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