California Privacy Policy

Last Updated: March 22, 2023

Four Corners Property Trust, Inc. and its subsidiaries and affiliated companies (“Company”) takes your privacy seriously. We want you to know how we collect, use, disclose, and retain your personal information.

This Privacy Policy explains:

  1. What categories of personal information we collect
  2. The categories of sources from which we collect this personal information
  3. The purposes for which we use your personal information
  4. How we may disclose your personal information
  5. How long we keep your personal information
  6. Privacy rights for California residents
  7. Changes to this Privacy Policy

CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect information from anyone under 13 years of age. The products and/or services we provide, together with our Site, are all directed to individuals who are at least 13 years old. If you are under the age of 13, you are not authorized to use our services or the Site.

Scope

This Privacy Policy applies to the personal information of individuals (“you”, “your”, or “yours”) collected by Company, including the personal information collected when you visit our website fcpt.com as it may be modified, relocated and/or redirected from time to time (the “Site”). This Privacy Policy does not apply to the personal information of individuals in their capacity as prospective, current, or former employees, contract workers, board members, or owners of Four Corners Property Trust, Inc. or their emergency contacts, dependents, or beneficiaries.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Other web sites

The Site may contain links to other web sites not operated or controlled by use (“Third Party Sites”). The policies and procedures we describe here do not apply to Third Party Sites. The links from the Site do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

1) WHAT CATEGORIES OF PERSONAL INFORMATION WE COLLECT

  1. Identifiers, for example: real name, alias, telephone number, postal address, and e-mail address.
  2. Internet Activity Information, for example: information about your usage of the Site, such as the pages you viewed, the services and features you used or interacted with; your browser type and details about any links or communications with which you interacted; internet protocol (IP); browser plug-in types and versions; and operating systems and platform.
  3. Professional Information, for example: business contact information and title.
  4. User Content, includes content you submit when you otherwise contact Company. This may include recordings you create, including audio recordings or voicemail you submit in connection with customer service.
  5. Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, e., date and time of the call and phone numbers.
  6. Characteristics of Protected Classifications Under California or Federal Law, for example: your age or gender.

Note on Sensitive Personal Information: Company does not infer characteristics from sensitive personal information. Company only uses sensitive personal information as necessary to perform the services or provide the goods the average person would reasonably expect when requesting those goods or services, to ensure security and integrity, short term transient use, to maintain the quality of our products and services, or for other purposes permitted by the California Privacy Rights Act and implementing regulations (“CPRA”) without the right to opt out.

Do We Use Cookies?

Yes. Cookies are small files that the Site or our service provider transfers to your computer’s hard drive through your Web browser that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly.

Tracking Across Time and Different Sites

The Site does not track your online activities over time and across websites or online services on an individually identifiable basis.

Do Not Track Setting

The Site currently does not respond to web browser “do not track” (DNT) signals or other mechanisms that indicate your preference for having information collected over time and across different web sites following your visit to our Site. DNT is a preference you can set in your browser’s settings to let the website you visit, including the Site, know that you do not want the websites collecting your personal identifiable information. If we do so in the future, we will describe how we do so in this Privacy Policy. You can also visit https://allaboutdnt.com/ to learn more.

2) THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

  • You, for example, when you register with our Site.
  • Service providers, for example, analytics providers, IT, and system administration services.

3) THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

Providing Products and Services, including:

  • To communicate with you.

Support and Marketing, including:

  • To respond to any requests, queries, suggestions, feedback, or comments you may have.

Monitoring, Security, and Compliance, including:

  • To administer and protect our business and our Site (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
  • To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
  • To protect the rights, property, or safety of Company, you, or others.
  • In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates.
  • To report suspected criminal conduct to law enforcement and cooperate in investigations.
  • To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
  • To ensure compliance with applicable laws and regulatory obligations.

Incidental Purposes: Any incidental purposes related to, or in connection with, the above.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Company discloses personal information as necessary for the purposes described in Section 3 above to the following categories of external recipients:

  • Service providers and contractors: Company discloses your personal information to service providers and contractors for the purposes above to assist us in meeting our business needs and contractual and legal obligations.
    • Company only discloses your personal information to service providers and contractors subject to written contracts under Company’s direction and instructions as required by applicable law.
    • Service providers and contractors include auditors, administrative service providers, law firms, and any other entity providing services to Company
  • Government or administrative agencies: For example, Company may report unlawful activity to regulatory authorities such as the Securities and Exchange Commission.
  • Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
  • Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others.
  • Corporate Transactions: We reserve the right to disclose and transfer your personal information, including your personal information:
    • To a subsequent owner or co-owner.
    • In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

We do not sell your personal information or disclose it to third parties for cross-context behavioral advertising. We also do not sell the personal information of children under 16 nor disclose it to third parties for cross-context behavioral advertising.

Aggregated and Deidentified Information

We may aggregate and/or deidentify information, use it internally, and disclose to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.

  • “Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.
  • “Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be data point that an unidentified visitor first entered the Site through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly. We prohibit vendors, by contract, from attempting to reidentify our Deidentified Information.

5) HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your personal information for the duration of the customer relationship, if any. We also retain your personal information for 12 months after our last interaction with you. We will retain personal information longer as necessary to comply with legal, administrative, or procedural requirements, for example, a litigation hold.

6) PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

  1. Your California Privacy Rights

Subject to applicable law, California residents have the following rights:

  • Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information obtained from you and for information about Company’s collection, use, and disclosure of your personal information. Please note that the CPRA’s right to obtain copies does not grant a right to the whole of any document that contains personal information, but only to copies of “specific pieces” of personal information. Moreover, California residents generally just have a right to know categories, for example, categories of third parties to which personal information is disclosed, but not the individual third parties.
  • Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
  • Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.
  • How to Exercise Your RightsCompany will respond to request to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
    • Call 415-965-8030
    • Email info@fcpt.com.
  • How We Will Verify Your RequestThe processes that we follow to verify your identity when you make a request to know, correct, or delete are described below. The relevant process depends on how and why the request is submitted.If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request.For a less risky request, such as a request to know how we handle your personal information, we will match at least two data points that you provide against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or information about products or services that you have purchased from us.For a more risky request, such as a request for a copy of specific pieces of your personal information, we will match at least three data points that you provide against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.

    We have implemented the following additional procedures when verifying the identity of requestors:

    1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
    2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
  • Authorized AgentsIf an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at info@fcpt.com.
  • Company’s Non-Discrimination PolicyCompany will not unlawfully discriminate against you for exercising your privacy rights under the California Privacy Rights Act.

7) CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at info@fcpt.com.