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Appendix H. Privacy Policy

Privacy Policy

Updated:

This Privacy Policy describes how Simplified Business Group, doing business as Rent Dynamics and/or RentPlus (and hereafter collectively referred to as the “Company”), collects, uses, and discloses information. The Company respects your privacy and understands the importance of protecting your personal information. Outlined in this Privacy Policy are the Categories of Personal Information we collect and the Purposes for Collecting Personal Information.

The Company also includes provisions specific to the California Consumer Protection Act (CCPA) and how those provisions relate to California residents or “consumers” as defined by the CCPA.

Topic Summary
Categories of Personal Information The Company collects various categories of personal information and what we collect depends on the type of service we provide. The categories of personal information we collect include some or all of the following: name, address, phone number, email address, date of birth, SSN, current and historical rent payments, and/or username.
Purposes for Collecting Personal Information The purposes for which the personal information will be used is dependent on the type of service provided and includes some or all of the following: to provide you with information about a potential or current community, including the number of bedrooms and bathrooms of a particular unit, the duration and conditions of lease terms, moving reasons, amenities that are offered or otherwise interest you, number of occupants per unit, pet information, information needed to schedule an appointment to tour a particular community or unit such as dates and times, reasons for rescheduling or for not setting an appointment, any disqualification reasons, following up on prior interest in a community, to report your past or current monthly rent payments to various credit bureaus, to send updates or promotional information about our services, and/or to respond to questions that you may have.
Information we collect about you We may collect Personal Information, Usage and Device Information (collectively, “information”, defined in detail below) about you in connection with your (or your organization’s) use of our Services that link to this Privacy Policy.

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How we use your information We use the information we collect only in compliance with this Privacy Policy. We may use your information to provide services (either directly to you or to those third parties who have engaged us as service providers to process your information on their behalf); respond to inquiries and provide customer support and technical assistance; communicate with you; process transactions; improve, develop, provide content for, operate, deliver and market our Services; implement social networking features; comply with our company policies and procedures and with applicable law; ensure proper and authorized use of the Services; perform Services tracking and analysis; and, as otherwise permitted by applicable law.

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How we share your information We may share your information with our business units, affiliates, subsidiaries, business partners, service providers and/or your representatives, in order to provide or improve our Services to you. We do not share information with third parties so that they can independently market their own products or services to you unless we have explicitly given you the option to opt-in such disclosures. We will never sell your Personal Information to any third party.

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Your Rights Regarding Your Personal Information Upon request we will review the information we have and take action based on our legal obligations. For California, please see the CCPA section below.

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Retention of your information We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. We keep your account data until you use your account settings or tools to delete the data or your account because we use this data to provide you Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Your Information and How We Share Your Information sections.
Security of your information We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to protect the confidentiality, integrity and availability of your data. This includes using Transport Layer Security (“TLS”) to encrypt data transmission and Advanced Encryption Standard (“AES”) to encrypt data storage. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact Customer Support or our Security team.

Click here to learn more about our security practices.
Cookies and similar Technologies We may use “cookies” and similar technologies to help deliver our Services. This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences and to offer you a more personalized user experience. Read our Cookie Policy to learn more.
Marketing Analytics and Communications We work with partners who provide us with marketing analytics and communications services. This includes helping us understand how users interact with our Services, communicating with you about our Services and features, and measuring the performance of those communications. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications. To learn more and about your privacy choices, please see more details in the How We Use Your Information and How We Share Your Information sections and read our Cookie Policy.
Links to Other Websites Our Services may contain links to other websites or services that are not owned or controlled by Rent Dynamics, including links to websites of our sponsors and partners. This Privacy Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.
Situations where this Privacy Policy does not apply This Privacy Policy does not apply to job applicants or employees, which are subject to relevant privacy notices. This Privacy Policy does not apply to the extent that:
• Our products and services set forth an additional or alternative Privacy Policy; or
• Applicable law imposes different processing or privacy requirements on your information.
Changes to this Privacy Policy We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you notification by email or notification alert within our Services. While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.
How to contact us You can contact us using the Contact Us page on our Sites or by mail at 91 E. 700 S. Logan, UT 84321.

If you have questions, suggestions, or concerns about this policy, or about our use of your information, including filing a complaint, please contact our Data Protection Officer or Privacy Officer at privacy@rentdynamics.com.

CALIFORNIA CONSUMER PRIVACY ACT – NOTICE

This Notice is to inform California residents or consumers about the personal information we collect or have collected over the past 12 months and to inform you that we may collect certain personal information about you as outlined in the Categories of Personal Information section above and as provided in the Purposes for Collecting Personal Information section above.

The following section provides additional details regarding the personal information we collect about California consumers and the rights granted to them under the California Consumer Privacy Act or “CCPA.”

Right to Know About Personal Information Collected, Disclosed, or Sold.

  • A California consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. The Company does not sell your personal information.
  • If you are a California consumer and would like to know what personal information we collect, use, or disclose about you, then you can submit a verifiable consumer request by emailing us at privacy@rentdynamics.com.
    • Before we can provide you the information you request, you are required under the CCPA to provide us information that allows us to verify your request and to match information about you that we already have on file. For example you may need to provide some or all of the following information: your first and last name, email address, phone number, address, your age, last four digits of your SSN, the community name(s) that you were interested in or the community name(s) where you are a current resident or were a resident over the past 12 months, and/or a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Right to Request Deletion of Personal Information.

  • A California consumer has the right to request the deletion of his or her personal information collected or maintained by a business. However, if the personal information we have collected is necessary to provide you with our business services then we cannot delete your personal information.
  • If you are a California consumer and would like to delete any personal information we have collected, used, or disclosed then you can submit a verifiable consumer request by emailing us at privacy@rentdynamics.com.
    • Before we can provide you the information you request, you are required under the CCPA to provide us information that allows us to verify your request and to match information about you that we already have on file. For example you may need to provide some or all of the following information: your first and last name, email address, phone number, address, your age, last four digits of your SSN, the community name(s) that you were interested in or the community name(s) where you are a current resident or were a resident over the past 12 months, and/or a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Collection and Sources of Personal Information.

  • We have collected personal information based on the Categories of Personal Information section above.
  • The sources of information that we collect come directly from you as a California consumer, or from our clients who provide us the information that they gathered from you in order for us to provide you with the services we listed in the Purposes for Collection Information section above, or from third-party advertising sources that provide us with information you initially provided to them.
  • The categories of third parties with whom we share personal information are with our clients and with various credit bureaus so we can report your past and current on-time rent payments.

Disclosure or Sale of Personal Information.

  • We have disclosed personal information to third parties in the preceding 12 months, but we have not sold any personal information in the preceding 12 months.
    • We do not sell personal information, nor do we sell the personal information of minors under 16 years of age.
  • The categories of personal information that we have disclosed to third parties for a business or commercial purpose in the preceding 12 months depends on the type of service provided and is outlined in the Categories of Personal Information and the Purposes for Collecting Personal Information sections above.

Right to Opt-Out of the Sale of Personal Information.

  • California consumers have the right to opt-out of the sale of their personal information. However, we do not sell personal information.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.

  • California consumers have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.

Authorized Agent.

  • A California consumer can designate an authorized agent to make a request under the CCPA on behalf of the consumer.

INFORMATION WE COLLECT ABOUT YOU

When you use our Services, we collect the following types of information.

INFORMATION YOU PROVIDE US (“PERSONAL INFORMATION”)

ACCOUNT INFORMATION. Some information is required to create an account on Services, such as your

  • name,
  • email address,
  • Password,
  • company, and
  • phone number.

ADDITIONAL INFORMATION. To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, such as

  • mailing address,
  • country information,
  • date of birth,
  • Social Security
  • additional contact phone numbers such as your mobile telephone number,
  • community or social media username

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, email address, contact information, and message.

INFORMATION FROM THIRD-PARTY SERVICES. If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address and friend list. You may also choose to grant us access to your personal information such as activity data or health data from other services. You can stop sharing the information from the other services with us by removing our access to each other service.

INFORMATION PROVIDED BY OTHER INDIVIDUALS. While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of personal information as described in this Privacy Policy. Please contact us immediately if you become aware of an individual providing us with personal information about another individual without being authorized to do so, and we will act consistently with this Privacy Policy.

PAYMENT AND CARD INFORMATION. Some Rent Dynamics Services support payments and transactions with third parties. If you activate this feature, you must provide certain information for identification and verification, such as your name, billing address, credit, debit or other card number, card expiration date and CVV code. This information is used solely to check your financial qualifications and collect payment from you. We do not store your payment information. We use a third-party service provider to manage payment card processing. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms. This service provider is not permitted to store, retain or use information you provide except for the sole purpose of credit card processing on our behalf.

INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES

USAGE AND DEVICE INFORMATION. When you use our Services, we receive certain usage data (“Usage and Device Information”). This includes information about your interaction with the Services, for example, when you view or search content, install or open applications or software, create or log into your account, import data into your account, or integrate a third-party service to your account. We may also collect data about the devices and computers you use to access our Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes.

PROVIDE AND MAINTAIN THE SERVICES

We use the information we collect to deliver the Services to you and honor our Terms of Service for each Service or business contract with you. For example,

  • to administer, operate, maintain and secure our Services;
  • to monitor and analyze trends, usage and activities in connection with our Services;
  • for accounting, recordkeeping, backup and administrative purposes;
  • to customize and improve the content of our communications, websites and social media accounts;
  • to provide customer service and support;
  • to communicate with you, including responding to your comments, questions and requests regarding our Services;
  • to process and complete transactions, and send you related information, including alerts and notifications about your service, purchase confirmations and invoices; and
  • to educate and train our workforce in data protection and customer support.

IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys and develop new features and Services.

COMMUNICATE WITH YOU

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the “Unsubscribe” link in an email.

PROMOTE SAFETY AND SECURITY

We use the information we collect to promote the safety and security of the Services, our users and other parties. For example, we may use the information

  • to authenticate users;
  • to facilitate secure payments;
  • to respond to a legal request or claim, conduct audits, and enforce our terms and policies;
  • to investigate and protect against fraud, malicious or unauthorized access, and other illegal activities; and
  • to demonstrate and verify compliance with our internal policies and procedures, and applicable privacy and data security laws and regulations, such as CCPA and GDPR.

USE AND DISCLOSURE OF DE-IDENTIFIED INFORMATION

“De-identified” means that we have removed, or rendered unreadable through complex computational algorithms, your personally-identifiable information, such as your name, address, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example:

  • In accordance with regulatory requirements, we may de-identify, store and use your information for internal quality control, validation and research and development. This is important for Rent Dynamics to maintain high quality Services. We may use de-identified information as permitted by law.
  • We may use or disclose de-identified information for general research and communications purposes. This may include analysis of this information to communicate observations and learnings, for example in the case of aggregated data. This may also include research collaborations with third parties, such as universities, in which we utilize de-identified data, at the individual level or in the aggregate, in accordance with our study protocols, and we may present or publish such information.

We use cookies and similar technologies for the purposes described above. For more information, please read our Cookie Policy.

For personal data subject to the GDPR/CCPA, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and/or other tools; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.

HOW WE SHARE YOUR INFORMATION

We do not share your personal information except in the limited circumstances described below.

WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct us to disclose your information to others, such as when you use our social features in our applications. For certain information, you may change your privacy preferences in account settings and use other provided tools to control how your information is visible to other users of the Services.

You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, or with your employer company or other organizations and provide consent to each organization. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings.

FOR EXTERNAL PROCESSING

We transfer information to our corporate affiliates, service providers and other partners who process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys.

We may preserve or disclose information about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect or investigate illegal activity, fraud, abuse, violations of our terms or threats to the security of the Services or the physical safety of any person. Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person. We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, to partners under agreement with us or as part of the community benchmarking information we provide to users of our subscription services. If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice for the transferring of any personal information to a new entity.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You can access and control your personal information via account settings and/or our tools we provide to you, regardless of where you live. If you live in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”), you have a number of legal rights with respect to your information, as outlined below.

Accessing and Exporting Data. By logging into your account, you can access much of your personal information. Using your account settings or by contacting us, you can also request a download information in a commonly used file format.

Editing and Deleting Data. Your account settings and certain platform APIs let you change and delete your personal information and/or account data. For instance, you can edit or delete the profile data you provide and delete your account if you wish.

If you choose to delete your account, please note that while most of your information will be deleted within 14 days, it may take up to 45 days to delete all of your information, such as the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How We Share Your Information section.

If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests, including as described in the How We Use Information section. You have a general right to object to the use of your information for direct marketing purposes. Please also review our Cookie Policy for your options to control how we and our partners use cookies and similar technologies for advertising.

Restricting or Limiting Data Use. In addition to the various controls that we offer, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time.

Onward Transfers of Data. If we intend to disclose your personal information to any third party that will have the right to process it, we will enter into a contract with that third party that provides that your personal information may be processed only for limited and specified purposes consistent with the consent you have provided to us, and that the third party must provide the same level of protection for your personal information that we are obligated to provide under this Privacy Policy while it is processing your personal information.

Changes to Privacy Policy. If we are using your personal information on the basis of your consent, and we change our Privacy Policy to permit any use or disclosure of your personal information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your personal information.

Further Assistance. If you need further assistance regarding your rights, please contact our Data Protection Officer at privacy@rentdynamics.com, and we will consider your request in accordance with applicable laws. If you reside in a Designated Country and you are not satisfied with our response, you will have a prompt, no-cost way of asserting your claim by contacting our chosen independent dispute resolution body JAMS. If you reside in a Designated Country, you may have the right, under certain conditions, to invoke binding arbitration, and, alternatively, you also have a right to lodge a complaint with your local data protection authority or with the Irish Data Protection Commissioner, our lead supervisory authority, whose contact information is available here.