PRIVACY POLICY
PURPOSE
This privacy policy (the “Privacy Policy”) describes our privacy practices regarding information that we collect from individuals or entities who access or otherwise interact in any manner whatsoever (collectively, “Users”) with our website (the “Site”). Unless specifically stated otherwise, this Privacy Policy applies only to information that we gather or collect via the Site.
USER CONSENT AND POLICY CHANGES
PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. USERS EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. ANY INDIVIDUAL OR ENTITY THAT DOES NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY IS NOT AUTHORIZED TO USE OR INTERACT WITH THE SITE IN ANY MANNER WHATSOEVER.
THE SITE IS NOT INTENDED FOR CHILDREN AND WE DO NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF WE LEARN THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO US THROUGH THE SITE, WE WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM OUR RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS MAY BE REQUIRED BY LAW).
We reserve the right, in our sole discretion, to modify, update, alter, revise and/or edit this Privacy Policy (“Updated Privacy Policy”) from time to time. Any and all Users hereby agree that we may notify Users of the Updated Privacy Policy by posting it on the Site and that use of the Site after the effective date of the Updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes agreement to, and consent to be bound by, the Updated Privacy Policy. Accordingly, Users should review this Privacy Policy and any Updated Privacy Policy before using the Site. The Updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified therein, and will apply to use of the Site thereon.
INFORMATION WE COLLECT
We collect Personally Identifiable Information and Non-Personally Identifiable Information. “Personally Identifiable Information” is information that identifies a User or can be used to identify or contact a User.
Personally Identifiable Information we collect may include, but is not limited to, a User’s name, age, email addresses, postal addresses, ZIP codes, social security number, driver’s license number, prior addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name and password (if a User elects to register with the Site), and information regarding emergency contacts, pets, vehicles (including license plate numbers), User tendencies and communication preferences, and any other information necessary or desirable to us in connection with providing quality services to our Users and customers.
We also may collect information that by itself typically cannot be used to identify or contact Users, such as demographic information (e.g. age, profession or gender), User Internet Protocol (IP) addresses, browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data, and other anonymous statistical data involving use of the Site (collectively, “Non-Personally Identifiable Information”).
Users may choose not to provide Personally Identifiable Information by not entering it on the Site; however such Users will not be able to utilize certain services and features if those services and features require Personally Identifiable Information in order to function.
HOW WE COLLECT INFORMATON
We may collect Personally Identifiable Information from Users at various places and through various mechanisms on the Site. This may include, for example, if Users complete and submit any electronic forms or payments to us on the Site, participate in promotions, contests, or sweepstakes, interact with any forum, bulletin board, or chat room that is offered by us on the Site, register for e-mail communications, or submit survey responses, questions or requests to the Site using a form or the e-mail address links on the Site. We may also ask Users to voluntarily provide us with information on this Site: for example, while many of the features of the Site are available without registering, Users may be asked to create an account on the Site if they desire to access certain features. Although a User may decline to voluntarily provide Personally Identifiable Information when asked, some features, products and services will be unavailable to such User as a result.
We may also collect Personally Identifiable Information from Users through means other than the Site, such as when Users submit paper rental applications, remit rent payments by check, or phone or visit our management office. This Privacy Policy does not apply to Personally Identifiable Information provided to us through the foregoing means, or to any means other than a User’s interaction with the Site. However, if we combine the Personally Identifiable Information we collect from a User outside of the Site with Personally Identifiable Information that we collect through the Site, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.
Furthermore, we may receive Personally Identifiable Information about Users from other sources. For example, if a User is applying for an apartment, condo, corporate housing, or employment, either via the Site, offline, or via a third party, we may obtain Personally Identifiable Information including, but not limited to, creditworthiness, criminal background, income, and residence history, among other information, as part of the application process. This Privacy Policy does not apply to Personally Identifiable Information about Users that we receive from other sources. However, we may combine the information we receive from these other sources with Personally Identifiable Information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.
USE OF COOKIES AND OTHER TECHNOLOGIES.
When Users visit the Site, we automatically collect certain information on User activities. “Site Usage Information” is information about how our visitors use and navigate the Site. This includes, for example, the number and frequency of visitors to each web page, the length of their stays, the type of browser each visitor is using to view the Site (for example, Internet Explorer, Firefox), the type of operating system each visitor is using, (for example, Windows XP, Mac OS), the domain name of each visitor's Internet service provider (for example, America Online, Earthlink), the visitor's IP address, the address (or "URL") of the web site that the visitor came from before visiting the Site, which pages were visited on the Site, what was clicked on, and certain other available information. An IP address is a number that is automatically assigned to a computer whenever it accesses the Internet, which our web servers use to identify where to send information requested by User computers. If a User requests pages from the Site, our servers log the User’s IP address as well as information about the User’s activities on those pages.
Site Usage Information is frequently anonymous information, since it is not normally associated with a User or their identity. However, Site Usage Information may be used for a number of purposes, such as system administration, analysis of User demographics, Site performance enhancement, reporting aggregate information to our business partners, or auditing Site use. If Site Usage Information is combined with a User’s Personally Identifiable Information in a manner that it is directly associated with a User’s identity, it will be treated as Personally Identifiable Information under this Privacy Policy.
To collect Site Usage Information, the Site (and any e-mails sent to Users by the Site or otherwise by us) may utilize Cookies, Web Beacons, Embedded Scripts or similar technologies:
“Cookies” are small data files sent to a User’s browser when a User visits the Site, which are stored on the User’s computer. Whenever a User visits the Site, Cookies automatically identify a User’s web browser, and may make navigating and using the Site easier. Also, by tracking User behavior, Cookies help us determine which areas are popular and which are not. Additionally, accepting Cookies may allow Users to, among other things, personalize and enhance their experience on the Site. If a User does not want to allow for use of Cookies, such User can generally opt-out by setting browsers to reject Cookies. However, please be aware that some areas and features of the Site may not be available to Users, in whole or in part, who disable the use of cookies.
“Web Beacons” are small, often invisible, graphic elements included in a web page or e-mail, allowing the party that set the Web Beacon to monitor and collect certain limited information about the viewer of the web page or e-mail message (such as the type of browser downloading the Web Beacon, the IP address of the computer that the Web Beacon is sent to and the time the Web Beacon was viewed, as well as the URL of the page the web beacon comes from). We may use Web Beacons for many purposes, such as to tally visitors to the Site, or to monitor how visitors navigate the Site, and we may include Web Beacons or similar technologies in e-mails in order to count how many of the e-mails (or particular articles, links, etc.) we sent were actually opened.
“Embedded Scripts” are programming codes designed to collect information about User interactions with the Site, which are temporarily downloaded onto computers from our server or a third party we work with, and are active only while a User is connected to the Site – thereafter, Embedded Scripts are deleted.
We may elect to utilize Google Analytics (and in the future may use other similar sites or services), a web analytics service provided by Google, Inc. (“Google”), to better assist us in understanding how the Site is used. Google Analytics will place Cookies on a User’s computer that will generate information that we select about use of the Site, including such User’s computer’s IP address. That information will be transmitted to and stored by Google, and will be used to evaluate User activities on the Site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Typically a User may refuse the use of Cookies by selecting the appropriate settings on their web browser. However, by doing so, such User may not be able to use the full functionality of the Site. Because Google is a third party, the use of Cookies by Google Analytics is covered by Google’s privacy policy (http://www.google.com/policies/privacy/).
In addition to Cookies, Web Beacons, Embedded Scripts, and Google Analytics, we reserve the right to use other now known or later developed technologies to assist us in observing and analyzing User behavior.
HOW WE USE THE INFORMATION WE COLLECT
We do not share Personally Identifiable Information with third parties for those third parties' marketing purposes. We may share Non-Personally Identifiable Information, such as Site Usage Information or other aggregated user statistics, with third parties. In addition, we may share Personally Identifiable Information as set forth in this Privacy Policy and in any other manner in which a User expressly consents via the Site.
We may, and reserve the right to, retain and use Personally Identifiable Information and Non-Personally Identifiable Information for any and all purposes that we deem necessary or desirable to us, including but not limited to (1) the provision of services or transactions; (2) analysis of rental applications or any other interactions by and among any and all Users and us otherwise; (3) communicating with Users regarding information, features or offers that we believe will be of interest to them; (4) responding to User requests; (5) contacting Users in regard to the Site; (6) processing information submitted through the Site; (7) conducting User surveys; (8) combining such information with any other information that we may be lawfully in possession of in order to analyze any and all associations between Users and us otherwise; and (9) the fulfillment of any other purpose disclosed at the time a User provides Personally Identifiable Information.
We may share Personally Identifiable Information with affiliates, subsidiaries, or third parties who, without limitation, require access to Personally Identifiable Information for business purposes related to tenancies or to process any application, request, inquiry, or other information. We may also share Personally Identifiable Information with third parties who perform services on our behalf, including, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renters’ insurance, or provide credit checks, resident screening, collection services, marketing assistance, or create, host and/or provide customer service on our behalf.
We may disclose Personally Identifiable Information and Non-Personally Identifiable Information (1) when we believe in good faith that the law requires it; (2) at the request of governmental authorities conducting an audit or investigation; (3) pursuant to a court order, subpoena, or discovery request in litigation; (4) to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Site and applicable laws, rules, and regulations; or (5) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Site, its Users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
We reserve the right to disclose and transfer Personally Identifiable Information in connection with a corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change. In addition, when a potential buyer is interested in purchasing our property, we may provide the potential buyer with information about the property and the tenants who live there, which may include Personally Identifiable Information. Upon the sale of the property in which a User lives, all of such User’s Personally Identifiable Information may be transferred to the purchaser.
HOW WE STORE INFORMATION
We maintain commercially reasonable safeguards to maintain the security and privacy of Personally Identifiable Information that we collect. However, we cannot guarantee the security of any data whatsoever submitted over the Internet. The information we collect from Users, in accordance with this Privacy Policy, is stored on servers protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process any of the information we may collect in the United States or any other country in which we or our agents maintain facilities. By using the Site, Users consent to the transfer of any information that we are authorized to collect hereunder to be transferred to and stored at any of these facilities. No storage or processing of Personally Identifiable Information on the Site or on other servers or databases to which such information may be transferred can be guaranteed to be completely secure. Please consider this prior to interacting with the Site and/or submitting Personally Identifiable Information to us via the Site.
Users are responsible for maintaining the secrecy of Personally Identifiable Information that they do not wish to be shared, and for controlling any and all interactions they may elect to have with the Site or any third party. Furthermore, we are not responsible for the functionality, privacy, or security measures of any other organization.
THIRD PARTIES
THIS PRIVACY POLICY DOES NOT GOVERN ANY INTERACTIONS OR USE, STORAGE, AND/OR FURTHER COLLECTION OR DISSEMINATION OF INFORMATION THAT MAY OCCUR WHEN USERS ELECT TO ENTER, REGISTER, UTILIZE, OR OTHERWISE INTERACT WITH, IN ANY MANNER WHATSOEVER, ANY THIRD PARTY, INCLUDING BUT NOT LIMITED TO THE RENTCAFE APPLICATION PORTAL OR RENTCAFE RESIDENT PORTAL LINKED TO THE SITE, REGARDLESS OF WHETHER ACCESS TO THIRD PARTY INTERACTIONS ARE AVAILABLE ON THE SITE, OR WHETHER SUCH INTERACTIONS BETWEEN USERS AND THIRD PARTIES ARE OTHERWISE CAUSED OR OCCASSIONED BY INTERACTING WITH THE SITE. ANY INTERACTIONS BY AND AMONG USERS AND THIRD PARTIES SHALL BE GOVERNED BY THE PRIVACY POLICIES AND PROCEDURES OF SUCH THIRD PARTIES. ANY THIRD-PARTY WEBSITE OR SERVICE THAT MAY PROCESS PAYMENTS OR PERFORM SCREENINGS FOR US, AS WELL AS ANY WEBSITES OF OUR ADVERTISERS, SPONSORS, AND AFFILIATED ENTITIES THAT ARE ACCESSIBLE THROUGH THE SITE ARE CONSIDERED THIRD PARTIES, AND THEREFORE ANY AND ALL INTERACTIONS USERS MAY HAVE WITH THEM ARE NOT GOVERNED BY THIS PRIVACY POLICY.
In addition, RentCafe and/or our other third-party service providers may ask Users voluntarily to provide Personally Identifiable Information or Non-Personally Identifiable Information through the Site or on their websites and may share such information with us, as governed by their respective privacy policies. Unless expressly provided otherwise herein, our use of, or interaction with, any information received from any such third party will be dictated by the privacy policies of such third party and not this Privacy Policy.
Furthermore, certain content on the Site may be served by a third party now or in the future. These third parties may also drop their own Cookies and/or use Web Beacons or Embedded Scripts. We do not control the use of such technology by third parties, the information they collect, or how they use and/or store such information.
Thus, Users should consult the specific privacy policies posted on third party sites when linking to them, as any links on the Site providing access to any third party web pages, services, or materials do not imply that we endorse or have reviewed such, and we are not responsible for any conduct employed by or related to any web pages, services, or materials linked to or from our Site, or any information or content contain therein. We are not responsible and do not have control over any third-parties that Users authorize to access Personally Identifiable Information or Non-Personally Identifiable Information, whether voluntarily or involuntarily. Any User who interacts with a third-party website or service does so at their own risk. We therefore encourage Users to monitor when and if they are interacting with a third party and not us.
This Privacy Policy applies explicitly to the interactions between individual Users and the Site and, in regard to the subject matter discussed herein, does not apply to any interactions that Users may have with one another. For more information on our role in regard to interactions by and among Users, please visit our Terms of Use, available at Greybarn-LI.com.
RIGHTS APPLICABLE TO USERS IN THE EUROPEAN UNION
Legal bases for using your Information
If you are subject to the EU General Data Protection Regulation (“GDPR”), our legal basis for collecting and using information that you provide to us will depend on the information concerned and the specific context in which we collect it. There are different legal bases that we rely on to use Personally Identifiable Information that you provide to us, namely:
Performance of a contract. The use of Personally Identifiable Information may be necessary to perform the terms and conditions or other policies under which we provide our services.
Consent. We may collect and use Personally Identifiable Information on the basis of your consent, which you may revoke at any time. Please contact us if you wish to withdraw your consent to our use of information provided by you.
Legitimate interests. We may use your Personally Identifiable Information for our legitimate interests to improve our services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances we shall ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personally Identifiable Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for the purposes described in the “HOW WE USE THE INFORMATION WE COLLECT” section of this Privacy Policy.
Choices under the GDPR
If your Personally Identifiable Information is subject to the protections offered by the GDPR, you may:
Access, correct, update or request deletion of your Personally Identifiable Information, at any time by contacting us using the contact details provided under the “CONTACT US” section below;
Object to processing of your Personally Identifiable Information, ask us to restrict processing of your Personally Identifiable Information or request portability of your Personally Identifiable Information;
Withdraw your consent at any time if we have collected and process your Personally Identifiable Information with your consent;
Complain to a data protection authority about our collection and use of your Personally Identifiable Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the United States and Canada) are available here:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
To exercise any of these rights, please contact us in accordance with the contact details set forth below. Please note that if you are not subject to the GDPR, the rights explicitly enumerated in this section do not apply to you.
EMAIL MANAGEMENT
Users may receive emails from us for a variety of reasons associated with their interactions with the Site. We respect the desire of Users to manage email correspondence. Users can manage receipt of some types of communication by following the instructions included emails we send. Please note that, even if Users unsubscribe from certain email correspondences, we may still need to email Users with important transactional or administrative information. If at any time you no longer wish to receive email communications from us, please contact us at info@greybarn-LI.com.
UPDATING USER INFORMATION
In accordance with routine corporate record-keeping practices, we may delete certain records. Except as otherwise herein provided, we are under no obligation to store any User’s Personally Identifiable Information or Non-Personally Identifiable Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information. However, we may retain Personally Identifiable Information and Non-Personally Identifiable Information for a commercially reasonable time for backup, archival, and/or audit purposes.
SEVERABILITY
If any provision of this Privacy Policy is held invalid under any applicable law, such invalidity will not affect any other provision of this Privacy Policy that can be given effect without the invalid provision. Further, all terms and conditions of this Privacy Policy will be deemed enforceable to the fullest extent permissible under applicable law.
CONTACT US
We invite you to contact us to discuss any of the above provisions at info@greybarn-LI.com.
