Version August 2020
This Policy may be supplemented or amended from time to time by privacy notices posted on this Site. These privacy notices provide a level of detail that we cannot provide in this more general description of our privacy practices. For example, certain pages of this Site may contain privacy notices providing details about the Personal Information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.
Our Site is maintained in the United States of America. By using the Site, you consent to and authorize the export of your information to the United States and its storage and use as specified in this policy. You understand and consent that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you do not consent to the storage of your Personal Information in the United States, do not provide us with any of your Personal Information.
Table of Contents
- What Information Do We Collect?
- How Do We Use The Information?
- Do We Disclose The Information to Outside Parties?
- Updating Personal Information and Preferences
- Steps We Take To Safeguard Your Personal Information
- Contact Us
- Privacy Notice For California Residents
- EEA Residents
1. What Information Do We Collect?
We collect personal information when you wish to use certain features of the Site, such as providing comments or feedback to us or registering to receive information from us. When you choose to use these features, we ask for information such as your name, e-mail address, mailing address, phone number, and other personal information (“Personal Information”).
With your opt-in consent, or if allowed by your settings on your mobile device, we may collect location information from your mobile device and use that information to deliver tailored content through our mobile website or through our mobile applications. Assuming you have consented to our collection of location information from your mobile device, our mobile website and mobile app may collect such information even if you are not logged into them. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile tracking activities via their device settings.
2. How Do We Use The Information?
We use Personal Information for the following general purposes: to respond to your inquiries about our properties or services, to respond to any comments or feedback you submit, to send you press releases, updates, or other general information about our properties or services, and to meet any applicable legal and regulatory requirements. We also use your Personal Information for legitimate business purposes in connection with our relationship with you as your landlord.
3. Do We Disclose The Information to Outside Parties?
We use non-personally identifiable information in the aggregate so that we can improve the Site and for business and administrative purposes. We may use or share such aggregated data with third parties for any purpose.
We may include links on our Site to third party websites that have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked websites.
4. Updating Personal Information and Preferences
If you have provided us with Personal Information and would like to change, correct, or request access to your Personal Information, or would like to opt out of receiving e-mail or other communications from us, you may do so by e-mailing us at [email protected].
5. Steps We Take To Safeguard Your Personal Information
We maintain reasonable administrative, physical, and technological measures to protect the confidentiality and security of Personal Information you submit on or through this Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your Personal Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. We retain your Personal Information, if provided by you through the Site, for as long as your inquiry is active (as determined by us) and for a reasonable time thereafter, or if applicable, for as long as you remain on our marketing list. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate, anonymous data previously collected and/or anonymize and aggregate your personal information.
We do not solicit any personal information from children under the age of 13. We encourage families to obtain additional information about safe use of the Internet at http://www.ftc.gov/kidzprivacy/.
7. Contact Us
Samuels & Associates
136 Brookline Avenue
Boston, MA 02215
8. Privacy Notice For California Residents
This Privacy Notice for California Residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to Contact Us.
a. Information We Collect
We collect the information described in What Information Do We Collect? available to us through your use of the Site. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include publicly available information from government records or deidentified or aggregated consumer information.
We may have collected the following categories of Personal Information from users of our Site over the past 12 months:
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement|
Please visit What Information Do We Collect? for information on our sources for collection of Personal Information.
b. Use and Sharing of Personal Information
We do not sell your Personal Information. Please review How Do We Use The Information?And Do We Disclose The Information to Outside Parties? to see how we use and share your Personal Information.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
c. Sales of Personal Information
We do not sell your personal information. However, from time to time, we may share our list of contacts with third parties who are providing, sponsoring, or co-sponsoring events on our behalf or for their own purposes.
In the preceding 12 months, we shared the following categories of Personal Information about users of our Site to the following categories of third parties.
|Category||Examples||Category of Third Party to whom Personal Information is Disclosed|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name||May be shared with event organizers, sponsors or co-sponsors to promote Samuels, the organizer or sponsor, or any third party|
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
d. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you the requested information, which may include:
- 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 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 disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.
e. Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is 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 business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.
f. Exercising Access, Data Portability, and Deletion Rights
You have certain rights to access, update or correct your Personal Information as provided in Personal Information Sales Opt-Out and Opt-In Rights. In addition, to exercise the access, data portability, and deletion rights described in this Privacy Notice, please submit a verifiable consumer request to:
Samuels & Associates
136 Brookline Avenue
Boston, MA 02215
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you must mail to the above address a notarized power-of-attorney, identifying yourself in a verifiable manner, and designating with specificity the actions that your agent is authorized to perform, or information authorized to request, on your behalf. The power-of-attorney must be signed by you within 12 months of the date on which we receive the request.
You may make a verifiable consumer request for access or data portability only twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information and confirm that you are a California resident. 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.
g. Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your Personal Information.
For additional rights you may have relating to our collection or use of your Personal Information, please see Personal Information Sales Opt-Out and Opt-In Rights.
The CCPA allows businesses to offer consumers financial incentives for sharing Personal Information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their Personal Information. Where we offer these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s Personal Information.
i. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email or write to us at the Contact Us above.
9. EEA Residents
Our undertakings under this Notice are intended to be consistent with your rights under the General Data Protection Regulation 2016/679 (“GDPR”). The GDPR affords you rights that are in addition to those set forth above in this Notice. We will comply with the following additional rights under the GDPR, subject to its terms and conditions:
|Access||You have the right to access the following additional information about your Personal Information to determine that we are processing it lawfully: (i) the purpose of the processing; (ii) the categories of Personal Information; (iii) identification of the recipients and intended recipients of the Personal Information; and (iv) our source of the Personal Information.|
|Data Portability||If we have your Personal Information because of a contract that we entered into with you or because you have consented to providing us your Personal Information, you may request that we provide you with a digital file of the Personal Information that you have provided to us, which includes any records we have collected from observing your digital activities. We will provide you with such digital file if and in a manner compliant with GDPR.|
|Updates or Corrections||Subject to our separate confirmation, you may request that we update or correct the Personal Information that we have about you.|
|Objection to or Restriction on Processing||If you feel that our access to or our use of your Personal Information impacts your fundamental rights or freedoms, you may object to the processing of such Personal Information or restrict the processing of such data by contacting us through the information provided under Contact Us above. In some cases, we may have legitimate grounds to process such data that may override your rights or freedoms.|
|Erasure/Removal||You may request that we erase your Personal Information if it is determined that we do not have a legal basis for using it, you withdraw your consent to our processing, you object to the processing and we have no overriding legitimate interest, or if required by law.|
|Withdrawal of Consent||If we use your Personal Information in a manner that you have previously consented to, you may withdraw your consent by contacting us through the information provided under Contact Us above.|
|Unsubscribe or Modify Preferences||If at any time you prefer to receive less marketing or other information from us, you may modify your preferences or unsubscribe by contacting us through the information provided under Contact Us above.|
|Supervisory Authority||If you believe your rights regarding your Personal Information have been breached or if a breach has been inadequately addressed, you have the right to report to or file a complaint with any independent public authority which is established by a European Union member state pursuant to Article 51 of the General Data Protection Regulation.|
If you have further questions about your rights as summarized above, or any questions about the Personal Information that we collect and use, please do not hesitate to Contact Us.