Effective Date: January 1, 2021
I. Personal Information Collection
We may collect personal information about you in a variety of ways. The personal information we may collect on the Site or when you communicate with us about a potentially available rental housing unit, or when you apply for or rent a housing unit includes the following categories of personal information. The sources from which the information is collected is also identified below.
|Personal Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A 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.||
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|Geolocation data||Physical location.||
|Professional, tenancy, or employment-related information||Current or past job history. Past postal addresses, landlords, and landlord references regarding tenancy.||
|Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||
Data Relating to Application for or Rental of a Housing Unit
We may also collect information from public records such as past eviction actions, prior landlords or similarly-situated individuals, which information may help us ascertain the likelihood that you will comply with the terms of your lease agreement and applicable laws.
II. Personal Information Exceptions (Not Covered by CCPA)
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
III. Personal Information Use & Processing
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site, telephonically or in person to:
- Deliver targeted advertising, newsletters, and other information regarding promotions, the Site and properties we manage to you.
- Allow you to access amenities, access features, and request service.
- Create and manage your account.
- Email you regarding business-related communications.
- Enable user-to-user communications.
- Increase the efficiency and operation of the Site.
- Notify you of updates to the Site.
- Offer new services and/or recommendations to you.
- Perform other business activities as needed.
- Provide electronic payment alternatives.
- Request feedback and contact you.
- Resolve disputes and troubleshoot problems.
- Respond to service requests.
- Send you a newsletter.
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online or in person is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
IV. Personal Information Sharing & Disclosure
We do not sell personal information collected and no such disclosure has occurred in the prior 12 months.
V. Personal Information Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with CCPA guidelines. This section describes your CCPA rights and explains how to exercise those rights.
In response to a verifiable consumer request for these services, we will disclose the following information:
- The categories, specific types, and sources of personal information we collected about you.
- Our business purpose for collecting the personal information.
- The categories of third parties with whom we share that personal information and the purpose for the disclosure.
We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither the Site nor our services are intended for children under the age of 18. We do not target our services or this Site to children under 18. We also do not knowingly collect personally identifiable information from children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.
VI. Deletion of Personal Information
You have the right to request that we delete any of your personal information that was collected and retained, subject to certain exceptions.
Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:
We may deny your deletion request if retaining the information is necessary for us to:
- Complete the transaction for which we collected the personal information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
- 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 or your property manager.
- 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.
VII. Submitting Consumer Requests – 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 by either:
Attn: Office Manager
111 Pine Street, Suite 1600
San Francisco, CA 94111
Toll Free Phone Number: (833) 396-2381
Only you (or someone legally authorized 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 confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) 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.
VIII. Consumer Request Responses and Timelines
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform you of the reason and extension period in writing. 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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you housing or services.
- Charge you different prices or rates for housing or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of housing or services.
- Suggest that you may receive a different price or rate for housing or services or a different level or quality of housing or services.
X. Other California Privacy Rights
In addition, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users, applicants, and residents who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.