Privacy Notice

Bolsa Retreat LLC  and our affiliates (collectively, “The Retreat,” “we,” or “us”) respect your privacy and are committed to protecting your Personal Information. This Global Privacy Notice describes the types of Personal Information we collect and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us about our privacy practices. Our privacy practices may vary in which we operate to reflect local practices and legal requirements, and specific privacy practices may apply to some of our products and services.

This Global Privacy Notice applies to the following websites and any associated Retreat Senior Living Community websites, products, services, and mobile applications (the “Services”). It does not apply to the collection and use of certain employment-related information.

When using our websites, you may choose to interact with features from third parties that operate independently from The Retreat such as social media widgets and links to third-party websites. The Retreat has no control over and is not responsible for the privacy practices of such third parties. This Global Privacy Notice does not apply to the extent The Retreat does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of these third parties.

Table of Contents

1. Types of Personal Information
2. Collection of Personal Information
3. Use of Personal Information
4. Disclosure of Personal Information
5. International Transfer of Personal Information
6. Security of Personal Information
7. Retention of Personal Information
8. Manage Your Personal Information
9. Global Policy Notice Changes
10. Contact Us

1. Types of Personal Information

“Personal Information” means any information relating to an identified or identifiable individual. Examples of Personal Information The Retreat may collect include:

• Payment information (credit card and other payment card information)
• Personal contact information (name, nickname, gender, mailing address, email address, phone number)
• Business information (office location, business contact information, department, job title/description, professional bio)
• Log-in credentials (username, password)
• Usage details (log-on activity, search terms, views, clicks, downloads, The Retreat-related preferences, lead submission information)
• Technical details (IP address, geolocation information, cookie/session IDs, authentication information, browser type/version, operating system/platform)
• Any other information you or other The Retreat customers, prospects or residents may upload or enter into the Services
• The Retreat may additionally collect information you submit when you create a lease as a landlord or complete a leasing application, such as move-in date, reference contacts, co-applicants, guarantors, pets, residence history, employment history, annual income, proof of income, driver’s license, vehicle information, Social Security Number, and date of birth
• The Retreat may additionally collect the type of transaction and the use, conditions, description, square meter, availability, and registration number of property from advertisers and photographs/images. The Retreat may additionally collect commercial preferences and contacts
• The Retreat may additionally collect purchase time frame, broker license number, desired business category and location, available capital, business cash flow, and other financial details
• The Retreat may additionally collect primary role in real estate, such as broker, business owner, investor, or appraiser, and broker license number
• The Retreat may additionally collect staff code

California Residents
We collect Personal Information as defined by the California Consumer Privacy Act, which is 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.

Personal Information does not include de-identified or aggregate information, publicly available information that is lawfully made available from federal, state, or local government records, and information covered by certain sector-specific privacy laws.

The Retreat has collected the following categories of Personal Information about consumers in the 12 months preceding the date Privacy Notice was last modified:

• Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security Number, or other similar identifiers)
• Categories of personal information described in California Civil Code §1798.80(e) (e.g., signature, phone number, bank account number, credit card number, debit card number, or other financial information)
• Protected classification characteristics under California or federal law
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information
• Geolocation data
• Professional or employment-related information
• Inferences drawn from other Personal Information (e.g., profile reflecting your preferences, characteristics, and behavior)

2. Collection of Personal Information

The Retreat may collect Personal Information using the following methods:

• Directly from you when you provide it to us (information you enter into web forms, subscription agreements, and contracts or submit to the Services)
• Through your participation in surveys, promotions, and contests
• The Retreat’s internal customer relationship management system and databases
• From third parties, such as analytics and email marketing service providers
• Researching or scraping public websites where permitted by the Terms of Use (company websites, search engines, social media)
• Automatically through tracking technologies (cookies, web beacons, log files), including over time and across third-party websites or other online services

For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see Use of Personal Information, our Cookie Policy, and Manage Your Personal Information.

Service-Specific

United States Listing Services
When you dial a phone number we publish for a listing, we or a service provider operating on our behalf may record the date, time and length of your call and the phone number from which the call originated, along with the call itself and any other information that may be captured. The types of Personal Information collected will depend on the nature of the submission or the features of the website used but could include your name, address, phone number, and/or email address.

The Retreat sales and customer service personnel and other Retreat representatives may collect Personal Information from you by email, phone, or meetings or events. The Retreat may additionally collect Personal Information from owners based on information from third-party sources, including, among others: (i) the reception/ concierge/farm manager/neighboring tenants; (ii) LinkedIn or other social networks (professional Facebook page, Twitter); (iii) the databases that can be accessed such as the Property Registry and the General Directorate; and (iv) the brochures of investment agents and lease conditions. Research scrapes some listings from landlords and agents to identify changes.

First name, last name, email address, and type of professional is required for us to create an account for you and sign you up to receive the Services. We will inform you at the point of collecting information from you whether you are required to provide this information to us.

In respect of each property advertised on the website, we will collect the details of the real estate agent that is advertising the property and the name of the individual real estate agent who should be contacted in case of inquiries. We collect this information from the applicable estate agent’s website. When completing a property inquiry, we will collect the name, email address, phone number, subject line, and detailed description of the inquiry.

Children Under 13
The Retreat website is not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If you are under 16, do not use or provide any information on this website or through any of its features, register, or make any purchases. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete it. If you believe we might have any information from or about a child under 13, please contact us.

California Residents
The Retreat collects Personal Information from the following categories of sources:

• Directly and indirectly from you
• Other customers
• Service providers
• Consumer reporting agencies
• Companies with public websites
• Government entities

European Economic Area (EEA) Residents
Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but will notify you first.

3. Use of Personal Information

We may use your Personal Information for the following purposes:

• Communicating with you
• Providing you with the Services
• Authenticating use, detecting potential fraudulent use, and otherwise maintaining the security of the Services
• Developing, testing, improving, and demonstrating the Services
• Creating and maintaining a customer relationship management system, member directories, and invitation lists for The Retreat events
• Carrying out our legal and contractual obligations and enforcing our rights, including billing and payment processing
• Anonymizing and aggregating information for analytics and reporting
• Advertising, marketing, and selling the Services, including linking together or merging Personal Information with other Personal Information so that we may better understand your needs and inform you about our Services and those of our partners
• Short-term transient use
• For any other purpose with your consent

Service-Specific

United States Listing Services
You may have the ability to share certain pages or content with third parties. If you use the “share” functionality, you will be asked for your email address and the recipient’s email address, and you may enter an optional message. We do not use the email addresses stored through the “share” functionality for any purpose other than sending a one-time email.

When you use our mobile application or our website, your location may be obtained from the mobile device or the network, or directly from you, and may be used to search for information you may need, including local searches for rental properties. When we execute such searches on your behalf, we do not transfer your identity or Personal Information to third parties other than the rental property owners or managers. This information is not used to create a profile about you or your activities. Your location is only stored in the application if you save your location (rental property) searches, and you may delete this information by clearing your search history. Location coordinates are shared with our geocoding service providers (such as Google Maps) only to perform the task of providing maps and directions at your request. No location information is shared with any third parties for marketing purposes. Our application does not interact or share information with any other applications installed on your mobile device.

If you send an email using the “Email a Listing to a Friend” service to a third-party email address that is not registered in our system, we do not use that email address for any purpose other than to send your email, and for us to automatically send the third party a one-time email inviting him or her to visit the website. We store this information for the sole purpose of sending this one-time email and for tracking the success of our referral program.

Online Advertising
The Retreat and third parties may use cookies and other tracking technologies to collect information, including Personal Information, to help us target content to you on the Services or elsewhere. This information may be associated with other information or combined with information from other sources, including information these third parties might track about your online activities over time and across the Internet. Third parties use this information to provide interest-based display advertising and retargeting on our behalf, which may include placing our advertisements on other websites you visit, including your social media accounts, or matching a cookie or device ID to your email address so we can send you promotional emails that may be of interest to you.

To make informed choices about targeted advertising, see Manage Your Personal Information.

Automated Decision-Making
We may use an automated process to identify properties that may be of particular interest to you and to bring these to your attention. We may do this by profiling your activity when using the Services. This profiling takes place based on properties you browse, searches you conduct, and your location. It helps us to understand what sort of properties you are interested in and to categorize your activity to help us determine the Services you require. For information about how users based in the European Union can object to our automated decision-making, see Manage Your Personal Information.

European Economic Area (EEA)
We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:

Consent
We may obtain your consent to process your Personal Information in certain circumstances, which may include when we send you relevant marketing, you elect to receive information from us, or you contact us to register an interest in our Services or company. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about our Services (see below).

Performance of a Contract
We rely on this lawful processing ground when we process your Personal Information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with the provision of our Services to you and the management of our relationships with third parties.

Compliance with a Legal Obligation
We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.

Legitimate Interests
We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with marketing information or other information in relation to our Services which we believe may interest you.

If you wish to have more information regarding the legitimate interests assessments we have conducted in order to reach these conclusions, please Contact Us.

4. Disclosure of Personal Information

We may disclose Personal Information:

• To affiliates and other entities within The Retreat’s group of companies, distribution partners, other Retreat residents, and service providers
• To third parties when you use a third-party feature in our Services
• To enforce or apply our Terms of Use and other agreements or comply with any court order, law, or legal process, including government or regulatory requests
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Retreat’s assets
• If we believe it is necessary to protect the rights, property, or safety of The Retreat or others
• For any other purpose disclosed by us when you provide Personal Information
• With your consent, such as when you choose to provide your information to third parties

We may also disclose de-identified information without restriction. Note that if you make any Personal Information publicly available on the Services, anyone may see and use such information.

Service-Specific

United States Listing Services
The Retreat may share information in the following areas on the Services: Marketing Center, Email Alerts and Professional Directory. When a customer enters a sale or lease listing in the Marketing Center, listing contact information is also entered. During this process, the listing submitter is able to view other Retreat customers’ contact information when he or she adds another contact to the listing. In addition, customers can view contact information (name, email and phone number) when viewing a property listing profile.

The Services may also allow users to share contact information with one another via email alerts. With email alerts, users can save their property search criteria to have information about properties that match the specified criteria emailed to them. When selecting this service, users are given the option of releasing their contact information to other users who have property listings that match their criteria. This contact information is then shared with the users who have property listings that match the buying or leasing criteria.

Apartments
it is important to note that any information you choose to include in your listing may be made publicly available via the website and other media in which the website listings are published, including affiliate sites. For example, you may include a phone number and/or an email address to allow users to contact you regarding your listing. As such, you may receive unsolicited phone calls and emails from third parties, even after your listing is no longer on the website. Except for required information, you should not include any contact or other information in your listing that you do not want other parties to see or use. If you wish to access, verify the accuracy of, or change any information in your advertisement, you can use this interface.

When applying for a lease, your redacted Social security number and date of birth are shared with TransUnion for purposes of a background check.

The Retreat allows users to opt in to a Prospect List. Users who opt in agree to have their name, role and phone number shared with sellers who have matching businesses.

Service Providers
The Retreat retains third party service providers to assist us in our business. For example, we use service providers to assist with analytics, email marketing, payment processing, customer relationship management, and IT infrastructure and support. The Retreat may permit these affiliates and service providers to access your Personal Information in order to assist us in providing services; however, we contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

California Residents
The Retreat shares Personal Information with the following categories of third parties and has disclosed the following categories of Personal Information for a business or commercial purpose in the 12 months preceding the date this Global Privacy notice was last modified:

The Retreat may also sell certain Personal Information. In the 12 months preceding the date this Privacy Notice was last modified, The Retreat sold:

• Identifiers (e.g., IP address and other online identifiers) and Internet or other electronic network activity information to advertising providers for the purpose of advertising our Services.

5. International Transfer of Personal Information

We may transfer your Personal Information to the United States, where we are headquartered, and to other countries which may not have the same privacy laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Global Privacy Notice, or as otherwise disclosed to you.

European Economic Area (EEA) Residents
If you live in the EEA, we may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as an intra-company agreement or the European Commission’s Standard Contractual Clauses or their equivalent under applicable law, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable.

You may contact us to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.

6. Security of Personal Information

The Retreat implements security safeguards to protect your Personal Information.

We take steps to secure Personal Information through administrative, technical and physical safeguards designed to protect against the risk of accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we encrypt payment card information in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and store sensitive information such as biometric and geolocation data on servers located in the United States with access limited to authorized employees.

Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

7. Retention of Personal Information

The Retreat generally retains records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements.

When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements.

Because we maintain our applications and websites to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

8. Manage Your Personal Information

You may manage your Personal Information by making certain choices. If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information if it is within your online account by logging in at any time or Contact Us. You may also have additional rights detailed below depending on where you live. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.

Direct Marketing Opt-Out
If you no longer wish to receive direct marketing emails from The Retreat, you may click the “Unsubscribe” link in an email at any time to stop receiving emails for that particular subject. Depending on the Services, you may also be able to manage notification preferences in your account. Note that The Retreat may still contact you in connection with providing you Services you have requested from us.

Tracking/Online Advertising Opt-Out
You may disable or delete browser cookies through your browser settings. Cookies are generally easy to disable or delete, but the method varies between browsers. To learn how you can manage Flash cookies, visit Adobe’s Flash player settings page. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our websites may not work properly.

You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative’s (NAI) opt-out page and the Digital Advertising Alliance’s (DAA) opt-out page and in the EEA by visiting The Programme’s opt-out page.

California Residents
If you live in California, you have the right to: (1) request that The Retreat disclose what Personal Information we collect, use, disclose, and sell; (2) request deletion of Personal Information; (3) opt-out of the sale of Personal Information; and (4) not receive discriminatory treatment by The Retreat for exercising these rights.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may Contact Us by email with proof of your written and signed permission to do so. Note that The Retreat may also require you to verify your identity and confirm that you gave permission.

Requests to Know
You have the right to request that we disclose the following information:

• Specific pieces of Personal Information The Retreat has collected about you;
• Categories of Personal Information The Retreat has collected about you, disclosed about you for a business purpose, or sold;
• Categories of sources from which the Personal Information is collected;
• Categories of third parties with whom The Retreat shares or to whom The Retreat sells Personal Information; and
• The business or commercial purpose for collecting and selling Personal Information.

To make such a request, please Contact Us by email or call us. In order to verify your request, The Retreat may require you to provide additional information to confirm the identity of the consumer.

Requests to Delete
You have the right to request that we delete Personal Information about you that we collected and maintain, subject to certain exceptions. To make such a request, please Contact Us by email, or call us. In order to verify your request, The Retreat may require you to provide additional information to confirm the identity of the consumer. Once we verify your request, we will delete and direct our service providers to delete your Personal Information, unless an exception applies.

Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your Personal Information. To make such a request, please Contact Us by email or visit Do Not Sell My Personal Information. To opt-out of The Retreat sharing your Personal Information with third parties to advertise our Services, please additionally manage Tracking/Online Advertising Opt-Out privacy controls.

California residents may also have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please Contact Us.

Nevada Residents
Nevada residents may have the right to opt-out of the sale of Personal Information we have collected or will collect. To make such a request, please Contact Us.

European Economic Area (EEA) Residents
If you live in the EEA, you may have the right to (1) request access to, rectification, or erasure of your Personal Information or restrict the processing of your Personal Information; (2) object to processing; (3) data portability (receive and transfer your Personal Information); (4) lodge a complaint with a supervisory authority; and, (5) where processing of your Personal Information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of Personal Information that occurred before you withdraw consent. To make such a request, please Contact Us.

9. Global Privacy Notice Changes

This Global Privacy Notice may be updated periodically to reflect changes in our privacy practices.

We will post changes on this page and identify the date the privacy notice was last revised at the top of the page. If we make material changes to our privacy practices, we will notify you through a notice on the home page of the website covered by this Privacy Notice. If a material change will apply to Personal Information we have already collected, we will additionally seek your affirmative consent.

10. Contact Us
We have appointed a Privacy Officer and Data Protection Officer to investigate and respond to privacy issues and to be accountable for our compliance with this Global Privacy Notice.

United States Residents
In order to properly respond to your questions or requests, concerns about our services, please email: [email protected].

Or write to:
The Retreat at Midway City
7880 Bolsa Avenue
Midway City, CA 92655

You may also make a complaint to your local data protection authority.