This privacy policy is effective January 31, 2020

Holland Partner Group and its affiliates, subsidiaries successors and assigns (collectively, “Holland,” “we,” “our” or “us”) respects your privacy (“Privacy Policy”).  This Privacy Policy describes 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 of this Privacy Policy. 

1.      What Personal Information We Collect.   Holland may collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you or your household (referred to herein as “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.

·       Characteristics of Protected Classifications Under California or U.S. Law - Including without limitation disability or medical condition, gender, marital status, military or veteran status

·       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 (e.g., as a security measure and to ensure the safety of our properties, we may also use video surveillance technology at our properties).

·       Professional or Employment Information -  Including without limitation benefits and entitlements data, bonus payments, business unit / division, company / entity, compensation data, contract type - 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.

·       Other Categories of Personal Data that Relates to or is 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.      How We Collect Your Personal Information.  Holland collects your personal information from the following categories of sources: Information you voluntarily provide to us; Information we collect automatically from you through your electronic device; 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., we may ask for your name to confirm you are on our RSVP List and we may 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 provide your consent for them to share your personal information with us.

 

3.      How We Use Your Personal Information. Holland collects and uses your personal information for business and commercial purposes in accordance with the practices described in this Privacy Policy.  Our business and commercial purposes for collecting and using information include without limitation:

·       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 Holland and its employees, residents and other persons or their property.

·       Pursuing legal matters such as defending against claims and/or establish or exercise any legal rights that Holland 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 Holland 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.      Who We Share Your Personal Information With. We 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 - Holland shares 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 Holland 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 - Holland 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.      Privacy Policies of Third Parties and External Links. Our websites contain links to several third-party websites, software, or applications not owned or controlled by Holland, 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.      RENTCafé. 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. For example, our Resident Services portal is run and operated by RENTCafé.   RENTCafé provides certain residential services such as payment processing, maintenance support and requests, and other technical support.  RENTCafé operates bulletin boards and chatrooms, and may offer promotions, contests or sweepstakes.  RENTCafé collects your personal information to provide you with these services and may require the creation of an account to access these services. RENTCafé has represented to us that it and its service providers store your data on a secure server.

 

For more insight, please read RENTCafé’s Terms of Service (https://resources.yardi.com/legal/rentcafe-terms-of-service/) and/or Privacy Statement (https://resources.yardi.com/legal/privacy-statement/), each of which RENTCafé has the right to modify from time to time.

 

7.      Cookies and Other Similar Technology. We also collect information automatically through the use of electronic tools. We may log the name of your Internet service provider, IP address, or use “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 placed by our website can only be accessed by our website; other websites you visit cannot access these cookies. We use cookies to maintain session and preference information to improve the use of the website. 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.

 

We also allow cookies to be placed on your computer by third parties for the purpose of website analytics. This allows a third party to collect data about your use of our website. We don’t share the data that third parties collect with anyone besides the third party. We use the data that is 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 use clear GIF Tracking Pixels to track user movement through our website for aggregated website traffic measuring. 

 

8.      Security and Storage.  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.      Policy Changes.  Holland 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 upper left hand corner of this Privacy Policy. If the changes are significant, we may provide a more prominent notice.

 

10.   Children.  Our websites are intended for general audiences and is not directed to 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 us at dataprivacy@hollandpartnergroup.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.   Your Choices You Have Over How Your Information is Used.  In this section, we describe the rights and choices available to all users.

·       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 contacting us at dataprivacy@hollandpartnergroup.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 resident community websites and portals are operated by our service providers such as RENTCafé.  If you are a resident of a Holland community and use your residential platforms and community website, you will need to opt-out of your residential platform and community website separately from our websites.  You will also need to opt-out separately from any third party websites you have registered with.

·       Cookies - 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 Holland or its service providers from providing you certain features of our 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 serve advertising across the internet by using the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. We do 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.  For example, 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.

California residents have additional rights as set forth below in the section entitled “California Residents: Your California Privacy Rights.”

 

12.   California Residents: Your California Privacy Rights. California residents have specific rights regarding their personal information as described below.  These rights are subject to certain exceptions.  When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.

·       Right to Know About Personal Information Collected or Disclosed - You have the right under the California Consumer Privacy Act (“CCPA”) to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

¨      The categories of personal information we have collected about you in the last 12 months.

¨      The categories of sources for the personal information we have collected about you in the last 12 months.

¨      Our business or commercial purpose for collecting that personal information.

¨      The categories of third parties with whom we share that personal information.

¨      The specific pieces of personal information we collected about you.

¨      If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

·       Right to Request Deletion of Personal Information - You have the right under the CCPA to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will delete all information that we are not allowed to maintain under applicable law.  

·       How to Exercise the Above Rights. To exercise your rights discussed described above, please submit a verifiable consumer request to us by emailing us at dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

 

You may make a verifiable consumer request no more than two times within a 12-month period. The verifiable request must:

¨      Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Such verification process will involve you confirming details of the personal information we have collected about you, and will increase in scope in the event the nature of your request relates to the disclosure of sensitive personal information or the deletion of any personal information;

¨      Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; and

¨      Include a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know/Delete request has been made.”

·       Right to Appoint an Authorized Agent - You are also permitted to designate an authorized agent to submit the above requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above method before processing the authorized agent’s request.

·       Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights - You may exercise your rights under the CCPA without discrimination. However, if you choose not to provide us with certain information, you may not be eligible to receive certain promotions and offers for our services.

·       Additional Disclosures Related to Collection, Use, and Disclosure of Personal Information - Sections 1 through 4 of this Privacy Policy describe the categories of personal information we collect, categories of sources of personal information that we collect from, the business or commercial purposed we collect for, and categories of third parties we disclose information to.

·       Sale of Personal Data - We do not believe that we sell your personal information as defined under the CCPA and we will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.

·       Direct Marketing and Do Not Track Signals - Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes.  Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any).  The notice will cover the preceding calendar year.  To obtain such a notice, please contact us as described below.  In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals.  Holland does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, most web browsers (like Safari) allow you to set the DNT signal on your browser so third parties (particularly advertisers) know you do not want to be tracked. 

 

13.   Nevada Residents: Your Nevada Privacy Rights. Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. Holland does not sell your personal information to third parties as defined in Nevada law, and will not do so without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us via the methods set forth below in the section entitled “How to Contact Us” below.

 

14.   Geographic Restrictions. 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.

 

15.   How to Contact Us.  If you have questions or concerns regarding our Privacy Policy or need to obtain a copy of this Privacy Policy in alternate format due to a disability, please contact us by email at dataprivacy@hollandpartnergroup.com or by telephone at 1-888-212-2157.

 

 

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