Privacy Notice for California Residents
Effective Date: January 2020
Last Reviewed on: January 2020
Information We Collect
Our web-based platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our web-based platform has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category A: Identifiers
Examples: Real name (such as first name and last name), alias, postal address, unique personal identifier, online identifier, internet protocol (“IP”) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital or familial status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), medical conditions, political affiliations or activities, status as a victim of domestic violence, assault, or stalking.
Category D: Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consumer histories or tendencies.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F: Internet or other similar network activity information.
Examples: Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement.
Category G: Geolocation data.
Examples: GPS coordinates or other location tracking information.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Employer, employment history, resumes and CVs, background checks, and other employment-related information.
Category J: Education information.
Examples: Records maintained by an educational agency or institution that pertain to a student, such as grades and transcripts.
Category K: Inferences.
Examples: Inferences drawn from any of the categories described above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
• Directly from you. For example, from forms you complete on our web-based platform.
• Indirectly from you. For example, from observing your actions on our web-based platform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
• To fulfill or meet the reason you provided the information.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To enhance the web-platform experience.
• To market additional products and/or services to you.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties: provider(s) of property management services, provider(s) of package delivery services, website(s) showing rental property availability, provider(s) of utility billing services, online payment processor(s), renters insurance provider(s), provider(s) of verification services for renters insurance, provider(s) of rental unit inspection services, provider(s) of resident surveys services, marketing services provider(s), provider(s) of chat services, provider(s) of services for resident screening and/or background checking, provider(s) of leasing applications, analytics provider(s), vendor compliance service provider(s), provider(s) of resident credit repair services, provider(s) of moving services for new residents, and provider(s) of services related to “smart” locks, thermostats, etc.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, the Company has disclosed personal information for a business purpose to the following companies: Amazon Hub, AMC LLC, Amenify, ApartmentList, ConService, Domuso, Epremium, HappyCo, Jetty, Kingsley, Market Apartments, OnSite Screen, Opiniion, Parcel Pending, PayLease, PowerPro, Rentlytics, RentPath, RLL Liability, Stern Risk, UB WEST, WesternReporting, Resident Aid, and SmartRent. Please see the websites for these companies for their respective privacy policies.
Sales of Personal Information
In the preceding twelve (12) months, the Company has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (1) sales, identifying the personal information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request.
Personal Information Sales Opt-Out Rights
You have the right to opt out of the sale or your personal information. However, because we do not sell personal information, this right does not apply.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the web-based platform and update the notice’s effective date. Your continued use of our web-based platform following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:
Apartment Management Consultants
Address 1954 Fort Union Blvd, Suite 500
Address: Cottonwood Heights, UT 84121
Toll Free Phone Number: 1 (888) 768-1711