Privacy Policy

Effective August 8, 2026 — Version 4.0

This Privacy Policy describes how Bearstone Properties (“we,” “us,” or the “House”) may collect, use, disclose, and protect the personal information of individuals (“you” or “applicant”) who visit this website or submit a rental application for the property located at 6 Gentle Breeze, Newport Coast, California 92657 (the “Site”). By accessing or using this Site, you acknowledge that you have read and understand this Policy and consent to the collection and processing of your information as described herein. This Policy does not create rights or remedies in any third party.

1. Scope, and How to Read This Policy

This Policy applies to personal information collected through the rental application on this Site (belcara.com, 6gentle.netlify.app, and any successor domain), to any documents uploaded or emailed in connection with that application, and to information collected automatically when you visit any page on this Site.

How to read this Policy. This Policy is written in two layers, and the distinction matters. Sections 2 through 9 describe the categories of information we may collect and the purposes and recipients for which we may process it — the full permitted envelope. Section 10 states our current operating practices as of the effective date above, which are narrower than that envelope. Practices may change at any time within the envelope described here, at our discretion; where a change would materially expand processing beyond this Policy, we will update this Policy and, where required by law, obtain consent before the change takes effect (Section 18). Except where applicable law provides otherwise, nothing in this Policy is a covenant, warranty, or guarantee that any particular practice will or will not be adopted in the future. If you do not accept this Policy, do not use the Site.

2. Categories of Information We May Collect

The following categories correspond to California Civil Code Section 1798.140(v) and include both information you provide and information we may collect automatically:

(a) Identifiers — full legal name, date of birth, telephone number, email address, mailing address, driver license number and state, IP address, application reference number, electronic signature.
(b) Financial information — employer name, position, supervisor contact information, gross monthly income, bank name, account type, and uploaded documents that may include federal tax returns, pay stubs, bank or investment account statements, and government-issued photo identification. Uploaded documents may incidentally contain Social Security numbers, bank account numbers, and routing numbers; we do not extract, index, or store any such identifiers separately from the uploaded documents themselves.
(c) Characteristics of protected classifications — only to the extent voluntarily disclosed or required by law for fair housing compliance.
(d) Internet or other electronic network activity information — browser user-agent string, pages viewed, referring page, scroll depth, session duration, clicks and interactions, and information regarding your interaction with the Site.
(e) Geolocation data — approximate location derived from IP address.
(f) Professional or employment-related information — employer, position, income, and employment history as you provide on the application.
(g) Education information — only if voluntarily disclosed.
(h) Inferences — profiles or scores reflecting preferences, characteristics, behavior, or aptitudes, including those generated by automated screening or AI-assisted review tools.
(i) Sensitive personal information — Social Security number, driver license or state identification card number, account log-in credentials, precise geolocation, and contents of communications, solely to the extent incidentally contained in uploaded documents or generated by the application process. We invoke Cal. Civ. Code Section 1798.121(a) only for the limited purposes of performing services you requested.

3. Sources of Information

We may collect personal information from: (a) you, directly through the application form, uploads, email, telephone, or text message; (b) TransUnion SmartMove or other consumer reporting agencies, solely as authorized by you; (c) landlords, employers, and personal references you identified; (d) your browser and device, automatically when you visit the Site; and (e) publicly available government records where relevant to tenancy verification.

4. Cookies, Pixels, Session Recording, and Similar Technologies

This Site may now or in the future use cookies, web beacons, tracking pixels, session replay tools, heatmaps, form analytics, chat or messaging widgets, embedded media players, A/B testing scripts, server and edge logs, device fingerprinting signals, analytics SDKs, and similar technologies (collectively, “Tracking Technologies”). By using this Site, you acknowledge that Tracking Technologies may be deployed as described in this Policy. The Global Privacy Control (GPC) signal is recognized as a valid opt-out of sale or sharing of personal information as required by California law.

This section addresses obligations under the California Invasion of Privacy Act (Cal. Penal Code Sections 631, 632, 638.51), the California Consumer Privacy Act, and the Ninth Circuit's holding in Javier v. Assurance IQ that pre-consent tracking activity may violate consent rules.

5. Analytics and Advertising

We may use analytics platforms (such as Google Analytics, Google Tag Manager, or comparable services) and advertising technologies (such as Meta Pixel, LinkedIn Insight Tag, Microsoft Clarity, or comparable services) to understand how visitors interact with this Site and to measure the effectiveness of advertisements. If we implement any such platform, we will disclose the specific platforms in use in Section 10 below. Your continued use of this Site after we post notice of any such change constitutes your acceptance of the updated practices.

6. Artificial Intelligence and Automated Processing

Rental applications submitted through this Site are evaluated with the assistance of artificial intelligence, machine learning, and other automated decision-making technology (“ADMT”). This is a standard part of our screening process and may include AI-assisted document review, scoring, risk assessment, or qualification analysis performed by our own systems or by third-party processors acting on our behalf. As of the effective date of this Policy, your personal information is not used to train third-party generative AI models; this is a statement of current practice subject to the change mechanism in Section 18.

Under California law (CCPA ADMT regulations, effective January 1, 2026), where ADMT is used to make or substantially assist a significant decision about housing, you have the right to: (a) receive information about how the ADMT is used in the evaluation; (b) request that a qualified human reviewer evaluate your application; and (c) appeal any adverse decision generated in whole or in part by ADMT. To exercise these rights, contact us using the information in Section 22.

This section addresses obligations under the CCPA ADMT regulations effective January 1, 2026, and California's AI transparency requirements under AB 2013.

7. Purposes of Processing

We may use your personal information for any of the following purposes: (a) evaluating your rental application for tenancy at 6 Gentle Breeze; (b) verifying employment, income, residence history, and references as authorized by you; (c) communicating with you regarding the status of your application, lease, or tenancy; (d) operating, maintaining, and improving this Site; (e) detecting, preventing, and responding to fraud, security incidents, and illegal activity; (f) complying with applicable legal obligations including fair housing, consumer reporting, data breach notification, and tax or reporting requirements; (g) establishing, exercising, or defending legal claims; and (h) any other purpose disclosed at or before the time of collection.

8. Disclosure of Information

We may disclose your personal information to the following categories of recipients: (a) service providers — a property management company, screening vendor, email or SMS delivery provider, cloud hosting provider, or other entity acting on our behalf under a written contract that restricts the use of your data to the services performed; (b) consumer reporting agencies — solely as authorized by you (note: you provide your information to TransUnion directly through their secure portal; we do not transmit it on your behalf); (c) professional advisors — attorneys, accountants, and consultants who need the information to advise us; (d) parties to a corporate transaction — if the property or business is sold, merged, or transferred, your information may be among the assets transferred, subject to the protections of this Policy; (e) government and law enforcement — to comply with a valid subpoena, court order, or other legal process, or to respond to a lawful request from a government agency; (f) at your direction — to any third party you authorize us to share information with; and (g) de-identified or aggregated data — information that can no longer reasonably identify you may be shared for any purpose.

9. Credit and Background Screening

Credit reports, criminal background checks, and eviction history are obtained through TransUnion SmartMove, a third-party screening service operated by TransUnion. Bearstone Properties does not collect, handle, or store your Social Security number at any point in the application or screening process. After initial review of your application, you will receive a separate screening invitation directly from TransUnion SmartMove. You will provide your Social Security number and authorize the screening directly through TransUnion's secure portal. The screening fee is paid by you directly to TransUnion and is not collected, handled, or processed by Bearstone Properties.

If we take adverse action based in whole or in part on information contained in a consumer report, we will provide you with the name and contact information of the consumer reporting agency, a statement that the agency did not make the adverse decision, and notice of your right to dispute the accuracy of the report.

Required by the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code Sections 1786-1786.60) and the federal Fair Credit Reporting Act (15 U.S.C. Section 1681 et seq.).

10. How the Site Is Currently Configured

This section describes how the Site is configured as of the effective date above. It is a statement of present configuration, not a promise, warranty, or representation about future practice. We may change any of it at any time within the envelope described in Sections 2 through 9, subject to the notice and consent commitments in Sections 4, 5, 6, and 18. Nothing in this section limits the rights reserved to us elsewhere in this Policy.

As of the effective date: the Site does not use cookies, web beacons, tracking pixels, session replay tools, or behavioral analytics. The Site does not deploy Google Analytics, Meta Pixel, or any similar third-party tracking technology. The Site does not use pen registers, trap-and-trace devices, or any technology that captures the content or metadata of your communications beyond the form submission itself. The only external services loaded by this Site are Google Fonts (for typography rendering) and Google Firebase (for encrypted data storage and document storage), neither of which is used by us to track, profile, or identify you. Firebase operates as our data sub-processor under Google Cloud's Data Processing Addendum.

As of the effective date: we have not sold your personal information. We have not shared your personal information for cross-context behavioral advertising. We have not disclosed your personal information to data brokers, advertisers, marketing platforms, or any third party for commercial purposes. In the twelve months preceding the effective date of this Policy, we have not sold or shared personal information as those terms are defined under Cal. Civ. Code Sections 1798.140(ad) and (ah). This is a statement of historical fact about the twelve-month period described. We expressly reserve the right to sell or share personal information in the future, subject to providing you with advance notice, an opportunity to opt out, and all rights required by applicable law before any such sale or sharing begins.

As of the effective date: rental applications are evaluated with the assistance of AI-based screening tools as described in Section 6. The rights described in Section 6 are available to all applicants.

11. Data Retention

We retain personal information only for so long as reasonably necessary to fulfill the purposes for which it was collected. Upon completion of our review, authorized personnel will download a copy of your application for evaluation purposes and will then permanently delete all application data, including all uploaded documents, from the online database. If your application is denied, all data is permanently deleted within ninety (90) days of the denial. If your application is approved and a lease is executed, only the information necessary for the lease agreement is retained; uploaded financial documents are permanently deleted from the application database.

12. Your California Privacy Rights

California residents may exercise the following rights at any time by contacting us at css@bearstonedc.com:

Right to Know and Access: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties to whom it has been disclosed. We will provide a copy in a portable, readily usable format within forty-five (45) days of receiving your verified request.

Right to Correction: You may request that we correct inaccurate personal information.

Right to Deletion: You may request that we delete all personal information we have collected from you, subject to exceptions permitted by law.

Right to Opt Out of Sale or Sharing: You may opt out of any future sale or sharing of your personal information by contacting us or by transmitting a Global Privacy Control signal from your browser.

Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use and disclosure of your sensitive personal information to what is necessary to perform the services you requested.

Automated Decision-Making: Your rights regarding ADMT used in the evaluation of your application are described in Section 6.

Right to Non-Discrimination: We will not deny you housing, charge you different rent, or provide a different level of service because you exercised any privacy right described in this Policy.

Shine the Light (Cal. Civ. Code Section 1798.83): California residents may request a list of categories of personal information disclosed to third parties for their direct marketing purposes, and the names and addresses of those third parties, once per calendar year.

Do Not Track / Global Privacy Control: The Global Privacy Control (GPC) signal is recognized as a valid opt-out of sale and sharing as required by California law.

Authorized Agents: You may designate an authorized agent to submit privacy requests on your behalf. We may require proof of the agent's authority and may verify your identity directly.

Verification: To protect your personal information, we will verify your identity before fulfilling any request. Verification may require you to confirm your name, the email address associated with your application, and your application reference number. We will not require you to create an account to exercise your rights. We may decline requests that are manifestly unfounded, excessive, or repetitive, or that would require disproportionate effort, as permitted by applicable law.

Rights provided under the California Consumer Privacy Act (Cal. Civ. Code Sections 1798.100-1798.199.100), the California Privacy Rights Act, and the CCPA ADMT regulations effective January 1, 2026.

13. Other State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, and other states with comprehensive privacy laws may have additional rights, including the right to access, correct, delete, and obtain a copy of their personal information, as well as the right to opt out of targeted advertising, profiling, and the sale of personal information. If you are a resident of any such state and wish to exercise your rights, contact us using the information in Section 22. If we decline a request, you may appeal the decision by contacting us with the subject line “Privacy Appeal.” If you are dissatisfied with the outcome of your appeal, you may contact the attorney general of your state.

14. No Smart-Home Surveillance

As of the effective date of this Policy, this property is not equipped with smart-home devices, IoT sensors, digital locks, environmental monitors, or any technology that collects data about tenant movements, habits, or home conditions. If any such technology is introduced in the future, we will disclose it in this Policy and provide notice before activation.

This section addresses the category of claims raised in ACLU of Northern California v. Equity Residential (S.F. Super. Ct. 2025).

15. Data Security

Your application data is transmitted over TLS-encrypted connections and stored in an encrypted database hosted by Google Firebase (Google Cloud Platform). Uploaded documents are stored in encrypted cloud storage with access restricted to authenticated Bearstone Properties personnel. We implement and maintain reasonable security procedures and practices appropriate to the nature of the personal information collected, including access controls, encryption at rest and in transit, and periodic security review.

16. Data Breach Notification

In the event of a security breach involving your personal information, we will notify you within thirty (30) calendar days of discovering the breach, in accordance with California Civil Code Section 1798.82, SB 446, and any other applicable notification requirements. Notification will be provided in the most expedient time possible and without unreasonable delay.

SB 446 (effective January 1, 2026) requires notification within 30 calendar days of discovery.

17. Children

This application is not directed to individuals under the age of eighteen. We do not knowingly collect personal information from minors. If we learn that we have collected personal information from a child under sixteen, we will delete it promptly.

18. Changes to This Policy

We may update this Policy at any time. Material changes will be posted on this page with a revised effective date at least seven (7) days before the change takes effect. Where we have your email address on file, we may also notify you of the change by email. Your continued use of the Site after the updated Policy takes effect constitutes your acceptance of the changes. The most recent version of this Policy posted on this Site supersedes all prior versions; any cached, archived, or third-party-hosted copy of a prior version is not binding. The effective date at the top of this Policy governs.

19. Fair Housing Compliance

Bearstone Properties complies with the federal Fair Housing Act (42 U.S.C. Section 3601 et seq.), the California Fair Employment and Housing Act (Cal. Gov. Code Section 12955 et seq.), and the Unruh Civil Rights Act (Cal. Civ. Code Section 51 et seq.). All applicants are evaluated without regard to race, color, religion, sex, gender, gender identity or expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other characteristic protected by law. Reasonable accommodations and modifications are available upon request.

20. Application and Screening Fees

As of the effective date, Bearstone Properties does not charge an application fee. Credit and background screening is conducted through TransUnion SmartMove at a fee of approximately $40 per applicant, paid by the applicant directly to TransUnion. Screening payments are not collected, handled, or processed by Bearstone Properties.

21. Text Messaging

If you opt in to receive text messages, property management staff may send you SMS notifications related to your rental application. Mobile information and messaging consent are not shared with third parties or affiliates for marketing or promotional purposes. Message frequency varies. Message and data rates may apply. Reply STOP to cancel, HELP for help. Carriers are not liable for delayed or undelivered messages.

22. Third-Party Sites, Links, and Embedded Content

This Site may contain links to third-party websites (such as TransUnion SmartMove, Google, or directory listing services). This Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party site before providing personal information.

23. International Transfers

This Site is operated from the United States. If you access this Site from outside the United States, your information may be transferred to, stored in, and processed in the United States, where privacy laws may differ from those of your jurisdiction.

24. Contact

For privacy inquiries, requests to exercise your rights, or complaints:

Bearstone Properties
6 Gentle Breeze, Newport Coast, CA 92657
Email: css@bearstonedc.com
Phone: (310) 721-6006

You also have the right to file a complaint with the California Privacy Protection Agency at cppa.ca.gov or the California Attorney General at oag.ca.gov.

25. Governing Law

This Policy is governed by the laws of the State of California. Any dispute arising under this Policy shall be resolved in the courts of Orange County, California.