PRIVACY POLICY

 

Last updated: March 12, 2020

A. General Privacy Policy

B. California Privacy Policy

C. Texas Privacy Policy

A. General Privacy Policy

Alliance Residential Company (hereinafter referred to as “ARC”) and its subsidiary companies, including but not limited to Alliance Residential, LLC; Alliance Southwest, LLC; Alliance Communities, LLC; and Alliance Communities, Inc., are committed to protecting the personal privacy of visitors and guests using its Internet sites (collectively, the “Site”).

ARC understands how important your privacy is to you. ARC collects and uses your personal information (such as your name, address, phone number and email address) for purposes including giving you superior customer service and providing you with convenient access to a wide range of products and services. We may use your personal information to keep you informed of new products, services and other information you may like to hear about. ARC may use your personal information to contact you to participate in surveys or gauge customer satisfaction.

Personal information is collected in different ways, such as when we ask for your contact information, when you register for information, answer surveys, or complete questionnaires on the Site. You may remove your email address from the distribution lists of ARC or our business partners at anytime by notifying us or the business partners, respectively.

 

Definitions of Types of Information

Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. In order for you to access certain services or to purchase services that are offered via the Site, we require you to provide us with such personal information. Personal information may include: contact data (such as your name, mailing and e-mail addresses) and financial data. If you communicate with us by e-mail or otherwise complete online forms, surveys or contest entries, any information provided in such communication may be collected as personal information.

 

Traffic Data

Traffic data is not personal information because it is anonymous information that does not personally identify you, but is helpful for marketing purposes or for improving your experience on the Site. Traffic Data is information on a user's patterns of access and usage of the Site. We automatically track and collect the following information when you visit our Site, including your: (i) IP address; (ii) domain server; (iii) type of computer; and (iv) type of web browser. We also use "cookies" as a method to gain dependable and consistent Traffic Data. "Cookies" are anonymous and do not personally identify you.

From time to time, ARC may run contests in which participants are asked for contact information, such as their e-mail address (es). If you participate in these contests, your contact information will be used primarily to reach you in connection with the contests. We may also use the collected contact information to send you information about ARC, our services, as well as offers tailored to your interests, if you have opted to receive these communications. You may choose to opt-out of receiving such mailings at the time of registration for the contest, or afterwards, by emailing us at [email protected].

 

Cookies

A "cookie" is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. Cookies do not damage your system or impair its functioning in any way. We use cookies to help us provide customizable services and to allow you to sign-in to the Site. You can choose whether to accept cookies by changing the settings of your browser. You can reset your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. If you choose not to accept these cookies, your experience at the Site and other websites may be diminished and some features will not work as intended.

 

Tracking over Time and Across Websites

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit know that you do not want the websites collecting your personal data.

We may track your online activities over time and across third-party websites or online services. For example, we might use web beacons to help us determine what links or advertisers brought you to our Site. We then track your activities on our Site.

 

Security

ARC operates secure data networks protected by industry standard firewall and password protection. ARC has security measures in place to attempt to protect against the loss, misuse and alteration of your user data under our control.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to close your browser after you have completed your visit to the Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal data.
 

Third-Party Relationships

In order to optimize your experience on the Site, ARC maintains relationships with many corporate partners and service providers. If you have any questions about whether certain information, content or services pertain to us, or are provided by one of our partners, please contact us at 602-778-2800.

 

Changes to This Privacy Policy

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal data, we will provide a prominent notice of such changes and  the effective date of the changes before making them.

 

B. California Privacy Policy

 

Assistance For The Disabled

Alternative formats of this California Privacy Policy are available to individuals with a disability.  Please contact [email protected] for assistance.

 

This California Privacy Policy explains:

  1. How we collect the personal information of California consumers
  2. How we share the personal information of California consumers
  3. California privacy rights

 

Scope:

This California Privacy Policy only applies to the personal information of residents of the state of California in their capacity as consumers (“California consumers”). “Consumer” does not include ARC’s employees, job applicants, owners, directors, officers, medical staff members, or contract workers (collectively, “HR individuals”), or the emergency contacts of HR individuals or the dependents or spouses who receive ARC benefits by virtue of their relationship to an HR individual in their capacities as HR individuals or emergency contacts, dependents, or spouses.  “Consumer” also does not include employees or other agents of a business engaged in a transaction with ARC in their capacities as employees or agents of that business.

 

This California Privacy Policy applies to all personal information of California consumers collected, disclosed for business purposes, or sold by ARC, regardless of whether the personal information is collected, disclosed or sold through ARC’s website.  To the extent that any part of the General Privacy Policy conflicts with any part of this California Privacy Policy, this California Privacy Policy prevails with respect to the personal information of California consumers.

 

1. How We Collect The Personal Information Of California Consumers

 

Categories Of Personal Information Collected In The Last 12 Months

 

Sources Of That Personal Information

Business Purposes And Commercial Purposes For Collecting That Personal Information

Identifiers, including: name, address, phone number, signature, email address, account name (log-in information), social security number, and driver’s license number

(a) current residents (“Residents”) and (b) prospective consumers who may be interested in becoming a resident (“Prospectives”)

 

  • To verify the identity of Residents and Prospectives
  • To perform services, including maintaining or servicing Resident accounts and providing customer service
  • To allow Residents to access their online accounts
  • To facilitate communications and to communicate with Residents
  • Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys
  • To promote and market the properties
  • To comply with laws and regulations

 

Categories described in Cal. Civ. Code § 1798.80(e)  including: social security number and driver’s license number

 

Characteristics of protected classifications under California or federal law, including: gender, age, marital status, and veteran status

Residents and Prospectives

 

The purposes listed for “Identifiers”

In addition:

  • Demographic information for internal research and development, to improve our services, and for marketing purposes

 

Internet or other electronic network activity information, including consumer’s interaction with ARC website and IP addresses

Automated technologies in the website, including Google Analytics

The purposes listed for “Identifiers”

In addition:

  • To promote and market the properties to Prospectives and Residents
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for these activities

 

Sensory information, including:  video surveillance of the properties, voicemails, and call recording

Residents and Prospectives

 

  • For quality assurance
  • To facilitate communications and to communicate with Residents
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for these activities

 

Professional or employment-related information, including: current employers

Residents and Prospectives

 

  • To verify employment of Residents and Prospectives
  • To determine income qualification

 

Profile information, including: preferences for the type of units prospective residents may be interested in renting

Prospectives

  • To help Prospectives with selecting units

Financial Information, including bank account information, credit/debit card numbers, income

Residents and Prospectives

The purposes listed for “Identifiers”

In addition:

  • To process rent payments
  • To determine income qualification

 

Product and Service Usage Information

Residents and Prospectives

 

  • To manage the properties and rental agreements
  • To promote and market the properties
  • For communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys
  • To perform services, including maintaining or servicing current resident accounts and providing customer service

 

 

2. How We Share The Personal Information Of California consumers

 

Disclosure of Personal Information: ARC discloses all the categories of personal information above for business or commercial purposes.  The personal information is disclosed to the following categories of third parties:

  • Service providers that assist ARC with administrative and operational functions
  • Owners of the property in which the Resident resides or to which the Prospective has applied
  • Government agencies, law enforcement, and other parties as required by law and as necessary to protect the rights, property, or safety of ARC, its subsidiaries or affiliates, employees, customers, and users

 

Sale of Personal Information: In the last 12 months, ARC has NOT sold California consumers’ personal information and will not sell this information. ARC has no actual knowledge that it sells the personal information of minors under 16 years of age.

 

3. Your California Privacy Rights and How To Exercise Them

a. Your California Privacy Rights

  • Right to Know: California consumers have the right to submit a verifiable request to know what personal information ARC collects, uses, discloses, and sells.
  • Right To Delete: California consumers have the right to submit a verifiable request for deletion of their personal information that ARC has collected or maintains. 
  • Right to Opt Out of Sale: California consumers have the right to opt out of the sale of their personal information. California consumers under the age of 16 must opt in to the sale of their personal information, or their parent or guardian must opt in on their behalf. As noted above, ARC did not sell California consumers’ personal information during the past 12 months. 

 

b. How to Exercise Your Rights

ARC will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California consumers can exercise their rights to know and to delete in the following ways:

 

c. How We Will Verify Your Request:

The processes that we follow to verify your identity when you make a request to know or a request to delete are described below.  The relevant process depends on why the request is submitted.

  1. Requests To Know Categories Or Purposes:  If you request to know categories of personal information collected, sources, sales, or ARC’s business or commercial purposes for use of your personal information, we will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity.  Examples of relevant data points include your mobile phone number, your zip code, or information about products or services that you have purchased from us.
  2. Requests To Know Specific Pieces Of Personal Information:  We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we will require you to sign a declaration under penalty of perjury that you are the California consumer whose personal information is the subject of the request.
  3. Requests To Delete Personal Information:  Our process for verifying your identity will depend on the sensitivity (as determined by ARC) of the personal information that you ask us to delete.  For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above.  For more sensitive personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.

 

We have implemented the following additional procedures when verifying the identity of requestors:

  1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information.  If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process.  We will not use that information for any purpose other than verification.
  2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

 

d. Authorized Agents

  • You may designate an authorized agent to exercise your right to know or your right to delete by submitting to us a completed “Authorized Agent Designation” form.  You can obtain the designation form by contacting us at [email protected].

 

If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you to follow the applicable process described above for verifying your identity.

 

d. ARC’s Non-Discrimination Policy

California consumers have the right not to be subject to discriminatory treatment by ARC for exercising their privacy rights under the California Consumer Privacy Act, and ARC will not discriminate on that basis. However, ARC may charge a California consumer a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the California consumer by the consumer’s personal information.  If ARC does so, it will provide consumers with any legally required notice.

 

For More Information

For questions or concerns about ARC’s privacy policies and practices, please contact us at  [email protected].

 

 

C. Texas Privacy Policy

 

This Texas Privacy Policy, as well as the General Privacy Policy, applies to the personal information of rental applicants and residents who reside in Texas. To the extent that any part of the General Privacy Policy conflicts with any part of this Texas Privacy Policy, this Texas Privacy Policy prevails with respect to the personal information of rental applicants and residents who reside in Texas.

 

General. We are dedicated to protecting the privacy of your personal information, including your Social Security Number and other identifying or sensitive personal information. Our policy and procedures are designed to help ensure that your information is kept secure, and we work to follow all federal and state laws regarding the protection of your personal information. While no one can guarantee against identity theft or the misuse of personal information, protecting the information you provide us is a high priority to our company and staff. If you ever have concerns about this issue, please feel free to share them with us.

 

How personal information is collected. You will be asked to furnish some of your personal information when you apply to rent from us. This information will be on the rental application form or other document that you provide to us or to an apartment locator service, either on paper or electronically.

How and when information is used. We use this information only for our business purposes involved in leasing a dwelling to you. Examples of these uses include, but are not limited to, verifying statements made on your rental application (such as your rental, credit and employment history), reviewing your lease for renewal and enforcing your lease obligations (such as to obtain payment for money you may owe us in the future).

How the information is protected and who has access. We allow only authorized persons to have access to your personal information, and we keep documents and electronic records containing this information in secure areas and systems.

How the information is disposed of. After we no longer need or are required to keep your personal information, we will store or destroy it in a manner designed to prevent unauthorized persons from accessing it. Our disposal methods will include shredding, destruction or obliteration of paper documents and destruction of electronic files.

Locator services. If you found us through a locator service, please be aware that locator services are independent contractors and are not our employees or agents--even though they may initially process rental applications and fill out lease forms. You should require any locator services you use to furnish you their own privacy policies.

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