Effective Date: January 1, 2020
Last Updated: November 17, 2020
Collecting and Using Information
Personally Identifiable Information We Collect Online
We may collect Personally Identifiable Information from you through your use of the Site. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
If you complete the “Contact Us” webform on our Site, you will voluntarily provide us with your first and last name and email address and may provide us with your telephone number and any additional Personally Identifiable Information that you choose to provide in the “tell us more” field.
Information as You Navigate Our Site
We automatically collect certain Personally Identifiable Information through your use of the Site, such as the following:
- Usage Information. We collect information such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
- Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.
- Location Information. We collect location information from Site visitors on a city-regional basis.
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect to contact you, improve our Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
- Contact you regarding our listings, events, special offers and promotions, and services that we feel may be of interest to you;
- Provide support;
- Maintain and improve our Site;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with applicable law.
How We Share Your Personally Identifiable Information
We may share the information that we collect about you in the following ways:
- With service providers who perform data and Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.).
- To service providers to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
- To any other person or entity as part of any business or asset sale; and
- To any other person or entity where you consent to the disclosure.
- Estimate audience size and usage patterns;
- Advertise content and services that relate to your interests;
- Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
- Recognize when you return to the Site.
How You Can Opt-Out of Cookies
Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.
You can opt-out of Cookies set by specific entities by following the instruction found at these links:
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use service providers to process your debit and credit card and/or bank account transactions.
“Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
The Site is not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
Notice to Nevada Residents
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to email@example.com.
Notice to California Residents
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
- Identifiers (name, postal address, internet protocol address, email address, Social Security number)
- Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Telephone number
- Bank account number
- Credit and debit card number
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Professional or employment-related information (including employment history)
- Imagery of face (i.e., photographs)
- Protected classifications (gender, age (40 and older), and marital status)
In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect, and have collected and sold, the above categories of Personal Information for the following business or commercial purposes:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider
- Undertaking activities to verify or maintain the quality of our services and to improve, upgrade, or enhance said services
- Advancing a person’s commercial or economic interests, such as by inducing another person to rent, lease, join, or subscribe to products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure or Sale of Personal Information
|Category of Personal Information||Category of Service Providers||Category of Third Parties|
|Name and email address||Property management provider; customer relationship management provider; website host and developer; payment processor; application processing and screening provider; legal services provider; collections agencies; resident survey provider; marketing provider; email service provider||Advertising agencies|
|Social security number||Application processing and screening provider|
|Unique personal identifiers (cookies, beacons, pixel tags, or other similar technology) and Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)||Data analytics provider; marketing provider; email service provider||Advertising agencies|
|Telephone number||Property manager; package/service request portal; customer relationship management provider; website host and developer; payment processor; application processing and screening provider; legal services provider; collections agency; resident survey provider; marketing provider|
|Postal address||Customer relationship management provider; payment processor; application processing and screening provider; legal services provider; collections agency; resident survey provider|
|IP address||Payment processor; customer relationship management provider; website host provider; application processing and screening provider; data analytics provider|
|Credit and debit card number; bank account number||Payment processor|
|Age; marital status; gender||Customer relationship management provider; application processing and screening provider|
|Signature||Application processing and screening provider; collections agency|
|Employment history; professional or employment-related information||Application processing and screening provider; collections agency|
|Imagery of face (i.e., photographs)||Smart key system|
We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know or Delete
Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct us to stop selling your Personal Information.
The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
You may submit a request to opt-out of sales through our interactive webform available by clicking on this link: “Do Not Sell My Personal Information.” You also may submit a request to opt-out of sales by emailing us at firstname.lastname@example.org or by contacting us toll-free at 1-800-505-1381.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Shine the Light Law
We do not disclose personal information obtained through our Site to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
How to Contact Us
For questions or concerns about our privacy policies or practices please contact us at:
c/o The Wolff Company II, LLC
6710 E. Camelback Rd., Suite 100
Scottsdale, AZ 85251
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