Through this Website we assist the Property Management Company in managing their property and other assets by, among other things, facilitating communication and transactions between Users, Third-Party Providers, and the Property Management Company. We merely host or process data and personal information about Users (“Personal Information”) on behalf of the Property Management Company and Third-Party Providers and have no direct relationship with Users. We are a data processor and not a data controller with respect to your personal information. In certain jurisdictions such as Massachusetts, “personal information” is defined to include first and last names, social security numbers, driver's license or state-issued identification numbers, financial account numbers, and credit or debit card numbers, including any account numbers that may or may not require a PIN. Our definition of Personal Information includes but is not limited to only such jurisdictional definitions. We also include email addresses, employee status, gender, addresses, locations, hire dates, job titles, and salary information as Personal Information.
Our top priority is protecting the privacy and security of any Personal Information about you collected or used on our Website, as well as maintaining the trust of our Subscriber. This includes both data submitted by the Subscriber and Personal Information submitted by Users to our Website.
The Property Management Company and Third-Party Providers make their own decisions about how or why Personal Information is processed, including any disclosure or transmission to third-parties. If your individual Personal Information has been submitted or entered into this Website, or was otherwise collected by us on behalf of the Property Management Company or Third-Party Providers, and you wish to exercise any rights you may have to access, correct, amend, or delete such Personal Information, please contact the Property Management Company or Third-Party Providers directly. If an authorized representative of the Property Management Company or Third-Party Providers requests that we update or remove the Personal Information in question, and the Property Management Company or Third-Party Providers have no ability to do so, we will acknowledge their request within 30 days.
PERSONAL INFORMATION WE COLLECT
We collect Personal Information from this Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company, Third-Party Providers, and to help us better understand how we can assist Users that are searching for residential housing to rent, lease, or obtain services as a resident in the rental property they occupy.
The different types of Personal Information we collect will depend upon what we will need in order to provide you with the particular product or service you are interested in. The information requested on our registration form includes some or all of the following Personal Information: name, address, email address, telephone number, user name, password, and birth month, day and year, and will include other information that you provide voluntarily (i) in connection with your use of any interactive tools or resources on this Website relating to finding, leasing, or accessing services for a rental property, including submission of an inquiry, contact or schedule a visit form, lease application or related payment, such as your name, social security number, social insurance number, driver's license number, government identification documents, personal image of yourself, present and prior postal addresses, zip codes, postal codes, telephone numbers and email addresses, monthly rent paid at previous residences, gender, age, marital status, date of birth, employers, job titles, occupation, income, references, and payment-related information, such as credit card information, bank account information and routing numbers, emergency contact information, and information about your pets and vehicles, including license plate numbers, (ii) in connection with your submission of rental payments, service requests, or other communications with the Property Management Company, its agents or Third-Party Providers, such as your name, address, telephone number, email address, automated clearing house (ACH) information, debit or credit card information, and/or the nature of work requested, (iii) in connection with your use of any interactive educational or informational resources provided to residents, (iv) in any postings you make in any Community or otherwise on our Website or in any emails that you send to us, (v) in connection with your use or purchase of any other services or products provided by this Website or by any Third-Party Providers, such as your debit or credit card information and your purchase history, or (vi) in connection with your use of any other aspect of this Website. Certain services and features on this Website may only be used if you voluntarily provide certain information about you.
Those interested in touring, inquiring, renting or leasing a residential rental property will likely be asked to include the following additional information: the type of rental property size you are looking for, where you want to live, the type of building you prefer, your proposed rent budget, the number of individuals in your household and their ages, a copy of your and any occupants government issued identification documents, personal image of yourself and any occupants, and if you have pets or not.
THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY OR THIRD-PARTY PROVIDERS THAT OWN, MANAGE, SERVE, OR OPERATE THE RESIDENTIAL RENTAL PROPERTY YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN SERVICES AS A RESIDENT IN THE RENTAL PROPERTY YOU OCCUPY.
USAGE TRACKING: USE OF IP ADDRESSES
Every device that connects to the Internet is given a number that is known as an Internet Protocol (IP) Address. These numbers are typically assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet. As permitted under applicable law, we collect IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for Users and auditing the use of our site.
We do not usually link any IP addresses to anything that can be personally identifiable. This means that your Internet session will be logged, but you will remain anonymous to us. We will seek to link your IP address to personally identifiable information when we deem it necessary (i) to identify and authenticate you when you submit certain information to the Website, such as request to visit the property, payments, request for services or other types of communication, (ii) to be pre-qualified for a rental property displayed on this Website, (iii) when you start or complete a lease application for a rental property displayed on this Website, or (iv) to protect this Website and other Users from harm and to prevent criminal misconduct.
A cookie is a small file which contains a string of characters that is sent to your computer when you are browsing the Internet and visit a website. When you visit the same website again, the cookie enables that site to recognize your browser. Cookies may store User preferences and other information about you. You can configure your browser to refuse all cookies, or to indicate when a cookie is being sent. However, there are some website features or services that may not function properly without cookies.
Improvements and updates to this Website are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies only to provide services better suited to your needs, and for the protection of our Website and Users from potential harm. We never save passwords or credit card information in cookies.
OUR USE OF INFORMATION ABOUT YOU
We may use Personal Information about you to create your account, to enable you to use this Website, including any communities, and to facilitate communication and transactions between Users and the Property Management Company, and other Third-Party Providers for transactions between you and any of them through this Website, including but not limited to using information about you (i) in connection with any interactive decision-making tools or resources relating to leasing an a rental property, including submission of an inquiry, contact or schedule a visit forms, lease application or related payments; (ii) in connection with assisting the Property Management Company and Third-Party Providers in marketing to you, including contacting you by email, phone, text message, or otherwise; (iii) in connection with assisting the Property Management Company and Third-Party Providers in processing your lease application, including investigating your background, leasing history, and creditworthiness through third-parties, including consumer reporting agencies; (iv) in connection with processing your rental payments, service requests, and other communications with the Property Management Company and Third-Party Providers; (v) in connection with your use of any interactive educational or informational resources provided to residents; (vi) in connection with your participation in any community or in dealing with any emails that you send to us; (vii) in connection with your use or purchase of any other services or products provided by this Website or by any third-party provider; (viii) in connection with your use of any other aspect of this Website; and (ix) generally to enhance and optimize your use of this Website. We may also use your email address or telephone number to respond when you submit a question, suggestion, or request assistance with using or accessing this Website.
We may link Personal Information we collect about you with other Personal Information we collect about you, whether offline or from third-parties or otherwise. We may use Personal Information about you to send you targeted messages, publications, news, and information about events, special offers, promotions, benefits, and other advertisements. We may use Personal Information about you to improve, to analyze trends, to administer this Website, to gather demographic information about this Website's users, to track user movements, and to customize the content and layout of this Website for each individual user.
INFORMATION WE SHARE OR DISCLOSE
Similarly, the Property Management Company, Third-Party Providers and others (such as lease screening service providers, payment processors, advertisers, etc.) may share Personal Information about your use of this Website with other appropriate persons for purposes of (i) performing functions that would reasonably be expected of a Property Management Company with respect to a prospective renter, such as contacting you by email, phone, text message, or otherwise to market its space and investigating your background, leasing history, creditworthiness, either directly or through the assistance of third-parties, including credit reporting agencies; (ii) complying with law, cooperating with governmental authorities, and consulting with attorneys and other advisers, (iii) attempting to avert a threat of harm to its, or others' safety, or other interests; (iv) defending it and its owners, personnel, and affiliates in connection with any legal actions or claims; and (v) other purposes of the Property Management Company in or outside the ordinary course of its business.
We may use Third-Party Providers to send and distribute email and to perform other marketing and support functions. We may share Personal Information about you with third-parties who offer goods and services we think may be of interest to you. From time to time, we may cooperate with other organizations or companies to provide co-sponsored or co-branded promotions, services or events and may share Personal Information about you with our co-sponsor. We also may provide Personal Information about you to service providers or contractors to perform functions on our behalf, such as, but not limited to, companies or individuals hired to: communicate news, deliver our promotional materials via e-mail and direct mail, to develop, enhance, market or provide any of our products, to process credit card payments and to assist us with sending communications and performing other marketing and support functions. These third-parties may use technologies to measure the effectiveness of ads and emails, and use Personal Information about your visits to this Website so that we may provide you with a better experience on this Website. We also may use third-party social media platforms, including third-party social media websites, to communicate with you. We also may share with third-parties aggregated demographic and statistical information, such as the daily number of unique visitors to this Website, the number of users who searched for certain types of housing, and how many users clicked on a particular advertisement.
Through this Website, we may make available areas that allow for User interaction with other users, such as blogs, forums, bulletin board services, chat areas, or other message and communications features. Some of these forums may require registration. Please remember that any Personal Information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose Personal Information about yourself.
We do not rent or sell your Personal Information in a personally identifiable form to anyone, provided however, certain Personal Information may be shared with the Property Management Company, Third-Party Providers and others such as hosting service providers, analytic service providers, email service providers, lease screening service providers, custom programmers, payment processors, advertisers as more fully described above.
We may anonymize your Personal Information so that you are not individually identified and provide that information to our partners and also third-parties. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Website, so that they, too, can provide you with an optimal online experience.
Advertisers: We may allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of Users who will see their advertisements or promotional offers, and you agree that we may provide any of the Personal Information we have collected from you in a form that is not personally identifiable to Advertisers, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in New York to show you ads or offers for New York businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to Users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment, and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
Affiliated Businesses: In certain situations, businesses or third-party websites we might be affiliated with may sell or provide products or services to you through, or in connection with this Website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such businesses’ or websites’ policies.
Agents: We might employ other companies and people to perform tasks on our behalf and need to share your Personal Information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
REVIEWS AND CONTENT SUBMISSIONS
This Website may allow you to provide and submit certain content (“Content”) in the form of a review or rating as to your experience in visiting or living at the properties featured on this Website. We may share your content with the Property Management Company, Third-Party Providers and others (such as review publishers, search engines, analytic service providers, syndication sites, advertisers, etc.), and other appropriate persons for purposes of publication to this Website, social media channels, as well as other third-party websites.
THIRD PARTY PROVIDERS
It is our intention to maintain reputable Third-Party Providers to offer Users a variety of products and services on this Website. We are not responsible for their information, privacy, or other business practices. When choosing to purchase products or services on this Website, you must take into consideration that you will be transacting business directly with a Third-Party Provider, and the Personal Information about you, collected by the provider, will be subject to the practices of that provider.
THIRD PARTY WEBSITE LINKS
This Website may contain links to third-party websites that are beyond our control and take you outside of this Website. For example, if you "click" on a banner ad, which is an advertisement or a search result, the "click" may take you off this Website and on to another site that is beyond our control. These other websites may include sites of other sponsors, advertisers or partners that may use their logo with ours as part of a co-branding agreement. These other websites might also send their own cookies to Users who become visitors to their websites to collect data or solicit information. We do not control these websites and therefore are not responsible for their content. The inclusion of hyperlinks to any other websites by us on this Website, does not infer any endorsement of the content or material on such websites, nor any association with the owners or operators of the websites or the businesses listed on any of these websites. Our policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control. Be advised that if you disclose Personal Information online, that all such Personal Information may be collected and used by people you do not know.
The information practices or content of such other websites or advertisers is governed by the privacy statements of all such other websites and businesses contained on those websites. Please be advised that this Privacy Statement is not applicable to those websites and businesses, which are instead governed by their respective privacy statements. Please review the privacy statements of such other websites and businesses to understand their Personal Information collection practices.
DATA TRANSFERS AND JURISDICTIONS
We collect Personal Information relating to you that is being processed. You have the right to request that we fix, correct, supplement, delete or block your Personal Information in the event that the data is inaccurate, incomplete or irrelevant to the purposes of the processing activities, or if the Personal Information is being processed in any other way, which infringes a legal provision. If you desire to exercise your rights, or if you have any questions, concerns or suggestions regarding the use, collection, or security of your Personal Information, please contact us at firstname.lastname@example.org
When a User requests that certain information about them be deleted, we will make all reasonable efforts to remove that data from our systems. Be advised that due to the nature of the Services that we provide, some information about you may not be fully deleted due to backups or archived copies; however, such information will only be used for the purpose of what our Website does, which is to provide information, facilitate communication, transactions, and services between you and the Property Management Company or Third-Party Providers in relation to you searching for residential housing to rent, lease, or obtain services as a resident in the rental property you occupy.
CORPORATE INFORMATION: This Website and its related downloadable applications and Services is operated, hosted, and maintained by 365 Connect, LLC. Please see the "Contact Information" section for information on how to contact us.
TYPES OF PERSONAL INFORMATION PROCESSED BY US: We collect Personal Information from this Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company or Third-Party Providers, and to help us better understand how we can assist Users that are searching for residential housing to rent, lease, or obtain services as a resident in the rental property they occupy. Please see the “Personal Information We Collect" and “Usage Tracking: Use of IP Addresses" sections for more information.
THE PURPOSE AND LEGAL BASIS FOR PROCESSING: We process Personal Information for our legitimate interest of operating this Website to make Users aware of the Property Management Company’s products and services. Please see the “Personal Information We Collect" section for more information.
RECIPIENTS: We may transfer Personal Information to our other entities, primarily entities in the United States of America and other countries in or outside the EU, and to our service providers and affiliates who host and/or provide our IT system. We may also transfer Personal Information with third-party professional advisors who provide accounting, consultancy, and legal services to us. Please see the "Information We Share or Disclose" section for more information.
INTERNATIONAL DATA TRANSFERS: Your information may be transferred to and processed on computers in the United States of America and other countries, which are not in the EU. Please see "Data Transfers” section for more information.
DATA SUBJECTS RIGHTS: Please see the "Email Consent and Opt-Out," and "Fixing and Deactivating Personal Information" section for more information. In addition to these rights, you may have data portability rights. Please see the "Contact Information" section to contact us about any of your rights.
REGULATORY BODY: You may contact the national data processing authority in the EU jurisdiction if you have any concerns regarding the processing of your Personal Information this Website.
Under the GDPR, you have the right to:
- Request copies of your personal data from us. We may charge you a small fee for this service.
- Request that we correct any information you believe is inaccurate, or that we complete your information you believe is incomplete.
- Request that we erase your personal data, under certain conditions.
- Request that we restrict the processing of your personal data, under certain conditions. Note that by making such requests, we may be unable to provide you a variety of services provided by this Website.
- Object to our processing of your personal data, under certain conditions. Again, by making such objections, we may be unable to provide you a variety of services provided by this Website.
- Request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you desire to exercise your rights under the GDPR, or if you have any questions, concerns or suggestions regarding the use, collection, or security of your Personal Information, please contact us at email@example.com
CALIFORNIA PRIVACY RIGHTS COMPLIANCE
The California Consumer Privacy Act (CCPA) grants California consumers the following rights:
- The right to know what Personal Information is collected, used, shared or sold, both as to the categories and specific pieces of personal information;
- The right to delete Personal Information held by businesses and by extension, a business’s service provider;
- The right to opt-out of sale of Personal Information. Consumers are able to direct a business that sells Personal Information to stop selling that information. Children under the age of 16 must provide opt in consent, with a parent or guardian consenting for children under 13; and
- The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.
We do not sell any Personal Information to third-parties. For a description of the categories of Personal Information we collect, use, or share, please refer to “Information We Share or Disclose” as defined herein.
To make a CCPA request, contact us at firstname.lastname@example.org ; please include your full name, email address, and physical address. To ensure continued protection of your Personal Information, you will need to provide information that will allow us to verify your identity. We will respond within 45 days of receiving the CCPA request.
The California Shine the Light Law grants California consumers the following rights:
Under California's "Shine the Light" law, California residents who provide Personal Information (as defined in the statute) in obtaining products or services for personal, family or household use, are entitled to request and obtain from us once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such Personal Information for the immediately prior calendar year. To obtain this information please contact us at email@example.com ; please include your full name and physical address.
California Residents Under 18 Years of age who have registered to use this Website: This Website is intended for a general audience of 18 years of age or older. Any California residents under the age of 18 who have registered to use this Website, and who posted content or information on this Website, can request removal by contacting us at firstname.lastname@example.org , detailing where the content or information is posted and attesting that you posted it. We will then make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable laws. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that we do not control.
MASSACHUSETTS PRIVACY RIGHTS COMPLIANCE
We make every attempt to comply with Massachusetts privacy laws, including specifically, MA ST 93H and 201 CMR 17.00. Pursuant to those requirements, we have:
- Provided a comprehensive, written information security program applicable to all records containing Personal Information about a resident of the Commonwealth of Massachusetts;
- Included administrative, technical, and physical safeguards in the security program for Personal Information protection;
- Designated one or more employees to maintain and supervise the security program implementation and performance;
- Identified the paper, electronic and other records, computing systems, and storage media, including laptops and portable devices, that contain Personal Information;
- Chosen to treat all your records as if they all contained Personal Information;
- Identified and evaluated reasonably foreseeable internal and external risks to paper and electronic records containing Personal Information;
- Evaluated the effectiveness of current safeguards;
- Included regular ongoing employee training and procedures for monitoring employee compliance within the security program;
- Included disciplinary measures for violators;
- Included policies and procedures in our security program for when and how records containing Personal Information should be kept, accessed or transported off our business premises;
- Provided for immediately blocking terminated employees’ physical and electronic access to Personal Information records (including deactivating their passwords and user names);
- Taken reasonable steps to select and retain a third-party service provider that is capable of maintaining appropriate security measures;
- Requested third-party service providers implement and maintain such appropriate security measures;
- Ensured that the length of time that we are storing Personal Information is limited to the time reasonably necessary to accomplish our legitimate business purpose or to comply with state or federal regulations;
- Limited access to Personal Information to those persons who have a “need to know” in connection with our legitimate business purpose, or in order to comply with state or federal regulations;
- Specified the manner in which physical access to Personal Information is to be restricted;
- Stored our records and data containing Personal Information in locked facilities, storage areas or containers;
- Instituted a procedure for regularly monitoring to ensure that the security program is operating in a manner reasonably calculated to prevent unauthorized access to or unauthorized use of Personal Information, and for upgrading it as necessary;
- Instituted a plan to review the security measures at least annually, or whenever there is a material change in business practices that may affect the security or integrity of Personal Information;
- Instituted a procedure for documenting any actions taken in connection with any breach of security, including requiring post-incident review of events and actions taken to improve security;
- Instituted secure authentication protocols that provide for; Control of user IDs and other identifiers; A reasonably secure method of assigning/selecting passwords, or for use of unique identifier technologies; Control of data security passwords such that passwords are kept in a location and/or format that does not compromise the security of the data they protect; Restricting access to Personal Information to active users and active user accounts; and Blocking access after multiple unsuccessful attempts to gain access;
- Provided secure access control measures that restrict access, on a need-to-know basis, to Personal Information;
- Assigned unique identifications plus passwords (which are not vendor supplied default passwords) to each person with computer access, such that those IDs and passwords are reasonably designed to maintain the security of those access controls;
- To the extent technically feasible, encrypted all Personal Information that is transmitted across public networks and that is to be transmitted wirelessly;
- To the extent technically feasible, encrypted all Personal Information stored on laptops or other portable devices;
- Instituted monitoring in place to alert us to the occurrence of unauthorized use of or access to Personal Information;
- Instituted reasonably up-to-date firewall protection for files containing Personal Information on any system connected to the Internet and installed all operating system security patches to maintain the integrity of the Personal Information;
- Instituted up-to-date versions of system security agent software (including malware protection) and reasonably up-to-date security patches and virus definitions; and
- Instituted training for employees on the proper use of our computer security system, and the importance of Personal Information security.
CAN SPAM ACT COMPLIANCE
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions; and
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in compliance with CAN-SPAM we agree to the following:
- NOT use false, or misleading subject line, “To,” “From,” “Reply-To,” or routing information;
- Identify any message as an advertisement that is, in some reasonable way;
- Monitor third-party email marketing services used on our behalf for compliance, if one is used;
- Honor opt-out/unsubscribe requests quickly; and
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.
ACCESSING AND CORRECTING INFORMATION ABOUT YOU
You can review and change information about you by logging into this Website and visiting your account profile page. The account profile page is only provided to Users that use the lease application and rental payments features. You may also send us an email at email@example.com to request us to provide, correct or delete any Personal Information about you that you have provided to us. We may not accommodate a request to change Personal Information if we believe the change would violate any law or legal requirement or cause the Personal Information to be incorrect. If you delete any or all of your postings from the Website, copies of the postings may remain viewable in cached and archived pages or might have been copied or stored by other Website Users.
Where we have provided Personal Information about you to a screening service provider in order to obtain a screening report for the Property Management Company or Third-Party Provider, the report may contain credit information. Under Provincial Legislation or the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), you may have the right to access, view, and correct credit information relating to you held by a credit bureau or credit reporting agency by contacting the credit bureau or credit reporting agency.
If we collected Personal Information about you on behalf of a third-party, we may have conveyed that information directly to the third-party. If so, it may not exist as part of our own records and you will have to go to the third-party to see the information.
CONTACTING THIS WEB SITE
If your Personal Information changes, which includes zip or postal code, phone, email or postal address, we offer a way to correct, update, delete or deactivate Users' Personal Information, through either logging into your account, if you registered for one, or by contacting us at firstname.lastname@example.org
UPDATED March 1, 2022