WHAT PERSONAL INFORMATION DOES BELL COLLECT?
We collect Personal Information from our Site in order to provide you with information on the Bell experiences in which you have expressed an interest, to provide you with information on other similar Bell experiences we believe will be of interest to you, and to better understand how we can help prospective clients, residents and employees. We also collect Personal Information for the purposes of administering certain services to residents and/or applicants, which may include, but not be limited to, services necessary or appropriate to complete any transaction, delivery, or provision of products and services, among other services that Bell may offer or provide from time-to-time (“Company Services”). The type of Personal Information we collect will depend upon what we will need in order to provide you with the particular product or service that interests you. In the case of prospective residents and applicants for employment, the information requested on our registration form includes some or all of the following Personal Information: name and address, age or date of birth, email address, occupation, employment information, telephone number, educational background and Social Security/national insurance number, payment card information, and/or financial account information.
Within the past twelve months, we have collected the following categories of Personal Information from consumers:
- A. Identifiers (e.g., name, address, email address, Social Security number);
- B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information);
- C. Protected legal classification characteristics (e.g., age, race, sex, citizenship, marital status);
- D. Commercial information (e.g., products or services purchased, purchasing history);
- E. Biometric information (e.g., genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data);
- F. Internet activity (e.g., browsing history, interaction with website);
- G. Geolocation data (e.g., physical location or movements);
- H. Sensory data (e.g., audio, electronic, visual, thermal, olfactory or similar information); and
- I. Employment information; Education information; and Inferences about personal preferences (i.e., cookies).
Within the past twelve months, we have not collected the following categories of Personal Information from consumers:
- A. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (e.g., 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); and
- B. Inferences drawn from other personal information (e.g. profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)./li>
For those interested in applying for employment at Bell, the following additional Personal Information may be requested or obtained: credit checks, background checks, reference checks and employment verification. Where required, we will obtain your consent before undertaking these checks. Once a candidate accepts a position, the candidate may be asked to provide additional information. Such additional information may include an invitation to self-identify ethnicity or race. This information is only collected for meeting government reporting requirements, and the provision of this information by candidates is voluntary.
WHAT KINDS OF SOURCES DO WE COLLECT THIS INFORMATION FROM?
- 1. Personal Information may be obtained directly from you; for example, when you use certain services on our website, communicate with us, request services, apply for an apartment or employment, make payments through a website or submit a request for information.
- 2. Personal Information also may be collected directly and indirectly from activity on our website, through the use of IP addresses and “cookies.”
We use persistent session and third party tracking cookies on our Site, which are cookies that stay in your web browser between visits. We use these to capture analytical information about our visitors that helps us improve the performance of our Site and create a better experience. These cookies allow us to recognize and count the number of visitors, to provide content related to a prior visit to the Site, and to see how visitors move around the Site and the products and services in which they are interested when they are using it. This information helps us to improve the way our Site works by making sure users are finding what they need more easily.
Most browsers are set up to accept cookies. If you want to change your cookie preferences, you can do so through your browser settings or refuse the cookies when you enter the Site. Please remember that our cookies are often used to give you certain functionality and without them you may not be able to use some portions of our Site (e.g., save properties from our listings). You can also remove cookies that already have been set in your browser via your browser settings.
- 3. Personal information may also be collected from third parties that interact with us in connection with the services we perform. For example, if you apply to rent an apartment, we may obtain information from third parties about your creditworthiness; if you apply for a job, we may obtain information from third parties about your employment or education history.
- 4. We also may collect personal information from other sources, including public data bases, joint marketing partners, and social network information. If you use a social network login to access our services, we may collect certain information from your social media account such as your name, email address, photo, list of social media contacts, and any other information that may be made accessible to us when you connect via your social media account.
CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org . At this time, Bell does not respond to Do Not Track browser settings or signals.
HOW DO WE USE THE INFORMATION WE COLLECT?
Bell may use, sell, or disclose any of the categories of Personal Information we collect from you for one or more of the business purposes as described below.
- 1. To fulfill or meet the reason for which the information was provided, to respond to your questions or other requests, to purchase a product or service, to process payment or facilitate delivery of goods or services;
- 2. To provide you with services or process transactions that you have requested;
- 3. To provide you with information, products or services that you request from us;
- 4. To provide you with email alerts and other notices concerning things that may be of interest to you;
- 5. To process applications, payments, or changes to your account information;
- 6. To evaluate your application for employment;
- 7. To verify information you have provided to us;
- 8. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing;
- 9. To support, personalize and develop our websites, products and services;
- 10. To create, maintain, customize and secure your account with us;
- 11. As necessary to protect the rights, property or safety of us, our clients or others;
- 12. To protect against, identify and prevent fraud and other unlawful activity; and
- 13. As required by applicable law.
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different or incompatible purposes.
WHAT INFORMATION DO WE SHARE OR DISCLOSE?
We do not share your Personal Information with third parties, unless:
- Such information is shared and/or commercialized following receipt of a specific request and/or permission from users;
- Such information is shared with affiliated companies and/or potential investors (in any form of business transaction, including purchase or merger);
- Such information is shared with vendors and service providers that may from time to time be selected or utilized by Bell, its agents, or the owners of residential communities we manage, for the purposes of administering or carrying out management responsibilities and business objectives for the community, such as third parties that process payments, assist with utility billing, provide collection services, etc.
- Such information is shared in order to comply with or in accordance with any applicable law and/or court orders and/or in order to prevent suspected illegal acts, frauds, or situations involving potential threats to the safety of any person, or as otherwise required by law. This circumstance includes responding to lawful requests by public authorities, including national security or law enforcement entities;
- Such information is shared in order to help Bell defend against claims and/or establish or exercise any legal right that Bell may have;
WHAT CATEGORIES OF MY INFORMATION WILL BE SOLD TO OTHER PARTIES?
- Marketing partners
- Trade associations
- Affiliates, parents or subsidiary organizations and
- Data analytic providers
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us by using the information provided in the “Contact Information” section below and requesting to exercise your right to opt-in. You do not need to create an account with us to exercise your right to opt-out. We will only use personal information provided in an opt-out request to review and comply with the request.
THIRD-PARTY SITE LINKS
You should be aware that when you are on the Bell website you could be directed to other third party sites that are beyond our control. There are links to other sites from Bell, which take you outside our service. These other sites may send their own cookies to visitors to collect data or solicit information. Bell does not control these sites and therefore is not responsible for their content. The inclusion of hyperlinks to any other sites by Bell does not imply any endorsement of the material on such sites, nor any association with their operators.
Bell policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control. Remember that whenever you give out information online, that information may be collected and used by people you do not know. If users have any questions about security, please contact us using the information in the “Contact Information” section.
EMAIL CONSENT AND OPT-OUT
You may choose to opt out of receiving future commercial email messages from us. Please note that if you are a resident of a Bell community and you use this Site and your community site, you will need to opt-out of your community site separately. For Bell residents, the opt-out function does not apply to Emergency Notifications. In addition, you also will need to opt-out separately from any third party sites with which you have registered. Please see the section on Third-Party Site Links.
We do not knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. By using our Site, you represent that you are not under 13 years of age. If you are a child under thirteen (13) years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site. In the event that we become aware that we have collected Personal Information from any child, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under age 13 may have provided personally identifiable information through the Site, please contact us using the information in the “Contact Information” section.
CORRECTING AND DEACTIVATING PERSONAL INFORMATION
This section includes information about how all users may exercise their Privacy Rights.
You have the right, freely and at reasonable intervals, to request that Bell inform you as to whether Personal Information relating to you is being processed. You have the right to request that Bell correct, supplement, delete or block your Personal Information in the event that the data are factually inaccurate, incomplete or irrelevant to the purposes of the processing activities or if the Personal Information is being processed in any other way which infringes a legal provision. If you wish to exercise your rights or if you have any questions or suggestions regarding the use, collection, or security of your Personal Information, please contact us using the contact details in the “Contact Information” section.
When a request for user deletion is received, we will make all reasonable efforts to purge said data from our systems. Due to the nature of our service, some information may not be fully removed due to backups or archived copies; however, such information will only be used for the purpose of performing a contract that the user has entered into with us.
RIGHT TO ACCESS PERSONAL INFORMATION PURSUANT TO CCPA
The California Consumer Privacy Act of 2018 (or “CCPA”) creates certain consumer rights for residents of California regarding their Personal Information. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. In order to exercise this right to access, you must submit a Verifiable Consumer Request to either:
A Verifiable Consumer Request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and must describe your request with sufficient detail that allows us to properly 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 that the Personal Information relates to you. Only you, or a person that you legally authorize to act on your behalf, may make a Verifiable Consumer Request related to your Personal Information. You also may make a request on behalf of your minor child. Making a Verifiable Consumer Request does not require you to create an account with us; however, we will consider requests made through your password protected account sufficiently verified when the request is related to Personal Information associated with that specific account. You may submit a Verified Consumer Request no more than twice within a 12 month period.
RIGHT TO NONDISCRIMINATION UNDER CCPA
If CCPA applies to you, we will not discriminate against you for exercising your CCPA rights. Unless permitted by CCPA, we will not deny you goods or services, charge you different rates or prices for goods or services, provide a different level or quality of goods or services, or suggest that you may receive a different rate/price for goods or services or a different level/ quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION UNDER CCPA
If CCPA applies to you, you have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your Verifiable Consumer Request (see requirements for this request above) to delete your Personal Information, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Pursuant to CCPA, we may deny your request to delete your Personal Information if retaining the information is necessary to complete the transaction or request for which we collected the information, to provide a good or service that you requested, to take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
In addition, we may deny your request to delete your Personal Information if retaining the information is necessary to 1) detect security incidents, protect against fraudulent or illegal activity, or prosecute those responsible for that activity; 2) debug to identify and repair errors that impair existing intended functionality; 3) exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided for by law; 4) comply with the California Electronic Communications Privacy Act; 5) engage in public or peer-reviewed research in the public interest; 6) enable solely internal uses that are reasonably aligned with the expectations of the consumer; 7) comply with a legal obligation; or 8) otherwise use the consumer’s Personal Information internally, in a lawful manner compatible with the context in which the information was provided.
NOTICE TO RESIDENTS IN THE EUROPEAN UNION
Bell Partners provides services exclusively within the United States and does not own or manage properties outside the United States. Bell does not intentionally market its products and/or services outside the United States, or have a presence outside the United States, including in the European Union (“EU”), any EU-member state, or any state belonging to the European Economic Area (“EEA”). If you choose to use our website and/or services from the EU, EEA, or other regions of the world, you acknowledge that we will transfer your Personal Information to the United States. Do not provide your Personal Information to us if you do not want this information transferred outside your country, or if the laws in your country restrict these types of transfers.
If you are a resident of the European Union, Bell will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”). Bell Partners Inc. is the Data Controller, as defined under GDPR. Your Personal Information will be collected and processed in compliance with these principles, as required by GDPR: lawfulness and transparency, purpose limitation, data minimization, accuracy, storage limitation, and confidentiality. In addition, you will be entitled to certain rights with respect to the Personal Information that we collect about you:
- 1. Right to be informed. The right to know how your Personal Information will be used;
- 2. Right of access and portability. The right to obtain access to your Personal Information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
- 3. Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete;
- 4. Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed;
- 5. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that information; and
- 6. Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing; and
- 7. Right to lodge a complaint with a supervisory authority if you believe that your rights herein have been infringed.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
If GDPR applies to you, you also have the right to know the time period for which your Personal Information will be stored, or, if not possible, to know the criteria used to determine that time period. We will retain your Personal Information for no longer than necessary. This length of time depends on any legal obligations that we have, the nature of any contracts that we have with you, and our legitimate interests as a business.
Bell takes reasonable technical and organizational measures in accordance with applicable laws to secure your Personal Information; however, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information or other information on the Site, or on other servers or databases to which the information may be transferred, can be guaranteed to be completely secure. You therefore disclose such Personal Information at your own risk. Please consider this limitation prior to submitting your Personal Information to us via the Site.
We limit access to Personal Information to employees who we reasonably believe need to receive such information to provide our services and/or perform their job duties, and we ensure that our employees are aware of the need to protect the Personal Information submitted to us through training and internal data protection policies.
NOTIFICATION OF CHANGES
If a user’s Personal Information changes (such as zip/postal code, phone, email or postal address), or if a user no longer desires to be registered with this Site, we provide a way to correct, update or delete/deactivate users’ Personal Information. This can usually be done in your BellResidents.com account settings or by emailing our Marketing Department through email@example.com
ACCEPTANCE OF THESE TERMS