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Updated June, 2020

California Consumer Privacy Policy

Bellwether complies with the California Consumer Privacy Act (“CCPA”) in handling the Personal Information of California residents.  This California Consumer Privacy Act Policy (“CCPA Policy”) supplements the information and disclosures already contained in our Privacy Policy.  Our CCPA Policy applies to all individuals residing in California from whom we collect Personal Information.

 

The chart below outlines the categories of Personal Information (as defined by the CCPA) that Bellwether has collected and/or disclosed for a business purpose in the preceding twelve (12) months. The examples of Personal Information provided in each category are taken from the CCPA and are included to help you understand what the categories mean.  They are not meant to indicate what Bellwether actually collects or discloses.  More information about our specific practices can be found in our Privacy Policy.

Use of Personal Information: The CCPA defines various business and commercial purposes for collecting, using and disclosing your Personal Information.  We collect your Personal Information in accordance with our Privacy Policy as a whole, but wanted to clarify that this also includes collection in accordance with specific CCPA-approved purposes below:
 

  1. Auditing related to a current interaction with you;

  2. Detecting security incidents;

  3. Identifying and repairing errors that impair functionality;

  4. Short-term, transient use;

  5. Contracting with service providers to perform services for us, including but not limited to providing analytic services and advertising services;

  6. Undertaking internal research to improve our technologies and demonstration of those technologies;

  7. Undertaking activities to maintain the quality of our services and to improve our services; and

  8. For other purposes for which we provide specific notice at the time the information is collected.

Collection and Disclosure of Personal Information: In the months since this notice was last updated, Bellwether has collected Personal Information on you, your use of our services, your devices, our affiliates, our vendors and our service providers. 

We share your Personal Information with the following categories of third parties as defined by the CCPA:

  1. Affiliates;

  2. Vendors and service providers including for date analytics and marketing purposes;

  3. Third parties integrated into our services;

  4. Third parties as required by law and similar regulatory disclosure requirements; and

  5. Other third parties from whom we obtained your permission to disclose your Personal Information.

Your California Privacy Rights:

If you are a California resident, you may exercise the following rights at any time:

  1. Right to know and access:  You may submit to Bellwether a verifiable request for information regarding the categories of Personal Information we collect or disclose, the purposes for which we collect that information, the categories of sources from which we collect that information, and/or specific pieces of Personal Information we collected about you during the past twelve (12) months;

  2. Right to delete: Subject to certain limited exceptions, you have the option to ask Bellwether to delete Personal Information about you that we have collected during the past twelve (12) months;

  3. Right to opt-out of sales (opt-in for minors): Not relevant, as we indicated above we do not sell your Personal Information; and

  4. Right against discrimination: You have the right not to be discriminated against for exercising your rights under the CCPA.

Note that your CCPA rights are subject to certain conditions and exceptions such as limitations on your right to know pursuant to legal privileges and according to Cal. Civ. Code Sec. 1798.105(d).

How to submit a request under the CCPA:

In order to exercise your right to know or your right to delete, please email us at info@bwecap.com and include “CCPA Request” in the subject line. 

Please include in your request:

  1. Full name and address;

  2. Former name (if applicable);

  3. Date of birth;

  4. Contact information (telephone number or email address);

  5. Your relationship to us (e.g., site visitor, client, etc.)

To ensure we are releasing data to the right person, you must also provide sufficient proof of identity to confirm you are entitled to the information requested.  We reserve the right to modify the proof we require based on the nature of your request and your relationship to us.  Please transmit any identification documents through secure communication channels.  We do not accept originals of identification documents. 

If you are requesting information on behalf of another individual, you must include identification for both yourself and the individual along with a copy of the written authorization to obtain you received.

We will endeavor to respond promptly to all information requests. 

As a general rule, Bellwether is not permitted to charge a fee when you exercise your right to information under the CCPA; however, if the request is patently excessive, we are allowed to charge a reasonable fee or refuse to act on the request.

How can individuals with disabilities access these disclosures?  Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of our CCPA Policy.

© 2020 by Bellwether Enterprise Real Estate Capital, LLC, a subsidiary of Enterprise Community Investment, Inc. Bellwether Enterprise is a national, full-service commercial and multifamily mortgage banking company that puts people and communities first. As a subsidiary of Enterprise Community Investment, Inc., we support its mission of creating and preserving affordable housing in thriving communities. With an unwavering commitment to regional expertise and unmatched customer service, we are making an impact beyond the bottom line.  We provide a variety of loan products from Life Insurance Companies and Pension Funds, Freddie Mac Targeted Affordable Housing Lender and Optigo® Lender, Fannie Mae Delegated Underwriting and Servicing (DUS®) - Multifamily Affordable and Market Rate Housing Lender, FHA, USDA and CMBS to name a few. We are Capital on a Mission. 

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