This website and its related downloadable applications and Services (collectively, our “Website”) is operated, hosted, and maintained by 365 Connect, LLC (“365 Connect,” “we,” “our” or “us”) and is licensed for use by us to the legal entity (“Subscriber”) that owns or manages the property featured on this Website (collectively the “Property Management Company”).
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, Service Providers, and the Property Management Company. We merely host or process Data and personal information about Users on behalf of the Property Management Company, and generally have no direct relationship with Users. We are a data processor and not a data controller with respect to your personal information.
Our top priority is protecting the privacy and security of Personal Information about you and 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 makes their own decisions about how or why Personal Information is to be processed, including any disclosure or transmission to third parties. If Personal Information relating to you as an individual has been submitted or entered into this Website, or was otherwise collected by us on behalf of the Property Management Company, 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 directly. If an authorized Property Management Company representative requests that we update or remove the Personal Information in question, and the Property Management Company has no ability to do so via use of the Services, we will acknowledge their request within 30 days.
PERSONAL INFORMATION WE COLLECT
We collect Personal Information from our Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company, and to help us better understand how we can assists Users that are searching for residential apartments to rent, lease, or obtain services as a resident in the apartment 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 and day, and will include other information that you provide voluntarily (i) in connection with your use of any interactive tools or resources on our Website relating to finding, leasing, or accessing services for an apartment, including submission of an inquiry, contact or schedule a visit form, lease application or related payment, such as your name, social security number, driver’s license number, present and prior addresses, 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 or its agents, 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 provider, 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 the Website may only be used by you if you voluntarily provide certain information about yourself.
Those interested in becoming residents will likely be asked to include the following additional information: the type of apartment or apartment 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, and if you have pets or not.
THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY THAT OWN, MANAGE, OR OPERATE THE RESIDENTIAL APARTMENTS YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN SERVICES AS A RESIDENT IN THE APAERTMENT 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, and 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 rental housing displayed on this Website, (iii) or when you start or complete a lease application for rental housing displayed on this Website, (iv) or to protect the Website and other Users from harm and to prevent criminal misconduct.
USE OF “COOKIES”
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 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.
If you desire to change your cookie preferences, you can do so through your browser settings. You may also limit the information we learn from certain cookies by logging directly into the registered areas of this Website rather than by logging in by using your social media log-in credentials. Be advised that our cookies are often used to provide you with certain functionality and without them you may not be able to use some of our Website Services.
OUR USE OF INFORMATION ABOUT YOU
We may use information about you to create your account, to enable you to use our Website, including any Communities, and to facilitate communication and transactions between Users, service providers, and the Property Management Company, and other third party provider 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 apartment, including submission of an inquiry, contact or schedule a visit forms, lease application or related payment, (ii) in connection with assisting the Property Management Company in marketing to you, including contacting you by email, phone, text message, or otherwise, (iii) in connection with assisting the Property Management Company in processing your lease application, including investigating your background, leasing history, and creditworthiness through third parties, including consumer reporting agencies, (iv) in connection with the processing of your rental payments, service requests, and other communications with the Property Management Company or its agents, (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 attempt to optimize your use of our 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 information we collect about you with other information we collect about you, whether offline or from third parties or otherwise. We may use information about you to send you targeted messages, publications, news, and information about events, special offers, promotions, benefits, and other advertisements. We may use information about you to improve the content of this Website, to enhance users’ experiences when visiting this Website, to analyze trends, to administer the Website, to gather demographic information about the 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 may share information about your use of our Website with third party providers and other contractors (such as lease screening service providers, payment processors, advertisers, etc.) and other appropriate persons for purposes of (i) performing functions that would reasonably be expected of a Property Management Company with respect to a prospective tenant, 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 service providers to send and distribute email and to perform other marketing and support functions. We may share 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 information about you with our co-sponsor. We also may provide 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 information about your visits to our Website so that we may provide you with a better experience on our 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 the Website, the number of users who searched for certain types of housing, and how many users clicked on a particular advertisement.
Through the 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 information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose 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 Property Management Companies and with third-party providers and other contractors such as hosting service providers, analytics 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. However, we never disclose aggregate usage information to a partner in a manner that would identify you personally, as an individual.
Advertisers: We may allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the information we have collected from you in a form that is not personally identifiable to an Advertiser, 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 Houston to show you ads or offers for Houston 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 the 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 business’ or websites’ policies.
Agents: We might employ other companies and people to perform tasks on our behalf and need to share your 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
Our 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 other contractors (such as review publishers, search engines, analytics 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 residents a variety of products and services on our Website, but we are not responsible for their information, privacy, or other business practices. When choosing to purchase products or services on our Website, you must take into consideration that you will be transacting business directly with a third-party provider, and the 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 other third party websites that are beyond our control, and take you outside of our Services. 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 sites might also send their own cookies to Users who become visitors to other 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 our Website, does not infer any endorsement of the content or material on such sites, 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 information online, that all such 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 information collection practices.
When this Website receives web browser “do not track” signals (or other mechanisms that provide consumers the ability to exercise their choices regarding the collection of personally identifiable information about a consumer’s online activities over time and across third-party websites or online services), our Website does not alter its behavior or change its services. Other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different websites when the consumer uses this website or its services.
SAFEGUARDING YOUR INFORMATION
We take all reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction; taking into account the risks involved in the processing and the nature of the Personal Information.
Our resident services and application accounts require a username and password to log in. You must keep your username and password secure, never disclose it to a third party, and do not allow others to utilize your account. You should fully exit from your account at the end each session, by utilizing the logout feature. You should also implement a practice of changing your password on a regular basis. If Users have any questions about security, please contact us at: email@example.com.
CHILDREN UNDER 13 YEARS OF AGE
Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use this Website in any way. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will take reasonable measures to delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
CALIFORNIA PRIVACY 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.
CAN SPAM ACT
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 tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in compliance with CANSPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Monitor third party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- 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 the Website and visiting your account profile page. You may also send us an email firstname.lastname@example.org to request us to provide, correct or delete any information about you that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the 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 information about you to a screening service provider in order to obtain a screening report for the Property Management Company, the report may contain credit information. Under 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 by contacting the credit bureau.
If we collected 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 THE WEB SITE
ACCEPTANCE OF THESE TERMS
LAST UPDATED JULY 20, 2018