(effective January 1, 2022)
California Consumers: For details on your privacy rights, and how to exercise them, please click here.
WHAT INFORMATION DOES ESSEX GATHER ABOUT ME?
We and our Service Providers collect certain PII you voluntarily provide in order to deliver services, or that is automatically collected via our Services.
PII You Provide
For example, you may be asked to provide PII such as name, email address, and phone number when requesting a tour of an Essex apartment community. If you do not provide this PII, we may not be able to assist you in scheduling a tour of an Essex apartment community or consider you for residence in an Essex apartment community. We may collect your email address so that we can send you information you have requested. We may also use your email address to inform you about current events or to send you updates regarding information that was previously sent to you.
Automatically Collected Data
When you visit our Services, we or our Service Providers, may collect information to administer the Services and analyze its usage.
Examples of this information include:
- Your IP address and/or device ID.
- The kind of browser or computer you use.
- Number of links you click within the Services.
- State or country from which you accessed the Services.
- Date and time of your visit.
- Name of your Internet service provider.
- Web page you linked to our Services from.
- Pages you viewed on the Services.
- Other usage activities information.
This information is collected to help us administer and operate the Services, better understand how users interact with and access the Services, and understand the types of users that access the Services.
HOW DOES ESSEX USE PII?
We collect and use PII for the following purposes:
- to provide you with Services or process transactions that you have requested;
- to communicate with you regarding information, features or offers that we believe will be of interest to you;
- to respond to your questions or other requests;
- to contact you with regard to the Services;
- to process any applications, payments or changes to your account information;
- to process other information or PII that you submit through the Services;
- to conduct user surveys;
- to contact you regarding a sweepstakes, contest or promotion in which you have participated,
- to evaluate your application for employment; and
- to fulfill other purposes disclosed at the time you provide your PII.
We may also use the information you provide to improve the Services, to customize your experience on the Services, to serve you specific content, or for other purposes subject to applicable law.
We may use the contact information you provide to communicate with you through email and other means, including mobile text messages, telephone calls, and push notifications. If you provide your telephone number, you agree that doing so is request to be contacted and we may contact that number even if it is registered on a corporate, state, or national Do Not Call Registry.
Sharing with Third Parties
We may share your PII with third parties who perform services on our behalf or on behalf of our many affiliates (e.g., the legal owner of one of our properties), including sending advertising to you. This includes, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renter's insurance, provide credit checks, resident screening, or collection services, manage package deliveries, provide marketing and advertising services, including marketing and analytics, to Essex, or create, host and/or provide customer service on our behalf. These third parties may have access to certain PII in order to provide these services to us or on our and our affiliates’ behalf. We and our service providers may convert PII to aggregate or deidentified data and use and share with except as may be limited by applicable law.
For more information about Essex’s third-party service providers, please contact us via email at firstname.lastname@example.org.
Essex may also disclose PII we collect from you to third parties in order to:
- Fulfill your service requests for services,
- Facilitate your directions,
- Protect ourselves from liability,
- Protect the safety and security of Essex and its users,
- Respond to legal process or comply with law,
- Provide information in connection with a merger, acquisition, or liquidation of our company; and/or
- As permitted or required by applicable law.
Affiliated and Subsidiary Companies
We may share PII with our affiliated or subsidiary companies who use PII for business purposes related to your tenancy or to process any application, request, inquiry, or as otherwise permitted bay applicable law This includes the owner of any community where you submit an application or where you lease, as well as the management company for such community.
PARCEL LOCKER PROVIDERS
Essex has partnered with various parcel locker providers in some of Essex’s apartment communities. These universal lockers allow for deliveries and returns of packages from and to third parties in a dedicated storage unit. Essex may share the names, addresses, and email addresses of residents in those apartment communities with parcel locker vendors to facilitate the registration process for the universal locker. You will be contacted to register for the universal locker when you first receive a package, and as such your direct us to share your PII with these shippers. If your community has a parcel locker provider, we encourage you to read that provider’s privacy notice and as well as their terms and conditions prior to registering.
Essex may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interests based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”).
Tracking Technologies Generally
Essex, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Essex with information collected by Essex, Essex does not consider Usage Information (including, without limitation, unique device identifiers) to be PII.
The methods that may be used on the Service to collect Usage Information include:
Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
Cookies: A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. To identify certain types of local shared objects on your device and adjust your settings, please visit: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices.
Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Essex’s web server, or from a third party with which Essex works and is active only while you are connected to the Service and deleted or deactivated thereafter.
Device Recognition Technologies: Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
Device and Activity Monitoring: Technologies that monitor, and may record, certain of your interactions with the Service, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.
Essex is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You can opt out of receiving certain promotional communications (emails or text messaging) from Essex at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from Essex to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Essex may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Essex’s ongoing business relations.
CHILD PROTECTION AND PRIVACY
Essex does not knowingly seek to collect PII from children under the age of 13 online. We will use commercially reasonable efforts to delete any PII or other information later determined to be provided by a child under the age of 13 online, as required by applicable law. Use of the Services by children under the age of 13 is not permitted. If you become aware that a child has provided PII through our Services, please email us at email@example.com.
In general, you may browse the Services without providing PII. However, if you choose not to provide certain PII through the Services, Essex may not be able to provide certain services or process certain of your requests. You may not be able to submit an application for employment, access resident services online, or otherwise use all of the features and products that Essex offers through the Services.
LEGAL REQUIREMENTS AND LAW ENFORCEMENT
SWEEPSTAKES AND PROMOTIONS
If you choose to enter a sweepstakes, contest or other promotion, your PII may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.
Essex will take reasonable steps to secure the PII you provide via the Services. Please note that no transmission of PII over the Internet or the subsequent electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any PII via the Services, please be aware of these inherent risks and know that you do so at your own risk.
We will retain your PII for as long as it is needed to fulfill the purpose for which it was collected or as required by the law. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.
CHANGES TO THIS PRIVACY STATEMENT
The Services is operated in the United States of America (U.S.) and is only intended for use by individuals accessing it from the U.S. If you are located in another jurisdiction, then please be aware that any PII you elect to supply will be transferred from your current location to the U.S. – to our servers, offices, and/or to the third parties described above (see “How Does Essex Use PII?”), and be subject to U.S. laws regarding data privacy and collection, which may be less stringent than or otherwise different from the laws in effect in the country in which you are located. By using this Services or by voluntarily providing us with your PII, you acknowledge and agree with your PII being processed and transferred as described above.
Effective January 1, 2022 (Updated: August 1, 2022)
Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.
Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
COLLECTION AND SHARING OF PI
In 2021, we collected, retained, used, and disclosed PI about California Consumers as follows:
Category of PI
Examples of PI
Categories of Recipients with which PI is Shared,
This may include but is not limited to: name, driver’s license or state ID number, postal address, Internet Protocol address, Social Security number or national identification number and details, email address, or prior address.
Business Purpose Disclosure: (1) Service Providers such as Internet listing services, analytics providers, operating system and platform providers, payment processors, fraud prevention and security providers, collection agencies, legal counsel, or external auditors; (2) public authorities / government bodies and (3) Third Parties as compelled or required by law.
This may include, but is not limited to: rental application information including credit and/or criminal history, financial account information, resident names, contact information, payment card number, date of birth, emergency contact details, insurance policy information, or status as victim of domestic violence, assault, or stalking.
Business Purpose Disclosure: (1) Service Providers such as Internet listing services, analytics providers, operating system and platform providers, collection agencies, financial institutions, legal counsel, and external auditors; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law.
This may include, but is not limited to: date of birth, citizenship status, disability or medical condition, gender, marital status, military or veteran status.
Business Purpose Disclosure: (1) Service Providers such as analytics providers, operating system and platform providers, collection agencies, and legal counsel; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law.
Customer Account Details / Commercial Information
This may include, but is not limited to: account profile, properties rented, services requested, properties viewed or considered, or other purchasing or consuming histories or tendencies.
Business Purpose Disclosure: (1) Service Providers such as analytics providers, operating system and platform providers, collection agencies, legal counsel, and marketing providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law.
Internet Usage Information
This may include, but is not limited to: web services history, browsing time, or information regarding your interaction with an Internet Services, application, or advertisement.
Business Purpose Disclosure: Service Providers such as analytics providers, operating system and platform providers, external auditors, and marketing providers.
This may include, but is not limited to: precise physical location.
Business Purpose Disclosure: Service Providers such as analytics providers, operating system and platform providers, external auditors, and marketing providers.
This may include but is not limited to voice or video recordings.
Business Purpose Disclosure: Service Providers such as analytics providers, operating system and platform providers, customer support providers, security providers, public authorities / government bodies, legal counsel, and external auditors.
Professional or Employment Information
This may include, but is not limited to: business unit or division, employer, compensation information, job title or role, office location, previous work history, reference or background check information, or salary or compensation.
Business Purpose Disclosure: (1) Service Providers such as analytics providers, operating systems and platform providers, legal counsel, external auditors, and collection agencies; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law.
Inferences Drawn from PI Above
This may include, but is not limited to: inferences about attitudes, behavior, characteristics, or preferences.
Business Purpose Disclosure: Service Providers such as analytics providers, marketing providers, operating system and platform providers, public authorities / government bodies, legal counsel, and external auditors.
The chart above reflects the categories of PI defined by the CCPA along with the applicable recipients with which we shared each category of PI in 2021. Keep reading this Section for information on our purposes for collecting and sharing PI, and our sources of collection. There may be additional information that we collected that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it for our own purposes.
Sources of PI
We may collect your PI directly from you, your devices, your email or social media accounts, from service providers such as credit reporting agencies, data providers, utility management providers, and analytics or marketing providers, from other individuals, such as friends or family, as well as from public sources of data such as government databases.
Use of PI
Generally, we collect, use and disclose your PI to provide you services and as otherwise related to the operation of our business. We may collect, use and disclose the PI described in the chart above for one or more of the following business purposes:
- Providing Products or Services;
- Processing Interactions and Transactions;
- Managing Interactions and Transactions;
- Research and Development;
- Quality Assurance;
- Security; and
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. We treat all of these purposes also as Other Business Purposes.
See also the next section on sharing generally.
SHARING OF PI
We disclose PI for Business Purposes as more fully explained in the section immediately above. We do not believe that we Sold your PI in 2021 as such is defined under the CCPA. As of August 1, 2022, we may Sell PI collected under this Notice. However, we provide California Consumers the opportunity to opt-out of such disclosures. For more information on our understanding of what is a “Sale” under the CCPA, and your “Do Not Sell” rights, including regarding Third Party cookies, see the “Do Not Sell” subsection of the “California Privacy Rights” section below. In addition, if you direct us to share PI we may, and that is not a Sale. Also, disclosures amongst the entities that constitute Company, as defined above, and to their Service Providers, are not Sales.
For more specific detail on our sharing of PI, see the chart above.
CALIFORNIA PRIVACY RIGHTS
We provide California Consumers the privacy rights described in this section. California Consumers have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations.
Making Requests and Verification:
As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”), which will be further explained as part of the request process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our Consumer Rights Request Portal here or call us at (833) 591-5938 and respond to any follow up inquires we may make. You may also obtain information on how to make, and may submit, a request by asking a manager at any of our leasing offices.
Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request, but you may use your account to do so. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise to respond to your California Consumer rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will not typically charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your Social Security number, driver’s license number or other government-issued ID number, financial account number, an account password, or security questions or answers in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us. There may be other limitations on your requests as more fully explained in Section below and in our responses to your requests.
Your California Consumer privacy rights are as follows:
THE RIGHT TO KNOW
Obtaining Copies of PI - Specific Pieces Request
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected and are maintaining for the period that is 12 months prior to the request date. To make a request, click here or call us at (833) 591-5938. If you are disabled and need reasonable accommodations to facilitate your request, let us know by contacting us over the phone toll free at (833) 591-5938, via email at firstname.lastname@example.org, or by mail at Essex Property Trust, Attention Legal Department, 1100 Park Place, Suite 200, San Mateo, California 94403. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process. We will verify your identity by matching information you provided with data we have maintained about you in our systems and we require that at least three of the data elements you provide match to data we already maintain about you. To protect your privacy and security we require verification of your identity to a high degree of certainty based on information we already have about you. If you cannot meet that standard, we will treat your request as a “categories request” as explained in the next section.
Information Rights - Categories Request
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have Collected about you.
- The categories of sources from which we Collected your PI.
- The business or commercial purposes for our Collecting or Selling your PI.
- The categories of Third Parties to whom we have shared your PI.
- If we disclosed your PI for business purposes:
- the categories of your PI we have disclosed for business purposes; and
- for each such category of PI, the categories of Third Parties to which it was disclosed.
- If we sold your PI:
- the categories of your PI we have sold; and
- for each such category of PI, the categories of Third Parties to which it was sold.
To make a request, click here, or call us at (833) 591-5938. You will be asked to provide your name, email address, country of residence, state, and request details. A confirmation email will be sent to the email address you provide to begin the process to verify your identity. To protect your privacy and security we require verification of your identity to a reasonable degree of certainty based on information we already have about you. If you cannot meet that standard, we will refer you to this Notice where you can review our categories disclosures generally in the Collection and Sharing PI section above.
Do Not Sell
We do not believe that we “Sold” your PI in 2021 as such is defined under the CCPA. As of August 1, 2022, we may Sell PI collected under this Notice. However, we provide California Consumers the opportunity to opt-out of such disclosures by emailing email@example.com or by calling us at (833) 591-5938. We believe that all of the parties we permit to operate cookies and other tracking technologies in association of our online services qualify as Service Providers under the CCPA and limit their data processing so as not to be a Sale by us to them. However, the rest of this section explains how you can exercise control over cookies, essentially opting out of their data collection, and in some cases provide certain opt-outs directly to cookie operators.
For instance, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices. Please note that when you use cookie control tools, you will have to change your settings for each browser and device you use, and your limitation on cookies can limit the functionality of online services you use, including our services. Use the help function on your browser or click on the applicable links below to learn more:
You can use mobile device settings to limit mobile tracking technologies and associated activities. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID. These controls work much like deleting cookies in a browser—the device is harder to associate with past activity, but tracking may still occur using the new advertising identifier. In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in.
For more information on cookies and other tracking technologies that may be associated with our Services and mobile applications, and more information on ways you may exercise preferences regarding them, see the Section Tracking Technologies Generally, above.
Clearing cookies or changing settings may affect your choices and you have to opt-out separately via each browser and other device you use. Cookie-enabled opt-out signals may no longer be effective if you delete, block or clear cookies. We are not responsible for the completeness, accuracy or effectiveness of any third-party notices, tools or choices.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a “Do Not Sell” expression by you, so we currently do not recognize these as do not Sell requests. We understand that various parties are developing “Do Not Sell” signals. Since we do not believe that we currently Sell PI, we do not currently look for such signals.
We will not knowingly Sell the PI of Consumers under 16.
We may disclose your PI for the following purposes, which are not a Sale: (i) if you direct us to share your PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, to Company’s Service Providers, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you. To make a request, click here or call us at (833) 591-5938 and respond to any follow up inquiries we may make. If you are disabled and need reasonable accommodations to facilitate your request, let us know by contacting us over the phone toll free at (833) 591-5938, via email at firstname.lastname@example.org, or by mail at Essex Property Trust, Attention Legal Department, 1100 Park Place, Suite 200, San Mateo, California 94403. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process. To protect your privacy and security we require verification of your identity to a reasonably high degree of certainty based on information we already have about you. If we are not satisfied that we have sufficiently verified your identity, we may direct you to this Notice for information on our PI practices generally.
However, you may alternatively exercise more limited control of your PI by instead exercising one of the following more limited opt-outs: editing your personal information associated with your Essex prospect account or deleting that account here, as well as opting out of marketing communications.
Non-Discrimination and Financial Incentive Programs
As of the Effective Date of this Notice we did not offer any Financial Incentive Programs requiring you to limit any of your CCPA rights. If we do so, the CCPA requires certain program terms and notices for California Consumer and the material aspects of any such program, and the rights of California participants, will be explained and described in the program terms. Participating in any such programs will be entirely optional. We may add or change programs and/or their terms by posting notice on the program descriptions so check them regularly.
You may designate an agent to exercise your CCPA rights on your behalf, subject to the CCPA’s agent validation and verification requirements. If you are an authorized agent making a request, please visit our Consumer Rights Request Portal for agents here.
Limitation on Rights
Notwithstanding anything to the contrary, we may Collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law. Further, to protect your privacy and security we will not provide you with access to or copies of sensitive personal information such as Social Security, government issued IDs, financial account numbers, or passwords or answers to security questions; provided, however, that we will inform you if we maintain any such applicable types of PI in response to an access request. We are also not required to search for PI not maintained in a searchable or reasonably accessible format that is used for internal purposes only, or other PI where the request is excessive, repetitive, unfounded or overly burdensome. In addition, as explained above, we will reject requests to the extent we are not able to sufficiently verify your identity, or your agent’s authority. If we conclude we have a basis for not fully responding to your request, our response to you will explain the basis for the limitation, unless we are prohibited from doing so by applicable law. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant more than 12 months prior to the request.
ADDITIONAL CALIFORNIA NOTICES
In addition to CCPA rights, certain Californians are entitled to certain other notices, including:
Third Party Marketing and Your California Privacy Rights
Separate from your CCPA “Do Not Sell” rights, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.
California's “Shine the Light” law permits California residents to request certain information regarding our disclosure of “personal information” (as defined by the “Shine the Light” law) to third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at email@example.com or by sending a letter to us at Essex Property Trust, Attention Legal Department, 1100 Park Place, Suite 200, San Mateo, California 94403. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
Online Privacy Practices
Tracking and Targeting
Any California residents under the age of eighteen (18) who have registered to use our online services and who posted information on the service can request removal by contacting us firstname.lastname@example.org, detailing where the information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the information or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal.