Effective Date: June 20, 2022
WHAT PERSONAL INFORMATION DOES PROPERTY OWNER COLLECT?
Categories and Types of “Personal Information”
We collect the following categories and types of personal information:
• Contact Information: your first and last name, current and previous mailing addresses, phone number, email address; • Other identifying information: IP address, social security number, taxpayer identification number, drivers license number, your photo, passport number, user names/account names and passwords, insurance policy number, credit history, sanctions and Politically Exposed Persona (“PEP”) screening results, tax documentation; • Financial Information: payment, banking and other financial history information, credit score; • Information regarding when you entered a particular unit and a defined area of common space (for residents who have access to Smart Community Products); • Geolocation data; • Commercial information: records of products or Services purchased, obtained, or considered (including, but not limited to Smart Community Products), other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, rent amount; • Employment or other professional information: current job and past job history, job title, and, in the case of prospective and current residents or tenants, pay history, income; • Demographic information: your date of birth, race, national origin, citizenship, marital status, veteran or military status, background check information, household information, whether you have pets;
• Internet or other electronic activity: your browsing and click history when you are using our websites and applications, including information about how you navigate within our Services and which elements of our Services you use the most; your internet protocol address, and cookie identification number; for those who have Smart Community Products installed, data captured from Smart Community Products, such as usage information, the temperature in your unit, smart light usage, possible leaks in the unit, movement detected via motion sensors that may be in your unit and whether you subscribe to our offered Wi-Fi. “Smart Community Products” are devices that allow for automated functions within your home, which may include, but are not limited to: device hubs, smart thermostats, smart locks, communal area access controls, leak sensors, video doorbells, window sensors, motion sensors, smart plugs, appliance sensors, HVAC sensors, garage door openers, and ubiquitous Wi-Fi. If you connect a third party device, such as digital home assistants to your SmartHub, we will know that you use such products; however, we will not be able to track the usage data of third party smart devices, other than Smart Community Products with the exception of digital home assistants if provided by the property; • Security visual and audio information: video or photo footage that we may capture; date and time that you arrive to and leave our premises; • Preferences: details that you provide to us about your interests, your communication preferences; and • Inferences: inferences drawn from the categories described above to create a profile about you to reflect your preferences, characteristics, behavior and attitude. For example, if you are a property employee at a property where Smart Community Products are installed, we may track your movements in and out of units to see how long unit tours last. If you are a resident at a property where Smart Community Products are installed, we may generally track how many people use our common spaces to better understand which amenities are popular among residents. .
HOW DOES PROPERTY OWNER USE YOUR PERSONAL INFORMATION?
Categories of Use
We use your personal information for the following purposes:
• Transactional Purposes: We use your contact information, demographic information, other identifying information financial information, internet or other electronic activity and commercial information to: o Create an account with us; o Provide you with certain property-specific Services, such as Smart Community Services in some locations; or maintenance of our properties; o Help you find and rent a unit within our properties; and o Communicate with you about your account, lease or unit.
• Analytical Purposes: We use your internet or other electronic activity, visual and audio information and geolocation data to analyze preferences, trends and statistics.
• Marketing Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, and inferences to inform you of our new products and events.
• Maintenance and Improvement of Services and Websites: We use your contact information, commercial information, and internet or other electronic activity to: o Provide and maintain functionality on our websites;
o Improve our websites and Services; o Handle your customer services requests, including direct your questions to appropriate individuals, and improve and monitor our customer support responses; o Optimize amenities at our properties; and o Help us diagnose technical and service problems and administer our websites.
• Security and Fraud Prevention: We use your contact information, audio and visual information, other identifying information, financial information, geolocation data, internet activity or other electronic activity, and inferences to protect the website, our properties, to protect you and other residents, and for fraud detection, theft prevention, emergency response purposes, and legal compliance.
WHAT ARE OUR SOURCES FOR YOUR PERSONAL INFORMATION?
We collect information from the following sources:
We collect information directly from you. We collect contact, financial, other identifying information and demographic information directly from you.
We collect information about you from third parties. We collect your contact information and certain identifying data from third parties, such our property managers. We may collect information from public databases or credit agencies.
We collect information from you passively. We collect internet or other electronic activity passively using tools like browser cookies, web beacons and tracking pixels, SDKs and other similar technologies. This activity is further described in the Usage Tracking: Cookies section below. We also collect information about you through some of the smart features of our units. For example, if your unit has a smart lock installed, we collect data regarding when the smart lock is used.
WHEN WE SHARE YOUR PERSONAL INFORMATION
Our Service Providers From time to time, we may establish a business relationship with other businesses whom we believe trustworthy (“Service Providers”). For example, we may disclose information we collect from you to third party vendors, service providers, contractors or agents, such as building maintenance staff and property managers. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
Your Roommates/Other People in Household If you have a roommate or other people in your household, we will share information about alerts and maintenance requests that may be prompted by Smart Community Products.
Our Affiliates We may share Personal Information (including internet or other electronic activity) with our Affiliates. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, including a property, we may disclose or transfer Personal Information in connection with such transaction.
Law Enforcement and Courts
In certain instances we may disclose your contact information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Property Owner or to others. We may also disclose your contact information when we believe the law or legal process requires it.
We use persistent tracking cookies on our websites which are cookies that stay in your web browser between visits. We use these to capture analytical information about our visitors that helps us to improve the performance of our website and create a better experience. These cookies allow us to recognize and count the number of visitors, to provide content related to a prior visit to our websites, to see how visitors move around the websites and the products and Services they are interested in when they are using them and to see what other types of products and services they may be interested in. This helps us to improve the way our websites work, for example by making sure users are finding what they need easily.
Most browsers are set up to accept cookies. If you want to change your cookie preferences, you can do so through your browser settings or refuse the cookies when you enter any of our websites. You may also limit the information we gain from certain cookies by logging directly into the registered areas of our sites rather than by logging in by using your social media log-in credentials. Please remember that our cookies are often used to give you certain functionality and without them you may not be able to fully use some of our websites.
You can also remove cookies that have already been set in your browser via your browser settings.
We use Google Analytics on the websites and Services to collect internet or other electronic activity, to analyze how users use the websites and Services. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
THIRD-PARTY SITE LINKS AND SERVICES You should be aware that when you are on Property Owner’s website you could be directed to other third-party sites that are beyond our control. There are links to other sites from Property Owner’s website, which take you outside our service. For example, if you click on a banner, an advertisement or a search result, the click may take you off our website. We may also partner with third party
service providers to provide certain services to you and you may have the option to use their applications and websites.
These other sites and services may send their own cookies to visitors to collect data or solicit information. Property Owner does not control these sites and services and therefore is not responsible for their content. The inclusion of hyperlinks to any other sites by Property Owner does not imply any endorsement of the material on such sites, nor any association with their operators.
SECURING INFORMATION Property Owner takes reasonable technical and organizational measures in accordance with applicable laws to safeguard users' Personal Information. While Property Owner strives to protect your Personal information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online, and you therefore disclose such Personal Information at your own risk.
You may choose to opt out of receiving future commercial email messages from us. Each mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. You may not be able to opt out of receiving other types of email messages from us, such as emails about the status of your lease, property notifications or maintenance-related emails.
CHILDREN'S PRIVACY Our websites are not directed at children. We do not collect or maintain information at our sites from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our websites. By using any of our websites, you represent that you are not under 16 years of age. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable information through any of our websites, please contact us using the information in the "Contact Information" section.
DATA TRANSFERS – INTERNATIONAL USERS If you provide Personal Information to us, it may be transferred to and processed on computers in the U.S. and other countries. Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers.
DO-NOT-TRACK DISCLOSURES; THIRD-PARTY TRACKING Certain mechanisms may allow you to send web browser signals, known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on websites. We do not respond to browser do not
track signals currently. We may not be aware of or able to honor and respond to every such mechanism. More information about “do not track” is available at www.allaboutdnt.org concerning such information.
Third parties, other than our service providers, do not have authorization from us to track which websites, apps, or other online services you visit prior to and after visiting our websites. Please note, however, that we cannot control third-party tracking and there may be some third-party tracking that occurs without our consent or knowledge.
NOTICE TO RESIDENTS OF CERTAIN STATES Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.
CALIFORNIA CONSUMER PRIVACY RIGHTS
If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act ( “CCPA Rights”). This section describes those rights and how you can exercise them with us.
CCPA RIGHTS REQUESTS
RIGHT TO KNOW AND RIGHT TO DELETION
You can request what Personal Information we have collected, used, disclosed, and sold in the preceding 12 months.
You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:
• Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you; • Security: to detect data security incidents; • Error Correction: to debug or repair any errors; • Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or • Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
Please note that if we delete your Personal Information, many of our services will not work the same. For example, we may longer be able to offer you the same level of service if we delete your Personal Information.
To submit a request to know or a request to delete, please email email@example.com. If you email us, you will be asked to verify your identity and we will need your [name and address with unit number]. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized
agent must submit that written proof at the time they make the request on your behalf. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.
SALE OF PERSONAL INFORMATION
We do not presently “sell” your information, as such term is defined under the CCPA. Further, we also do not knowingly sell the personal information of minors 16 years old or younger.
NON-DISCRIMINATION We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.
CONTACT INFORMATION If your Personal Information changes (such as zip/postal code, phone, email or postal address), please email us at firstname.lastname@example.org to update your information. We may ask you to authenticate your identity before we can make any changes.
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