Privacy Policy for The Highland Club in Baton Rouge, LA

Privacy Policy

US Privacy Policy

We recognize the importance of protecting the privacy of personal information. Learn more about what information we collect, use, and share in relation to operating this website.

EU Privacy Policy

Our top priority is protecting the privacy and security of personal information about you, and maintaining the trust of our clients. Learn more about our Privacy Policy for EU residents.

US PRIVACY POLICY

VIEW EU PRIVACY POLICY

SITE OPERATION

This website and its related downloadable applications and Services (collectively, our "Website") is operated, hosted, and maintained by 365 Connect, LLC ("365 Connect," "we," "our" or "us") and is licensed for use by us to the legal entity ("Subscriber") that owns or manages the property featured on this Website (collectively the "Property Management Company").

Through this Website we assist the Property Management Company in managing their property and other assets by, among other things, facilitating communication and transactions between Users, Service Providers, and the Property Management Company. We merely host or process Data and personal information about Users on behalf of the Property Management Company, and generally have no direct relationship with Users. We are a data processor and not a data controller with respect to your personal information.

Our top priority is protecting the privacy and security of Personal Information about you and maintaining the trust of our Subscriber. This includes both data submitted by the Subscriber and Personal Information submitted by Users to our Website.

This Privacy Policy applies solely to information collected by us about the persons or entities ('you" or "your) who are residents of the United States ("USA") and access or use this Website. If you are a resident of the European Union, view our EU Privacy Policy.

We collect and pass on information for the Property Management Company to use and share for its purposes and also for our own purposes in connection with our operation of the Website. This Privacy Policy primarily addresses our collection, use, and sharing of information about you, and not the collection, use, or sharing of information about you by the Property Management Company or other third parties, as to which you should consult their respective privacy policies or them.

We encourage you to read this Privacy Policy and our Website Terms of Use before you send or share Personal Information with us or use this Website, and to read them again at each return visit.

A USER WHO NAVIGATES THIS WEBSITE GIVES PERMISSION TO US TO SHARE ANY OR ALL PERSONAL INFORMATION THAT YOU PROVIDE WHILE USING THIS WEBSITE WITH THE PROPERTY MANAGEMENT COMPANY IN FURTHERANCE OF SEEKING TO RENT OR LEASE RESIDENTIAL HOUSING, OR ACCESS AND USE SERVICES THAT ARE AVAILABLE ON THIS WEBSITE. IF YOUR DO NOT CONSENT OR AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THIS WEBSITE. CONTINUED USE OF THIS WEBSITE CONSTITUES YOU HAVE FREELY GIVEN SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL INFORMATION BEING PROCESSED PURSUANT TO THIS PRIVACY POLICY.

WEBSITES COVERED UNDER THIS PRIVACY POLICY

This Privacy Policy describes our privacy practices regarding what specific information we collect from you when you visit this Website, and also any associated or related Websites that contain a link to this Privacy Statement (collectively the "Websites") only.

THIS PRIVACY POLICY DOES NOT APPLY TO OTHER WEBSITES

Our confidentiality, privacy, and other obligations related to the Services we provide to the Property Management Company, for the property that is featured on this Website, is limited to this Website only, and does not extend beyond this Website. The Property Management Company may own, operate, license or list the same property on other websites, online marketplaces, and advertisements, for which will contain their own Privacy Policy and Terms of Use, which we strongly encourage you to read before using those respective websites. The Property Management Company may also use separately owned or third-party websites for the processing of rental applications, agreements, payments, and other services to assist you in either qualifying to become a resident or providing services to you as an existing resident. Those owned or third-party websites may contact a link on this Website for the purpose of convenience. Upon clicking a link, you may leave this Website to engage with those websites, for which they will contain their own Privacy Policy and Terms of Use, which we strongly encourage you to read before using those respective websites. Please be advised that this Privacy Statement is not applicable to those websites, which are instead governed by their own respective privacy statements.

PLEASE BE ADVISED THAT THIS PRIVACY POLICY IS NOT APPLICABLE TO ANY OF YOUR PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND THIRD PARTIES TO ASSIST USERS WHO PARTICIPATE IN THE APARTMENT RENTAL SEARCH, APPLICATION PROCESS, OR WHO MIGHT BECOME RESIDENTS OF THE PROPERTY FEATURED ON THIS WEBSITE. ALL PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND THIRD PARTIES IS GOVERNED BY THE PRIVACY STATEMENTS OF THE PROPERTY MANAGEMENT COMPANY, AND THEIR PARTNERS OR THIRD PARTIES WHO CREATE AND MANAGE THEIR OWN WEBSITES AND PROVIDE SERVICES TO YOU, AND HAVE NOTHING TO DO WITH US, AND ARE NOT UNDER OUR CONTROL.

The Property Management Company makes their own decisions about how or why Personal Information is to be processed, including any disclosure or transmission to third parties. If Personal Information relating to you as an individual has been submitted or entered into this Website, or was otherwise collected by us on behalf of the Property Management Company, and you wish to exercise any rights you may have to access, correct, amend or delete such Personal Information, please contact the Property Management Company directly. If an authorized Property Management Company representative requests that we update or remove the Personal Information in question, and the Property Management Company has no ability to do so via use of the Services, we will acknowledge their request within 30 days.

Any use of Personal Information by us is done so pursuant to the agreements between us and the Property Management Company, or in accordance with the Terms of Service published on this Website. This Privacy Policy does not apply to our Services or any Property Management Company data. If you have any questions or concerns about the data practices of the Property Management Company that is using our Services to process your Personal Information, you need to contact them directly, and ask for their Privacy Policy or Privacy Statement.

PERSONAL INFORMATION WE COLLECT

We collect Personal Information from our Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company, and to help us better understand how we can assists Users that are searching for residential apartments to rent, lease, or obtain services as a resident in the apartment they occupy.

The different types of Personal Information we collect will depend upon what we will need in order to provide you with the particular product or service you are interested in. The information requested on our registration form includes some or all of the following Personal Information: name, address, email address, telephone number, User name, password, and birth month and day, and will include other information that you provide voluntarily (i) in connection with your use of any interactive tools or resources on our Website relating to finding, leasing, or accessing services for an apartment, including submission of an inquiry, contact or schedule a visit form, lease application or related payment, such as your name, social security number, driver's license number, present and prior addresses, telephone numbers and email addresses, monthly rent paid at previous residences, gender, age, marital status, date of birth, employers, job titles, occupation, income, references, and payment-related information, such as credit card information, bank account information and routing numbers, emergency contact information, and information about your pets and vehicles, including license plate numbers, (ii) in connection with your submission of rental payments, service requests, or other communications with the Property Management Company or its agents, such as your name, address, telephone number, email address, automated clearing house (ACH) information, debit or credit card information, and/or the nature of work requested, (iii) in connection with your use of any interactive educational or informational resources provided to residents, (iv) in any postings you make in any Community or otherwise on our Website or in any emails that you send to us, (v) in connection with your use or purchase of any other services or products provided by this Website or by any third-party provider, such as your debit or credit card information and your purchase history, or (vi) in connection with your use of any other aspect of this Website. Certain services and features on the Website may only be used by you if you voluntarily provide certain information about yourself.

Those interested in becoming residents will likely be asked to include the following additional information: the type of apartment or apartment size you are looking for, where you want to live, the type of building you prefer, your proposed rent budget, the number of individuals in your household and their ages, and if you have pets or not.

THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY THAT OWN, MANAGE, OR OPERATE THE RESIDENTIAL APARTMENTS YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN SERVICES AS A RESIDENT IN THE APAERTMENT YOU OCCUPY.

USAGE TRACKING: USE OF IP ADDRESSES

Every device that connects to the Internet is given a number that is known as an Internet Protocol (IP) Address. These numbers are typically assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet. As permitted under applicable law, we collect IP addresses for the purposes of system administration, gathering and analyzing aggregated information, and creating a better experience for Users and auditing the use of our site.

We do not usually link any IP addresses to anything that can be personally identifiable. This means that your Internet session will be logged, but you will remain anonymous to us. We will seek to link your IP address to personally identifiable information when we deem it necessary (i) to identify and authenticate you when you submit certain information to the Website, such as request to visit the property, payments, request for services or other types of communication, (ii) to be pre-qualified for rental housing displayed on this Website, (iii) or when you start or complete a lease application for rental housing displayed on this Website, (iv) or to protect the Website and other Users from harm and to prevent criminal misconduct.

USE OF "COOKIES"

A cookie is a small file which contains a string of characters that is sent to your computer when you are browsing the Internet and visit a website. When you visit the website again, the cookie enables that site to recognize your browser. Cookies may store User preferences and other information about you. You can configure your browser to refuse all cookies, or to indicate when a cookie is being sent. However, there are some website features or services that may not function properly without cookies.

Improvements and updates to this Website are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies only to provide services better suited to your needs, and for the protection of our Website and Users from potential harm. We never save passwords or credit card information in cookies.

We may use cookies for many purposes, including to remember your safe search preferences, to track Users' movements around the website, to analyze trends, administer the website, to count how many visitors we receive to a page, to help you sign up for our services, to protect your data and to gather demographic information about our User base as a whole. Users can control the use of cookies at the individual browser level. We may partner with a third party to either display advertising on our website or to manage advertising on other sites. A third party partner may use cookies or similar technologies in order to provide you advertising or other content, based upon your browsing activities and interests or to make the ads you see more relevant to you.

If you desire to change your cookie preferences, you can do so through your browser settings. You may also limit the information we learn from certain cookies by logging directly into the registered areas of this Website rather than by logging in by using your social media log-in credentials. Be advised that our cookies are often used to provide you with certain functionality and without them you may not be able to use some of our Website Services.

WEBSITE ANALYTICS

This Website may use web analytics tools and services, some from third parties, such as web analytic services provided by Google, Inc. ("Google"), to better assist us in understanding how the Website is used. These web analytics tools and services will place cookies on your computer that will generate information that we select about your use of the Website, including your computer's internet protocol address. That information will be transmitted to and stored by us and or third party providers. The information will be used for the purpose of evaluating consumer use of the Website, compiling reports on Website activity for our use, and providing other services relating to Website activity and usage. We may also transfer this information to third parties where required to do so by law, or where such third parties process the information on our behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Website. Use of cookies by Google Analytics is covered by Google's privacy policy located at https://policies.google.com/privacy.

OUR USE OF INFORMATION ABOUT YOU

We may use information about you to create your account, to enable you to use our Website, including any Communities, and to facilitate communication and transactions between Users, service providers, and the Property Management Company, and other third party provider transactions between you and any of them through this Website, including but not limited to using information about you (i) in connection with any interactive decision-making tools or resources relating to leasing an apartment, including submission of an inquiry, contact or schedule a visit forms, lease application or related payment, (ii) in connection with assisting the Property Management Company in marketing to you, including contacting you by email, phone, text message, or otherwise, (iii) in connection with assisting the Property Management Company in processing your lease application, including investigating your background, leasing history, and creditworthiness through third parties, including consumer reporting agencies, (iv) in connection with the processing of your rental payments, service requests, and other communications with the Property Management Company or its agents, (v) in connection with your use of any interactive educational or informational resources provided to residents, (vi) in connection with your participation in any Community or in dealing with any emails that you send to us, (vii) in connection with your use or purchase of any other services or products provided by this Website or by any third-party provider, (viii) in connection with your use of any other aspect of this Website, and (ix) generally to enhance and attempt to optimize your use of our Website. We may also use your email address or telephone number to respond when you submit a question, suggestion, or request assistance with using or accessing this Website.

We may link information we collect about you with other information we collect about you, whether offline or from third parties or otherwise. We may use information about you to send you targeted messages, publications, news, and information about events, special offers, promotions, benefits, and other advertisements. We may use information about you to improve the content of this Website, to enhance users' experiences when visiting this Website, to analyze trends, to administer the Website, to gather demographic information about the Website's users, to track user movements, and to customize the content and layout of this Website for each individual user.

INFORMATION WE SHARE OR DISCLOSE

We may share information about you with the Property Management Company and with third-party providers and other contractors (such as hosting service providers, analytics service providers, email service providers, lease screening service providers, custom programmers, payment processors, advertisers, etc.) and other appropriate persons for purposes of (i) performing functions pertinent to the Website's apparent and reasonably deducible purposes, including but not limited to those discussed above under "Our Use of Information About You"; (ii) maintaining, upgrading, and improving the Website; (iii) complying with law, cooperating with governmental authorities, and consulting with our attorneys and other advisers; (iv) attempting to avert a threat of harm to our or others' safety or other interests; (v) defending us and our members, managers, officers, employees, and affiliates in connection with any legal actions or claims; and (vi) enforcing the Terms of Use of this Website. We also reserve the right to transfer personal information about you to a third party that acquires substantially all of our assets.

Similarly, the Property Management Company may share information about your use of our Website with third party providers and other contractors (such as lease screening service providers, payment processors, advertisers, etc.) and other appropriate persons for purposes of (i) performing functions that would reasonably be expected of a Property Management Company with respect to a prospective tenant, such as contacting you by email, phone, text message, or otherwise to market its space and investigating your background, leasing history, creditworthiness, either directly or through the assistance of third parties, including credit reporting agencies, (ii) complying with law, cooperating with governmental authorities, and consulting with attorneys and other advisers, (iii) attempting to avert a threat of harm to its or others' safety or other interests, (iv) defending it and its owners, personnel, and affiliates in connection with any legal actions or claims, and (v) other purposes of the Property Management Company in or outside the ordinary course of its business.

We may use third-party service providers to send and distribute email and to perform other marketing and support functions. We may share information about you with third parties who offer goods and services we think may be of interest to you. From time to time, we may cooperate with other organizations or companies to provide co-sponsored or co-branded promotions, services or events and may share information about you with our co-sponsor. We also may provide information about you to service providers or contractors to perform functions on our behalf, such as, but not limited to, companies or individuals hired to: communicate news, deliver our promotional materials via e-mail and direct mail, to develop, enhance, market or provide any of our products, to process credit card payments and to assist us with sending communications and performing other marketing and support functions. These third parties may use technologies to measure the effectiveness of ads and emails and use information about your visits to our Website so that we may provide you with a better experience on our Website. We also may use third-party social media platforms, including third-party social media websites, to communicate with you. We also may share with third parties aggregated demographic and statistical information, such as the daily number of unique visitors to the Website, the number of users who searched for certain types of housing, and how many users clicked on a particular advertisement.

We also may disclose information about you (i) to a person who in our good faith judgment appears to be you or your agent, (ii) in situations where sharing or disclosing the information is required in order to offer you products or services we think you may be interested in, (iii) to a third party or parties where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process, (iv) if, in our good faith judgment, it is necessary or desirable to enforce compliance with our internal policies or the Terms of Use , to try to prevent illegal activity or suspected fraud, or to try to protect our Website, customers, or others; and (v) to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of our assets.

Through the Website, we may make available areas that allow for user interaction with other users, such as blogs, forums, bulletin board services, chat areas, or other message and communications features. Some of these forums may require registration. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose information about yourself.

We do not rent or sell your Personal Information in a personally identifiable form to anyone, provided however, certain Personal Information may be shared with Property Management Companies and with third-party providers and other contractors such as hosting service providers, analytics service providers, email service providers, lease screening service providers, custom programmers, payment processors, advertisers as more fully described above.

We may anonymize your Personal Information so that you are not individually identified, and provide that information to our partners and also third parties. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Website, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage information to a partner in a manner that would identify you personally, as an individual.

Advertisers: We may allow advertisers and/or merchant partners ("Advertisers") to choose the demographic information of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the information we have collected from you in a form that is not personally identifiable to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in Houston to show you ads or offers for Houston businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment, and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.

Affiliated Businesses: In certain situations, businesses or third party websites we might be affiliated with may sell or provide products or services to you through, or in connection with the website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.

Agents: We might employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

REVIEWS AND CONTENT SUBMISSIONS

Our Website may allow you to provide and submit certain content ("Content") in the form of a review or rating as to your experience in visiting or living at the properties featured on this Website. We may share your content with the Property Management Company, third-party providers and other contractors (such as review publishers, search engines, analytics service providers, syndication sites, advertisers, etc.), and other appropriate persons for purposes of publication to this Website, social media channels, as well as other third party websites.

THIRD PARTY PROVIDERS

It is our intention to maintain reputable third-party providers to offer residents a variety of products and services on our Website, but we are not responsible for their information, privacy, or other business practices. When choosing to purchase products or services on our Website, you must take into consideration that you will be transacting business directly with a third-party provider, and the information about you, collected by the provider, will be subject to the practices of that provider.

THIRD PARTY WEBSITE LINKS

This Website may contain links to other third party websites that are beyond our control, and take you outside of our Services. For example, if you "click" on a banner ad, which is an advertisement or a search result, the "click" may take you off this Website and on to another site that is beyond our control. These other websites may include sites of other sponsors, advertisers or partners that may use their logo with ours as part of a co-branding agreement. These other sites might also send their own cookies to Users who become visitors to other websites to collect data or solicit information. We do not control these websites and therefore are not responsible for their content. The inclusion of hyperlinks to any other websites by us on our Website, does not infer any endorsement of the content or material on such sites, nor any association with the owners or operators of the websites or the businesses listed on any of these websites. Our policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control. Be advised that if you disclose information online, that all such information may be collected and used by people you do not know.

The information practices or content of such other websites or advertisers is governed by the privacy statements of all such other websites and businesses contained on those websites. Please be advised that this Privacy Statement is not applicable to those websites and businesses, which are instead governed by their respective privacy statements. Please review the privacy statements of such other websites and businesses to understand their information collection practices.

TRACKING

When this Website receives web browser "do not track" signals (or other mechanisms that provide consumers the ability to exercise their choices regarding the collection of personally identifiable information about a consumer's online activities over time and across third-party websites or online services), our Website does not alter its behavior or change its services. Other parties may collect personally identifiable information about an individual consumer's online activities over time and across different websites when the consumer uses this website or its services.

SAFEGUARDING YOUR INFORMATION

We take all reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction; taking into account the risks involved in the processing and the nature of the Personal Information.

Our resident services and application accounts require a username and password to log in. You must keep your username and password secure, never disclose it to a third party, and do not allow others to utilize your account. You should fully exit from your account at the end each session, by utilizing the logout feature. You should also implement a practice of changing your password on a regular basis. If Users have any questions about security, please contact us at: notices@365connect.com.

CHILDREN UNDER 13 YEARS OF AGE

Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use this Website in any way. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will take reasonable measures to delete that information. If you believe we might have any information from or about a child under 13, please contact us at notices@365connect.com.

CALIFORNIA PRIVACY RIGHTS

Under California's "Shine the Light" law, California residents who provide personal information (as defined in the statute) in obtaining products or services for personal, family or household use, are entitled to request and obtain from us once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year. To obtain this information please contact us at notices@365connect.com; please include your full name and physical address.

CAN SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in compliance with CANSPAM we agree to the following:

  • NOT use false, or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.

ACCESSING AND CORRECTING INFORMATION ABOUT YOU

You can review and change information about you by logging into the Website and visiting your account profile page. You may also send us an email at notices@365connect.com to request us to provide, correct or delete any information about you that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete any or all of your postings from the Website, copies of the postings may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

Where we have provided information about you to a screening service provider in order to obtain a screening report for the Property Management Company, the report may contain credit information. Under the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), you may have the right to access, view, and correct credit information relating to you held by a credit bureau by contacting the credit bureau.

If we collected information about you on behalf of a third party, we may have conveyed that information directly to the third party. If so, it may not exist as part of our own records and you will have to go to the third party to see the information.

CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You should check this Website frequently to see recent changes.

CONTACTING THE WEB SITE

If you have any questions about this Privacy Policy, the practices of this Website or your dealings with this Website, or have a question regarding the products or services offered by any of the third-party providers, please email us at: notices@365connect.com.

ACCEPTANCE OF THESE TERMS

By using this Website, or providing any information to us, you acknowledge that you are aware of the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy or any amended terms, you must not access or use this Website or Services.

LAST UPDATED JULY 20, 2018

EU PRIVACY POLICY

VIEW US PRIVACY POLICY

SITE OPERATION

This website and its related downloadable applications and Services (collectively, our "Website") is operated, hosted, and maintained by 365 Connect, LLC ("365 Connect," "we," "our" or "us") and is licensed for use by us to the legal entity ("Subscriber") that owns or manages the property featured on this Website (collectively the "Property Management Company").

Through this Website we assist the Property Management Company in managing their property and other assets by, among other things, facilitating communication and transactions between Users, Service Providers, and the Property Management Company. We merely host or process Data and Personal Information ("Personal Information") about Users on behalf of the Property Management Company, and generally have no direct relationship with Users. We are a data processor and not a data controller with respect to your personal information.

Our top priority is protecting the privacy and security of Personal Information about you and maintaining the trust of our Subscriber. This includes both data submitted by the Subscriber and Personal Information submitted by Users to our Website.

This Privacy Policy pertains to Website Users ("you" or "your") who are residents of the European Union ("EU") and access or use this Website. If you are a resident of the United States, view our US Privacy Policy.

We recognize the importance of protecting the privacy of individual-specific Personal Information collected from our Website Users. This Privacy Policy describes what Personal Information we gather, how we use it and how you can correct, change and limit our use of it. It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information to provide you a valuable service.

We encourage you to read this Privacy Policy and our Website Terms of Use before you send or share Personal Information with us or use this Website, and to read them again at each return visit.

A USER WHO NAVIGATES THIS WEBSITE GIVES PERMISSION TO US TO SHARE ANY OR ALL PERSONAL INFORMATION THAT YOU PROVIDE WHILE USING THIS WEBSITE WITH THE PROPERTY MANAGEMENT COMPANY IN FURTHERANCE OF SEEKING TO RENT OR LEASE RESIDENTIAL HOUSING, OR ACCESS AND USE SERVICES THAT ARE AVAILABLE ON THIS WEBSITE. IF YOUR DO NOT CONSENT OR AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THIS WEBSITE. CONTINUED USE OF THIS WEBSITE CONSTITUES YOU HAVE FREELY GIVEN SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL INFORMATION BEING PROCESSED PURSUANT TO THIS PRIVACY POLICY.

WEBSITES COVERED UNDER THIS PRIVACY POLICY

This Privacy Policy describes our privacy practices regarding what specific information we collect from you when you visit this Website, and also any associated or related Websites that contain a link to this Privacy Statement (collectively the "Websites") only.

THIS PRIVACY POLICY DOES NOT APPLY TO OTHER WEBSITES

Our confidentiality, privacy, and other obligations related to the Services we provide to the Property Management Company, for the property that is featured on this Website, is limited to this Website only, and does not extend beyond this Website. The Property Management Company may own, operate, license or list the same property on other websites, online marketplaces, and advertisements, for which will contain their own Privacy Policy and Terms of Use, which we strongly encourage you to read before using those respective websites. The Property Management Company may also use separately owned or third-party websites for the processing of rental applications, agreements, payments, and other services to assist you in either qualifying to become a resident or providing services to you as an existing resident. Those owned or third-party websites may contact a link on this Website for the purpose of convenience. Upon clicking a link, you may leave this Website to engage with those websites, for which they will contain their own Privacy Policy and Terms of Use, which we strongly encourage you to read before using those respective websites. Please be advised that this Privacy Statement is not applicable to those websites, which are instead governed by their own respective privacy statements.

PLEASE BE ADVISED THAT THIS PRIVACY POLICY IS NOT APPLICABLE TO ANY OF YOUR PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND THIRD PARTIES TO ASSIST USERS WHO PARTICIPATE IN THE APARTMENT RENTAL SEARCH, APPLICATION PROCESS, OR WHO MIGHT BECOME RESIDENTS OF THE PROPERTY FEATURED ON THIS WEBSITE. ALL PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND THIRD PARTIES IS GOVERNED BY THE PRIVACY STATEMENTS OF THE PROPERTY MANAGEMENT COMPANY, AND THEIR PARTNERS OR THIRD PARTIES WHO CREATE AND MANAGE THEIR OWN WEBSITES AND PROVIDE SERVICES TO YOU, AND HAVE NOTHING TO DO WITH US, AND ARE NOT UNDER OUR CONTROL.

The Property Management Company makes their own decisions about how or why Personal Information is to be processed, including any disclosure or transmission to third parties. If Personal Information relating to you as an individual has been submitted or entered into this Website, or was otherwise collected by us on behalf of the Property Management Company, and you wish to exercise any rights you may have to access, correct, amend or delete such Personal Information, please contact the Property Management Company directly. If an authorized Property Management Company representative requests that we update or remove the Personal Information in question, and the Property Management Company has no ability to do so via use of the Services, we will acknowledge their request within 30 days.

Any use of Personal Information by us is done so pursuant to the agreements between us and the Property Management Company, or in accordance with the Terms of Service published on this Website. This Privacy Policy does not apply to our Services or any Property Management Company data. If you have any questions or concerns about the data practices of the Property Management Company that is using our Services to process your Personal Information, you need to contact them directly, and ask for their Privacy Policy or Privacy Statement.

PERSONAL INFORMATION WE COLLECT

We collect Personal Information from our Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company, and to help us better understand how we can assists Users that are searching for residential apartments to rent, lease, or obtain services as a resident in the apartment they occupy.

The different types of Personal Information we collect will depend upon what we will need in order to provide you with the particular product or service you are interested in. The information requested on our registration form includes some or all of the following Personal Information: name, address, email address, telephone number, User name, password, and birth month and day, and will include other information that you provide voluntarily (i) in connection with your use of any interactive tools or resources on our Website relating to finding, leasing, or accessing services for an apartment, including submission of an inquiry, contact or schedule a visit form, lease application or related payment, such as your name, social security number, driver's license number, present and prior addresses, telephone numbers and email addresses, monthly rent paid at previous residences, gender, age, marital status, date of birth, employers, job titles, occupation, income, references, and payment-related information, such as credit card information, bank account information and routing numbers, emergency contact information, and information about your pets and vehicles, including license plate numbers, (ii) in connection with your submission of rental payments, service requests, or other communications with the Property Management Company or its agents, such as your name, address, telephone number, email address, automated clearing house (ACH) information, debit or credit card information, and/or the nature of work requested, (iii) in connection with your use of any interactive educational or informational resources provided to residents, (iv) in any postings you make in any Community or otherwise on our Website or in any emails that you send to us, (v) in connection with your use or purchase of any other services or products provided by this Website or by any third-party provider, such as your debit or credit card information and your purchase history, or (vi) in connection with your use of any other aspect of this Website. Certain services and features on the Website may only be used by you if you voluntarily provide certain information about yourself.

Those interested in becoming residents will likely be asked to include the following additional information: the type of apartment or apartment size you are looking for, where you want to live, the type of building you prefer, your proposed rent budget, the number of individuals in your household and their ages, and if you have pets or not.

THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY THAT OWN, MANAGE, OR OPERATE THE RESIDENTIAL APARTMENTS YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN SERVICES AS A RESIDENT IN THE APAERTMENT YOU OCCUPY.

USAGE TRACKING: USE OF IP ADDRESSES

Every device that connects to the Internet is given a number that is known as an Internet Protocol (IP) Address. These numbers are typically assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet. As permitted under applicable law, we collect IP addresses for the purposes of system administration, gathering and analyzing aggregated information, and creating a better experience for Users and auditing the use of our site.

We do not usually link any IP addresses to anything that can be personally identifiable. This means that your Internet session will be logged, but you will remain anonymous to us. We will seek to link your IP address to personally identifiable information when we deem it necessary (i) to identify and authenticate you when you submit certain information to the Website, such as request to visit the property, payments, request for services or other types of communication, (ii) or to be pre-qualified for rental housing displayed on this Website, (iii) when you start or complete a lease application for rental housing displayed on this Website, (iv) or to protect the Website and other Users from harm and to prevent criminal misconduct.

USE OF "COOKIES"

A cookie is a small file which contains a string of characters that is sent to your computer when you are browsing the Internet and visit a website. When you visit the website again, the cookie enables that site to recognize your browser. Cookies may store User preferences and other information about you. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, there are some website features or services that may not function properly without cookies.

Improvements and updates to this Website are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies only to provide services better suited to your needs, and for the protection of our Website and Users from potential harm. We never save passwords or credit card information in cookies.

We may use cookies for many purposes, including to remember your safe search preferences, to track Users' movements around the website, to analyze trends, administer the website, to count how many visitors we receive to a page, to help you sign up for our services, to protect your data and to gather demographic information about our User base as a whole. Users can control the use of cookies at the individual browser level. We may partner with a third party to either display advertising on our website or to manage advertising on other sites. A third party partner may use cookies or similar technologies in order to provide you advertising or other content, based upon your browsing activities and interests or to make the ads you see more relevant to you.

If you desire to change your cookie preferences, you can do so through your browser settings. You may also limit the information we learn from certain cookies by logging directly into the registered areas of this Website rather than by logging in by using your social media log-in credentials. Be advised that our cookies are often used to provide you with certain functionality and without them you may not be able to use some of our Website Services.

WEBSITE ANALYTICS

This Website may use web analytics tools and services, some from third parties, such as web analytic services provided by Google, Inc. ("Google"), to better assist us in understanding how the Website is used. These web analytics tools and services will place cookies on your computer that will generate information that we select about your use of the Website, including your computer's internet protocol address. That information will be transmitted to and stored by us and or third party providers. The information will be used for the purpose of evaluating consumer use of the Website, compiling reports on Website activity for our use, and providing other services relating to Website activity and usage. We may also transfer this information to third parties where required to do so by law, or where such third parties process the information on our behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Website. Use of cookies by Google Analytics is covered by Google's privacy policy located at https://policies.google.com/privacy.

OUR USE OF INFORMATION ABOUT YOU

We may use information about you to create your account, to enable you to use our Website, including any Communities, and to facilitate communication and transactions between Users, service providers, and the Property Management Company, and other third party provider transactions between you and any of them through this Website, including but not limited to using information about you (i) in connection with any interactive decision-making tools or resources relating to leasing an apartment, including submission of an inquiry, contact or schedule a visit forms, lease application or related payment, (ii) in connection with assisting the Property Management Company in marketing to you, including contacting you by email, phone, text message, or otherwise, (iii) in connection with assisting the Property Management Company in processing your lease application, including investigating your background, leasing history, and creditworthiness through third parties, including consumer reporting agencies, (iv) in connection with the processing of your rental payments, service requests, and other communications with the Property Management Company or its agents, (v) in connection with your use of any interactive educational or informational resources provided to residents, (vi) in connection with your participation in any Community or in dealing with any emails that you send to us, (vii) in connection with your use or purchase of any other services or products provided by this Website or by any third-party provider, (viii) in connection with your use of any other aspect of this Website, and (ix) generally to enhance and attempt to optimize your use of our Website. We may also use your email address or telephone number to respond when you submit a question, suggestion, or request assistance with using or accessing this Website.

We may link information we collect about you with other information we collect about you, whether offline or from third parties or otherwise. We may use information about you to send you targeted messages, publications, news, and information about events, special offers, promotions, benefits, and other advertisements. We may use information about you to improve the content of this Website, to enhance users' experiences when visiting this Website, to analyze trends, to administer the Website, to gather demographic information about the Website's users, to track user movements, and to customize the content and layout of this Website for each individual user.

INFORMATION WE SHARE OR DISCLOSE

We will not share your Personal Information with third parties unless: (i) User gives permission to share its Personal Information; (ii) to enforce compliance with our Terms of Use and applicable law, which may include developing tools and algorithms that help us prevent violations, (iii) to protect the rights and safety of our Employees, Customers and third parties, as well as our own, (iv) to meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms, (v) to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements, (vi) to prosecute and defend a court, arbitration, or similar legal proceeding, (vii) to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, (viii) to provide suggestions to you, including adding features and using data to suggest products or services that you may be interested in or that may be relevant to you, (ix) to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website, (x) to improve our Services, we might use your Personal Information to assess and improve our products, services, marketing, and User relationships and experiences, (vi) to provide our partners and service providers with statistical information about our Users, without this information being used to identify any individual User.

THIRD PARTY WEBSITE LINKS

This Website may contain links to other third party websites that are beyond our control, and take you outside of our Services. For example, if you "click" on a banner ad, which is an advertisement or a search result, the "click" may take you off this Website and on to another site that is beyond our control. These other websites may include sites of other sponsors, advertisers or partners that may use their logo with ours as part of a co-branding agreement. These other sites might also send their own cookies to Users who become visitors to other websites to collect data or solicit information. We do not control these websites and therefore are not responsible for their content. The inclusion of hyperlinks to any other websites by us on our Website does not infer any endorsement of the content or material on such sites, nor any association with the owners or operators of the websites or the businesses listed on any of these websites. Our policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control. Be advised that if you disclose information online, that all such information may be collected and used by people you do not know.

The information practices or content of such other websites or advertisers is governed by the privacy statements of all such other websites and businesses contained on those websites. Please be advised that this Privacy Statement is not applicable to those websites or businesses, which are instead governed by their respective privacy statements. Please review the privacy statements of such other websites and businesses to understand their information collection practices.

THIRD PARTY PARTNERS

We may share data with trusted third party partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer or User support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

We partner with trusted third parties to provide you with certain services, content, and resources that we think may be relevant to you. When you engage with these third party partners, we provide a link to the third party partner's privacy policy so you can learn more about how to opt-out of their communications. In all cases where we share your information with such third party partners, we explicitly require those third party partners to acknowledge and adhere to our privacy policies.

SERVICE PROVIDERS

We employ other companies and people to provide services to visitors and Users of our Websites, and may need to share your information with them to provide information, products and services to you. Examples may include analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide us in order to provide you with a better website experience, and providing customer or User support. In all cases where we share your information with such companies or people, we explicitly require them to acknowledge and adhere to our privacy policies.

DATA TRANSFERS

Be advised that if you provide Personal Information to us, it may be transferred to, and processed on computers in the United States of America and other countries, which are not in the EU. Please do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers.

SAFEGUARDING YOUR INFORMATION

We take all reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction; taking into account the risks involved in the processing and the nature of the Personal Information.

Our resident services and application accounts require a username and password to log in. You must keep your username and password secure, never disclose it to a third party, and do not allow others to utilize your account. You should fully exit from your account at the end each session, by utilizing the logout feature. You should also implement a practice of changing your password on a regular basis. If Users have any questions about security, please contact us at: notices@365connect.com.

EMAIL CONSENT AND OPT-OUT

By providing Personal Information to us on our Website, you give affirmative consent that we may reach out to you by email, and provide you with information and notices relating to you searching for residential apartments to rent, lease, or obtain services as a resident in the apartment you occupy, and with regard to other properties or services that may be available and of interest to you in the future.

You may choose to opt out of receiving future commercial email messages from us as a result of your registrations with us. Each email sent by us will have a link with instructions on how to remove yourself from our email list.

CHILDREN'S PRIVACY

We knowingly do not collect any Personal Information from a child under the age of 13 without the consent of that child's parent or guardian. Certain elements of our Services require the submission of Personal Information to access or use the Services. Except in certain cases where limited contact information may be collected and not retained, these elements of our Services are not available to children under the age of 13. If a child who we know to be under the age of 13, and for whom we have not received parental consent attempts to utilize our Services, which is not available to children, they will not be able to access it, and may receive a message, which relays that they are not eligible for such feature.

If you are a parent or guardian and you believe that your child under age 13 may have provided Personally Identifiable Information through this Website, Please contact us at: notices@365connect.com

FIXING AND DEACTIVATING PERSONAL INFORMATION

You have the right whenever you choose, to request that we let you know whether or not Personal Information relating to you is being processed. You have the right to request that we fix, correct, supplement, delete or block your Personal Information in the event that the data is inaccurate, incomplete or irrelevant to the purposes of the processing activities, or if the Personal Information is being processed in any other way, which infringes a legal provision. If you desire to exercise your rights, or if you have any questions, concerns or suggestions regarding the use, collection, or security of your Personal Information, please contact us at notices@365connect.com

When a User requests that certain information about them be deleted, we will make all reasonable efforts to remove that data from our systems. Be advised that due to the nature of the Services that we provide, some information about you may not be fully deleted due to backups or archived copies; however, such information will only be used for the purpose of what our Website does, which is to provide information, facilitate communication, transactions, and services between you and the Property Management Company in relation to you searching for residential apartments to rent, lease, or obtain services as a resident in the apartment you occupy.

CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You should check this Website frequently to see recent changes.

CONTACT INFORMATION

If your Personal Information changes, which includes zip or postal code, phone, email or postal address, we offer a way to correct, update, delete or deactivate Users' Personal Information, through either logging into your account, if you registered for one, or by contracting us at notices@365connect.com

You may use this email to contact us for any other reason relating to this Privacy Policy. Your e-mail should state that it is a "data protection question" and that it is "time sensitive."

You may also contact us as follows:

EMAIL: notices@365connect.com

SUBJECT: Privacy Policy

GDPR INFORMATION

The EU General Data Protection Regulation ("GDPR") was placed in effect on May 25, 2018. This section of the Privacy Policy constitutes a Notice to you as a data subject for purposes of the GDPR, and sets forth our processing of your personal data (as defined in the GDPR).

CORPORATE INFORMATION: This website and its related downloadable applications and Services is operated, hosted, and maintained by 365 Connect, LLC. Please see the "Contact Information" section for information on how to contact us.

TYPES OF PERSONAL INFORMATION PROCESSED BY US: We collect Personal Information from our Website in order to provide information, facilitate communication, transactions, and services between you and the Property Management Company, and to help us better understand how we can assists Users that are searching for residential apartments to rent, lease, or obtain services as a resident in the apartment they occupy. Please see the "Personal Information We Collect" and "Usage Tracking: Use of IP Addresses" sections for more information.

THE PURPOSE AND LEGAL BASIS FOR PROCESSING: We process Personal Information for our legitimate interest of operating the Website to make Users aware of the Property Management Company's products and services. Please see the "Personal Information We Collect" section for more information.

RECIPIENTS: We may transfer Personal Information to our other entities, primarily entities in the United States of America and others in or outside the EU, and to our service providers and affiliates who host and/or provide our IT system. We may also transfer Personal Information with third-party professional advisors who provide accounting, consultancy, and legal services to us. Please see the "Information We Share or Disclose" section for more information.

INTERNATIONAL DATA TRANSFERS: Your information may be transferred to and processed on computers in the United States of America and other countries, which are not in the EU. Please see "Data Transfers" section for more information.

DATA SUBJECTS RIGHTS: Please see the "Email Consent and Opt-Out," and "Fixing and Deactivating Personal Information" section for more information. In addition to these rights, you may have data portability rights. Please see the "Contact Information" section to contact us about any of your rights.

REGULATORY BODY: You may contact the national data processing authority in the EU jurisdiction in which you would normally access this Website if you have any concerns regarding the processing of your Personal Information.

ACCEPTANCE OF THESE TERMS

By using this Website, or providing any information to us, you acknowledge that you are aware of the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy or any amended terms, you must not access or use this Website or Services.

LAST UPDATED JULY 20, 2018