age of 16 but at least 13, you have the right to only have your information sold if you opt in and affirmatively authorize the sale of your personal information; if a child is less than 13, then the child’s parent or guardian must opt in and affirmatively authorize the sale of personal information.  Our current practice is to not sell your personal information for monetary or other valuable consideration and we have not done so in the preceding 12 months.  We may, however, share your personal information with third parties as described elsewhere in this notice and receive some benefit, such as a service or an improvement in service, in return.

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.

This right does not prohibit a business 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.  In certain instances, we may need your information to provide you with a particular service.  For example, if you decide to join Caruso Rewards, you will need to provide us with certain information about yourself.  To provide you with the benefits of Caruso Rewards, 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 a Caruso Rewards account.

Personal Information Collected (By Categories Set Forth In CCPA).  During the preceding 12 months, we have collected the following categories of personal information about California consumers (including, but not limited to, customers, job applicants and/or employees):

  • 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 Caruso Reward 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).

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, customers, 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);
  • “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 Caruso Reward 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).

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