Effective date: July 31, 2020

INTRODUCTION & GENERAL POLICY STATEMENT

The McCaffrey Group Inc., McCaffrey Home Mortgage Inc., Brent’s Realty, Inc. dba McCaffrey Home Realty, Inc. and our affiliated companies (“McCaffrey Homes,” “Company,” “we,” or “us”) are committed to protecting your privacy through our compliance with this policy.  This policy applies to visitors to our website at mccaffreyhomes.com (“Site”), consumers, employees of McCaffrey Homes and job applicants (“you” or “your”).  You may navigate the entire Site without providing any personal information.  Any personal information that we may collect about you is voluntarily provided to us by you. 

This policy describes the types of information we may collect from you, or that you may provide, and our practices for collecting, using, maintaining, protecting, and disclosing that information.  This policy applies to information we collect:

• When you visit or interact with our Site.
• In email, text, other electronic messages or any form of correspondence between you and the Company.
• By phone or in person.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

INFORMATION WE MAY COLLECT

We collect 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”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

The specific pieces of personal information that we collect from you depends upon your purpose for contacting the Company.  Within the last twelve (12) months, we have collected the following categories of personal information from consumers, employees and/or job applicants:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, products and services you inquire about or purchase, and information or applications that you submit to us.
• Indirectly from you. For example, from observing your actions on our Site.
• Third Parties with your consent.  For example, from references, recruiters, or service providers.

USE OF PERSONAL INFORMATION

McCaffrey Homes does not sell your personal information.

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request information, ask a question about, or purchase our products or services, we will use that personal information to respond to and process your request. If you provide your personal information in connection with an employment application, we will use that information to evaluate your application and, if hired, may use the information to provide you with the benefits of your employment.
• To provide, support, personalize, and develop our Site, products, and services.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our employees, Site, properties, products, services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise permitted by law.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING OF PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

            Category B: California Customer Records personal information categories.

            Category C: Protected classification characteristics under California or federal law.

            Category D: Internet or other similar network activity.

            Category E: Geolocation data.

            Category F: Professional or employment-related information.

            Category G: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.

OTHER INFORMATION WE COLLECT

We may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including details of your visit to our Site such as traffic data, location data and resources accessed and information about your computer and internet connection. 

The information we collect automatically is only statistical data and does not include personal information.  It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to estimate our audience and usage patterns and customize our Site according to interests.

The technologies we use for this automatic data collection may include:

• Traffic data.  We may automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; and (4) types of web browsers used to access the Site.
• Cookies (or browser cookies). We use cookies on this Site. We use our own cookies to recognize you and your login information, and we use other companies' cookies, such as Google, Inc. ("Google") to analyze how our Site is used and to optimize it for our customers and guests. Google Analytics uses cookies to help us analyze how browsers use our Site and third party websites, but Google only receives a truncated IP address, not information sufficient to identify you personally.IF YOU DON'T WANT TO CONSENTto our use of cookies or tracking technology, you must block or disable them with your web browser settings or opt-out via the link below.
  For information about cookies and to learn how to block, disable, reject and delete them, please GO TO www.aboutcookies.org.
  To opt-out of analysis by Google Analytics on our Site and other websites, GO TO https://tools.google.com/dlpage/gaoptout
  If you choose to use our Site without blocking or disabling cookies, or opting out of other tracking technologies, you consent to our use of these cookies and tracking technologies, and to our use of any Personal Information we collect from using them.

• Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Site may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
  For each particular device, individuals may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by visiting https://optout.networkadvertising.org/?c=1 or the Digital Advertising Alliance visiting https://optout.aboutads.info/?c=2&lang=EN.  Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
  In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
  If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

• Do Not Track.Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

CHILDREN UNDER THE AGE OF 16

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Site. We do not knowingly collect personal information from children under 16.  If you are under 16, do not use or provide any information on this Site or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 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 16, please contact us at (see Contact Information below).

YOUR RIGHTS AND CHOICES

The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. This section does not apply to personal information we collect from employees and job applicants.

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• 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 share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request)..

Deletion of Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.).
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.

Exercising Access, Data Portability, and Deletion of Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 888-256-0003
• Emailing us at privacy@mccaffreyhomes.com or privacy@mccaffreyhomemortgage.com
• Write us at The McCaffrey Group, Inc., Attn: Privacy Rights, 7020 N. Van Ness Blvd., Fresno, CA 93711.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Name, phone number, e-mail address or other information we can confirm against our records.
• 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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.  If applicable, the response we provide will explain any reasons why we are unable to comply with a request.

PROMOTIONAL OFFERS FROM THE COMPANY

If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@mccaffreyhomes.com or privacy@mccaffreyhomemortgage.com. If we have sent you a promotional email, you may follow the “Unsubscribe” link at the bottom of the email.

NON-DISCRIMINATION

We 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.

OTHER CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us at The McCaffrey Group, Inc., Attn: Privacy Rights, 7020 N. Van Ness Blvd., Fresno, CA 93711.

CHANGES TO OUR PRIVACY POLICY

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

CONTACT INFORMATION

If you have any questions or comments about this privacy policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

              Phone: 888-256-0003

              Email: privacy@mccaffreyhomes.com or privacy@mccaffreyhomemortgage.com

              Postal Address:
              The McCaffrey Group, Inc.
              Attn: Privacy Rights
              7020 N. Van Ness Blvd.
              Fresno, CA 93711