Hughes Marino Data Privacy Policy

Last Updated: 12/7/2023
Last Reviewed: 12/7/2023

Your privacy is important to us. Hughes Marino, Inc. and its subsidiaries and affiliates (collectively “Hughes Marino”, “we”, “us”, and “our”) respect your privacy concerns and recognize the importance you place on protecting your privacy. This privacy policy (“Privacy Policy” or “Policy”) applies to your use of our website, as well as your interactions with Hughes Marino employees, agents, and contractors (collectively our “Services”). This Policy describes how we collect, use, share, and protect your personal information (“Personal Information” or “Personally Identifiable Information”). This Privacy Policy also explains your rights and choices provided by law and lists multiple ways to contact us for more information or to make a request concerning this Policy or your Personal Information. By providing information to us or by using any of our Services, you indicate that you have read, understood, and agree to the terms and conditions of this Privacy Policy.

Types of Information We Collect
How We Collect Information
Cookies and Third Party Information
How We Use Your Information
How We Store and Protect Your Information
Linking to Other Sites
How We May Share Information We Collect
Your Choices and Control Over Your Personal Information
Rights of California Consumers
California Consumer Privacy Notice
Changes to Our Privacy Policy
Hughes Marino Contact Information

Types of Information We Collect

As an integral part of our business and in order to provide our Services, we routinely collect our clients’ Personal Information. We regularly collect Personal Information from the following categories, and therefore have collected Personal Information from each of these categories in the preceding 12 months.

  1. Identifiers
    • Your name, postal address, e-mail address, or phone number
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Section 1798.80(e))
    • Your name, signature, physical description, education, employment, or medical information that is limited to descriptions concerning health symptoms, test results, and vaccination status
  3. Protected classification information
    • Your age, religion, marital status, gender, or military status
  4. Commercial information
    • Records of your personal property, products or services purchased, or other consuming histories or tendencies
  5. Internet or other similar network activity
    • Your interactions with our website (including cookies) and marketing materials
  6. Geolocation data
    • Information collected automatically via our website or shared with us directly by you
  7. Your professional or employment-related information
    • Your current or past job history
  8. Inferences drawn from other Personal Information
    • Your attitudes and abilities
  9.  Sensitive Personal Information
    • Your social security number, driver’s license, state id, or passport number, financial account information, and racial or ethnic origin

Please note Personal Information does not include certain types of publicly available information, de-identified data, or aggregated information.

How We Collect Information

Hughes Marino obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you:
    • for example: from forms you fill out on our website or in person, or from emails and other communication with Hughes Marino employees, agents, and contractors; and
  • Indirectly from you:
    • for example: from observing your interaction with our website or marketing emails, or from interactions you have with Hughes Marino employees, agents, and contractors; and
  • From third-party business partners:
    • for example: social media sites or ad networks.

Cookies and Third Party Information

Please note, when you visit our website, we and our trusted partners may use cookies (small text files, each containing a string of characters, that are sent to your computer when you visit a website) or similar technologies to identify your browser or device. Most browsers recognize when a cookie is offered and allow you to refuse or accept it. Your browser’s help menu should show you how to modify how it treats cookies. Cookies are used to enhance your online experience and are not used to track your navigational habits, unless we otherwise obtain your permission to do so. Depending on how you visit our website, some of the information we collect will be used to identify you and some of the information we collect is anonymous. We use the information we collect to make our website more useful and engaging for all our clients, and to help provide you Services.

Our website currently utilizes cookies to perform strictly necessary functions, as well as improve website performance. There are also targeting cookies present on our website. Strictly necessary cookies are used to distinguish between human and bot website visitors. Performance cookies assist us in curating the performance of our website, we use them to collect information such as unique users, page visits, and session data. Targeting cookies may provide us with information about what advertising has been viewed prior to coming to our website and general geographic location of browsers and target ads.

You can control our use of cookies on the website through the opt-out banner at the bottom of this page. If you have already interacted with the opt-out banner and you would like to review or change your choices, you can access the banner by clicking on the circle icon at the bottom left of the page.

We may receive personal information about you from third parties, including, for example, information about your relationships with various product and service providers and your use of certain applications. For example, if you access our web pages through a third-party account, such as Disqus, Facebook, Twitter, Instagram, or Google, that third party may pass certain information about your use of its service to us. This information could include the user ID associated with your account, any information you have allowed the third party to share with us, and any information you have made public in connection with that service. You should always review your privacy settings on third-party websites and services before using them to log-into/access our website.

Some third-party websites do track your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, most browsers allow you to set the DNT signal through your browser settings so that third parties (particularly advertisers) know you do not want to be tracked.

Third parties that have content embedded on our website, such as a social feature, may set cookies on a user’s browser or obtain information about the fact that a web browser visited our website from a certain IP address. Third parties cannot collect any other Personally Identifiable Information from our website unless you provide it to them directly.

How We Use Your Information

We use the Personally Identifiable Information listed from A through I above in a variety of ways, including:

  • To perform services on behalf of Hughes Marino, this may include:
    • contacting or meeting with our clients in person or in other communal settings when they express interest in our services; and
    • providing real estate services to our clients and otherwise managing our client relationships.
  • To perform direct marketing services, this may include:
    • sending emails and other marketing communications to keep our past, current, and future clients informed about our latest services, products, and news (you may always choose to opt out of receiving this information by contacting Hughes Marino via the instructions contained in the email or by using any method of contact information listed below);
  • To respond to law enforcement requests and as otherwise required by applicable law, court order, or government regulations.

We may also use de-identified and aggregate data about our clients for our own analytical purposes as they relate to our legitimate business needs. We use this and other Personal Information to provide better Services to our current clients and to reach out to potential clients who may benefit from working with us. We continually strive to operate, evaluate, and improve our business practices (including developing new service lines, managing our communications, and evaluating our marketing strategies) so that we may provide optimal Services to our clients.

We will notify you before we collect additional categories of Personal Information or use your Personal Information for a purpose that is different from or in addition to the purposes already stated in this Privacy Policy. Unless you ask us not to, we may contact you in the future to tell you about our Services or to notify you about changes to this Privacy Policy.

How We Store and Protect Your Information

At Hughes Marino, we recognize our responsibility for protecting your privacy and Personal Information. We seek to use reasonable organizational, technical, and administrative measures that are designed to safeguard your Personal Information. 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. In the event that information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation, and, where appropriate, notify those individuals whose information may have been compromised and take any additional steps in accordance with applicable laws and regulations.

Linking to Other Sites

Our website may contain links to other websites that are not operated or controlled by Hughes Marino. These linked websites likely contain their own, different policies regarding the collection, use, and safeguard of your Personal Information. We are not responsible for the privacy practices or content of such linked websites. The links on our website do not imply that we endorse or have reviewed such companies’ privacy policies, if any, nor does a link imply an affiliation with the third party. We strongly encourage you to review the privacy policies of any third party when linking to such websites.

Please note that we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, social media platform provider, or operating system provider, including any information you disclose to other organizations through or in connection with our social media pages.

How We May Share Information We Collect

With the exception of medical information, we distribute the Personal Information listed from A through I above with our service providers, contractors, business partners, and corporate affiliates, with other parties you may authorize, and with parties as and when required by law, or in other circumstances. Therefore, we have disclosed our clients’ Personal Information listed from A through I above in the past 12 months.

We disclose Personal Information to these parties in order to provide our services, including real estate services and benefits to employees.

Hughes Marino does not sell your Personal Information. Limited personal information, such as approximate geolocation data, website advertising interactions, and browser/device information, is shared with third parties through cookies on our website. You can control our use of cookies on the website through the opt-out banner at the bottom of this page.

Some of the Personal Information we collect is categorized as “sensitive.” For example, if we are collecting information for employment, we may ask for social security or banking details. We do not use or disclose sensitive personal information for purposes outside of the limited expectations set forth in the California Civil Code, and we do not collect sensitive personal information with the purpose of inferring characteristics about a consumer.

Your Choices and Control Over Your Personal Information

You have several choices available when it comes to your Personal Information, and we will honor the choices you make to protect your privacy.

If you would like to review or request changes to any of your Personally Identifiable Information that we maintain, please contact us using any method of contact information listed below.

You may also contact us at any time to change your subscription preferences to any of our marketing material. Subscription preferences can also be updated by clicking on an “unsubscribe” hyperlink contained in promotional emails sent by us or on our behalf. Please be aware that even if you opt-out of receiving future promotional communications from Hughes Marino, you may still receive specific transactional communications that relate to past, present, or future business partnerships with Hughes Marino.

California consumers may be offered additional control over their Personal Information as described in the Rights of California Consumers section below.

Rights of California Consumers

Residents of California are offered additional and specific rights as indicated by the California Consumer Privacy Act of 2018 (the “CCPA”). If we have collected personal information because of a written or verbal communication or transaction for services on behalf of a business as part of your employment duties, and such communication or transaction occurs while acting on behalf of a business and solely related to these transactions or services, these rights will not apply to you.

If you are not a California resident, these rights will not apply to you.

These rights include:

The Right to Access Your Personal Information

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, 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 that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific pieces of Personal Information we have about you; and
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • Sales – identifying the Personal Information categories that each category of recipient purchased; and
    • Disclosures for a business purpose – identifying the Personal Information categories that each category of recipient obtained.

The Right to Request Deletion of Your Personal Information

You have the right to request that we delete your Personally Identifiable Information that we have collected from you and retained (subject to certain exceptions). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your request if retaining your Personal Information is necessary to perform any of the following actions, among others:

  • Complete the transaction for which we collected your Personal Information, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Comply with the California Electronic Communications Privacy Act; or
  • Comply with a legal obligation.

The Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate Personally Identifiable Information that we have collected about you and retained. Once we receive and confirm your verifiable consumer request, we will correct the personal information at issue on our systems.

We will also instruct any service providers or contractors that maintain the personal information at issue, due to their connection with Hughes Marino, to make the necessary corrections in their respective systems.

We may deny your request to correct the Personally Identifiable Information if:

  • We are unable to satisfactorily verify your identity in relation to the information maintained;
  • We are unable to determine if the correction is accurate based on surrounding circumstances; or
  • We are unable to reasonably complete the request – you will be provided with an explanation if this is the case.

We may also delete the contested personal information as an alternative if the deletion is not viewed to negatively impact you; or if we receive your consent to the deletion.

The Right to Opt-Out of the Sale or Sharing of Your Personal Information and the Right to Limit the Use of Your Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your information. This is often referred to as the right to “opt-out.” You can exercise your opt-out rights by using the opt-out banner at the bottom of this page or by contacting us directly through the contact information below. If you have already interacted with the opt-out banner and you would like to review or change your choices, you can access the banner by clicking on the circle icon at the bottom left of the page.

Some browsers will allow you to set an Opt-out preference signal that will then be communicated to a business that sells or shares personal information to inform them of your choice to opt-out.

The right to Limit the Use of your Personal Information can be asserted when a business utilizes your Personal Information for purposes outside of what you would expect them to be. The Personal Information collected by Hughes Marino is utilized for specific business purposes and information is not collected for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes outside of the limited expectations set forth in the California Civil Code, and we do not collect sensitive personal information with the purpose of inferring characteristics about a consumer.

The Right to Non-Discrimination

You have the right to non-discrimination. Hughes Marino will not discriminate against you for exercising any of your CCPA rights. We will not:

  • Deny you services;
  • Charge you different prices or rates for services;
  • Provide you a different level or quality of services; or
  • Suggest that you may receive a different price or rate for services.

How to Make a Request

Residents of California may contact us to exercise any of their rights under the CCPA by either:

Only you or an agent authorized to act on your behalf may make a request under the CCPA regarding your Personal Information. You may only make a “request to know” to Hughes Marino under the CCPA twice within any 12-month period, and we must be able to verify your identity in order to respond to your request. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information; and
  • Provide sufficient detail that allows us to understand, evaluate, and respond to it.

Verifying a California Consumer Request

In order to further protect our clients’ privacy and as required under the CCPA, we must verify each request that comes to us under the CCPA before we supply the information or take the action as requested. In order to verify your request, we may ask you to provide several pieces of Personal Information that we may use to match with your Personal Information that we already maintain. Please note that requests made through an authorized agent are subject to separate verification of the consumer’s identity. We will only use Personal Information provided in a CCPA request to verify the requester’s identity or authority to make such request. If we are unable to verify your identity, we will explain to you why your identity cannot be reasonably verified in light of the nature of your request, and we therefore may not be able to process your original request.

California Consumer Privacy Notice

California Consumers may also receive a Privacy Notice which details additional information required under the CCPA. This notice is complementary to the information found in this Privacy Policy and can be accessed here.

Children’s Policy

Our Services are not intended for children under the age of 16 and we do not knowingly or intentionally collect Personal Information from children under 16 online. If we discover that we have inadvertently collected Personal Information from a child under 16 it will be deleted.

Changes to Our Privacy Policy

We may revise this Privacy Policy at any time. We will continue to evaluate this Policy against new technologies and business practices, as well as our clients’ needs and preferences, and we reserve the right to update, change, amend, or modify this Privacy Policy at any time and from time to time without prior notice unless otherwise required by law. Please review this policy periodically.

If we make any material changes to this Privacy Policy (as determined by us), we will post a notice on our website and update the date of the Policy.

This Privacy Policy was last updated on the date indicated above. Your continued use of our Services, including your decision to supply Hughes Marino with Personal Information, indicates your agreement with the terms of such revised and then-current Privacy Policy.

Hughes Marino Contact Information

Hughes Marino operates this website from its headquarters in San Diego, California. If you have any questions or comments about this Privacy Policy, the ways in which Hughes Marino collects and uses the Personal Information described in this Policy, your choices and rights regarding our use of your Personal Information, or if you wish to exercise your rights under any applicable laws, please reach out to a member of our team using any of the following contact methods.

Phone:1-833-389-0117
Email:Privacy@HughesMarino.com
Address:Hughes Marino
Attn: Legal Department
1450 Front Street
San Diego, CA 92101