Privacy Policy
1. Overview
This Privacy Policy describes our online and offline practices in the collection, use, and disclosure of your personal information, and the rights you have regarding your personal information. In this Policy, the terms “Bosa Development,” “Bosa,” “company,” ”us,” “we,” and “our” refer to Bosa Development and its affiliates and subsidiaries.
2. Who This Policy Applies To
This Policy applies when you visit or use our websites where this policy is posted (each a “Site” and collectively “Sites”), contact our customer service team, purchase our products or services, or otherwise interact or communicate with us.
3. How We Collect, Use, and Share Your Personal Information
As further described in the table below, we collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with our consumers (“Personal Information”). Personal Information does not include publicly available information from government records, deidentified information, or aggregated information.
The following table describes the categories of Personal Information we may have collected in the last twelve (12) months, along with the corresponding categories of sources, purposes, and third parties with whom we shared your Personal Information.
| COMMERCIAL INFORMATION | ||
|---|---|---|
| We collect records of your property, purchases, or deposit amount and any properties considered. | ||
| We collect this information directly from you. |
We use this data is to:
|
We disclose this data to the following categories of third parties:
|
| FINANCIAL INFORMATION | ||
|---|---|---|
| We collect payment information | ||
| We collect this information directly from you. |
We use this data to:
|
We disclose this data to the following categories of third parties:
|
| INTERNET OR NETWORK ACTIVITY | ||
|---|---|---|
| We collect IP address, cookie data, browser type, traffic patterns, network and website interaction history, browsing time, and pages visited. | ||
| We collect this information from you indirectly through your Site usage and activity. |
We use this data:
|
We disclose this data to the following categories of third parties:
|
| PERSONAL IDENTIFIERS | ||
|---|---|---|
| We collect name, postal address, telephone number, email address, and business contact information. | ||
| We collect this information directly from you. |
We use this data to:
If you apply to work with us, we also use this data to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process. |
We disclose this data to the following categories of third parties:
|
| GEOLOCATION DATA | ||
|---|---|---|
| We collect IP address, cookie data, browser type, traffic patterns, network and website interaction history, browsing time, and pages visited. | ||
| We collect this information from you indirectly through your Site usage and activity. |
We use this data:
|
We disclose this data to the following categories of third parties:
|
4. Combination of Information
We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
5. How We Use Cookies
We use cookies, tags, and similar technologies to improve functionality, monitor site activity, and customize your user experience. A cookie is a small piece of text that is placed on your website browser, device, or hard drive when you visit a site. We use cookies to analyze how you interact with our site. This enables us to monitor and improve our site performance, services, and your experience. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, understand online activity, and monitor and improve our site performance, services, and your experience. You can change your preferences regarding our use of cookies by clicking and changing your cookie preferences.
Session Replay Technology
We use session replay technology on our Site. Session replay technology, also referred to as session playback or user experience replay, collects information regarding, records, and tracks your interactions with a website or application. It then and transforms those logged user events (such as mouse movements, clicks, page visits, scrolling, tapping, etc.) into a reproduction of what you actually did on the website or application. We use session replays for quality control, customer service, fraud prevention and security, and marketing purposes. Our session replay technology is owned and operated by a third-party who acts as our service provider. The information collected by this technology may be collected by, transferred to, and stored by our third-party service provider.
Cross-Context Behavioral Advertising
We allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. Our advertising partners may collect information about your activities on our Site on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may also collect IP address, browser or operating system type and version, and demographic or inferred-interest information, as well as personal information if you have submitted such information to us through the Site, such as your name, postal address, email address, or device ID. They collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies. For example, our advertising partners may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use. They may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. These third parties partners use this information for our and their own advertising, analytics, attribution, and reporting purposes. To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by clicking and changing your cookie preferences to disable analytics and advertising cookies.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit
www.allaboutdnt.com.
Google Analytics
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at
//tools.google.com/dlpage/gaoptout.
6. How We Collect Information on Minors
Our products and services are intended for users who are 13 years or older. We do not knowingly collect information from children under 13 years old. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at info@andiasandiego.com. If we learn that we have collected the information of a child under 13, we will delete such information from our records.
7. How We Retain Your Information
To the extent permitted by applicable law, Bosa Development will retain your Personal Information for as long as the company believes it is necessary to fulfill the purposes for which it was collected, including for the purpose of meeting any legal, accounting, or other reporting requirements or obligations, and other legitimate and essential business purposes. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future.
We use the following criteria to determine retention periods:
- how long the information is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data, and
- what the expectation for retention was at the time the data was provided to us.
8. Processing in the United States and Canada
Please be aware that information we obtain about you will be processed in the United States and across Canada by or service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States, Canada or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.
9. California Privacy Rights
Shine The Light. If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@insightglobal.com and include “CA Shine the Light” in the subject line of your email.
California Consumer Privacy Act.
Use or Disclosure of Sensitive Personal Information
In the preceding 12 months, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Sale or Sharing of Personal Information. In the preceding 12 months, we have “sold” or “shared” (as those terms are defined in the CCPA) identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to marketing/analytics/advertising partners. We do not knowingly sell or share the personal information of minors under the age of 16.
Your Rights
Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
- You have the right to request that we tell you (i) the categories of personal information we have collected, sold, or shared about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed, sold or shared personal information.
- You have the right to request that we provide you with a copy of your personal information.
- You have the right to request that we delete personal information that we have collected from you.
- You have the right to opt-out of the sale of your personal information.
- You have the right to opt-out of the sharing of your personal information for cross-contextual behavioral advertising.
- You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA.
- You have the right to correct inaccurate personal information that we hold about you.
- You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights
To exercise any of your rights, please email us at info@andiasandiego.com. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.
If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at info@andiasandiego.com.
Cookie Based Opt-Outs for Do Not Sell or Share for Cross Context Behavioral Advertising
We engage in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising. In addition to contacting us, you may need to disable sharing through cookies set by third parties on our Sites. To manage your cookie preferences, please click and ensure that Analytics and Advertising cookies are disabled
Global Privacy Control and Opt-Out Preference Signals
Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” or other opt-out preference signals. If you have enabled Global Privacy Control or an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Site by disabling analytics and advertising cookies. We will respond to these signals in a frictionless manner. Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. If you configure this setting on your browser, certain features on our site may not work and you will receive less targeted advertising. You will also only be opted out of online sales or sharing of personal information through your use of the global privacy control or opt-out signal, and will need to turn it on for each browser you use. Refer to the “Exercising Your Rights” above if you would like to extend your opt-out request beyond the online advertising practices described above.
10. Canada Privacy Rights
Your Rights
If you are a resident of Canada, subject to certain exceptions and limitations, you have the following rights:
- Your right of access: Upon your written request, subject to certain exceptions, we will inform you of the existence, use, and disclosure of your personal information and will provide you with a copy of that personal information within the timeframes provided for by law. Access requests should be sent to us using the contact information below. We try to respond to all legitimate requests within one month. Occasionally, if required or permitted by law, it could take us longer than one month if your request is particularly complex or you have made a number of requests. In these cases, we will notify you and keep you updated. Depending on the scope of your request, or if you require additional copies, we may need to charge you a reasonable fee where permitted under law.
- Your right to rectification: If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we will let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
- Your right to be forgotten: If you are a resident of the province of Quebec, you have the right to control the dissemination of your personal information. As such, you may request that we de-index (i.e. delist from search results) any hyperlinks associated with your name and that provide access to your personal information if the underlying dissemination of your personal information contravenes the law or a court order, or if it otherwise causes serious injury to your reputation or privacy. This also includes your right to re-index (i.e. list in search results) any hyperlinks associated with your name where doing so can prevent the perpetuation of a serious injury to your reputation or privacy. You can contact us for assistance in deleting personal information previously provided to us. Please note that we will take a reasonable amount of time to process your request.
- Your right to personal information portability: If you are a resident of the province of Quebec, you have the right, in certain circumstances, to obtain the personal information that you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your rights in relation to automated decision-making and profiling: If you are a resident of the province of Quebec, you have the right to know if we use your personal information to render a decision based exclusively on automated processing of such information. Upon request, you also have the right to know the categories of personal information used to render the decision, the reasons, and the principal factors that led to that decision. You have the right to correct the information used to render the decision, if you notice any inaccuracy. Lastly, you can submit observations in support to a request to review any automated decision reached using your personal information.
- Your right to request information about data processing: You may contact us to request information about our data processing activities, namely what personal information was collected from you and how process it. You may ask us to clarify the categories of persons that have access to your personal information and the applicable retention period for that information.
- Your right to withdraw consent, deactivate your account, or unsubscribe: You have the right to withdraw that your consent to our collection, use, and disclosure of personal information at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising Your Rights.
To exercise any of your rights, please email us at info@andiasandiego.com. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
11. External Links
Our Privacy Policy applies only to your use of the Bosa Development website. This website may contain links to other sites. These sites are governed by their own privacy statements and policies, and Bosa Development is not responsible for their operations, including but not limited to their information practices. We do not disclose personal information to those operating linked sites and we are not responsible for their practices. Links to other sites do not disclose personal information to those operating linked sites and we are not responsible for their practices. Links to other sites do not imply our endorsement of the materials or policies on those websites. Bosa Development encourages you to review the privacy statements of websites you choose to link to from Bosa Development so that you can understand how those websites collect, use and share your information. Bosa Development is not responsible for the privacy statements or other content on websites outside of the Bosa Development and Bosa Development family of websites.
12. Disclaimer
Nothing in this Policy will restrict Bosa Development’s ability to otherwise:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law; or
- Exercise or defend legal claims.
13. Changes to this Policy
From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.
14. Resolving Concerns and How to Contact Us
If you have questions or concerns regarding this Policy or the handling of your Personal Information, please email us at info@andiasandiego.com.
Effective August 24, 2024
Last Updated: May 2, 2024
