This privacy policy (the “Privacy Policy”) of Moss Management Services, Inc. (“Moss”, “Company,” “we,” “us,” or “our,”) privacy practices regarding information we collect from persons or entities (“you” or “your”) who access our property’s RENTCafé Resident Portal website or our related mobile applications that may be available for download (collectively, the “Site”). To access the Privacy Policy of RENTCafé, please visit: https://www.rentcafe.com/apartments/privacypolicy.aspx.
 

PURPOSE. The purpose of this Privacy Policy is to inform you about the types of information we may gather about you, including information gathered when you visit the Site, and information we may receive from third parties or affiliates in addition to that online information, how we may use that information, whether we disclose that information to anyone, and the choices you have regarding our use of, and your ability to correct, the information. Company strives to help visitors of the Site protect their privacy while using our Site.
 

THE SITE IS NOT INTENDED FOR CHILDREN AND COMPANY DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF COMPANY LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).
 

YOUR CONSENT AND POLICY CHANGES. PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION, INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE SITE
 

Company may amend this Privacy Policy from time to time. Should the Privacy Policy be modified in any way, the new Privacy Policy will be posted to this webpage. As we may make changes from time to time without notifying you, we suggest that you periodically review the Privacy Policy. By using the Site after the effective date of any modification to the Privacy Policy, you expressly consent, without qualification, to the collection, use and disclosure of information, including Personally Identifiable Information (that you previously provided or later provide), as described in the new Privacy Policy.

 

TYPES OF INFORMATION COLLECTED. We collect two types of information: Personally identifiable information and non-personally identifiable information. Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”). We also may collect information that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data, information about you such as how you use the Site and your communication preferences, and other anonymous statistical data involving the use of our Site (“Non-Personally Identifiable Information”).
 

Personally Identifiable Information we collect may include, but is not limited to: your name, email addresses, postal addresses, postal codes, user Internet Protocol (IP) addresses, social security/insurance 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 you choose to become a registered user of the Site or our products and services), emergency contact information, information about your pets, information about your vehicles including license plate numbers, and other information either desirable or necessary to provide quality services to our customers and visitors. We may also collect information about you such as your use of the Site and communication preferences.

 

Additional Information we may collect includes your name, signature, social security number, address, telephone number, passport number, insurance policy number, education, employment, employment history, financial information, medical or health insurance information, records of products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, credit history, lease information, rental history, rent amount, browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, internet postings, age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status, pictures, videos, and sounds, employment or other professional information i.e. current job and past job history, job title, and, in the case of prospective and current residents or tenants, pay history, income.

PURPOSE FOR OBTAINING INFORMATION

  1. We process and retain Personal Information to achieve the purpose you provided the information to us for; including, but not limited to contracting with us to become a tenant or applying for employment with us.
  2. We process Personal Information for the performance of services and to better understand how we can help prospective residents, current residents and employees in the future.
  3. We also process Personal Information in accordance with our legal rights and obligations under applicable laws.

Third Parties with Whom We Share Personal Information

Contracted service providers who provide IT, system administration and hosting, payment processing, research and analytics, marketing and data enrichment for the purposes set forth above.

Our affiliates where required based on the affiliate’s relationship with you or where sharing of data is necessary to fulfill a request you have submitted.

Third-party advertising networks and websites so that Moss can market and advertise on third party platforms and sites.

Professional advisors such as lawyers, bankers, auditors and insurers.

Third parties who are part of a business transition such as a merger, reorganization or the sale of all or a part of our business.

 

 

You may choose not to provide your Personally Identifiable Information by not entering it on the Site; however, you will not be able to use certain services and features if those services and features require Personally Identifiable Information in order to function.

 

USE OF COOKIES AND OTHER TECHNOLOGIES. Like many other website operators, Company may use cookies to customize content specific to your interests and track your use of the Site. “Cookies” are text files that are placed on your computer and may be used to store your personal information. In addition to cookies, Company may use other now known or later developed technologies, to assist Company in observing the behavior of users visiting the Site. These technologies access individual user information but the information is used only to compile aggregated statistics about the Site’s usage.

 

This Site uses 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 Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for Company’s use, and providing other services relating to Site activity and usage. 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. The use of cookies by Google Analytics is covered by Google’s privacy policy: https://www.google.com/policies/privacy/.

 

You can choose to delete existing cookies, allow or block all cookies, and set preferences for certain websites in your browser’s settings. Please note you may not be able to use the full functionality of the Site if you choose to block all cookies.

 

HOW WE COLLECT AND USE INFORMATION. We may collect information in several ways by your use of this Site, as well as from forms you submit to us, personal correspondence, such as emails or letters that you send to us, information you include in an application you complete on the Site, information you provide when scheduling a property visit through the Site, or any other activity through which you identify yourself to us. When you visit the Site, our servers may log your IP address, the URL of your request and other information that is provided in the HTTP header. We may also ask you to voluntarily provide us with personal information on this Site. For example, while many of the features of the Site are available without registering, you may be asked to create an account on the Site if you desire to access certain features. Further, in some instances, we may ask you to provide personal information in order to perform screening services. Although you may decline to voluntarily provide Personally Identifiable Information when asked, some features, products and services will be unavailable to you as a result.
 

Company may use the information collected from you to provide services which you have requested from us, including, without limitation, enabling you to use the Resident Portal. We may also use your personal information to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits.

 

EMAIL MANAGEMENT. You may receive emails from Company for a variety of reasons. We respect your desire to manage email correspondence. If you have an account with Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.

 

SHARING OF INFORMATION COLLECTED. Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any information we gather from you on our Site.
 

We may share with third parties, including, without limitation, our corporate partners, aggregated demographic and statistical information that is not personally identifiable.
 

Company may also disclose an individual’s personal information:

 

To a person who in the reasonable judgment of Company is seeking the information as an agent of the individual;

In situations where sharing or disclosing your information is required in order to offer you products or services you desire;

To a third party or parties, where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process;

If, in the reasonable judgment of Company, it is necessary to enforce compliance with our internal policies or the Terms of Use, to prevent illegal activity or suspected fraud, or to protect our Site, customers, or others; and

To any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of Company’s assets.

 

Company may be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena/summons. We also may disclose such information in response to a law enforcement agency’s request.

 

HOW WE STORE YOUR INFORMATION. Company is committed to protecting the security of any personal information you provide to us. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. In spite of these protections, Company cannot guarantee the security of any data submitted over the Internet. After your information reaches Company, however, it is protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process your personal information in the United States or Canada or any other country in which we or our agents maintain facilities. By using the Site, you consent to the transfer of your information among these facilities, including those located outside your home country.

 

THIRD-PARTY WEBSITES. This Privacy Policy applies solely to information collected by Company. This Privacy Policy does not apply to other websites that are accessible through this Site, including but not limited to any third-party websites.

 

DATA RETENTION. In order to provide you with the products and services you request, answer questions you may have about the products and services provided, and for our own accountability to external regulatory bodies, we retain your information for a period deemed reasonable under the circumstances. Information stored is removed, destroyed, or deleted from time to time when it appears we will no longer have a need to contact you. Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law.
 

 

ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION. You can see, review and

change most of your personal information by logging into your account on the Site and editing your Account Profile or by contacting us at the addresses below. If your personal information changes or is inaccurate, you must change it promptly.

 

There may be circumstances where your personal information is not accessible, reviewable or able to be modified by you through your account. With some exceptions, you have the right to see what personal information we hold about you. We can help you identify what records we might have about you and we will also try to help you understand any information you do not understand. We may need to confirm your identity before providing you with this access, and we reserve the right to charge a nominal fee for such requests. In some cases, we may require that your request to us for access be made in writing. If we cannot give you access, we will tell you within 30 days or as soon as reasonably practicable and provide you with a reason, as best we can, as to why we cannot give you access.

 

RIGHTS OF INDIVIDUALS. Site users who wish to correct, update, change, or erase the information they submit on the Site should be able to go back to the applicable web form or their account to edit their user or organization record. For additional information or problems accessing your information from such page, please contact Company using one of the methods listed below.
 

If you consider that we have processed your personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

 

Notice to California Residents Regarding Your California Privacy Rights

California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes during the immediately prior calendar year (12 months only). To make such a request, please contact us at: [email protected] or submit your request via postal mail to Moss & Company, Attention: Data Privacy, 15300 Ventura Blvd., Suite 405, Sherman Oaks, CA 91403, (818) 990-5999. You must

reference California Consumer Privacy Act as the subject line in your request, and include your full name, e-mail address, and postal address in your message.

What are your rights

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their Personal Information. These rights and the methods for exercising them are described in more detail below. Please note that this section applies only to and the rights described in it can only be exercised by residents of California.

  1. Under the CCPA you have the right to:
  2. To Request a Disclosure of Information Collected
  3. To Request a Disclosure of Information Sold
  4. To Request an Opt-Out of the Sale of Your Personal Information. Opt-Out Link
  5. Nondiscrimination relating to Consumers who exercise CCPA rights
  6. To Delete the Information Collected
    1. However, under certain circumstances your request that your Personal Information be deleted may be denied if:
      1. The information retained by Moss is related to a “business purpose” which is defined as information:
        1. Reasonably necessary and proportionate to achieve the operational purpose for which it was collected or processed, or,
        2. For another operational purpose that is compatible with the context in which it was collected.
      2. Some examples of a “business purpose” under CCPA may include but are not limited to:
        1. Auditing related to a current interaction with the person whose data Moss has obtained i.e. ad impressions and verifying positioning and qualify of ad impressions;
        2. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
        3. Debugging errors that impair functionality;
        4. Short-term, transient use, provided the Personal Information (a) is not disclosed to another third party, and (b) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction;
    2. Performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and 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;
    3. Undertaking internal research for technological development and demonstration; and
    4. Undertaking activities to verify or maintain the quality or safety of, or upgrade or enhance, a business’ service or device.

Based upon our understanding of the term "sell" under the CCPA, we do not and have not sold your your Personal Information in the last 12 months.

 

CONTACTING US.

 

If you have questions regarding this Privacy Policy or the use of information collected, please contact Drew Abrams at [email protected]ny.com (818) 990-5999.

If you send us an e-mail, your communication should clearly be marked as a data protection query and as being time sensitive.

You may also contact us by postal mail at Moss & Company, Attn.: Data Privacy, 15300 Ventura Blvd., Suite 405, Sherman Oaks, CA 91403. If you contact us by mail, your communication should clearly be marked as a data protection query and as being time sensitive.
 

Canada. To the extent it is applicable, this policy is made under the Personal Information Protection and Electronic Documents Act. There are some rare exceptions to the commitments set out above.

 

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

 

 

Address: 112 Kent Street, Ottawa, ON K1A 1H3 Phone: (613) 995-8210

Toll-free: (800) 282-1376

Facsimile: (613) 947-6850

TTY: (613) 992-9190

Website: www.priv.gc.ca/en/

 

 

 

 

Updated: December 31, 2019

 

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