Last updated: 08/06/2021

1. Introduction:

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Specific Privacy Notice”) supplements the information contained in the Privacy Policy of The I Grace I-Grace, Commissioned Private Residences, Inc. and all its related entities (collectively “I-Grace,” “we,” or “us”) and our affiliate websites, subdomains, mobile versions and any associated applications (collectively, the “Site”). This California Specific Privacy Notice shall govern I-Grace’s data collection and usage regarding California residents, including but not limited to, offline and online. 

Any terms defined in the California Consumer Privacy Act (“CCPA”) have the same meaning when used in this California Specific Privacy Notice. California residents with disabilities may access this notice in an alternative format by emailing us at (info@igrace.com).

I-Grace will continue to revise our California Specific Privacy Notice to reflect the development of the CCPA and our understanding as to how it relates to our data practices.

2. Children:

Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request Personal Information from anyone under the age of 13 without requesting parental consent. NOTICE: Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting children’s privacy online.

If we become aware that you are under the age of Majority and are attempting to or have submitted Personal Information via the Site, we will not accept such information and we will take steps to remove such information from our records. This may involve us having to access and verify your age and other relevant details.

3. Information We May Collect From You:

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, email address, unique personal or online identifier,IP address, account name, Social Security number driver’s license number, passport number, date of birth or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Physiological, behavioral and biological characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity or other identifier or identifying information, such as, fingerprints, or and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.	YES
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

 

4. What Personal Information Do We Collect About You, For What Purpose And On What Ground We Process It:

• User Requests. We capture Personal Information when users send us questions or comments via e-mail or via our contact form such as your name, email address and phone number. Personal Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. 

• Communications. We may use your Personal Information to contact you with newsletters, marketing or promotional materials from I-Grace. You may unsubscribe from these communications by following the instructions contained within the communication or emailing us at: info@igrace.com. Please note that due to marketing production schedules you may receive messages already in production.

• Social Media. We may also obtain your Personal Information through your use of social media such as Facebook, Instagram, LinkedIn or YouTube, depending on your settings or the privacy policies of these social media services. To change your settings on these services, please refer to their respective privacy notices.

• Careers. We may post job openings and opportunities on the Site. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the Personal Information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with I-Grace.

• Log Data. Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this.

5. We Share Information With:

Personal Information may also be shared under the following limited circumstances:

• With Service Providers: In some cases, we will employ or work with service providers such as marketing or security consultants, temporary workers, third-party software developers, or outsourcers to complete a business process or provide a service on our behalf. For example, we may use service providers to send e-mails on our behalf. While this may require that we share some Personal Information, we will only share Personal Information that the service provider must have to perform the requested services.

• For Legal Reasons/ Security: We reserve the right to release Personal Information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so; (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or our safety, the safety of our users, or the safety of others; or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the Privacy Policy.

• In case of a sale of a business: Personal Information may be transferred in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of our business, or its subsidiaries.

• Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer that aggregated information to third-parties.

6. How We Use Cookies:

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

7. Your Right to Access to Specific Information and Data Portability Rights:

You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of Personal Information we collected about you.
2. The categories of sources for the Personal Information we collected about you.
3. Our business or commercial purpose for collecting or selling that Personal Information.
4. The categories of third parties with whom we share that Personal Information.
5. The specific pieces of Personal Information we collected about you (also called a data portability request).
6. If we sold or disclosed your Personal Information for a business purpose, a separate list disclosing:
   • sales, identifying the Personal Information categories that each category of recipient purchased; and
   • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
     • Please note that we do not sell your Personal Information.

8. Deletion Request Rights:

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

You may object to I-Grace using your Personal Information for the above purposes at any time by emailing us at: info@igrace.com. If you do so, I-Grace will cease using your Personal Information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such Personal Information is permitted to be used by I-Grace for another purpose set out in this California Specific Privacy Notice or I-Grace determines and demonstrates a compelling legitimate interest to continue in processing your Personal Information.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

9. Exercising Access, Data Portability and Deletion Rights:

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

1. Calling us at 800-770-1807; or
2. Emailing us at info@igrace.com.  

Regarding our marketing materials, you may also withdraw your consent at any time by following the instructions contained within the communication or emailing us at: info@igrace.com.  If an individual withdraws their consent to receiving marketing emails, we will still be able to send them essential service communications that are necessary for the performance of our services. 

10. Authorized Agents:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information if you provide the authorized agent written permission signed by you or pursuant to a valid Power of Attorney. You may also make a verifiable consumer request on behalf of your minor child. When you use an authorized agent to submit a request, we may require you to:

1. Provide the authorized agent signed permission to do so. 
2. Verify their own identity directly with the business.
3. Directly confirm with the business that they provided the authorized agent permission to submit the request. 

11. Verifiable Consumer Requests:

The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.

2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

12. Response Timing and Format:

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

13. Sale of Personal Information:

We do not sell your Personal Information.  

14. Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you services.
2. Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of services.
4. Suggest that you may receive a different price or rate for services or a different level or quality of services.

15. Changes to This California Specific Privacy Notice:

We may, in our sole discretion, modify or revise this California Specific Privacy Notice at any time.  Such changes or updates are effective immediately after we give notice of the change or update, which we may do so by revising the Last Revised date at the top of the California Specific Privacy Notice or by otherwise posting on the Site, by email, conventional mail and/or by any other means that provides reasonable notice.  If you are subscribed to one of our mailings, you must provide us with your correct email address and make sure that email from us is not filtered from your inbox by your ISP or email software. You agree that your use of the Site, after the date such notice is posted, means that you accept and agree to be bound by such modifications or revisions to the California Specific Privacy Notice.  You agree that we shall not be liable to you for any damages that might result from any changes to this California Specific Privacy Notice, if any.

16. Contact Us:

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to info@igrace.com.