Privacy Policy
Last updated March 27, 2020
Introduction
This Privacy Policy sets out the privacy
practices of The ConAm Group of Companies and its affiliates (“ConAm”,
“Company”, “our”, “we”, or “us”) in relation to information that we may collect
about you in the circumstances listed below. This Privacy Policy is in
addition to our Terms and Conditions.
· When
you visit this domain, or any associated URLs owned or controlled by ConAm (collectively,
the “Website”) or access our applications (“Apps”), and any content or features
available on the Website or Apps;
· Offline,
in our interactions we may have with you;
· When
you apply for a job with ConAm;
· In
email, and through other electronic messages between you and us through the
Website and Apps;
· When
you interact with our advertising and Apps on third-party websites and
services, if those advertising or Apps include links to this Privacy Policy.
This Privacy Policy does not apply to
information we collect in your capacity as an employee or contractor of
ConAm.
Please read this Privacy Policy carefully
to understand our policies and practices regarding your information and how we
will treat it. By providing your information to ConAm either through the
Website or otherwise, you signify that you consent to the use of information
about you in accordance with this Privacy Policy, as posted here. If you do not
agree with any term in this Privacy Policy, you should not access and use the
Website or Apps and please do not otherwise provide us with any information
about you.
The Privacy Policy may change from time to time. If we make
changes, we will notify you, obtain your consent and take any other such
measures as required by applicable law.
Information We Collect About You and How We Collect it
Information You Provide to us:
We collect information about you as
follows:
· By
filling in forms on our Website or Apps including information you upload to our
Website and information you provide at the time you register to use our Website
or Apps, subscribe to our services or request further services;
· When
you communicate with us through any means or engage in any transaction on our
Website or Apps;
· When
you have questions about or report a problem with our Website or services;
· When
inquiring about or applying for a job at ConAm;
· When
dealing with ConAm in your capacity as an investor or potential investor;
· When
engaging in search queries on the Website.
Information We Collect Through Automatic
Data Collection Technologies:
In addition, as you navigate through and
interact with our Website or App, we may use automatic data collection
technologies to collect certain information about your equipment, browsing
actions, and patterns.
We also may use these technologies to
collect information about your online activities over time and across
third-party websites or other online services (behavioral tracking). Please
read below (Do Not Track) for information on how you can opt-out of
behavioral tracking on this Website and how we respond to web browser signals
and other mechanisms that enable consumers to exercise choice about behavioral
tracking.
The information we collect automatically is
statistical data, however, it may include information about you, and we may
maintain it or associate it with information about you that we collect in other
ways or receive from third parties.
Technologies we use include:
Cookies (or browser cookies). A cookie is a small file that may be
used, for example, to collect information about the Website and your browsing
activity. You may refuse to accept browser cookies by activating the
appropriate setting on your browser. However, if you select this setting you
may be unable to access certain parts of our Website. Unless you have adjusted
your browser setting so that it will refuse cookies, our system will issue
cookies when you direct your browser to our Website. Specific information about
how we use such technologies and how you can refuse certain cookies is set in
our Cookie Policy.
Web Beacons. Pages of our the Website and our
emails may contain small electronic files known as web beacons (also referred
to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company,
for example, to count users who have visited those pages or opened an email and
for other related Website statistics (for example, verifying system and server
integrity).
Information Received from Other Sources
We may obtain information about you from
other sources, such as public databases, social media platforms (Such as
Facebook, Twitter, Instagram) as well as from other third parties, including
affiliates and vendors. We are not responsible for the privacy practices of
third parties and encourage you to read and understand how any third party or
social media platform may use and share information about you.
We do not purchase any information about
individuals to perform targeted advertising or provide any special offer to
customers.
Categories of information collected
We have in the last 12 months collected
information about you via the means set out above:
· Name,
postal address, home address (current and previous), age or date of birth,
email address, telephone number, number of children, vehicle information
including license plate number, your occupation, employment information, education,
driver’s license number, passport number, military ID, social security number
or other tax or national identification number, information related to
properties which you would like further information, or project;
· Social
Media Profile Information (Your name, gender, birthday, email, current city,
state and country, user identification number for your contacts, profile
picture URL, and any other information that you choose to make public);
· Marketing
leads and search results and links, including paid listings (such as sponsored
links);
· Any
information you may submit to us in correspondence, using any means of contact.
In certain instances, we may need to
collect additional or more detailed information. In addition to the above
categories of information, we have collected information about you in the last
12 months in the following contexts:
As an investor, we collect information
about your assets, your income, transactional activity in your account,
information about your product and service needs, investment experience, bank
account details, wire transfer instructions, investor profile, details from
passports or other government-issued documents including social security
numbers or EIN’s, and authentication information for access to your account;
As an applicant to or member of an
apartment community, we collect information about the property that you have
purchased, leased or rented, your income, your creditworthiness, utility
account information, any other tenants that you may wish to include on the
lease, information about any pets, bank account details, maintenance requests,
bank account details, credit card information, emergency contact and next of
kin.
As a visitor to our Website or App user, we
have collected details of your visits to our Website, traffic data, clickstream
data, location data, logs and other communication data, the resources that you
access and use on the Website such as your IP address, internet service
provider, operating system and browser type;
As a job applicant, we have collected
information we need to handle your application including your ability to
legally work in the country for which you are applying for employment,
information regarding your qualifications, references, professional licenses or
resume information, personal and family details, criminal history (as permitted
by law), medical and health screening details, and information with respect to
career commencement and development including date of hire, employee category
and full-time or part-time status. Where permitted by applicable law, you
will be given the opportunity to provide information on your gender, race, or
ethnicity. We may gather this information from you for reporting and
record-keeping requirements, but we will only use this information in
accordance with applicable law and will not use it in making any employment
decisions. Providing this information is strictly voluntary, and you will not
be subject to any adverse action or treatment if you choose not to provide it.
Such information will be kept in a confidential file separate from your
application for employment.
How We Respond to Do Not Track Signals
Some web browsers may let you enable a “Do
Not Track” feature that sends signals to the Website you visit, indicating you
do not want your online activities to be tracked or engaged in other types of
data collection. These are segments of computer code that communicate with a
Website similar to cookies. However, this is different than blocking or
deleting cookies, as browsers with a “do not track” feature enabled may still
accept cookies. This Website does not currently honor “Do Not Track” requests.
If we do so in the future, we will describe how in this Privacy Policy.
How We Use Your Information
Below are the ways that we use information
about you:
Offerings and Services that Interest you:
· When
you visit or do business on our Website;
· When
you make submissions to us;
· When
you request information from us;
· Employment
opportunities beyond the position you may have applied for;
· When
you contact us.
Marketing Communications
· To
track our visitors' use of the Website for internal market research;
· To
improve the Website and the services ConAm promotes or provides through the
Website or through other means;
· To
customize the content and/or layout of our Website for each individual visitor;
· To
notify you about updates to the Website or services;
· Contact
you about jobs that may be of interest to you;
· Contact
you about investments that may be of interest to you.
Professional Interactions – Customer
Relationship Management
· To
communicate with you over phone or email;
· To
complete any leasing process;
· To
request a credit report in connection with leasing or job applications;
· To
process job applications;
· To
contact you in response to your inquiries, comments, and suggestions;
· To
contact you otherwise when necessary;
· To
complete any transactions you may perform at the Website;
· To
use certain de-identified and aggregated data for data analytics;
· Document
and report accidents, injuries and incidents;
· To
provide better service to customers.
Other Uses:
· To
develop and display content and advertising tailored to your interests and to
measure its effectiveness;
· To
improve our Website and deliver a better and more personalized service,
including by using information collected automatically to estimate our audience
size and usage patterns, speed up your searches and recognize when you return
to our Website;
· To
ensure safe and guaranteed services performance to you, upgrade and improve
functionality of the services;
· To
store this information in aggregated and anonymized form so that it is not
associated with any individual;
· As
otherwise permitted or required by law.
Third Parties with Whom We Share Your
Information
We share, and have shared over the last 12
months, information collected about you with selected third parties for our
business purposes. The categories of recipients (which maybe updated from
time to time) include third party vendors, service providers, affiliates,
contractors or agents who perform services for us or on our behalf and require
access to such information to do that work, such as IT service providers,
organizations providing background checks, DMV record checks, and income
verification, cloud service providers, application service providers, utility
billing, marketing, advertising and communications agencies, auditors and tax
professionals, payment processors, and data analytics
providers.
We also share information about you in the following contexts:
· Business
Transfers: We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing,
or acquisition of all or a portion of the business to another company,
resulting in a change of control of your information;
· Employment
Offers: If you apply for employment with ConAm, some of the
information you provide through our Website and services will be transferred
into our internal human resources and related systems for use processing your
application, which may involve sharing your information with select third
parties for related purposes, including credit and background checks. If
you are offered and accept a position with us, some of the information you
provide through our Website and services will be transferred into our internal
human resources and related systems for use during your employment. By using
our Website and services, you agree to such a transfer and use of your
information;
· Apartment
Community: We may share or transfer your information in instances
where you have an apartment community managed through ConAm or an application
to lease an apartment managed by ConAm, including to:
o Process your
application, including credit and background checks;
o Generate legal documents
(e.g., lease paperwork, addendums, legal notices);
· Allow
websites to allow for online payments, communication, package tracking and
maintenance request management;
· Process
and collect funds associated with payments (e.g., checks or money orders);
· Generate
utility billing and utility statements;
· Engage
in occupancy tracking and reporting;
· Record
interactions and communications during and after the leasing process;
· Assist
in collecting debts
Other Times: We may share information about you when we
believe in good faith that such release is necessary to comply with law or
legal process, including laws outside your state or country of residence; to
protect our rights, property, or safety of our employees.
Can I Opt-Out of Email Marketing?
Opt-out of email marketing: You can unsubscribe from our
marketing emails at any time by clicking on an unsubscribe link in the emails
that we send or by contacting us using the form provided at https://sq1compli.conam.com/sar if
the link is not included in the marketing email you received. You will then be
removed from the marketing email list – however, we will still need to send you
service-related emails that are necessary for the administration and use of
your account.
Is Your Information Transferred Internationally?
While you may be able to set up an account
while located outside the United States, we do not operate outside the United
States, in particular, we do not operate in the European Union or provide
services or products to the European Union residents. Our Website, Apps,
and all of our data, including any information about you, are hosted on servers
located in The United States. If you are using or accessing our Website or
Services from outside of the United States, please be aware that your
information will be transferred to, stored, and processed in the United States.
United States laws may not offer the same privacy protections as the law of
your jurisdiction.
Is My Information Safe?
Please remember that we cannot guarantee
absolute security as the Internet and methods of online transmission are not
100% secure. Transmission of information to and from our services is at your
own risk. You should only access the services within a secure environment.
Do We Collect Information from
Minors?
Our Website and Apps are not directed to
children under the age of 13. We do not knowingly collect information from
children under the age of 13, nor do we knowingly distribute such information
to third parties. If you are under 13, please do not give us any information
about you. If you believe that a child under the age of 13 has provided
us with their information, please contact us as provided for below and we will
seek to delete the information in our possession.
How Does the California Consumer Privacy
Act Apply?
This section provides additional
information in relation to any information we collect that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular California
resident or household (“Personal Information” under the California Consumer
Privacy Act of 2018 (“the CCPA”)).
Collection,
Use and Disclosure of Personal Information
Over the last 12 months, we have collected
the categories of Personal Information from California residents as set out in
section 2 above and disclosed Personal Information for a business purpose as
set out in section 4 above. We may use or otherwise disclose Personal
Information for the purposes set out above.
ConAm does not sell Personal Information,
as that term is defined under the CCPA.
Rights
Where applicable, and subject to certain
exceptions, you may have the following rights under the CCPA in relation to
Personal Information that we have collected about you. These rights are,
to the extent required by the CCPA and subject to verification and any
applicable exceptions:
· Right to
Know/Access: You may have the right to request that we disclose certain
information to you about our collection and use of certain Personal Information
about you as described below:
o the
specific pieces of Personal Information collected;
o the
categories of Personal Information collected;
o the
categories of sources from whom the Personal Information is collected;
o the
purpose for collecting the Personal Information; and
o the
categories of third parties with whom we have shared the Personal Information.
· Right to
Delete: You may have the right to request that we delete the Personal
Information.
·Freedom from
Discrimination: You have the right to be free from unlawful discrimination
for exercising any of the rights above.
In addition to the CCPA, California’s
‘Shine the Light’ law permits California Residents to request, once a year and
free of charge, certain information regarding our disclosure of information
about you to third parties for their direct marketing purposes.
To make a request in relation to the rights
described above, please use the contact information in section 10:
We will
need to verify your identity prior to addressing your request. Only you,
or someone legally authorized to act on your behalf, may make a verifiable
consumer request related to Personal Information collected about you. To
designate an authorized agent, the authorized agent must provide sufficient
information that allows us to reasonably verify that they have been authorized
by you to act on their behalf. You may only make a verifiable consumer
request for access twice within a 12-month period.
Contact Us
If you have any questions about this
Privacy Policy and our privacy practices, please contact us at:
Internet by completing the form accessible at https://sq1compli.conam.com/sar
Telephone +1 858 614 7200
Mail The ConAm Group of Companies,
3990
Ruffin Road,
San
Diego, CA 92123