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Bozzuto Privacy Policy

Last Updated on: December 18, 2023

 

Bozzuto & Associates, Inc., d/b/a The Bozzuto Group, a Maryland corporation, and its subsidiaries and affiliates (“Bozzuto,” “we,” “us,” or “our”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). We adopt this Policy to comply with data privacy laws applicable to Bozzuto, including the California Consumer Privacy Act of 2018 (“CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and the Connecticut Data Privacy Act (“CTDPA”). Terms used but not defined in this Policy shall have the meanings given to them under the CCPA and/or other applicable privacy laws.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using our Websites (defined below) and our services, you agree to be bound by the terms set forth in this Policy. This Policy may change from time to time (see Section 17 below “Changes to Our Privacy Policy”). Your continued use of this Website and our services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

1.  Scope of This Policy

This Policy applies to our practices of collecting, using, maintaining, selling, and disclosing personal information:
      • Through our websites, https://www.bozzuto.com and our other individual property websites where this Policy is posted (our “Websites”), and any email, text, and other electronic messages between you and this Website, and when you interact with our advertising and mobile applications on third-party websites, if those applications, sites, or advertising include links to this Policy.  
      • Through our offline practices and any products and services we provide. This Policy refers to our Website and offline practices collectively as our “services.”
      • Of former, current, and prospective residents; customers; vendors; B2B contacts; officers, owners, directors, contractors, beneficiaries, emergency contacts, and job applicants.

Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances and our relationship to such individual.  This Policy is intended to describe our overall privacy and data protection practices.
This Policy also describes the rights of individuals regarding their personal information, which may vary depending on the individual’s state of residency.  The descriptions below regarding our collection, use, and disclosure of your information apply equally regardless of our relationship with you unless noted otherwise.
Bozzuto’s website may include links to third party websites, services, and applications. These links are provided solely as a convenience to you and are not an endorsement of the content of such sites.  This Policy does not apply to those sites, as we have no control over or responsibility for third parties’ collection or use of your information. These third party sites may have their own privacy policies that you should review.

2. Categories of Personal Information that We Collect

Bozzuto recognizes the importance of protecting the privacy and security of personal information.  “Personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:
      • Publicly available information from government records. 
      • Information made available to the general public by the individual or through widely distributed media.
      • Deidentified or aggregated consumer information.

Bozzuto collects personal information in a variety of contexts.  For example, we collect personal information to provide our services, for human resources or personnel functions, and for vendor management purposes.  The personal information we collect about a specific individual will depend on our relationship or interaction with that individual.  We collect the following categories of personal information:

Category

Examples

Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Other

Personal Information
Name, signature, Federal Employer Identification Number, 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. Some personal information included in this category may overlap with other categories.
Protected Characteristics
Age (40 years or older), 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).

Commercial Information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or Network Activity
Browsing history, search history, IP address, operating system, browser type, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation Data
Physical location or movements.
Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or Employment Related Information
Current or past job history or performance evaluations, information from background checks, resumes, or personnel files.
Education Information
Education information that is not publicly available and contains personally identifiable information, such as student transcripts.
Inferences
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Inferences drawn from other personal information.
• Social Security number, driver’s license, state identification card, or passport number;
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• Precise geolocation data;
• Racial or ethnic origin, religious or philosophical beliefs, or union membership;
• The contents of mail, email, and text messages unless Bozzuto is the intended recipient of such communication; and
• Genetic and biometric data.

3. Sources of Personal Information

The sources from which we collect personal information depend on our relationship or interaction with the specific individual.  Bozzuto obtains the categories of personal information listed above from the following types of sources:
      • Directly from you when you provide it to us. For example, from forms, inquiries, or applications you complete on the Website, in person, or information provided verbally. 
      • Indirectly from you.  We automatically collect information about you when you use our services. The type of information that we collect varies depending on the settings of your web browser or device, but it may include: the pages you view on our Website; the date and time you access our Website; how long you use our services; the type of web browser you are using (for example, Firefox or Chrome); the type of device you are using (for example, whether you are using a mobile device); your Internet Protocol address; and device IDs (including device advertising identifiers). With your permission, we will collect your device’s location information to help you identify available properties near your location; you may disable this feature through your device’s settings. Our vendors and/or third party may also track your online behavior through links that you click on our Website. See Section 10 below titled “Cookies and Tracking” for more information. We may associate this information with the personal information that we collect about you, such as whether and when you logged into your account.
      • Social media. If you choose to link, create, or log in to your services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.
      • Real estate professionals. If you interact or list a property with a broker, independent agent, or other real estate professional, we may receive personal information about you and your property from them, such as your name and property address, listing and contact information, among other things.
      • Public records or widely available sources, including information from the media, and other records and information that are made available by government entities.
      • Outside companies or organizations that provide data to support activities such as fraud prevention, underwriting, and marketing. 
      • Outside companies or organizations from whom we collect personal information to support human resources and workforce management activities.  
      • Outside companies and organizations from whom we collect personal information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development. 


4. Purposes for Collection, Use, and Disclosure of Personal Information

The purposes for which we collect, use, and disclose personal information vary depending on our relationship or interaction with a specific individual.  The table below lists the purposes for which we collect, use, and disclose personal information in different contexts and examples related to each.

Purposes for Collection, Use, and Disclosure

Examples

Providing and managing products and services
• Provide you with information, products, or services.
• Provide you with notices about your rental agreement, including expiration and renewal notices.
• Fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about a residential community we manage, we will use that personal information to respond to your inquiry. If you become a resident of a residential community we manage and you provide your personal information to make payments for rent and other services.
• Provide, support, personalize, develop, and improve our Website and services.
• Create, maintain, customize, and secure your account.
• Process your requests, purchases, transactions, and payments and prevent transactional fraud.
• Obtain support for fulfilling the above purposes from our vendors.
• 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.
• To comply with our legal or regulatory obligations.
Supporting our everyday operations, including to meet risk, legal, financial, and compliance requirements
• Perform accounting, monitoring, or reporting.
• Carry out our obligations and enforce our rights arising from any contracts entered into with customers or business partners.
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Support audit and investigations, legal request and demands, as well as exercise and defend legal claims.
• Enable the use of service providers for business purposes.
• Comply with laws, regulations, policies, procedures, and contractual obligations.
• Obtain support for fulfilling the above purposes from our third-party service providers and contractors.
Providing advertising and marketing services
 • Market, personalize, develop, and improve our products and services.
• To provide you with alerts and notices concerning our products or services, or events or news, that may be of interest to you.
• Obtain support for fulfilling the above purposes from our vendors.
 

Managing, improving, and developing our business
• Maintaining the quality or safety or our Website or services.
• Performing internal research to improve service delivery.
• Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• Obtain support for fulfilling the above purposes from our vendors.
Ensuring security, integrity and functionality of our Website and services
• Maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• Enable information security and anti-fraud operations.
• Obtain support for fulfilling the above purposes from our vendors.
Planning and facilitating business transactions
• Engage in due diligence, planning, and implementing an actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of Bozzuto or another business.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
Supporting employment, infrastructure, and human resource management
• Provide benefits to officers, owners, directors, employees, contractors, applicants, and dependents, including healthcare and retirement plans.
• To process and provide tuition reimbursement.
• To provide scholarship opportunities.
• Drug testing.
• Maintain contact information for emergency contacts.
• Manage pay and compensation activities.
• Manage and operate our facilities and infrastructure.
• Establishing training and/or development requirements.
• Process employment applications and determine eligibility.
• Gathering evidence for disciplinary action or termination.
• Establishing contact in the event of an emergency.
• Reporting on company metrics and compiling directories.
• To comply with state and federal laws and regulations requiring employers to maintain certain records (such as immigration compliance records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records).
• To conduct workplace investigations (such as investigations of workplace accidents or injuries, harassment claims, or other alleged misconduct).
• To manage workers’ compensation claims.
• Obtain support for fulfilling the above purposes from vendors.
In addition, we may collect, use, or disclose your personal information in any other way as described at the point of collection, or for any other purpose with your consent or at your direction. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes than described above without providing you notice.


5. How Long We Retain Your Personal Information

Based on contractual requirements and/or legal requirements, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements.  Additional information such as emails, and vendor agreements are maintained for business purposes for an indefinite amount of time.  Interest lists are maintained for an indefinite amount of time.


6. Categories of Third Parties To Whom We Disclose Personal Information
We may disclose your personal information to a third party for the business purposes as described above. The categories of third parties to whom we disclose personal information about an individual depend on, among other things, our relationship to or interaction with that individual. Such third parties include:
      • With our corporate affiliates we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.
      • With account servicing systems, payment processors, and fraud prevention vendors we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.
      • With shipping providers we disclose Identifiers and Other Personal Information.
      • With word processing, communication applications, and calendar providers we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.
      • With governmental and regulatory agencies we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.
      • With advisors such as lawyers, accountants, auditors, banks / lenders, insurers, and consultants we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.
      • With data analytics, network monitoring services, website hosts, and incident response providers we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Inferences, and Sensitive Personal Information.  
      • With government entities or law enforcement agencies or as otherwise legally required we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.  
      • With merger and/or acquisition parties we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Education Information, Inferences, and Sensitive Personal Information.  
      • With insurance and benefits providers we disclose Personal Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Professional or Employment Related Information, Inferences, and Sensitive Personal Information.
      • With marketing providers we disclose Other Personal Information, Protected Characteristics, Commercial Information, Commercial Information, Geolocation Data, Inferences, and Sensitive Personal Information.

7. Selling or Sharing of Personal Information
As applicable to California, Virginia, and Connecticut residents only, you have the right to opt-out of the sale of your personal information, and “sharing” of your personal information or targeted advertising.   

      • Bozzuto but does not sell personal information.
      • The CCPA defines “sharing” as renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by the business to a third party for cross‐context behavioral advertising, whether or not for monetary or other valuable consideration.   The VCDPA and CTDPA contain similar provisions for “targeted advertising.”  Some of the cookies, pixels, etc. that our site uses may constitute “sharing” under the CCPA or targeted advertising under the VCDPA and CTDPA.  
             • With our advertising providers, we share Identifiers, Other Personal Information, Internet or Network Activity, Geolocation, and Inferences.
             • See below in Section 8(E) for instructions on how to opt out of sharing your personal information under the CCPA.
             • See below in Section 9(D) for instructions on how to opt out of targeted advertising under the VCDPA and CTDPA.
      • Our website is not aimed at minors and we do not knowingly sell, “share” the personal information of, or target advertising to minors under 16 years of age without affirmative authorization.


8. Rights Under The CCPA
The CCPA provide California residents with rights regarding their personal information - the Right to Know, the Right to Delete, the Right to Correct, the Right to Limit use of Sensitive Personal Information, the Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information, and the Right to Non-Discrimination. This section describes your rights and explains how to exercise those rights, if applicable.

A. Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “Right to Know”). Once we receive your request and confirm your identity, we will disclose to you:
      • Categories of Personal Information Collected, Disclosed, Sold, and/or Shared:
          • The categories of personal information we collected about you.
          • The categories of sources for the personal information we collected about you. 
          • Our business or commercial purpose for collecting or selling that personal information. 
          • The categories of third parties with whom we disclose that personal information and the corresponding categories of personal information disclosed. 
          • If we sold or shared your personal information, the applicable categories of personal information.
      • Specific Information
          • The specific pieces of personal information we collected about you.

B. Right to Delete
You have the right to request that Bozzuto and our service providers delete certain personal information that we collected about you (the “Right to Delete”). Your deletion rights are subject to several legal exceptions, and we may also deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 et. seq.) or other applicable federal, state, or local law or regulation.
    6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    7. Comply with a legal obligation.
    8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Once we receive your request to delete and confirm your identity, we will review your request to evaluate if an exception applies that permits or requires us to retain part or all of the information. For example, we are subject to legal requirements to obtain certain records for minimum retention periods. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

C. Right to Correct Inaccurate Personal Information
You have the right to request that Bozzuto correct inaccurate personal information about you (the “Right to Correct”). Once we receive your request and confirm your identity, we may request documentation from you to determine the accuracy of the information we maintain. If we determine that the information we maintain is inaccurate, we will correct it or delete if such deletion does not negatively impact you and you consent to this deletion. We reserve the right to deny your request, if we determine that the contested information is more likely than not to be accurate, based on the information available to us.

D. Right to Limit the Use of Sensitive Personal Information
You have the right to direct a business that collects your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected.  However, Bozzuto only uses Sensitive Personal Information as exempt from the CCPA; to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.

E. Right to Opt Out and How to Submit a Request to Opt Out
The CCPA gives consumers the right to opt-out of 1) the sale of their personal information, 2) the sharing of their personal information for cross-context behavior advertising, or 2) for use in automated decision making.
      • We do not sell your personal information.  We do not sell the personal information of minors under 16 years of age without affirmative authorization.
      • To opt out of sharing for cross-contextual behavioral advertising you may use the Global Privacy Control (GPC) for your browser.   Our Website responds to GPC signals in a frictionless manner.  To learn more about how to enable GPC in participating browsers, visit www.globalprivacycontrol.org/.
      • Authorized agents may also email Privacy@Bozzuto.com to opt-out of sharing for consumers.

F. Right to Non-Discrimination 
Bozzuto will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

G. Submitting a Request to Know, Request to Delete, or Request to Correct 
You can submit a verified consumer request to know, correct, or delete personal information by either:
      • Calling us at (888) 701-4566
      • Completing this request form. 
Only you, or an authorized agent, may make a request. You may also make a request on behalf of your child (please note that our Website is not directed to minors and we do not knowingly collect personal information about minors). Your request must:
      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent. 
      • Bozzuto will ask you to provide your first and last name, email, phone number, and may ask for additional information, as needed, to confirm your identity or the identify of your authorized representative.  We will avoid requesting sensitive personal information, except when needed, to verify a request.
      • 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 the request to verify the requestor’s identity or authority to make it.

 H. Authorized Agents
 You may authorize an agent to make a request on your behalf through the methods described above. If you choose to use an authorized agent, Bozzuto requires that you provide the authorized agent with written permission to allow them to submit your request and that you verify your identity directly with Bozzuto.  In the alternative, an authorized agent can provide Bozzuto with documentation of power of attorney for the consumer.  Failure to provide the appropriate documentation may result in Bozzuto denying your request.  Bozzuto will also need to verify the identity of the authorized agent.

I. Response Timing and Format 
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email Privacy@Bozzuto.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) 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 include any personal information collected on or after January 1, 2022. The response we provide will explain the reasons we cannot comply with a request, if applicable. For Requests to Know specific pieces of information, 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.


9. Rights Under The VCDPA and CTDPA
The VCDPA and CTDPA provide Virginia and Connecticut residents, respectively, with rights regarding their personal information - the Right to Know; the Right to Delete; the Right to Correct; the Right to Opt-Out of Sale of Personal Information, Targeted Advertising, and/or Profiling; and the Right to Non-Discrimination. This section describes your rights and explains how to exercise those rights, if applicable.  

Please note that the VCDPA and CTDPA right do not extend to residents in a B2B (commercial) or employment relationship with Bozzuto. 

A. Right to Know
You have the right to request that we confirm processing of your personal information and access to your personal information (the “Right to Know”). Once we receive your request and confirm your identity, we will respond accordingly.  

B. Right to Delete
Subject to exceptions, you have the right to request that Bozzuto delete your personal information (the “Right to Delete”).  Once we receive your request and confirm your identity, we will respond accordingly.

C. Right to Correct Inaccurate Personal Information
You have the right to request that Bozzuto correct inaccurate personal information about you (the “Right to Correct”). Once we receive your request and confirm your identity, we may request documentation from you to determine the accuracy of the information we maintain. 

D. Right to Opt Out and How to Submit a Request to Opt Out
The VCDPA and CTDPA give consumers the right to opt-out of 1) the sale of their personal information, 2) targeted advertising, or 2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
       We do not sell your personal information.  We do not sell the personal information of minors under 16 years of age without affirmative authorization.
       Bozzuto only engages in profiling in furtherance of decisions that produce legal or similarly significant effects when providing specific goods or services requested by you and as exempt from these privacy laws.
      To opt out of targeted advertising you may use the Global Privacy Control (GPC) for your browser.   Our Website responds to GPC signals in a frictionless manner.  To learn more about how to enable GPC in participating browsers, visit www.globalprivacycontrol.org/ 
       You may designate an authorized agent to submit a request to opt-out.  For such requests, authorized agents should email us at Privacy@Bozzuto.com and be sure to include evidence of the authorization.
       Parents, guardians, and conservators may submit requests for their children but please note that we do not knowingly collect personal information about minors under the age of 16.

E. Right to Non-Discrimination 
Bozzuto will not discriminate against you for exercising any of your VCDPA and CTDPA rights. Unless permitted by the VCDPA and CTDPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

F. Submitting a Request to Know, Request to Delete, or Request to Correct 
You can submit a verified consumer request to know, correct, or delete personal information by completing this request form. 

Parents, guardians, and conservators may also make requests on behalf of consumers (please note that our Website is not directed to minors and we do not knowingly collect personal information about minors). Your request must:
      Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent. 
      Bozzuto will ask you to provide your first and last name, email, phone number, and may ask for additional information, as needed, to confirm your identity or the identify of your authorized representative.  We will avoid requesting sensitive personal information, except when needed, to verify a request.
      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 the request to verify the requestor’s identity or authority to make it.

G. Response Timing and Format
 We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. Under VCDPA, if we require more time (up to another forty-five (45) 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.  The response we provide will explain the reasons we cannot comply with a request, if applicable. 

Under the VDCPA, you may only make each request twice per year.  Under the CTDPA, you may only make each type of request once per year.  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.

H. Appeal Process
If you believe we denied your request in error, please email us at Privacy@Bozzuto.com.  Please include your denial letter and documentation and/or information supporting your appeal.  We will review and respond within sixty (60) days.


10. Right to Opt-Out of Promotional Emails
Your provision of personal information through any of our registration forms on the Website constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to our own or third parties’ products or services. If you do not wish to have your email address/contact information used by Bozzuto to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to Privacy@Bozzuto.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or select the “unsubscribe” link at the bottom of the email. This opt out does not apply to information provided to Bozzuto as a result of a rental agreement or other transaction.  Please note that if you are a resident of a Bozzuto community and you use this Website and your community website, you will need to opt-out of your community email communications separately.

11. Cookies, Tracking, and Analytics
We or our vendors may use cookies and other mechanisms to track information about your use of our services.  This section describes our use of such technologies and how you may exercise certain choices with respect to such technology:

      • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of Bozzuto’s Website may then be inaccessible or not function properly.
      • Cookies. We or our vendors may use cookies to track visitor activity throughout our services. A cookie is a text file that a website transfers to your device for record-keeping purposes. We or our vendors may use cookies to track user activities on our Website, such as the web pages you view and time you spend on our services. The help section on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies may not be able to browse certain areas of the services. When you register at the Website, we may use a cookie to store a unique, random session ID. We may use this ID to identify you in our database and to track information while you are on our Website.
      • Embedded Scripts. We may use embedded scripts, which is code designed to collect information about how visitors interact with a website, such as the website that linked you to our Website.
      • Analytics. We use service providers, such as Google Analytics, to evaluate the use of our services. We use these tools to help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

12. Children Under the Age of 16
Our Website is not intended for children under sixteen (16) years of age. No one under age sixteen (16) may provide any personal information to or on the Website. We do not knowingly collect personal information from children under sixteen (16). If you are under sixteen (16), do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under sixteen (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 sixteen (16), please contact us at Privacy@Bozzuto.com.

13. Data Retention
We will keep your personal information no longer than necessary to fulfill the purposes described in this Policy. We retain personal information for the retention period required by law, and may occasionally retain it beyond the required period, if deemed reasonably necessary to fulfill an ongoing business need, or to comply with applicable tax, legal, customer service, or accounting requirements.

14. Security
We take commercially reasonable measures designated to safeguard your personal information. Despite these efforts, no measure is 100% effective in preventing all data security incidents and we cannot make any guarantees as to the security your personal information. We recommend that you take measures to protect the security of your own personal information, such as not using the same password for multiple accounts, creating strong passwords, safeguarding your own information, and being vigilant about emails from unknown senders and clicking on unknown links.

15. Website For United States Access Only
The owner of this Website is based in the State of Maryland in the United States. We provide this Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. This Website is not to offer goods or services to anyone located outside of the United States. 

16. Social Media
We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about disclosing your information through those platforms and networks with us.

17. Do Not Track Signals
Our Website does not respond to Do Not Track signals.  For information on using Global Privacy Control signals, please see Section 8(E) above.

18. Changes to Our Privacy Policy
We reserve the right to amend this Policy at our discretion and at any time. We will post any changes we make to our Policy on this page. When we make changes to this Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

19. Contact Us
If you have any questions or comments about this notice, the ways in which Bozzuto collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:
     Phone: 1-866-698-7513
     Website: www.Bozzuto.com
     Email: Privacy@Bozzuto.com
     Postal Address:
            The Bozzuto Group 
            Attn: Digital Marketing 
            6406 Ivy Lane, Suite 700 
            Greenbelt, MD 20770

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