California Consumer Privacy Statement

California Consumer Privacy Statement

Effective Date: January 2, 2023

This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to (i) Grubb Properties personnel, (ii) investor information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act, or (iii) information about potential residents or residents that is collected, maintained, disclosed, sold, communicated or used subject to regulation under the Fair Credit Reporting Act, provided that such information is not collected, maintained, used, communicated, disclosed or sold except as authorized by the Fair Credit Reporting Act. This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively, the “CCPA/CPRA”).

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the last updated date of this Statement) the following categories of personal information about you online or offline:

• Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, bank account number, credit card number, debit card number and other financial information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender and marital status
• Commercial Information: commercial or investment information, including financial products or investment services considered, obtained, or purchased, and other investing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information, such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the last updated date of this Statement) the categories of personal information listed above for the purposes described in the Grubb Properties website Privacy Policy and for certain business purposes specified in the CCPA/CPRA, such as:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing services, providing analytics services, providing storage or providing similar services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
• Providing advertising and marketing services, except for cross-context behavioral advertising (which is addressed in the “Sale or Sharing of Personal Information” section of this Statement);
• Managing career opportunities with us; and 
• Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

2. Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our website Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitations and our records retention requirements.

3. Sources of Personal Information

During the 12-month period prior to the last updated date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us
• Through your device
• Vendors who provide services on our behalf
• Businesses and counterparties that we are evaluating in connection with a potential investment, disposition, or other business opportunity
• Social networks
• Data analytics providers
• Online advertising services
• Internet service providers
• Operating systems and platforms
• Data brokers, such as public databases, credit bureaus, credit reporting service providers and background check services
• Recruiting and talent agencies
• Job references, such as your employers or teachers

4. Sale or Sharing of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as social networks and online advertising services) to collect personal information via automated technologies on our websites for social networking and cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the last updated date of this Statement) the following categories of personal information about you to social networks and online advertising services:

• Identifiers
• Commercial Information
• Online Activity
• Inferences

We do not have actual knowledge that we sell or share personal information of minors under 16 years of age. We do not sell or share sensitive personal information.

5. Disclosure of Personal Information

During the 12-month period prior to the last updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

6. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.  

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you. 

Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.

How to Submit a Request: To submit a request to access, correct or delete your personal information, please complete this form or email us at privacy@grubbproperties.com. You can opt out of the sale or sharing of your personal information by clicking here or broadcasting the Global Privacy Control signal. To submit a request as an authorized agent on behalf of a consumer, please email privacy@grubbproperties.com with the subject line Authorized Agent Request. For questions or concerns about our privacy policies and practices, please contact us as described in the “Contact Us” section of the Grubb Properties Privacy Policy.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of or deletion of your personal information, we may ask you to provide information to help us identify you, depending on the nature of your relationship with Grubb Properties. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require that you verify your identity as set forth above. We also may require you to provide the authorized agent a written confirmation that you have authorized the agent to act on your behalf and the scope of such authorization.

Additional Information: If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.