Privacy Policy

  1. Global Web Privacy and Cookie Policy

    Last updated: January 2020

    Please Read Carefully.

    Peak Financing (PEAK”, “we”, “us” or “our”), recognizes
    the importance of protecting your privacy. Our Global Web Privacy and Cookie
    Policy (“Policy”) applies to your use of our global public
    websites (collectively, the “Site”), as well as
    your professional interactions with PEAK employees. This Policy is designed to
    assist you in understanding how we collect, use, safeguard and disclose your
    personal information and your choices in making informed decisions when using
    the Site. We also describe how you can contact us about our privacy practices.

    A.    Global Web Privacy
    Policy

    1.  

      1.    Your Acceptance Through Use

      2.    The Types of Information We Collect

      3.    How We Use Your Information

      4.    Information Provided to
      Us About You by Third Parties

      5.    Third Parties with Whom
      We Share Your Personal Information

      6.    International Data Transfers

      7.    Security

      8.    How Long We Keep Your Personal Information

      9.    Your Privacy Rights

      10. Changes to this Policy

      11. Data Protection Officer

  2.  

    B.    Cookie Policy – Automatic Data Collection

    1.  

      1.    Cookie Use by Us

      2.    Performance Tracking

      3.    Managing Your Cookie Preferences

  3.  

    C.    Contact Us

  4.  

    A.  Global Web Privacy Policy

  5.  

    1.  Your Acceptance Through Use

    This Global Web Privacy
    Policy describes how PEAK collects, uses and discloses certain personal
    information obtained through this Site. Please note that, to the extent
    permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of this Global Web Privacy Policy
    . This Global Web Privacy Policy is incorporated into, and is part of, the Terms and Conditions, which govern your use of the Site in general.

  6.  

    2.  The Types of Information We Collect

    The types of personal information we may collect from you, or
    you may choose to provide include:

    §  Contact information (such as your name, postal or e-mail address, and phone
    number)

    §  In relation to our recruitment activities, your professional information (such
    as your name, business email, business phone, business address, country in
    which you do business, your industry, job title or role)

    §  Account information (such as username or password)

    §  Client Relationship data (such as business contact information, country in which you do business, your industry, job title or role, professional interactions and relationship data, including your primary PEAK contacts and your record of interactions with PEAK, your contact preferences, and information you provide to us which assist us in serving the business relationship, such as the types of investments you are interested in)

    §  Online identifiers (such as your mobile device advertising identifier and geo-location data)

    §  Information about your use of our websites. For more
    information, see our Cookie Policy

    In addition, we collect the following information about you from
    third parties:

    §  Your social media interactions with us (for example, when you “like” a post on social media platforms)

    §  Technical information from advertisements we place on third party websites (such as your IP address, browser type and version, device identifiers, location and time zone setting)

  7.  

    3.  How We Use Your Information

    Communications With You – Offerings and Services In Which You
    Expressed Interest:

    When you visit or transact business on this Site, you may be required to register with us or be requested to provide us with personal and account information. When you provide us with this information, we may use it to contact you about the offerings or services in which you have expressed an interest. PEAK has a legitimate business interest to use the personal information we collect from you to provide such requested services. Where we have relied on your consent, however, if you tell us that you do not want us to use this information as a basis for further contact with you (by accessing our opt-out procedure described below), we will respect your wishes.

  8.  

    Communications With You – Newsletters and Marketing Purposes:

    In order to keep our users and clients informed about our latest news, products and services, we may send e-mails and marketing communications to the email address provided to us while registering on our Site or requesting information from us. PEAK complies with applicable laws when using your personal information for this purpose, and where applicable (such as in the EU) relies on your consent. Please be aware that we do sometimes partner with third parties to send marketing communications that promote a third party’s products and services (for example, those of our business partners) as well as our own. If you elected to opt–in to any of our email lists, newsletters or other promotional offerings and later decide that you no longer wish to receive such newsletters or promotional e-mail from us, you may unsubscribe by following the instructions contained in each email we send to you (or use the opt-out procedure described below).

  9.  

    Professional Interactions With You – Customer Relationship
    Management:

    We may use your client relationship data (collected via a
    business card with a PEAK employee or when you communicate with a PEAK employee via phone or email, for example) to provide you with services you request and manage our relationship with you. We may also use certain de-identified and aggregated data about our clients for our internal data analytics purposes. PEAK has a legitimate business interest to use the personal information we collect from you to provide such requested services and in order to be able to service our clients better. With your consent, we may send you information or services or a promotional nature that we consider may be relevant to you.

  10.  

    Other Uses:

    We may also use the personal information we obtain about you for
    the following purposes:

    §  Operating, evaluating and improving our business (including developing new products and services; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, and mobile applications and any other digital assets)

    §  Preparing and furnishing aggregated data reports, which may include anonymized information

    §  Enforcing our Terms and Conditions or other legal rights We also may use the
    information in other ways for which we provide specific notice at the time of
    collection. If you object to us using information in other ways you can e
    mail support@PEAK.com.

  11.  

    4.  Information Provided to Us About You by Third
    Parties

  12.  

    Third-Party Content:

    We may present or embed content on our Site, such as property
    listings, that is provided by our third-party vendors. This content may contain
    links to other sites not operated by PEAK or may request personal information.
    For example, this content may ask for an email address to subscribe to alerts
    or share a listing with a friend. This information is collected by our vendors
    and not by us. In some cases, these vendors may share the personal information
    they collect from you with us. We are not responsible for the privacy practices
    of our vendors. We encourage you to review their privacy policies to understand
    how they will use and share the personal information you provide to them.

    Third Party Usage:

    You may also separately
    share your information with other Web sites or entities, such as those that
    create professional marketing lists, to receive special offers and promotions
    from their affiliates. These Web sites or entities may
    share your information with us
    . PEAK is not responsible for and
    assumes no liability if a partner or other Web site or entity collects, uses or
    shares, any information about you in violation of its own privacy policy, or
    applicable law.

    Marketing Data:

    Where applicable law
    allows, we will purchase marketing data from third parties and add it to our
    existing user database to better target our advertising and to provide
    pertinent offers in which we think you would be interested. We may also
    associate this marketing data to the personally identifiable information that
    you provide to us.

  13.  

    5.  Third Parties with Whom We Share Your Personal
    Information

  14.  

    Third Parties for Retargeting Advertising:

    We will, in some cases,
    share information about how you use our Site with third-party vendors to
    present you with more relevant advertising. For example, our vendors may track
    your browsing activity on our Site using cookies to show you ads based on your
    interests when you browse the Web or use social media. Our vendors will, in
    some cases, also share information about your browsing activity on our Site
    with us for analytics purposes. PEAK relies on your
    consent for such processing of your personal information.
     More
    information on these cookies, including how to provide or revoke your consent,
    may be found in our Cookie Policy below.

  15.  

    Service Providers:

    We may share your personal information with companies acting as
    our authorized agents in providing our services, including the following
    categories of service provider:

    §  infrastructure and IT service providers, including cloud service providers

    §  marketing, advertising and communications agencies

    §  external auditors and advisors

    §  cookie analytics providers

    §  online advertisers

    §  providers of website testing / analytics services

    Each service provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification or disclosure. Because we operate globally, we may transfer your information to countries or jurisdictions that do not provide the same level of data protection as the country in which you are based. If we make such a transfer, we will, or our vendors will, as applicable, provide for the proper safeguards required by applicable law to ensure that your information is protected. More information on International Data Transfers of your personal information is below.

    Where we share your
    personal information for our legitimate interests you can object to this
    disclosure. Please be aware that when you object to disclosure of your personal
    information for PEAK’s legitimate interests it may affect the services we
    provide to you. More information on Your Rights are below.

  16.  

    Legally Affiliated Entities:

    In the event that PEAK is merged, or in the event of a transfer
    of our assets, Site or operations, PEAK may disclose or transfer your personal
    information in connection with such transaction. In the event of such a
    transfer, PEAK will notify you via email or by posting a prominent notice on
    our Site for 30 days of any such change in ownership of PEAK resulting in a
    change of control of your personal information. We may also share your personal
    information with PEAK affiliates in order to provide or offer services to you.

    Legally Compelled Disclosure:

    We will also disclose
    your personal information when required to do so by law, for example, in
    response to a court order or a subpoena or other legal obligation, in response
    to lawful requests by public authorities, including to meet national security
    or law enforcement agency’s requirements, or in special cases when we have
    reason to believe that disclosing your personal information is necessary to
    identify, contact or bring legal action against someone who may be causing
    injury to or interference with (whether intentionally or unintentionally) our
    rights or property.

  17.  

    6.  International Data Transfers

    Processing In the US and Elsewhere by Registration on This Site

    PEAK is a global business. We may transfer the personal
    information we collect about you to recipients, and your personal information
    may be stored and processed, in countries other than the country in which the
    information was originally collected, including the United States and elsewhere
    that may have less stringent data protection laws than the country in which you
    initially provided the information.

    When we transfer your information to countries other than the
    country in which the information was originally collected, we will protect your
    information as described in this Policy or as otherwise disclosed to you at the
    time the data is collected (e.g. via program specific privacy notice) and will
    comply with all applicable data protection laws in making such transfers.

    If you are located in a
    non-US jurisdiction, the transfer of personal information is necessary to
    provide you with the requested information and/or to perform any requested
    service. To the extent permitted by law, such submission also constitutes
    your consent for the cross-border transfer.

    With respect to transfers originating from the European Economic
    Area to the United States and other non-EEA jurisdictions:

    §  PEAK US affiliates are EU-US and Swiss-US Privacy Shield certified, and

    §  PEAK has executed EU Standard Contractual Clauses with respect to personal
    information collected in the European Economic Area and transferred to PEAK in the United States and elsewhere.

    Where allowed by applicable law, you may ask for further
    information on the safeguards that we have put in place to safeguard the
    transfer of your data to outside of the EEA by contacting us as indicated
    below.

    Privacy Shield Certification:

    PEAK complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding personal information that is collected by PEAK affiliates or corporate customers located in the European Economic Area and/or United Kingdom and/or Switzerland and transferred to PEAK, Inc. and its wholly owned US-based affiliates, which include PEAK Global Investors LLC, PEAK GWS Puerto Rico Inc., PEAK Clarion Securities LLC, PEAK Security Services, Inc., PEAK Heery Inc., PEAK HMF, Inc., PEAK Multifamily
    Capital, Inc., PEAK Capital Markets, Inc., PEAK Technical Services, LLC, PEAK
    Hana Operations, LLC, Forum Analytics, LLC and Trammell Crow Company LLC in the
    United States (“PEAK US”). This Policy supplements the data protection notices that Clients and Client contacts may have received.
    PEAK has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer,
    security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. PEAK is subject to
    investigatory enforcement powers of the Federal Trade Commission as it relates to conformation with Privacy Shield requirements.

    Disclosure and Liability for Onward Transfer:

    PEAK is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. PEAK may, as disclosed above in Third Parties with Whom We Share Your Personal Information, transfer personal information onward to third parties. PEAK remains liable under the Privacy Shield Principles if a third party processes such personal information in a manner inconsistent with the Principles, unless we prove we are not responsible for the event giving rise to the damage.

    Independent Recourse of Privacy Shield Complaints:

    In compliance with the EU-US and Swiss-US Privacy Shield Principles, PEAK commits to resolve complaints about our collection or use of your personal information. EU, United Kingdom and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact PEAK at: support@PEAK.com.

     

    7.  Security

    PEAK endeavors to protect the security of your personal information and your choices for its intended use. We use Secure Socket Layers or SSL technology to protect the transmission of sensitive personal information such as your credit card number. We store your personal information on a secure
    server, and use procedures designed to protect the personal information we
    collect from unauthorized access, destruction, use, modification or disclosure.

    Although we will take (and require our third-party providers to take) commercially reasonable security precautions regarding your personal information collected from and stored on the Site, due to the open nature of the Internet, we cannot guarantee that any of your personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.

  18.  

    8.  How Long We Keep Your Personal Information

    We will only retain the personal information we collect about you for as long as necessary for the purpose for which that information was collected, and to the extent permitted by applicable laws. We take steps to ensure that when we no longer need to use your personal information, we remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

  19.  

    9.  Your Privacy Rights

    Marketing Communications:

    When you register on this Site, we may ask you to select whether you would like to receive email and electronic communications from us such as offers, news, reports and other promotional communications. You may withdraw your consent or opt-out of receiving such communications at any time
    by contacting us as described below.

    Additionally, where we process your personal information for our
    legitimate interests you will have the right to object to such processing.
    Please be aware that where you object to this sort of processing it may affect our ability to carry out tasks as listed in this policy.

    You may contact us by sending us an e-mail at support@peakfinancing.com,
    including a copy of the e-mail you have received and by typing “Remove” in the subject line of your e-mail

     

    Your election not to receive newsletters or promotional and
    marketing correspondence from us will not: (i) preclude us from corresponding with you, by email or otherwise, regarding your existing or past relationship with us, and (ii) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal information in the course of maintaining and improving the Site.

    Requesting Access to Your Personal Information and Other Rights:

    You may also have rights under applicable law to request to review, access, correct, delete, port or object to our processing your personal information processed by us, and lodge a complaint with a supervisory authority. If so, you may do so by making a request on PEAK’s
    data subject rights portal
    or submitting your request to support@PEAK.com.

    Independent Recourse for Privacy Shield Complaints:

    Information about independent recourse for Privacy Shield complaints can
    be found above.

  20.  

    10.Changes to this Policy

    We are a rapidly evolving, global business. We will continue to assess this Policy against new technologies and services, business practices as well as our clients’ needs, and make changes to this Policy from time to time as required. If we make any material changes to this Policy, we will make changes here and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes).

     

     

    5.  Cookie Policy – Automatic Data Collection

    By browsing on our Site, you are agreeing to our use of cookies.

    What is a Cookie:

    A cookie is a small text file that a website stores on your personal computer, telephone or any other device, with information about your navigation on that website. Cookies facilitate browsing and to make it more user-friendly. A cookie contains the name of the server it came from, the expiry of the cookie, and a value – usually a randomly generated unique number.
    Cookies do not give access to nor damage your computer.

    1.  Cookie Use by Us

    How we use Cookies:

    We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device
    until they expire, unless you delete them before that time. We group browser
    cookies on our site into three categories, which you can manage through our
    Cookie Preference Manager:

    §  Required cookies: These cookies are necessary to enable the basic features of
    this site to function, such as identifying you as a valid user, ensuring that
    no one else can sign on simultaneously with your account from another computer and helping us serve you better based on your registration preferences. These cookies also allow you to select your cookie preferences.

    §  Functional cookies: These cookies allow us to analyze your use of the site to
    evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, providing us information about how our site is used and helping us facilitate any promotions or surveys that we provide.

    §  Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

    Cookies Are Not Used to Store Sensitive Data:

    The cookies we use do not store sensitive personal information, such as your address, your password, or your credit card data.

  21.  

    2.  Performance Tracking

    We sometimes use cookies, as well as tracking technology, such as web beacons, within the promotional emails that we send to our subscribers or advertisements for our Site. These performance tracking devices help us to
    track whether an e-mail recipient has completed an event, such as signing up
    for a free trial for example. Such information is non-personally identifying
    and collected on an aggregate level. We sometimes utilize third party service
    providers to help us track the activity within our Site. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking but the data would not be tracked in a personally identifiable way.
    Third parties whose products or services are accessible on our Site may also
    use cookies, and we advise you to check their privacy policies for information
    about their cookies and other privacy practices.

    If you would like more information about the third party cookies on our website and to find out more about your choice to not have your information used by third parties, please
    contact us at support@PEAK.com

  22.  

    3.  Managing Your Cookie Preferences

    Cookie Preference Manager:

    Our preference manager allows you to restrict our use of cookies other than Required Cookies. If you use our preference manager on a mobile device, we process your device’s Advertising Identifier. When you access our preference manager, persistent cookies will be set by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. If you clear your browser cookies, this will remove all cookies including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie only knows your last set of preferences and does not reflect the current state of cookies on your browser.

    Do Not Track:

    We currently do not respond to “Do Not Track” signals from your
    browser. Our use of tracking technologies may instead be controlled through our Cookie Preference Manager.

    Avoiding Use of Cookies on this Site:

    If you prefer to completely prevent us from using cookies on your devices, before navigating on this Site, you must first disable the use of cookies in your browser and then delete the cookies saved in your browser associated with this Site.

    Disabling and Preventing Further Use of Cookies:

    You may restrict, block or delete the cookies from this Site at any time by changing the configuration of your browser. You can find out how to do this, and find more information on cookies, at https://www.allaboutcookies.org/. In addition, while each browser has different settings and configurations, cookies settings can typically be adjusted in the “Preferences” or “Tools” menu. Your browser’s “Help” menu may provide additional information.

  23.  

    6.  Contact Us

    You are always free to contact us if you have questions or
    concerns regarding this Policy, have a question or problem related to your use
    of the Site, or wish to exclude your personal information from our direct
    marketing purposes. Our standard business practice is to retain any
    communications from our Site visitors to help us to serve each of you better.

    You may contact us by emailing support@PEAK.com.

     

    2.    In the United States, PEAK’s collection, use and disclosure of certain personal
    information through PEAK’s public websites and professional interactions with PEAK employees is governed by the PEAK Global Web Privacy & Cookie Policy,
    as well as the following state-specific policies, as applicable:

     

    California Consumer Privacy Notice

    Effective Date: January 1, 2020

    This California Consumer Privacy Notice (“Notice”) supplements the information provided in PEAK’s Global Web Privacy & Cookie Policy. This Notice applies solely to consumers who reside in the State of
    California (“you”) and generally explains how PEAK Group, Inc. and
    its subsidiaries (“PEAK”) collect and use Personal Information in relation to your use of our global public websites, your participation in PEAK events and PEAK’s marketing and our business development practices. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.

    We reserve the right to update this Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Information.

    1.    How “Personal Information” Is Defined in this Notice

    2.    Personal Information We Collect, Purposes of Use and Sources

    3.    Disclosure of Your Personal Information

    4.    Sale of Your Personal Information

    5.    Right to Know, Access, and to Delete Your Personal Information

    6.    How to Exercise Your Rights

    7.    Non-Discrimination for Exercising Rights

    8.    Disclosures for Third Parties’ Direct Marketing

  24.  

    9.  How “Personal Information” Is Defined in this Notice

    “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. “Personal information” does not include information publicly and lawfully made available in government records, deidentified or aggregate information about California consumers or households, and information excluded from the CCPA’s scope (for example, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994).

  25.  

    10.Personal Information We Collect, Purposes of
    Use and Sources

    In this section we set out what categories of Personal Information we collect about you, how we use it, and the sources of such Personal information. This section is to be read together with, and supplements, the
    information we provide in our Global Web Privacy & Cookie Policy.

  26.  

    1.  General Information

    For general notice on the categories of personal information we may collect and the business or commercial purposes for the use of such Personal Information, please refer to the following information in the Global Web Privacy & Cookie Policy:

    §  The Types of Information We Collect

    §  How We Use Your Information

  27.  

    2.  Your Right to Know About Personal Information
    Collected in the last 12 months

    In the last 12 months, PEAK has collected the categories of Personal Information described in the table below. The categories included in the table have been defined in a way that we believe will be meaningful to you:

    §  In the second column, we have provided reference to the corresponding category or categories of Personal Information specified in the CCPA. A description of such categories follows directly after this table.

    §  In the third column, we set out the business or commercial purpose for use of such information.

    §  In the fourth column, we set out the categories of sources from which such information was collected.

     

    Categories of PI collected

    CCPA
    Category (See Below)

    Business
    or Commercial Purpose(s)

    Categories
    of Sources

    Contact
    information (such as your name, postal or e-mail address, and phone number),
    Professional Information (such as your name, business or personal email,
    business phone, business address, country in which you do business, your
    industry, job title or role, information about your education and
    qualifications)

    A,
    B, I

    To communicate with
    clients, prospective clients, job candidates, and others with whom we have or
    are inquiring about establishing a business relationship

    To provide offerings
    and services in which you expressed interest

    To send newsletters
    and marketing to you

    For other business
    and marketing purposes

    To
    identify potential candidates for job openings at PEAK. For more information on our recruitment practices, please see
    our 
    US Job Applicant
    Privacy Notice
    .

    Individual directly
    or indirectly

    Publicly-available
    websites

    Third
    parties, including third party vendors who may share personal information
    they collect from you with us

    Account
    information (such as username and password)

    A,
    B

    We
    may require you to create an account to access certain information offerings
    or services

    Individual
    directly

    Client
    Relationship Data (such as business contact information, country in which you
    do business, your industry, job title or role, professional interactions and
    relationship data, including your primary PEAK contacts and your record of
    interactions with PEAK, your contact preferences, and information you provide
    to us which assist us in serving the business relationship, such as the types
    of investments you are interested in)

    A,
    B, D

    To provide offerings
    and services in which you expressed interest

    To send newsletters
    and marketing to you

    For other business
    and marketing purposes

    To
    generate aggregated and de-identified data analytics to improve and better
    manage our client relationships

    Individual directly
    or indirectly

     

    Event
    Attendance Information

    A,
    B, D

    To
    administer and facilitate your attendance at any of our events

    Individual
    directly

    Online
    identifiers (such as your mobile device advertising identifier and
    geo-location data)

    A,
    D, F, G

    To operate, evaluate
    and improve our online business offerings, including developing new products
    and services

    To manage our
    communications

    To determine the
    effectiveness of and optimize our advertising

    To analyze our
    products, services, websites, mobile applications and any other digital
    assets

    To facilitate the
    functionality of our websites, and mobile applications and any other digital
    assets

     

     

    Individual directly
    or indirectly

    Third party vendors

     

    Cookie data

    For
    more information regarding our use of cookies, see our 
    Cookie Policy.

    A,
    D, F, K

     

    Individual directly
    or indirectly

    Third party vendors

     

    Social
    media interactions with us (for example, when you “like” a post on social
    media platforms)

    A,
    B, F, K

     

    Individual directly
    or indirectly

    Third party vendors

     

    Marketing
    Data & Technical information from advertisements we place on third party
    websites (such as your IP address, browser type and version, device
    identifiers, location and time zone setting)

    A,
    C, D, F, K

    To
    better target our advertising and to provide pertinent offers in which we
    think you would be interested

    Third party vendors

     

     

    The 11 enumerated categories under the definition of “Personal
    Information” in the CCPA, some of which are referenced in the second column of the table above, are:

    4.   Identifiers such as 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.

    5.   Any categories of personal information described in subdivision
    (e) of Section 1798.80 of the California Civil Code.

    6.   Characteristics of protected classifications under California or
    federal law, including 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).

    7.   Commercial information, including records of personal property,
    products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    8.   Biometric information (defined in the CCPA as an individual’s
    physiological, biological or behavioral characteristics, including an
    individual’s deoxyribonucleic acid (DNA), that can be used, singly or in
    combination with each other or with other identifying data, to establish
    individual identity. Biometric information includes, but is not limited to,
    imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and
    voice recordings, from which an identifier template, such as a faceprint, a
    minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that
    contain identifying information).

    9.   Internet or other electronic network activity information,
    including, but not limited to, browsing history, search history, and
    information regarding a consumer’s interaction with an Internet Web site,
    application, or advertisement.

    10. Geolocation data.

    11. Audio, electronic, visual, thermal, olfactory, or similar information.

    12. Professional or employment-related information.

    13. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

    14. Inferences drawn from any other type(s) of Personal Information as defined by the CCPA to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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    11. Disclosure of Your Personal Information

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    1.  General Information

    For general information on the categories of third parties with whom we share your Personal Information, please refer to the following information in the Global Web Privacy & Cookie Policy:

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    §  Third Parties with Whom We Share Your Personal Information

  31.  

    2.  Your Right to Know About Personal Information
    Shared in the last 12 months

    In the last twelve (12) months, in the course of operating our business, PEAK has disclosed all of the categories of Personal Information identified in column 1 of the table above to the following categories of third parties for a business purpose.

    §  Our affiliates.

    §  Service providers.

    §  Third parties to whom you or your agents authorize us to disclose your personal
    information in connection with products or services we provide to you, including in government filings.

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    12. Sale of Your Personal Information

  33.  

    1.  Your Right to Know About the Sale of Your Personal Information

    California law requires that we provide you with information about certain disclosures of Personal Information to third parties, where the disclosure involves monetary or other consideration. California treats these disclosures as “sales” of information, even if no money changes hands. In the twelve (12) months preceding January 1, 2020, we “sold” certain categories of Personal Information to third parties for a business or commercial purpose, as described in the chart below. As of January 1, 2020, we do not engage in the sale of Personal Information.

    2.   Categories of Personal Information Sold

    Categories of PI collected

    CCPA
    Category (See Above)

    Categories
    of Third Parties to whom such PI categories were sold

    Contact
    information & Your Professional Information

    A,
    B

    Sponsors
    & Business Partners

    Event
    Attendance Information

    A,
    B, D

    Sponsors &
    Business Partners

     

    Cookie
    data

    A,
    F, K

    Advertising Networks

     


    13.Right to Know, Access, and to Delete Your
    Personal Information

    As a consumer residing in the state of the State of California,
    you have the right to request that: (i) PEAK discloses the categories of
    Personal Information that we collected, the categories of the sources of such
    Personal Information, the business or commercial purposes for collecting such
    Personal Information, the categories of third parties to whom we disclosed such Personal Information, and/or, if we sold or disclosed your Personal Information, the categories of Personal Information that each category of recipient purchased or obtained, and/or (i) that we provide you with copies of such Personal Information. You may make two such (2) requests in any 12-monthperiod.

    Subject to certain exceptions, you may also request that we delete any Personal Information about you that we may hold. We may have grounds to deny your deletion request as provided for in the CCPA.

    Upon receipt of your request to know, for access, or for deletion, we will need to reasonably verify that you are the person about whom we collected Personal Information. We may do so by asking for additional information (“Verifiable Information”) to compare against the information we hold about you, or if you have an account with us, by asking you to log in to that account. We will only use Verifiable Information to verify your identity or authority to make the request. We may also ask you to provide additional detail or clarify your request to allow us to properly understand, evaluate and respond to it.

    Types of Verifiable Information we may ask for depend on the context of your relationship with PEAK, but may include:

    §  Name of a PEAK employee with whom you interacted,

    §  Date or other details of a transaction you had with PEAK,

    §  Email address, phone number, or other contact information we may have on file for you.

    14. How to Exercise Your Rights

    You may exercise your rights to know, access, delete or opt out by completing the form in our Data Subject Rights Portal or by calling us at +1 (866) 428 4722. We will ask for your name, email address, and your relationship to us in order to begin processing your request.

    You may authorize someone to submit a rights request on your behalf. You may do this by providing that person with power of attorney pursuant to the California Probate Code. Alternatively, you may provide that person with signed, written permission to submit requests on your behalf, but we will still require you to verify your identity with us directly by one of the methods listed above. In either case, we will also require that person to verify their personal identity via one of the above methods, or, in the case of a business entity, by response to communications directed at a well-known internet domain associated with that business or to contacts provided in that entity’s official filings with the California Secretary of State.

    15.Non-Discrimination for Exercising Rights

    We are prohibited from discriminating against you because you exercised any of your rights to know, access, delete or opt-out of the sale of your Personal Information.

    16. Disclosures for Third Parties’ Direct Marketing

    Under California’s Shine the Light Act, users of our Website who are California residents may request certain information regarding our disclosure of their Personal Information to third parties (if any), if such information is used for such third parties’ direct marketing purposes. (See Section 4 above). To make such a request, please send an email support@PEAK.com.

     

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