Who We Are
JOEL Commercial LLC (“JOEL COMMERCIAL”), together with any subsidiaries and affiliates, is a leading provider of commercial real estate and investment management services.
Our Privacy Commitment
We take our responsibility to protect the personal information provided to us seriously. This Privacy Policy explains how we do that. It describes how we collect personal information, how we use the personal information we hold, how we protect it, and the privacy rights you may have (where applicable).
Changes to This Privacy Policy
JOEL COMMERCIAL may update this Privacy Policy from time to time. If we do, the revised policy will be posted on this page and, where appropriate, we may provide notice on our homepage. You should review this page periodically to understand any changes.
The Personal Information We Collect
When we collect personal information, we aim to be transparent about how we collect it and how we use it.
The categories of personal information below outline what we may collect, the sources of that information, the purposes for collecting it, and the third parties with whom we may share it.
Depending on the nature of your relationship with JOEL COMMERCIAL (or our subsidiaries and affiliates) and the products, mobile apps, or services you use, we may not collect all of the personal information described below.
1) Information
Description
Including records of personal property, products or services purchased, obtained, or considered, and real estate interests and preferences.
Sources
- You (directly from the consumer)
- Public records
- Authorized or legal representatives
- Payment processors and other financial institutions
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties that provide access to information you make publicly available, such as social media platforms
- Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms
- Cookies, web beacons, and similar technologies (automatically) when you visit our websites or third-party websites
- Third-party advertising partners and other third parties who provide digital marketing services
- Third parties who provide website and online security services
- When you contact or visit us
- Your mobile devices and other internet-connected devices, applications, and services (automatically)
- Inferences we draw from information collected from and about you, such as your preferences
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Provide our products, mobile apps, and services
- Administer, manage, analyze, and improve our products, mobile apps, and services
- Issue invoices and collect payments
- Fulfill payment obligations
- Communicate with you regarding our products and services
- Procure vendor and supplier products and services, including managing related contractual obligations
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Advertising and product promotion, including contacting you regarding products, services, and topics that may be of interest
- Engage in joint marketing initiatives
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, services, and advertisements
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide product fulfillment services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who deliver physical communications, such as postal services and couriers
- Third parties who provide marketing and data analytics services, including social media platforms used to deliver ads, website and email optimization providers, email marketing vendors, and data analytics vendors
- Third-party network advertising partners
- Third parties who assist with our information technology and security programs
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
2) Contact Details
Description
Name, address, email, and telephone number.
Sources
- You (directly from the consumer)
- Authorized or legal representatives
- Payment processors and other financial institutions
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
- Your mobile devices
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Provide our products, mobile apps, and services
- Administer, manage, analyze, and improve our products, mobile apps, and services
- Issue invoices and collect payments
- Fulfill payment obligations
- Communicate with you regarding our products and services
- Respond to your requests
- Procure vendor and supplier products and services, including managing related contractual obligations
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Advertising and product promotion, including contacting you regarding products, services, and topics that may be of interest
- Engage in joint marketing initiatives
- Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- Provide access to, monitor, and secure our facilities, equipment, and other property
- Detect security incidents and other fraudulent activity
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
- Establish, execute, or terminate an app download
- Inform you of updates and new features of our apps that may be of interest
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide product fulfillment services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who deliver communications, such as postal services and couriers
- Third parties who provide marketing and data analytics services, including social media platforms used to deliver ads, website and email optimization providers, email marketing vendors, and data analytics vendors
- Third-party network advertising partners
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
3) Financial Information
Description
Including bank account number, credit or debit card number, payment amounts, financial means, or other financial information.
Sources
- You (directly from the consumer)
- Public records
- Authorized or legal representatives
- Payment processors and other financial institutions
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
Purposes
- Issue invoices and collect payments
- Fulfill payment obligations
- Fulfill services you have requested
- Assess eligibility for certain services
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
4) Identification Data
Description
Date of birth, proof of residency, government-issued ID, driver’s license number, passport number, or other similar identifiers.
Sources
- You (directly from the consumer)
- Authorized or legal representatives
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
- When you contact or visit us
Purposes
- Fulfill payment obligations
- Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- Comply with legal and regulatory obligations
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
5) Location Data
Description
GPS coordinates or similar information regarding the location of a device.
Sources
- You (directly from the consumer)
- Your computer and mobile devices (automatically) when you visit or interact with our websites
- Your mobile devices and other internet-connected devices and applications (automatically)
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Detect security incidents and other fraudulent activity
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
6) Network Activity Data
Description
Internet or other electronic network activity information, such as browsing history, search history, cookie data, referring or exiting URLs, clickstream data, time spent on a webpage or advertisement, and other information regarding an individual’s interaction with a website, application, email, advertisement, or social media page.
Sources
- Third parties who provide digital marketing and analytics services using cookies and similar technologies that contain a unique identifier, such as an advertising ID
- Third parties that provide access to information you make publicly available, such as social media platforms
- Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms
- Cookies, web beacons, and similar technologies (automatically) when you visit our websites or third-party websites
- Cookies, web beacons, and similar technologies (automatically) in emails we send for marketing purposes, such as whether a recipient opened an email or clicked a link
- Third-party advertising partners and other third parties who provide digital marketing services
- Third parties who provide website and online security services
- Your mobile devices and other internet-connected devices and applications (automatically)
- Inferences we draw from information we collect, such as your preferences
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Provide our products, mobile apps, and services
- Administer, manage, analyze, and improve our products, mobile apps, and services
- Analyze and better understand your needs, preferences, and interests and personalize our website, advertising, products, mobile apps, and services
- Conduct internal business analysis
- Track the success of marketing campaigns and determine the effectiveness of, and optimize, promotional and marketing activity
- Improve the functionality and design of our website, emails, or social media pages
- Advertising and product promotion, including contacting you regarding products, services, news, and topics that may be of interest
- Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide product fulfillment services
- Third parties who provide marketing and data analytics services, including social media platforms used to deliver ads, website and email optimization providers, email marketing vendors, and data analytics vendors
- Third-party network advertising partners
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
7) Professional Information
Description
Professional information such as business title, position, organization, reporting structure, or similar information.
Sources
- You (directly from the consumer)
- Public records
- Authorized or legal representatives
- Consumer reporting agencies and other third parties who verify the information you provide
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Provide our products, mobile apps, and services
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Advertising and product promotion, including contacting you regarding products, services, and topics that may be of interest
- Engage in joint marketing initiatives
- Comply with legal and regulatory obligations
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Third parties who deliver communications, such as postal services and couriers
- Third parties who provide marketing and data analytics services, including social media platforms used to deliver ads, website and email optimization providers, email marketing vendors, and data analytics vendors
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
8) Tenant Data
Sources
- You (directly from the consumer)
- Public records
- Authorized or legal representatives
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
- Inferences we draw from information collected, such as your preferences
Purposes
- Determine product, mobile app, and service eligibility and coverage
- Provide our products, mobile apps, and services
- Administer, manage, analyze, and improve our products, mobile apps, and services
- Issue invoices and collect payments
- Communicate with you regarding our products and services
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Advertising and product promotion, including contacting you regarding products, services, and topics that may be of interest
- Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- Provide access to, monitor, and secure our facilities, equipment, and other property
- Detect security incidents and other fraudulent activity
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who deliver communications, such as postal services and couriers
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
9) Visual and Voice Recordings
Description
Audio, electronic, and visual information, such as customer service call recordings, voice commands, photographs, and recordings from CCTV cameras.
Sources
- When you contact or visit us
Purposes
- Administer, manage, analyze, and improve our products, mobile apps, and services
- Analyze and better understand your needs, preferences, and interests
- Conduct internal business analysis and market research
- Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- Provide access to, monitor, and secure our facilities, equipment, and other property
- Detect security incidents and other fraudulent activity
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Comply with legal and regulatory obligations
- Identify you and your device(s) for the purposes listed above, including to monitor your use of and interactions with products, mobile apps, and services
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
10) Written Signature
Description
An individual’s written signature, such as a signature on a contract or lease document.
Sources
- You (directly from the consumer)
- Authorized or legal representatives
- Payment processors and other financial institutions
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies and other third parties who verify the information you provide
Purposes
- Issue invoices and collect payments
- Fulfill payment obligations
- Detect security incidents and other fraudulent activity
- Monitor, investigate, and enforce compliance with our policies, product and service terms and conditions, and legal and regulatory requirements
- Comply with legal and regulatory obligations
- Identify you for the purposes listed above
Sharing for Business or Commercial Purposes
- JOEL COMMERCIAL employees who require it to perform their jobs
- Other entities of the JOEL COMMERCIAL group that help us deliver services
- Authorized or legal representatives
- Third parties who provide product fulfillment services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third parties who assist with fraud prevention, detection, and mitigation
- Consumer reporting agencies
- Our lawyers, auditors, and consultants
- Legal and regulatory bodies and other third parties as required by law
Our Legal Basis for Processing Your Information
We rely upon the appropriate legal bases under applicable privacy law for processing personal information and sensitive (special category) personal information. These include processing personal information where necessary for fulfillment of a contract, where processing is necessary to carry out legal obligations, where you have provided consent, or where processing is in our legitimate interests.
Where we rely on legitimate interests, we use personal information to run our business and to provide the services you have requested. We collect information you provide voluntarily or that is provided on your behalf. If you do not provide information we need, we may be unable to offer certain products, mobile apps, or services.
Information Storage
We may transfer and store the information we collect from you outside your country of origin. It may be processed by staff or suppliers outside your country of origin. When we do this, we aim to ensure the information is secure and properly protected, including by relying on adequacy decisions or implementing appropriate safeguards (such as Standard Contractual Clauses).
Keeping Your Information Safe
We are committed to maintaining appropriate security measures to protect personal information wherever it is located and whether it is in electronic or manual form. We may use a variety of measures depending on where the information is stored and the relationship between JOEL COMMERCIAL and any recipient organizations.
How Long We Keep Your Information
We strive to keep your information only for as long as needed for legitimate business or legal reasons. We will then delete it safely and securely.
Your Personal Information Rights
Where applicable, you may have the following rights over your personal information. To exercise any of these rights, use our online form for personal information rights requests.
Right of Access
You can request a copy of the personal information we hold about you. In most cases, there is no charge for providing this information. You may also request that information you provided to us be delivered in an electronic format.
Right to Data Portability
In certain circumstances, when processing is based on your consent or a contract, you may request that JOEL COMMERCIAL transmits your personal information directly to another organization.
Right of Erasure (Right to Be Forgotten)
If you do not want us to hold or use your personal information, you can request that we erase it. We may need to retain certain personal information for legal reasons, such as compliance with regulatory requirements.
For marketing purposes, we may add your name to a suppression list so that you are not contacted in the future.
Right to Rectification
If you believe the personal information we hold about you is incorrect, we will review and correct it if necessary. We are committed to maintaining personal information that is accurate, relevant, and current.
Right to Restrict Processing
You may request that we suspend processing of your personal information in certain circumstances, such as when you contest the accuracy of the information or have concerns about how it was processed. Restrictions may apply for a limited period while JOEL COMMERCIAL verifies the information or evaluates its grounds for processing.
Right to Object
Subject to applicable law, you may object to processing where we rely on legitimate interests. You also have the right to object to the use of your personal information for direct marketing.
These rights may be limited in certain situations, such as where JOEL COMMERCIAL can demonstrate a legal requirement or compelling legitimate grounds to process personal information.
Stopping Us From Contacting You
If you have provided consent to receive marketing and information, you may withdraw your consent at any time by emailing info@JOELCommercial.com.
California Residents Only
If you are a California resident as defined in the California Consumer Privacy Act (CCPA), you may have additional rights regarding your personal information. Where applicable, you may have the right to:
- Request access to the categories and specific pieces of personal information we collect
- Request deletion of personal information (subject to certain exceptions)
- Request correction of inaccurate personal information
- Opt out of the sale or sharing of personal information as defined under California law (if applicable)
How to Raise a Concern or Ask a Question
If you have concerns about our handling of personal information, please email us at info@JOELCommercial.com. If you are not satisfied with how we address your complaint, you may contact your Data Protection Authority or the equivalent authority in your state or country, where applicable.
Contact Us
If you have questions about this Privacy Policy or our privacy practices, contact:
JOEL Commercial LLC
Email: info@joelcommercial.com
Phone: 208.575.4280
Address: 500 E Shore Drive, 200-4305 Eagle, Idaho 83616