California privacy policy

Last Revised on: 9/20/2022

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in Clear Investment Group, LLC’s primary privacy policy.  Clear Investment Group, LLC (“CIG,” “we,” “us,” or “our”) has adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to CIG’s primary privacy policy, including the following terms:

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  It does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; or certain information and activities governed by existing state and federal laws, which include the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a Third Party for monetary or other valuable consideration.

“Service Provider” means a for-profit entity, that processes information on our behalf and to which we disclose Personal Information for a business purpose pursuant to a written contract.

“Third Party” means a person or entity, other than a Service Provider, that collects Personal Information on our behalf or receives it from us.

The Personal Information We Collect and Disclose

The information below describes the categories of Personal Information we may collect, examples of the type of Personal Information in each category, and the types of parties with whom Personal Information is shared.  We disclose certain Personal Information to Service Providers and Third Parties for a business purpose. This information covers the past 12 months.

Personal Information Categories

• Identifiers: name, user/account name, postal address, email address, contact information, internet protocol address, internet cookie identification number, social security number, taxpayer identification number, bank account/credit card number, driver’s license number, passport number, date of birth, picture, resident identification number, device identification number, emergency contact details.
• Personal Information categories listed in California Civil Code § 1798.80(e): name, signature, social security number, address, telephone number, passport number, insurance policy number, education, employment, employment history, financial information, medical or health insurance information.
• Protected classification characteristics under California or federal law: age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status.
• Commercial Information: records of products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, credit history, lease information, rental history, rent amount.
• Internet or other electronic network activity information: browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, internet postings.
• Sensory data: pictures, videos, and sounds.
• Employment or other professional information: current job and past job history, job title, and, in the case of prospective and current residents or tenants, pay history, income.

We will not collect a category of Personal Information not listed above.

Parties with Whom We Share Personal Information

• Contracted Service Providers who provide IT, system administration and hosting, payment processing, research and analytics, marketing and data enrichment for the purposes set forth above.
• Our affiliates as required based on the affiliate’s relationship with you or where sharing of data is necessary to fulfill a request you have submitted.
• Sponsors of events, contests and promotions in which you have expressed interest or for which you have registered.
• Third Party advertising networks and websites that enable CIG to market and advertise on Third Party platforms and sites.
• Third Party business partners that may contact you about their services.
• Professional advisors such as lawyers, bankers, auditors and insurers.
• Third Parties who are part of a business transition such as a merger, reorganization or the sale of all or a part of our business.

Personal Information of Minors

We do not knowingly collect the Personal Information of individuals under the age of 16; nor do we sell the Personal Information of minors.

Right to Opt-Out

You have the right to request that we not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA, we may subsequently inform you that you need to opt-in if it is required to complete a transaction that you initiate.

Disclosure of Data Collection and Sharing Practices

You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months.  You may make such a request up to twice in a 12-month span.  Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements.  We will notify you following submission of your request if this is the case.

If you would like to request: (1) the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of Third Parties with whom we have shared that Personal Information; and/or (4) the business purpose for collecting that Personal Information, call (312) 883-5480.

Deletion of Your Personal Information

You have the right to request that we delete certain Personal Information that we have collected.  Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements.  We will notify you following submission of your request if this is the case.

CIG generally collects information in connection with leasing apartments to residents to facilitate the operation and security of a community.  In order to comply with legal obligations, much of this personal information is exempt from deletion under the CCPA.  We may not delete some or all personal information if it is necessary for us, or our service providers or affiliates, such as to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of CIG’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer,
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
• Identify and repair errors that impair existing intended functionality,
• Exercise free speech, ensure the right of another consumer 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 pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code,
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with CIG,
• Comply with a legal obligation, or
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Verification Process

To help maintain security of resident information, when you make one of the above requests, we will ask that you provide a few pieces of information about yourself. We will only use the information you provide to verify your identity and the Personal Information that is relevant to your request. We will retain a record of your request, but we will not retain the information you provide beyond the period of time necessary to respond to your request. Verification of identity will be completed via phone, email or postal mail correspondence.

When you make a request, you will be asked to provide:

• Name:
• Mailing address:
• Telephone number:
• Email address:
• Community:
• Resident or Applicant:
• If Resident
• Unit number:
• Do you still live at this community?
• Proof of residence in California at the time we collected Personal Information

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. 

Pursuant to the CCPA:

• Only an individual with power of attorney, or a business entity or natural person registered with the California Secretary of State, may act as an authorized agent.
• We may require that you or the authorized agent do the following:
  • Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.
  • We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
  • Verify your identity with us directly. This does not apply if you have provided a valid power of attorney to the authorized agent.

Additional Information

If you would like additional information regarding our California Privacy Policy, you can email IR@clearinvestgroup.com

Non-Discrimination

We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy.  Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

Changes to Our California Privacy Policy

CIG reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.