California Privacy Notice

Updated and Effective as of: November 23, 2020.

This Notice supplements the Privacy Policy of OPVHHJV LLC, d/b/a Pathlight Property Management (together with its affiliates, "Pathlight") and applies only to California consumers.

This California Privacy Notice sets forth the disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act ("CCPA").

Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

PERSONAL INFORMATION PATHLIGHT COLLECTS

The CCPA defines "Personal Information" as 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.

The Personal Information we collect about you will depend upon how you use our Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may also collect and/or use additional types of information, and will do so after providing notice and obtaining your consent to the extent such notice and consent is required by the CCPA.

Category of Personal Information Collected	Categories of Sources from which the Information was Collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose	Categories of Third Parties to Whom this Type of Personal Information is Sold
Identifiers This category includes information such as name, contact information, and online or device identifiers.	We may collect this type of information from: Consumer, Cookies and Tracking Technologies, Third Party Service Providers, Third party social media companies, Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners, Third party data resellers.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Providing you with our newsletter and/or other marketing materials or other communication, Analytics for business reporting and providing personalized services, Allowing you to participate in polls, sweepstakes, contests, or promotions or activities, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third parties who deliver our communications, Third parties we partner with for contests, sweepstakes, or promotions, Third party advertising and analytics companies, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, Third parties or affiliated companies when you agree to or request that we share your information with them, Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).	Third party advertising business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances. We may share information with third parties with whom we have a relationship, such as through a referral program, and some of this sharing may be considered a sale under CCPA.
Any categories of personal information described in subdivision (e) of Section 1798.80 This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as “personal” under this California law.	We may collect this type of information from: Consumer, Cookies and Tracking Technologies, Third Party Service Providers, Third party social media companies, Third party business partners, such as joint marketing partners, Third party data resellers.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Providing you with our newsletter and/or other marketing materials or other communications, Analytics for business reporting and providing personalized services, Allowing you to participate in polls, sweepstakes, contests, or promotions or activities Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third parties who deliver our communications, Third parties we partner with for contests, sweepstakes, or promotions, Third party advertising and analytics companies, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, Third parties or affiliated companies when you agree to or request that we share your information with them, Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).	We may share information with third parties with whom we have a relationship, such as through a referral program, and some of this sharing may be considered a sale under CCPA. Third party advertising, analytics, and similar business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.
Characteristics of protected classifications under California or federal law This category includes information such as age, sex (including gender), and marital status.	We may collect this type of information from: Consumer, Third Party Service Providers, Third party business partners.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Analytics for business reporting and providing personalized services, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, Third parties or affiliated companies when you agree to or request that we share your information with them, Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).
Commercial information This category includes, for example, payment information you provide for goods, services, customer service records, and information about the products you have purchased.	We may collect this type of information from: Consumer, Third Party Service Providers, Third party business partners.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Analytics for business reporting and providing personalized services, Allowing you to participate in polls, sweepstakes, contests, or promotions or activities, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, such as those who help us process transactions and deliver our communications, Third parties we partner with for contests, sweepstakes, or promotions, Third party advertising and analytics companies, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, Third parties or affiliated companies when you agree to or request that we share your information with them, Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).	We may share information with third parties with whom we have a relationship, such as through a referral program, and some of this sharing may be considered a sale under CCPA.
Internet or other electronic network activity information This category includes information about the web browser and operating system you are using, the website or ad that referred you to our Services, areas of the Sites that you visited, and terms entered into a search engine that led you to the Sites.	We may collect this type of information from: Consumer, Cookies and Tracking Technologies, Third Party Service Providers, Third party social media companies, Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners, Third party data resellers.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Analytics for business reporting and providing personalized services, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third party advertising and analytics companies, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, Third parties or affiliated companies when you agree to or request that we share your information with them, Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).	Third party advertising, analytics, and similar business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.
Audio, electronic, visual, thermal, olfactory, or similar information This category includes, for example, images, video, or audio recordings.	We may collect this type of information from: Consumer, Cookies and Tracking Technologies, Third Party Service Providers.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition.
Inferences drawn from any of the information identified above to create a profile about a consumer These inferences may relate to your perceived interests, preferences, characteristics, or behavior.	We may collect this type of information from: Consumer, Cookies and Tracking Technologies, Third Party Service Providers, Third party social media companies, Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners, Third party data resellers.	We may use this type of information for: Providing the functionality of the Sites and fulfilling your requests, Providing customer service, Analytics for business reporting and providing personalized services, Accomplishing our business purposes as described in detail in our privacy policy.	We may disclose this type of information to: Service Providers, Third parties we partner with for contests, sweepstakes, or promotions, Third party advertising and analytics companies, Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition. Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).	We may share information with third parties with whom we have a relationship, such as through a referral program, and some of this sharing may be considered a sale under CCPA. Third party advertising, analytics, and similar business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.

EXERCISING YOUR CALIFORNIA ACCESS, DELETION, AND DO-NOT-SELL RIGHTS

California consumers have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”); (2) that we delete the Personal Information we have collected from you (“Right to Delete”); or (3) the right to opt-out from the sale of Personal Information, all subject to exceptions set forth in the CCPA. More information on each of these rights is below.

Agents

If you are an agent submitting a request on a consumer’s behalf, you may submit a request as instructed below, and under “Request Details”, please indicate that you are an authorized agent and provide the requested pieces of information associated with the individual who is the subject of the request. We will ask you to provide a declaration signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that the agent is authorized to act on your behalf, we may deny the request.

How to Make a Request to Know or Request to Delete

If you are a California consumer and would like to request information about the Personal Information, we have collected about you in the prior 12 months or request that we delete information we have collected about you, please complete this form. You may also call us toll-free at 1-855-921-0222.

Verifying Requests

In order to verify your identity, we will request that you provide the following pieces of information when you contact us with your request: your first and last name and email address that you have previously provided to Pathlight. We may ask for additional information as needed to fully verify your request.

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request

Other Important Information:

Right to Know

In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Right to Delete

To ensure that we do not delete your personal information in response to a fraudulent request, once you submit the request, we will follow up to confirm that you want your information to be deleted. Note that you may also delete certain Personal Information you have provided to us through your online account.

RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION

The CCPA also provides a right to California consumers to request to opt-out of the sale of Personal Information. Pathlight does not sell your personal information for monetary compensation, but we may share information with third parties with whom we have a relationship, such as through a referral program, some of which may be considered a sale under the CCPA.

If you are a California resident and would like to opt out of the sale of Personal Information now or in the future, please submit your request by completing this form. You may also call us toll-free at 1-855-921-0222.

Also as discussed above, certain third-party analytics and advertising companies may collect data from visitors to our Sites, including to better serve you more relevant advertisements. Click here to open our Cookie Preferences tool and opt out of certain third-party collection that may be considered “sales” under the CCPA by toggling off the switch next to “Sale of Personal Data”.

The Digital Advertising Alliance (“DAA”) offers tools for California consumers to send requests under the CCPA to opt out of the sale of personal information by some or all of the participating companies (privacyrights.info). You can also limit this type of tracking through industry opt-outs (networkadvertising.org and aboutads.info) and by limiting ad tracking on your mobile device. Note that these are cookie-based opt-outs. If you disable your cookies or upgrade your browser after opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers. You can limit this type of tracking on mobile devices by using the limiting ad tracking features within the operating system of your mobile device or using DAA’s AppChoices application, described here.

You may also be able to limit the access these third parties have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies.

USERS YOUNGER THAN 16

Pathlight does not knowingly sell Personal Information of minors younger than 16 years of age.

RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHTS

California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.

CONTACT FOR MORE INFORMATION

You can contact us for more information by emailing consumerprivacy@pathlightmgt.com.