Privacy Policy

HAWTHORNE RESIDENTIAL ACQUISITIONS LLC

PRIVACY POLICY

Last Modified: October 26,2021

Introduction

[Hawthorne Residential Acquisitions LLC] (“Hawthorne” or “we”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.HRPInvestments.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On the Website.
  • In email, text, and other electronic messages between you and the Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Hawthorne or any third party (including our affiliates and subsidiaries), unless this policy is linked; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@hrpliving.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“personal information“);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website, such as the “reach out” feature. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We do not use these technologies to collect information or track your activities across different websites or other online services, whether you configure your browser’s Do Not Track feature or otherwise.

The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Speed up your searches.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you direct your browser to our Website.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Google Analytics.  Hawthorne uses Google Analytics to monitor and identify trends and the Website’s usage statistics. Google Analytics employs cookies that are stored on your computer. The information generated by these cookies, such as time, place and frequency of your visits to our Website, including your IP address, is transmitted to a Google location in the US for storage.  Google uses this information for purposes of evaluating your use of the Website and for compiling reports on the Website’s activity for Hawthorne. Google may also transfer this information to third parties if required to do so by law or where such third parties process data on Google’s behalf. You can prevent Google’s cookies from being installed on your computer by adjusting the settings on your browser (as noted above). However, by doing so, you may not be able to access certain parts of our Website. Information collected by Google is subject to Google’s Privacy Policy, which can be found here.

Third-Party Use of Cookies and Other Tracking Technologies

Some websites linked on the Website are served by third parties or affiliates of Hawthorne. These third parties and affiliates may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use their website. The information they collect may be associated with any personal information you provide them, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control our affiliates’ or any third parties’ tracking technologies or how they may be used. If you have any questions about any website linked from this Website, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To engage with prospective residents.
  • To provide you with information that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about real estate and related services that may be of interest to you. If you do not want us to use your information in this way, please contact us at privacy@hrpliving.com. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We do not sell your personal information. However, we may disclose aggregated information about users of our Website and information that does not identify any individual without restriction.

We may also disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • 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 Hawthorne’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hawthorne about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Hawthorne, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or our affiliates’ real estate or services, you can opt-out at any other time by sending us an email stating your request to privacy@hrpliving.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to a response by Hawthorne to any request for information.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@hrpliving.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Accessing and Correcting Your Information

You can send us an email at privacy@hrpliving.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

This section applies to Personal Information that Hawthorne handles as a “business” (as defined under the California Consumer Privacy Act of 2018 (“CCPA“)) if you are a California resident. California residents are protected as “consumers” by the CCPA with respect to Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA, and does not include information exempted from the scope of the CCPA. Personal Information does not include publicly available information from governmental records, de-identified or aggregated consumer information, or other information excluded or exempted from the CCPA’s scope. Hawthorne does not “sell” (as such term is defined in the CCPA) Personal Information collected from you (and will not sell your Personal Information without providing you notice of this change in the treatment of your Personal Information and a right to opt-out). Hawthorne does not collect or sell the Personal Information of children under 16 years of age.

Your California privacy rights

California residents have the following rights under the CCPA:

  • Information.  To request the following information about how Hawthorne collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that Hawthorne has collected.
    • The categories of sources from which Hawthorne collected Personal Information.
    • The business or commercial purpose for collecting Personal Information.
    • The categories of third parties with whom Hawthorne shares Personal Information.
    • Whether Hawthorne has disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
  • Access.  To request a copy of the Personal Information that Hawthorne has collected about you during the past 12 months.
  • Deletion.  To request that Hawthorne delete the Personal Information that it has collected from you.
  • Nondiscrimination.  To exercise the rights described above free from discrimination as provided in the CCPA.

How to Exercise your Rights

To exercise your rights described above, please submit a request to Hawthorne at privacy@hrpliving.com with “California Consumer Request” in the subject line. Only you, or someone legally authorized to act on your behalf, may make a request with respect to your Personal Information. Hawthorne will need to verify your identity to process request and Hawthorne reserves the right to confirm your California residency.  Government identification may be required.  If you wish to designate an authorized agent to make a request on your behalf, Hawthorne will need to verify both your and your agent’s identities and your agent must provide a valid power of attorney or other proof of authority acceptable to Hawthorne in Hawthorne’s reasonable discretion.

Hawthorne will acknowledge receipt of your request within 10 days and will endeavor to respond within 45 days of receipt of your request.  If Hawthorne requires more time (up to an additional 45 days), Hawthorne will notify you of its need for additional time. Hawthorne cannot process your request if you do not provide sufficient detail to allow Hawthorne to understand, evaluate and respond to your request. In certain cases, Hawthorne may be required or permitted by law to deny your request.  You may make a request for disclosure of Hawthorne’s information collection practices, the information Hawthorne has collected about you or Hawthorne’s information sharing practices up to twice within a 12-month period.  For requests for a copy of the Personal Information Hawthorne has collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily usable, including by mailing you a paper copy or sending an electronic copy to your email address if you have an email address on file with Hawthorne.

For deletion requests, please understand that California law permits Hawthorne to retain certain information and not delete it under certain circumstances.  For example, Hawthorne is not required to comply with a deletion request if the information is necessary to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; and to comply with legal obligations.  If Hawthorne receives such a request from you, Hawthorne will notify any of Hawthorne’s service providers to delete your information as well.

Hawthorne will not discriminate against you as a result of your exercise of any of your CCPA rights.

Collection, Use and Disclosure of Personal Information

The categories of Personal Information that Hawthorne collects and the sources from which Hawthorne collects them are described above in Collection of Information.  These categories include identifiers, personal information, geolocation data, and internet or other similar network activity information.  The business and commercial purposes for which Hawthorne uses Personal Information and the third parties with whom Hawthorne shares Personal Information are described are described above in How We Use Your Information and Disclosure of Your Information. 

General Data Protection Regulation

If you are a resident of the European Union (“EU“), Hawthorne will process your personal information in compliance with the EU General Data Protection Regulation (“GDPR“).  For information submitted through our Website, Hawthorne is the data controller, as defined under GDPR.  In accordance with GDPR, you, as a data subject, will be accorded with any applicable rights, which may include the following:

  • right of confirmation;
  • right of access;
  • right to recertification;
  • right to erasure;
  • right of restriction of processing;
  • right to data portability;
  • right to object;
  • right to withdraw data protection consent; and
  • right to lodge a complaint with a supervisory authority.

If you wish to exercise any of the rights set out above, please send a written request to Hawthorne at privacy@hrpliving.com. Hawthorne may need to request specific information from you to confirm your identity and ensure your right to access your personal information (or to exercise any other right listed above). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

privacy@hrpliving.com.