PRIVACY POLICY

This Privacy Policy is effective as of March 10, 2021.

The Angelo Property Co., L.P. and its affiliates, subsidiaries, successors, and assigns (collectively, the “Company,” “we,” “our” or “us”) respects your privacy. This policy (the “Privacy Policy”) details our information gathering and disseminating practices and your rights regarding your personal information. By visiting our websites, offices, properties, and events, you are accepting the practices described in this Privacy Policy. References in this Privacy Policy to “you” and “your” mean the user and/or visitor of our websites, services, offices, properties, and events. We encourage you to read this Privacy Policy before you send or share personal information with us. You acknowledge that by accessing, using, or visiting our websites, services, offices, properties, and events, you are agreeing to be bound by the terms and conditions herein. 

1.      Categories of Information Collected

The Company may collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you or your household (your “Personal Information”). The categories of Personal Information we may collect and have collected directly from you within the past 12 months include:

·        Identifiers. Including, without limitation, your real name, alias, account name, online identifier, Internet Protocol Address, unique identifiers, email address, postal address, phone number, driver’s license number, social security number or national identification number and details, passport number, signatures, or other similar identifiers. Our web servers automatically collect unique identifiers that can be used to recognize you or your device, including, without limitation, your domain name, Internet Protocol address, beacons, pixel tags or other device and mobile identifiers or similar technology.

·        Personal Records. Including without limitation account number and password, application and claims history, financial account information, resident names, contact information, payment card number, credit history, criminal history, date of birth, emergency contact details, or insurance policy information.

·        Protected Classifications Under Washington or U.S. Law. Including, without limitation, race, creed, color, national origin, sex, marital status, or disability.

·        Payment Data. Including, without limitation, your credit card information, billing address or any financial information you provide in connection to your resident application for one of our properties or when you pay rent. 

·        Commercial Information. Including without limitation records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·        Internet or Other Electronic Network Activity Information. Including, without limitation, your browsing history, search history, and any other information regarding your interaction with our websites and advertisements. 

·        Geolocation Data. Including, without limitation, information that can help identify your physical location like your GPS coordinates or the approximate location of your electronic devices.

·        Audio and Visual Information. Including, without limitation, voice and video recordings for the purposes of, but not limited to, surveilling our properties to ensure the safety thereof.

·        Professional or Employment Information:  Including, without limitation, benefits and entitlements data, bonus payments, business unit/division, company/entity, compensation data, contract type, whether fixed term/temporary/permanent etc., corporate credit or debit card numbers, hours of work, job application details (e.g., application form, interview notes, references), job title/role, line/reporting manager, office location, personnel number, previous work history, qualifications/certifications, reference or background checks, salary/wage, salary/wage expectation, or start date.

·        Inferences Drawn About your Preferences. Including, without limitation, your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, decisions, and actions as it relates to the apartment size you are looking for, where you want to live, the type of building and living environment you prefer, your proposed rent budget, the number of individuals you wish to live with, whether you have or want pets, and other preferences as it relates to our services and properties.

·        Data Reasonably Capable of Being Associated with You. Including, without limitation, the messages you send us via social media websites, networks or other services that host user-generated content (e.g., your comments to our Instagram or Facebook posts or when you tag or otherwise link us in your social media posts) and your answers to our resident surveys. 

·        Data About Others. Including, without limitation, Personal Information of individuals whom you list as an emergency contact, family member or apartment occupants, such as their real name, alias, email address, phone number, postal address, date of birth, the type of your relationship with them, marital status, and age. Please do not share Personal Information about other individuals with us unless you have their permission to do so.

2.      Collecting Personal Information

The Company collects the following categories of information: information you voluntarily provide to us; information we collect automatically from you through your electronic device(s); and information from third parties. We may collect data when you:

·        Create an account on our website.

·        Sign up for our newsletters.

·        Participate in our surveys.

·        Submit a resident application for one of our properties.

·        Register as a resident at one of our properties. 

·        Use our website (i.e., through our browser cookies, web beacons, third party software development kits, and other similar technology). 

·        Voluntarily complete a survey or send us messages or other content regarding feedback and inquiries relating to our websites, services, offices, properties, events, marketing material, and other advertisement and collaboration proposals.

·        Voluntarily comment on our social media posts hosted by third party platforms or tag or otherwise link us on your social media posts.

·        Voluntarily disclose Personal Information to our customer service providers and staff.

·        Visit our properties (i.e., through our access control and video surveillance technology).

·        Use our guest Wi-Fi service.

·        Attend our events (e.g., proof of identification confirming you are on our RSVP List; we may also take photos and record videos at our events for marketing and promotional purposes).

·        Participate in our chat logs offered on our websites, residential platforms and community websites, and message boards.

·        Interact with other third parties (e.g., our service providers) and consent for them to share your Personal Information with us.

3.      Utilizing Personal Information

The Company collects and uses your Personal Information for business and commercial purposes in accordance with the practices described in this Privacy Policy. The information collected may be used in the following ways:

·        Sending you alerts regarding our services, properties, and events you have expressed an interest in, or we think may interest you. 

·        Processing your applications, rent payments, and insurance claims.

·        Operating, managing, and improving our websites, services, offices, properties, events, marketing material, resident outreach, and promotions.

·        Performing services requested by you, such as responding to your comments and property requests, processing, servicing, or enforcing transactions, and sending related communications.

·        Maintaining the security and integrity of our systems, operations, websites, services, offices, properties, and events.

·        Engaging service providers to conduct background checks, credit screens, fraud detections, payment processing services, property management services and other similar and related services.

·        Preventing and addressing fraud, unlawful access, and breach of our policies and terms.

·        Sending you technical notices, updates, security alerts, information about our policy changes, and other administrative messages.

·        Helping to establish and verify the identity of users and complying with all applicable laws and regulations.

·        Protecting the rights, property, or safety of the Company and its employees, residents and other persons or its property.

·        Pursuing legal matters such as defending against claims and/or establish or exercise any legal rights that the Company may have.

·        Analyzing trends and usage, such as the efficiency of deliveries and operations, and troubleshooting problems with our website, software, or Wi-Fi systems.

·        Facilitating our accounting, auditing, and reporting requirements for internal purposes or in connection with a merger, acquisition, or other business transaction.

·        Re-posting content voluntarily provided by you on our message boards or social media networks, platforms, or other user-generated content providers not operated by the Company for our marketing purposes.

·        Creating promotional videos from audio or videos taken at our events for our own marketing purposes. 

·        Conducting surveys to better understand how we can help current and prospective residents.

·        Fulfilling any other business or commercial purposes at your direction or with your consent.

4.      Sharing Personal Information 

The Company may disclose information we collect in accordance with the practices described in this Privacy Policy. The categories of third parties to whom we may disclose, and have shared information with within the last 12 months, include, without limitation:

·        Service Providers. We share information with entities that help us with maintaining and operating our websites, payment processing, data analytics, marketing, and advertising, and for other business and commercial purposes discussed in this Privacy Policy. These companies may only use such information to perform specific services that we have contracted them for and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for any purpose except as prohibited by applicable law.

·        Vendors. We may share information with vendors and other entities in connection with tailoring advertisements, measuring and improving our websites and advertising effectiveness, processing your reservations to our events, executing our services and events, enabling other enhancements to our websites, services, offices, properties, events, and marketing material, and helping us execute our other business and commercial purposes discussed in this Privacy Policy. These companies may act as our service providers, or in certain contexts, independently decide how to process your information.

·        Affiliates. We share information with our related entities including, without limitation, our parent, subsidiaries and sister companies, or to their employees, agents, contractors, representatives, legal counsel and/or accountants, for: operational, management and administrative purposes; internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes; or as otherwise permitted or required by law.

·        Promotional Partners. If you voluntarily subscribe to our newsletters, we share information to help us provide and operate our newsletter offerings.  This includes without limitation sharing your information with our service providers that maintain our newsletters, our third-party partners (if applicable) participating in our promotions or events, or other third parties for administrative purposes.

·        Third Parties in Connection with a Merger, Acquisition or Other Business Transaction. We may share information if the Company is involved in a merger, acquisition, sale of all or a portion of its assets, financings, joint ventures, reorganizations, dissolution, liquidations, or other event where we sell or transfer all or a portion of our business assets or equity.  WE WILL NOT PROVIDE YOU WITH NOTICE BEFORE DISCLOSURE IN SUCH CASES. 

·        Third Parties for Security and Compelled Disclosure Purposes. The Company must disclose information about you in response to lawful requests by public authorities, including but not limited to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud. Such disclosures may be carried out without notice to you.

·        Third Parties that You Direct Us to Share With. We share information at your request or direction, such as when we contact your family member that you listed as your emergency contact after you have been involved in an accident. We may also share your information with other third parties as required by applicable law or to those you have consented or directed us to share your information with.

5.      This Privacy Police Does Not Apply to External Links

Our websites contain links to several third-party websites, software, or applications not owned or controlled by the Company, and this Privacy Policy does not apply to such websites, software, or applications or the use of any data by such websites, software, or applications. Should you decide to navigate to any websites, software, or application or webpages external to our websites, you do so entirely at your own risk. We are not responsible for the actions, privacy, security, or content of such third-party websites, software and applications. If you are asked to provide information on one of these websites, software, and applications, we encourage you to carefully review their privacy policy before sharing your information.

6.      Utilizing On-Site’s Leasing Software

We use separate sites for the processing of resident applications and agreements and to assist our residents with other tasks which are required or helpful to them. You will move away from our websites when engaging in those activities (e.g., when viewing a residential property for rent on alangelo.com, clicking on the “Apply Now” button will re-route users to an application portal operated by On-Site.com). On-Site, a RealPage, Inc. subsidiary, provides certain residential services which may include application and payment processing, maintenance support and requests, and other technical support. On-Site collects your Personal Information to provide you with these services and may require the creation of an account to access and maintain these services. On-Site has represented to us, and publicly represents on its webpage (on-site.com), that it and its service providers store your data on a secure server, but makes the following disclaimer, “no security program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose Personal Information. We maintain security incident response policies and procedures to handle incidents involving access to personal data we process.”

For more insight, please read On-Site’s Terms of Service (https://www.on-site.com/tos-announcement/) and/or Corporate Privacy Policy (https://www.on-site.com/privacy-policy/), each of which On-Site and/or RealPage, Inc. has the right to modify from time to time.

7.      Use of Cookies and Similar Technology

Currently, the Company does not automatically collect Personal Information through the use of “cookie” technology to store your preferences and record session information. A “cookie” is a small piece of data placed on your computer by us. Within your web browser, cookies can only be accessed by our website; other websites you visit cannot access these cookies. However, the Company reserves the right to modify its websites from time to time, and may adopt the use of cookies to, amongst other things, maintain session and preference information to improve the use of our websites. Should the Company begin to use cookies on its websites, you may set your web browser to decline our cookies; however, this may render portions of our website unusable. To learn more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit https://www.allaboutcookies.org.

While the Company does not currently use cookie technology, if such technology is later adopted, we may allow cookies to be placed on your computer by third parties for the purpose of website analytics. This would allow a third party to collect data about your use of our website. We would not share the data collected with anyone besides the third party and would only use the data collected in the following ways:

·        to report, in aggregate, how our visitors find and use our website;

·        to understand overall visitor behavior; and

·        to update and improve our website.

            As we adopt additional technology, we may also gather information through other means. Additionally, we may use log files to track how the website is being accessed and used. Log files track anonymous user information such as IP addresses, browser types, Internet service providers, referring and exit pages, platform type, date and time stamps, and number of clicks to, from, and within the website. We may also use clear GIF Tracking Pixels to track user movement through our website for aggregated website traffic measuring.

8.      Storing Your Personal Information

We believe our websites incorporate safeguards to protect the security, integrity, completeness, accuracy, and privacy of the Personal Information we have collected. We have put in place reasonable precautions to protect information from loss, misuse, and alteration; however, despite our efforts, please be aware that no security measures are perfect or impenetrable and we cannot guarantee that the information you transmit or provide to us will be completely secure. 

We will retain your Personal Information for as long as needed to provide you with our services (e.g., as long as you have an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our services, or maintaining security, and in each case, as consistent with applicable law. We may retain non-Personal Information that has been sufficiently aggregated or anonymized for a longer period.

9.      Implementing Changes to the Privacy Policy

The Company may at any time amend the provisions in this Privacy Policy. Changes to this Privacy Policy will be reflected by the “Effective Date” as displayed in the first line of this Privacy Policy. If the changes are significant, we may provide a more prominent notice.

10.   Children Sharing Personal Information without Parental Consent

Our websites are intended for general audiences and are not directed toward children under 13. We do not knowingly collect Personal Information from children under 13. If you become aware that a child has provided us with Personal Information without parental consent, please contact our customer service representative at Nicolek@alangelo.com. If we become aware that a child under 13 has provided us with Personal Information without parental consent, we will take reasonable steps to remove such information and terminate the child’s account (if applicable).

11.   Our Users’ Rights

All users sharing Personal Information with the Company have the following rights:

·        Review and Update Your Account Information. If you submitted a resident application or registered for an account with us, you may review, update, or delete certain Personal Information regarding your account by logging into your account and editing your profile information or by contacting our customer service representative at Nicolek@alangelo.com.

·        Opt-Out of Marketing Communications. You may opt out of marketing-related emails and direct mail by following the opt-out or unsubscribe instructions located at the bottom of such messages. You may continue to receive service-related and other non-marketing emails and direct mail (e.g., confirmation emails regarding receipt of your resident application). As discussed above, our application and leasing portals are operated by our service providers such as On-Site. If you reside within a Company-owned community and use these portals, you will need to separately opt-out of marketing communications sent by these providers. You will also need to opt-out separately from any third-party websites you have registered with.

·        Cookies. While the Company does not currently utilize cookie technology, it is important to know that most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Note that disabling cookies and/or other tracking tools may prevent the Company or its service providers from providing you certain features of our/their websites. 

·        Advertising Choices. Your device settings may provide functionality to limit use of advertising ID associated with your device for interest-based advertising purposes. Additionally, you can manage third-party advertising preferences for some of the third parties we work with that advertise across the internet by using the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. The Company does not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do. 

·        Privacy Settings and Location Data. Users of our websites can disable our access to their device’s precise geolocation in their electronic device settings.

·        Choosing Not to Share Your Personal Information. If you do not provide information that we need to provide you with our services, we may not be able to provide you with such services or provide you access to certain features of our websites, properties, or events (e.g. if you do not provide us with the information we request in our resident applications, we may not be able to process your application and provide you with an opportunity to be a resident at one of our properties). 

·        Third Party Platforms or Social Media Networks. We encourage you to review your privacy options and settings of third-party platforms, including without limitation social media platforms and networks, that you use in connection with our websites, services, and properties.   We recommend you understand what choices you have about sharing information from those platforms and networks with us.

12.   Our Websites are Intended for U.S. Residents Only

We may limit the availability of our websites to any person or geographic area at any time. If you access our websites from outside the United States, you do so at your own risk.

OUR WEBSITES ARE INTENDED FOR UNITED STATES RESIDENTS ONLY. IF YOU ARE A USER ACCESSING OUR WEBSITES FROM ANY OTHER COUNTRY WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM THE LAWS OF THE UNITED STATES, PLEASE BE ADVISED THAT THROUGH YOUR CONTINUED USE OF OUR WEBSITES, YOU ARE TRANSMITTING YOUR PERSONAL DATA TO THE UNITED STATES AND YOU CONSENT TO THAT TRANSMISSION. ADDITIONALLY, YOU UNDERSTAND THAT YOUR PERSONAL INFORMATION MAY BE TRANSMITTED TO AND PROCESSED IN COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE LESS STRINGENT THAN IN YOUR COUNTRY.

13.   Contact the Company

For more information about the Company’s Privacy Policy, or if you would like to obtain a copy of this Privacy Policy in alternate format due to a disability, please contact our customer service representative by email at Nicolek@alangelo.com or by telephone at (360) 694-3343.