Topa Equities, Ltd. dba Anderson Holdings, Topa Property Group dba Anderson Real Estate, and Duesenberg Investment Company (collectively, “Topa” or the "Company") are committed to treating the personal and corporate information of our customers, vendors, and website visitors with respect and sensitivity.
If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any CCPA-specific information is identified in this Policy. Explanation of your rights under the CCPA can be found here.
Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., California). Otherwise, the Policy applies to all users of our Services, regardless of location.
Children. The Services of the Company are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in the United States means someone under the age of 13) has provided us with personal information without parental consent, contact us at the location identified below in the Contact Us section.
We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, request information, apply for employment, or obtain any other Services.
For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession).
When providing our services, in the employment context, or for prospective employees, the Company collects only the following categories of Personal Information as defined by the CCPA:
Identifiers Name, address, email, phone.
Other Data Certain financial information, and for employees and prospective employees, possibly medical and health information
Professional Data For employees and prospective employees, CV, resume, employment history, etc.
Education Data For employees and prospective employees, educational background, grades, scores, etc.
For visitors to our Sites we collect some limited types of the following category of Personal Information as defined by the CCPA:
Internet Activity Browsing history, search history, IP address, website interactions
Topa does not sell your Personal Information to any Third Parties or disclose your personal information to third parties for any business purpose.
• To provide you with the information or Services that you request from us
• To carry out our obligations arising from any contracts entered into between you and us, or between you and any of our affiliates
• To notify you about changes to our Services
• To comply with applicable laws and regulations
• To perform data analyses (including anonymization and aggregation of Personal Information)
• For prospective employees, to respond to and process your job application and CV
When you visit our sites, our web server automatically collects and stores some information using Google Analytics cookies. Like most websites, we collect information such as time of visit, frequency of visits to our Sites, duration of visit, unique client ID, and IP address.
We do not collect any other categories of information from website visitors.
Information we receive from other sources.
Topa may occasionally receive information from our subsidiaries and affiliated companies. In those situations, we will use the information for the purposes set forth above and in the privacy policies of the subsidiary or affiliate.
Topa uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.
We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you for as long as is necessary to protect us from a legal claim.
The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section.
6.1 Right to Know About Personal Information Collected, Used, Disclosed, or Sold
California consumers have the right to request that the Company disclose what personal information it has collected, used, disclosed, and sold over the 12-month period preceding the Company’s receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in the Contact Us section.
6.2 Right to Request Deletion of Personal Information
California consumers have the right to request the deletion of their personal information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in the Contact Us section.
6.3 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that the company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data).
6.4 Submitting a CCPA Data Request
To submit a request to know about the Personal Information we collect about you as described in Section 6.1 or a request for deletion of your Personal Information as described in 6.2, please contact us by calling this toll free number 1-855-761-TOPA (8672) or by emailing us at CCPA@andersonholdings.com.
We are required to verify the identity of the individual submitting a request to know or delete a request. To verify your identity, you must provide:
• If Topa has previously received your email address, Topa may verify that you have access to that email address by sending a verification code; or
• Verification of government issued identification. In the event the person requesting the information is not the individual we have on record Topa may require legal documents to support the requestor’s legal authority to obtain and access those records
6.5 Authorized Agent
California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:
• Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
• Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465
6.6 Exclusion for Business to Business Information
The rights set forth in this section do not apply to personal information reflecting a written or verbal communication or a transaction between Topa and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with Topa occur solely within the context of Topa conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency.
6.7 Exclusion for Employee Data
The rights set forth in this section do not apply to personal information that is collected by Topa about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Topa to the extent that the natural person's personal information is collected and used by Topa solely within the context of the natural person's role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of Topa..
Topa Equities, Ltd.
Attn: Privacy Manager
1900 Avenue of the Stars
Los Angeles, CA 90067
CCPA-Specific Requests: Please submit CCPA-specific data requests through the procedures set forth in Section 6 above.
Updated October 2021