Privacy Statement

INTRODUCTION

This Privacy Policy is dated and effective January 1, 2021

Carr Properties [Carr Properties and its affiliates] (“Company” or “we”) respects your privacy and is committed to protecting it. This Policy describes:

The types of information that we may collect or that you may provide to us which could reasonably be associated or linked with a particular individual or household (“personal information”).
Our practices for collecting, using, maintaining, protecting, and disclosing personal information.

It is our goal to collect, use, maintain, protect and disclose personal information in a responsible manner, whether we do so in the context of interacting with visitors to our website www.carrprop.com, developing business, providing services and products, managing our employees, vendors and contractors, or processing applications to join our team (collectively, the “Services”).

This Privacy Policy DOES NOT apply to:

Information which is publicly available, anonymized or aggregated, and other information which is excluded from the scope of applicable privacy laws; and
Information that you provide to or is collected by any third party, including via links on our website www.carrprop.com (the “Website”). These third parties, their websites and apps may have their own privacy policies, which we encourage you to read before providing information on or through them. These links are provided to you for convenience purposes only, and you access them at your own risk.

Please read this Privacy Policy carefully to understand our data practices. Our Privacy Policy, applicable law, and our terms of use and other agreements with you, together govern our relationship as it relates to your personal information. Our collection, use, maintenance, protection and disclosure of personal information will vary based on our relationship or interaction with you. Through your use of the Services, you accept the terms of this Privacy Policy and consent to the data practices we describe in this Privacy Policy. If you do not agree with our policies and practices, do not use the Services.

We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. We may provide supplemental or updated privacy notices on specific occasions when we are collecting or processing your personal information. Such supplemental privacy notices should be read together with this Privacy Policy. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We encourage you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your personal information and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Privacy Policy or privacy notices shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified by its effective date.

CATEGORIES AND SOURCES OF INFORMATION

We collect, use and share personal information from various sources to perform the Services and to accomplish our business and commercial purposes and objectives. You supply most of the personal information in our possession, whether directly when you or your authorized agent provide the information to us so that we can provide Services, or indirectly from the collection or generation of information in the course of our provision of Services. Should you choose not to provide some of the personal information we request, we may be unable to provide you with one or more of the Services.

Online Users. If you use our Website or applications (e.g., the Carr Experience), you may provide contact and other information to enable us to furnish you with Services and information. You also may provide contact and other information when using email outside of our website. In addition, your browser will provide other information automatically, as described further below:

Automatic Data Collection. We may collect certain information when you use our Website or Services. This information includes, but is not limited to, information about the Internet Protocol (“IP”) address or other identifier assigned to your device, browser type, operating system type, Internet Service Provider, mobile carrier, platform type, location information, the date and time of your visit, the pages you visit and the links you click, the time spent on the Website or usage of certain features of the same. Information we collect may be associated with accounts and other devices.

As further discussed below, similar to other Internet services, the Website uses “cookies,” small pieces of computer code that enable our Internet servers to recognize a user each time they initiate a session on our Website. Cookies do not store personal information; they simply help to tailor websites to individual visitors’ use. Blocking or deletion of cookies may prevent access to website content and features. Along with cookies, pages of the Website and our emails 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 monitor the uses of those pages or messages. A web beacon can collect information such as the IP address of the device or the type of browser that downloaded such page, the URL of such page, the time such page was viewed, and the identification number of any cookie on the computer previously placed by that server.

Anonymized or Aggregated Information. We record certain anonymized or aggregated information about your use or evaluation of our website. Anonymized or aggregated information is used for a variety of functions, including the measurement of interest in and use of various portions or features of the Website or Services. Anonymized or aggregated information is not personal information, and we may use such information in a number of ways, including internal analysis and research. We may share this information with third-parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Clients. The type of personal information we collect that relate to our clients, including prospective clients, varies depending on the clients and Services. It may include information related to our clients’ employees, clients, and contractors, communications with our clients, and other information that may be relevant to provision of the Services. We may collect information such as personal identifiers (e.g., name, contact information); characteristics (e.g., nationality); biometric information (e.g., photographs); financial and other personal information (e.g., account information for billing or deposits); Internet or network activity information (e.g., browsing history and interactions with our Website and applications); audio, video, electronic or similar information (e.g., call recordings, recordings of events); education, professional or employment-related information (e.g., job title, work history). We may collect information directly from you when you or your authorized agent provide the information to us, as well as indirectly through your activities on our Website (e.g., submissions through our website portal, website usage details collected automatically) and through our provision of Services, including through third party sources (e.g., public records).

Job Applicants. Job applicants are asked to provide contact information, resume, transcripts, school, graduation year, the office, department, position for which you are applying, and other information. We also may collect information from third parties such as previous employers and personal references. We may use third party contractors to collect information related to references and other employment qualifications.

Employees. Personal information that we obtain relating to our employees include, without limitation, personal identifiers, characteristics (e.g., race, gender, age), biometric information (e.g., fingerprint, photograph), financial, health and other personal information (e.g., bank account information, health insurance information), Internet or network activity information (e.g., browsing history); geolocation data (e.g., device location), audio, video, electronic or similar information (e.g., call records, recordings of meetings), professional or employment-related information (e.g., resume, work history), education (e.g., school, degree, graduation year) and miscellaneous other information (e.g., marital status). We use employee identification and username to regulate access to our technology such as email, records and word processing. We also collect information about employees’ beneficiaries and dependents to the extent our employees choose to enroll them in our benefit plans and arrangements.

Information from Other Sources. We collect contact and payment information from our vendors, contractors and their employees to facilitate our use of their services. We may collect contact information from you if you register to attend an event sponsored by us.

HOW WE USE AND DISCLOSE INFORMATION

We use or disclose the personal information we collect to accomplish our business and commercial purposes and objectives and to respond to your inquiries, fulfill your requests, send you communications such as electronic newsletters and notices, and provide other Services. The information we collect also may be used to personalize your experience. Our uses of personal information include the following:

To meet the reason you provided the information and to administer and perform the Services;
To engage in marketing and business development, including without limitation to provide notices and information to our clients, including prospective clients;
To process employment applications, make employment determinations, and manage and support our team, including to verify eligibility and administer employment benefits and accommodations;
To provide, maintain, personalize and develop our Website, databases, network, infrastructure, devices, assets and Services;
To debug, including to identify and repair technical errors that impair intended functionalities;
To perform security functions, including to detect security breaches, protect against fraud and malicious activities, and take action against wrongdoers;
To serve and protect the rights, property or safety of our clients, employees, us or others, as necessary or appropriate;
To perform auditing and due diligence functions, including without limitation for purposes of onboarding prospective clients, legal and regulatory compliance;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, sale, transfer or other transaction concerning some or all of our assets;
To respond to governmental authorities, including law enforcement requests, and as required by applicable law, court order, or regulations.

We will not disclose personal information to unrelated third parties, except as described in this Privacy Policy or as required by law. We may disclose personal information as follows:

With vendors, contractors, consultants, and other service providers, including to perform business and technology related functions and to support the provision of the Services, but only to the extent such information disclosure is necessary for them to perform their functions and provide such services, and only pursuant to binding obligations requiring such third parties to maintain the privacy and security of such information;
When you give us your consent to do so, including if we notify you (e.g., through this Privacy Policy) that the information you provide will be shared in a particular manner and you provide such information;
When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants, or court orders;
When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to investigate, prevent, or take action to protect our rights, property, or safety or the rights, property or safety of our users, our employees, copyright owners, third parties or the public, including without limitation to enforce our policies or contracts, to collect amounts owed, or to protect against fraudulent, abusive, inappropriate, or unlawful activities;
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, where personal information may be transferred as part of such a transaction, as permitted by law and/or written agreements between you and us; and
To enforce or apply this Privacy Policy or our other statements, terms of use or agreements.

We do not rent or sell personal information to unaffiliated third parties for their own business or commercial purposes.

More on Use and Disclosure of Online Information

We may store some information on your computer when you access the Website. This information is commonly known as a “Cookie” and once recorded is not intended to be accessible by any other company. We may use Cookies or other similar technologies in order to better understand how the Website is being accessed and used. Cookies also help us to determine if the Website is being delivered efficiently. In addition, Cookies allow us to enhance your online experience by potentially customizing your use of the Website and potentially eliminating the need for you to reenter data every time you visit the Website. The use of Cookies is an industry standard and is used by most major sites to provide the visitor with tailored information.

Pages of the Website and our emails 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 or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

To enable better website design and user experience, the Website utilizes Google Analytics, an industry standard employed to analyze website traffic and provide aggregate reports of how the pubic interacts with the Website. Additional information about such analytics can be found at www.google.com/policies/privacy/partners/. To opt out of Google Analytics, you can reach us at [email protected].

YOUR CHOICES ABOUT PERSONAL INFORMATION

General. You have certain choices about the use and disclosures of your personal information, as set out in this Privacy Policy. You may decline to provide personal information to us. Declining to provide your personal information may mean that we will be unable to provide certain Services to you (e.g., Website features that require personal information) or to hire you to join our team.

Do Not Track. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Website does not respond to browser “do not track” signals, but we do provide you the option to opt out of interest-based advertising (“IBA”). To learn more or to opt-out of this type of advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.

Opting Out of Email Marketing Communications. We may use your personal information to send notifications or otherwise to communicate with you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communication or contact us at [email protected]. Please note that you cannot opt out of administrative communications relating to the Services we provide, such as billing and Service notifications.

Other Requests. We may keep information that you have provided permanently, unless you request that it is removed. You may send us an email at [email protected] to request access to, correct, or delete personal information that you have provided to us. We may not accommodate a request to change or delete personal information if we believe such action could violate any law or legal requirement or could cause the information to be incorrect.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, no Internet, electronic operating system or data security system is ever completely secure or error free. We therefore cannot guarantee the security of any information, including information you transmit to us through the Website or provide online. We are not responsible for circumvention of any privacy settings or security measures. For instance, it is possible that unauthorized “hackers” may post or transmit offensive or obscene materials on the Website and that you may be involuntarily exposed to such materials. It also may be possible for other users or “hackers” to improperly gain access to personal information. By using the Services, you assume the risk of such occurrences. We request that you do not send, and we will not be liable for your sending, sensitive or confidential information electronically. Any transmission of personal information is at your own risk.

THIRD-PARTY LINKS AND WEBSITES

This Privacy Policy and these terms apply only to our Website and Services. Our Website and Services may provide links to other websites, applications, and information for your convenience that are not operated by us. We do not control linked third-party websites, applications, services or practices, which may differ from those set out in this Privacy Policy. You access these third-party links at your own risk, and any information you provide to linked third parties is not covered by this Privacy Policy. These third parties, their websites and apps may have their own privacy policies, which we encourage you to review before providing information on or through them. If you have any questions relating to a link or advertisement, contact the responsible third party directly. Inclusion of links to a third party or third-party content is not an endorsement of such third parties or third-party content, and we hereby disclaim all liability related thereto

CHILDREN UNDER THE AGE OF 16

We do not intentionally collect information about any person under the age of 16. Our Website and Services are not directed at children 16 years of age or younger. 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 age 16, please contact us at [email protected].

CALIFORNIA PRIVACY RIGHTS

California residents have additional privacy rights and should click here for additional information.

CONTACTING US

If you have questions or concerns about the information that we collect, you may contact us at [email protected].