Last Revised on: 11/3/2021
Definitions Specific to this Policy
“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 BH 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.
If you would like to request that we not sell your Personal Information, click here or call (888) 717-0717. The preceding link will take you to a form that you can complete and submit to make a request for information that we will then verify.
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, click here or call (888) 717-0717. The preceding link will take you to a form that you can complete and submit to make a request for information that we will then verify.
If you would like to request the specific pieces of Personal Information we collected about you, click here or call (888) 717-0717. The link will take you to a form that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
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.
BH 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 BH’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 BH,
- 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.
If you would like to request that we delete your non-exempt Personal Information pursuant to the requirements of the CCPA, click here or call (888) 717-0717. The preceding link will take you to a form that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
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:
- Mailing address:
- Telephone number:
- Email address:
- 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
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.
BH Management Services, LLC
Attn: Consumer Privacy
400 Locust St., Suite 790
Des Moines, IA 50309