PRIVACY POLICY AND CALIFORNIA NOTICE AT COLLECTION
Effective Date: August 1, 2026
Last Updated: October 27, 2026
1. Scope
This Policy describes Lucere Management’s (“Lucere,” “we,” “us” or “our”) online and offline practices concerning personal information. It applies to website visitors, property owners, tenants and their personnel, prospective clients, vendors, business contacts and other individuals who interact with Lucere outside a workforce relationship. A separate California Workforce Privacy Notice applies to applicants, employees and other Workforce Members.
2. Notice at Collection: Categories, Purposes and Retention
During the preceding 12 months, Lucere collected, and may continue to collect, the categories below. The examples do not mean that Lucere collects every listed item from every person. Lucere collects and retains information only as reasonably necessary for the stated purposes, the applicable relationship and legal, accounting, security, dispute and recordkeeping requirements.
Identifiers. Name, alias, postal address, email address, telephone number, signature, online identifier, IP address and similar identifiers. Used to communicate, authenticate users, administer properties and relationships, provide services and maintain security. Retained for the relationship and afterward under applicable contract, dispute, security and legal-retention periods.
California customer-record information. Contact, signature, financial, payment and similar information described by California Civil Code section 1798.80(e). Used for transactions, billing, accounting, contracting, fraud prevention and compliance. Retained for the transaction or relationship and applicable tax, accounting, contract and legal-retention periods.
Protected characteristics. Age, disability or other characteristics protected by California or federal law, if voluntarily provided or required for an accommodation or legal purpose. Used only for the request, accommodation or compliance purpose. Retained only while necessary for that purpose and applicable legal obligations.
Commercial information. Property, lease or occupancy relationships, services requested or provided, transaction history, preferences and related records. Used to manage properties and business relationships, provide services, bill and resolve disputes. Retained for the relationship and applicable contract, accounting and legal-retention periods.
Internet, device and network activity. Browser and device type, cookie identifiers, pages viewed, referring page, access logs and interactions with Lucere’s website or systems. Used for functionality, analytics, support, security and fraud prevention. Retained under Lucere’s operational and security log schedules and, if associated with an incident, for the incident and legal-retention period.
Geolocation data. Approximate location derived from an IP address. Used for security, analytics and service administration. Retained with the associated website or security record under the same schedule.
Audio, electronic and visual information. Emails, messages, website submissions, documents and, if used, call or security-camera recordings. Used for communications, operations, safety, training, recordkeeping and legal matters. Retained for the matter or operational need and applicable legal-retention period.
Professional or employment-related information. Title, employer and other business-contact or professional information. Used to manage business relationships and communications. Retained for the relationship and applicable business-record period.
Inferences. Preferences or characteristics inferred from interactions or records, if created. Used to provide and improve services and communications. Retained only while relevant to the relationship or purpose.
Sensitive personal information. Account credentials, government identifiers, precise geolocation, financial-account access information or other sensitive information, if reasonably necessary and lawfully collected. Used only for permitted operational, security, legal or service purposes. Retained only while necessary for that purpose and applicable legal obligations.
Lucere does not sell or share these categories of personal information. Lucere may disclose the categories for the business purposes described in Section 5. Lucere may collect additional information only after providing any notice required by law.
3. Sources of Personal Information
Lucere may collect personal information:
Directly from individuals, including through forms, communications, transactions and service interactions.
From organizations and business relationships, including property owners, tenants, clients, vendors, referral sources, counterparties and their representatives.
From service providers and public sources, including payment, identity, security, professional and public-record sources when reasonably necessary.
Automatically from the website and systems, through cookies, logs and similar technologies.
4. How We Use Personal Information
Lucere may use personal information to:
Provide and administer services, including managing commercial properties and relationships with owners, tenants, vendors and other stakeholders.
Communicate and respond, including responding to inquiries, service requests and transaction-related communications.
Operate the business, including billing, accounting, recordkeeping, vendor management and internal administration.
Operate and improve systems and services, including the website, internal technology and approved AI-assisted workflows.
Protect Lucere and others, including detecting and addressing fraud, misuse, safety concerns and security incidents.
Comply with law and agreements, including establishing, exercising or defending legal rights.
5. Disclosures for Business Purposes
During the preceding 12 months, Lucere may have disclosed identifiers, California customer-record information, commercial information, internet or network activity, geolocation data, audio/electronic/visual information, professional information, inferences and sensitive personal information, as applicable, to:
Service providers and contractors, including hosting, IT, cybersecurity, communications, document management, property management, payment, accounting, records management, AI and consulting providers that process information under contract for specified purposes.
Business participants, including property owners, clients, tenants, vendors and counterparties when reasonably necessary to manage a property, provide services or complete a transaction.
Professional advisers, including attorneys, accountants, auditors and insurers.
Authorities and transaction recipients, when required by law or reasonably necessary to protect rights, safety or property, investigate misconduct, or complete a merger, financing or transfer of all or part of the business.
6. Sale, Sharing, Minors and Financial Incentives
Lucere does not sell personal information or share it for cross-context behavioral advertising and has not done so during the preceding 12 months. Lucere therefore does not provide a separate sale or sharing opt-out link. If these practices change, Lucere will update this Policy, provide the required opt-out method and honor legally recognized opt-out preference signals. Lucere does not have actual knowledge that it sells or shares personal information of consumers under age 16. Lucere does not offer a financial incentive or price or service difference in exchange for personal information.
7. Sensitive Personal Information
Lucere uses and discloses sensitive personal information only for purposes permitted without a right to limit, such as providing requested services, maintaining security and integrity, preventing fraud, processing transactions, short-term transient use and complying with law. Lucere therefore does not provide a separate Limit the Use of My Sensitive Personal Information link. If Lucere’s practices change, it will provide the notice and limitation right required by law.
8. AI and Automated Decisionmaking
Lucere may use approved AI service providers, including Anthropic’s Claude Team, to assist authorized personnel with drafting, summarizing, organizing and analyzing information. Lucere limits submitted information to what is reasonably necessary and requires human review of material outputs.
Lucere does not currently use automated decisionmaking technology to make a significant decision about a consumer. Before any covered use begins, Lucere will conduct the required review, provide any pre-use notice, and offer applicable opt-out and access rights or a legally permitted human-review appeal process.
9. California Privacy Rights
Subject to legal limits and exceptions, California residents may request:
Know and access. The categories and specific pieces of personal information Lucere collected, sources, purposes, and categories of recipients, including information collected on or after January 1, 2022, unless responding would be impossible or involve disproportionate effort.
Delete. Deletion of personal information Lucere collected, subject to exceptions.
Correct. Correction of inaccurate personal information Lucere maintains.
Opt out or limit. Opt out of sale, sharing or covered automated decisionmaking, and limit certain uses of sensitive personal information, if those practices apply. Lucere’s current practices do not trigger these rights as described above.
No retaliation or discrimination. Equal service and treatment for exercising CCPA rights, subject to lawful differences permitted by the CCPA.
9.1. Submitting a Request
Submit a request through either of the following methods: (1) call us at 310-775-2123, or (2) via email at hello@luceremgmt.com with the Title: PRIVACY REQUEST. Describe the request and provide enough information for Lucere to locate the relevant records.
Lucere generally confirms receipt of requests to know, delete or correct within 10 business days and responds within 45 calendar days. Lucere may extend the response period once by up to 45 additional calendar days when reasonably necessary and will explain the extension.
9.2. Verification and Authorized Agents
Lucere will use a reasonable verification process based on the nature of the request and the sensitivity of the information. Lucere may request information it already maintains, signed confirmation, identity documentation or another reasonable method, and will use verification information only for that purpose. An authorized agent may submit a request on a consumer’s behalf. Lucere may require proof of authorization and may contact the consumer directly to verify identity and permission, unless the agent holds a valid power of attorney.
10. Cookies and Online Tracking
Lucere’s website may use cookies and similar technologies for functionality, security, analytics and embedded content. Browser settings may allow visitors to block or delete cookies, although some features may not function properly. Lucere does not use website information to track visitors across unrelated websites for targeted advertising. Providers of embedded features may collect information directly, subject to their own privacy policies.
Some browsers offer a Do Not Track signal. Because there is no uniform standard for these signals, the website does not currently respond to them. Lucere will honor legally required opt-out preference signals if its practices later require an opt-out.
11. Security
Lucere uses reasonable administrative, technical and physical safeguards appropriate to the nature of the personal information it maintains. No method of transmission or storage is completely secure, and Lucere cannot guarantee absolute security.
12. Children
Lucere’s website and services are not directed to children under 13, and Lucere does not knowingly collect personal information online directly from children under 13.
13. Changes to This Policy
Lucere may update this Policy from time to time. The Last Updated date above identifies the most recent revision, and Lucere will provide additional notice of material changes when required by law.
14. Contact
Questions or requests may be directed to:
Lucere Management
9663 Santa Monica Blvd., Suite 155
Beverly Hills, California 90210
Email: hello@luceremgmt.com
Telephone: 310-775-2123