- Tenants (residential and commercial), and employees of commercial tenants, and any guarantors of such tenants, of any of our Properties (collectively, “Tenants”);
- Contractors, vendors, and other service providers, including their employees, that provide us with services (collectively, “Contractors”);
- Potential Tenants or applicants that have submitted a lease application or other related information to Northland by any means, including electronically or in person, in connection with the Business (collectively, “Applicants”);
- Users that have registered an account with Northland (“Registered Users”); and
- Casual visitors of (i) our website (the “Website”), or (ii) Properties (collectively, “Site Visitors”).
We use the term “you” to refer to (i) Tenants; (ii) Contractors; (iii) Applicants; (iv) Registered Users; and (v) and Site Visitors (as the context permits).
3. The Information We Collect. Information that you may provide or that we may collect from or about you in connection with our Business falls into two broad categories: (i) Personal Information, and (ii) Anonymous Information.
3.1 Personal Information. We use the term “Personal Information” to mean any information that identifies you as an individual. The Personal Information we collect may include the following:
- Your name;
- Your address;
- Your email address;
- Your phone number;
- Your social security number;
- Information about your income and other employment demographic information;
- Information obtained from background checks related to your lease or application to a Property;
- Your birthday;
- Your payment information;
- Your other transaction history (i.e. if you are a Tenant, then your maintenance requests, package notifications, etc.);
- Time and location data as to when you access other control mechanisms offered in connection with our Business (such as smart home features);
- Your browsing history when logged into our website;
- Your vehicle information;
- Device identifiers, such as cookies;
- Device information, such as hardware and software settings;
- Other characteristics of a user device, which, by themselves or taken in conjunction with other information, are sufficient to distinguish that user device over time from a population of other user devices;
- IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
- Tracking information that we, or a third party, collects.
3.2 Anonymous Information. We may also collect, process, and use information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individuals cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information.
4. How We Collect Personal Information. We collect the above information through the following means and technologies:
4.1 Registered Users; User Names. In order to participate in certain Services we offer to Registered Users, we require that you use the process described in Section 2.2 (Your Consent if you are Not a Site Visitor) to complete the registration process by consenting to become a Registered User. Upon request at certain Properties, our employees may provide you with in-person assistance with the registration process. After completing the registration process, Registered Users may be provided with an email username and password, which allows them to gain access to password-protected portions of our Website and to otherwise use certain functionality available on our Website. This information is used by Northland in providing the Website and conducting its Business, as further detailed below.
4.3 Resident Services. If you are a Tenant, we may provide you with a convenient platform to submit a maintenance request, get announcements, communicate with your Property manager, add vehicle information, get notified that a package has arrived, and access other Services related to the Property in which you reside. In these instances, we use any information you provide to us for the purposes for which you submit the information.
4.4 Emails; Live Chat; Social Media. You may have the ability to contact us via email, “live chat” functionality, instant messaging, Facebook Messenger, Snapchat, and other social media platforms with questions, comments, or feedback concerning our Business. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we use any information you provide to us for the purposes for which you submit the information.
4.5 Questionnaires and Surveys. We may allow you to participate in surveys and questionnaires, which we may post or otherwise provide to you from time to time. You are free to choose whether you participate in a survey or questionnaire. We may ask that, in addition to providing your responses, you also provide Personal Information. In these instances, we use any information that you provide to us for the purposes for which you submit the information. We may also add your Personal Information to your customer profile, as well as for advertising and marketing purposes. Survey and questionnaire information may be used for the purposes of monitoring or improving our Business. As further set out in Section 10.2 (Opt-Out), please understand that you will not be allowed to “opt out” of formal notices related to our Business, such as the operation of the Website and App, and legal, and other related notices concerning safety (such as notices related to fire alarm testing, repairs, or other exigent circumstances) and your relationship with us.
4.6 Newsletters and Special Offers. You may choose to sign up to receive optional communications from us including, for example, emails, mobile notifications, or “push” notifications with information related to our Business, including deals, news, and other events. In addition, if you are a Registered User or if you have previously provided Northland with your email address (such as through the means described in Section 4.12 (Provision of Personal Information Offline)), then we may choose to send news, bulletins, marketing materials, or other information. We will use Personal Information to determine which communications may interest you, and to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 10 (Changing or Removing Information; Opting Out).
4.7 User-Generated Content. As further set out below, we may provide you with the ability to submit content to us for our internal use or to submit content to us for public consumption (collectively, “User-Generated Content”). If you include any Personal Information relating to others in your User-Generated Content, then you represent that you have full permission and authority to do so.
4.7.2 User-Generated Content Provided to Us for Public Consumption. We may give you the ability, for example, through our Website or a third party social media platform, to engage with us and others in public exchanges by providing User-Generated Content, which may include opportunities for you to provide comments, reviews, recommendations, and other input. Please understand that, if you include Personal Information in such User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use such Personal Information. We are not responsible for Personal Information that you decide to include in such User-Generated Content, and we will not take down, remove, or edit User-Generated Content, except as required by applicable law.
4.8 Verifying Identity. If you submit requests or information to us, then we may use Personal Information (and other information that we have about you) to verify your identity and to process your request. This is designed to further protect you and to reduce the threat of identity theft and fraudulent transactions.
4.9 Tenant Eligibility; Background Checks. If you are an Applicant (that is applying for a lease with us), then we will request that you disclose certain information, including Personal Information, on your rental application or other documents to determine your eligibility to lease from us. We will use such information, or provide such information to our Contractors, to: (i) determine your eligibility to lease from us when you apply; (ii) determine that you continue to meet eligibility requirements during your lease term with us; (iii) complete the leasing process; and (iv) request credit and background check reports and other information about you from third parties in connection with your lease eligibility (collectively, “Eligibility Information”). To allow appropriate control over Personal Information, we will make some of this Eligibility Information available to you and you will be able to view, change, or update such Eligibility Information that you have previously submitted to us and certain information that we have used to make decisions about you (including for your lease) to ensure that such decisions made about you are based on accurate information by contacting us in accordance with Section 19 (Contact Us). If you determine that such Eligibility Information is inaccurate or contains discrepancies, you will be able to identify and provide evidence of such inaccuracies or discrepancies to us and we then will evaluate any decisions we made based on such identified inaccuracies and discrepancies.
4.10 Smart Home Features. We may collect information from you, including Personal Information, in order to provide you with smart home features such as (i) Wi-Fi connected smart thermostats; (ii) Wi-Fi connected smart outlets; (iii) Wi-Fi connected smart ceiling fans and lights; (iv) Wi-Fi connected smart door locks; (v) video conferencing and facial recognition; and (vi) other smart home products. If smart home features are offered to you, then we will use the information we collect from them, or provide such information to our Contractors, in order to provide you with such smart home features.
5. How We Collect Anonymous Information. We use Anonymous Information to analyze the effectiveness of, and improve, our Business and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics related to our Business, including users and the use of our Website and App, and we may share Anonymous Information with third parties, including Advertisers (if any) and our Contractors (in accordance with Section 7.1 (Northland Contractors)). Anonymous Information provided to third parties as outlined in this Section 5 (How We Collect Anonymous Information) will not allow anyone to identify you. We may collect Anonymous Information through features of the software that support our Business (such as those on the Website and the App), through cookies and through other means described below.
5.1 IP Addresses; Logs. Northland may automatically receive and record information in our server logs from your browser or mobile device, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser or mobile device operating system, referrer addresses, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.
5.2 Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your computer or mobile device from a website or a mobile application and stored on your hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website or a mobile application upon future visits. We may include cookies on our Website or the App, and use them for a variety of purposes, such as to recognize you when you return to our Website or the App and to remember your preferences. You may set your browser or mobile device so that it does not accept cookies. Cookies must be enabled, however, if you wish to access certain personalized features of the Website or the App.
5.4 Click-Throughs. We may send email messages, which use a “click-through URL” linked to content related to our Business. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We may track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 10 (Changing or Removing Information; Opting Out).
6. Internal Uses of Information. We may use your Personal Information and Anonymous Information to perform internal administration, auditing, operation, and troubleshooting in connection with our Business, including to evaluate and improve our Business, and to develop and test new Business Practices and/or Services.
7. How We Share the Collected Information. We will not disclose your Personal Information to unaffiliated third parties without your express consent, except as set out in Section 9 (Advertising) and in the following limited circumstances:
7.1 Northland Contractors. We may employ Contractors, including Payment Processing Companies, to perform functions on our behalf, such as collecting or providing information, responding to and sending electronic mail, or other functions necessary to our Business. We may need to share your Personal Information with these Contractors. We will provide Contractors with only that information necessary or desirable to perform their functions, and we will not allow them to use your Personal Information for any other purpose.
7.2 Legal. Northland will reveal your Personal Information to the extent we reasonably believe that we are required to do so by applicable law.
8. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information. We will retain your Personal Information for as long as reasonably necessary to conduct the Business or provide the Services to you or as necessary for compliance with applicable law. You may request that we delete your information in accordance with the procedures and limitations set out in Section 10.3 (Deleting Information).
9. Advertising. We participate in advertising to keep our customers apprised on product offerings, Property promotions, and associated content. As further set out below, we may use the information you provided to us to provide you with advertising or promotions based on your interaction with our Business. These advertisements and promotions may be related to the Business, or for other third party services and products that we think may interest you.
9.1 Our Use of Anonymous Data for Advertising. Like many companies, we utilize targeted Northland banners and ads and may display these to you when you are on other websites and mobile applications. We do this using a variety of digital marketing networks and ad exchanges in addition to using a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks. The banners and ads that you may see displayed will be based on information we hold about you, such as your previous use of our Website or the App. This may include your search history on our Website or the App, the content you read on our Website or the App, or on Northland banners or ads you have previously clicked on.
9.3 Promotional Partners Use of Limited Personal Information. We may also provide a limited subset of your Personal Information to promotional partners that provide us with performance based incentives if you subscribe to, or use, their services (collectively, “Promotional Partners”). This may include, by way of limited example, if we provide a cable TV provider with your contact information and we receive an incentive if you subsequently subscribe to the cable TV provider’s services. Such limited subset of your Personal Information may include: (i) your name; (ii) your address; (iii) your email address; and (iv) your telephone number. We will never provide Promotional Partners with: (a) your social security number; (b) your payment information; or (c) your other transaction history (as described in Section 3.1 (Personal Information)).
10. Changing or Removing Information; Opting Out.
10.1 Access and Transparency. To allow appropriate control over Personal Information, you will be able to view, change, or update your Personal Information, including Eligibility Information that you previously submitted to us in accordance with Section 4.9 (Tenant Eligibility; Background Checks).
10.2 Opt-Out. If we choose to send to you bulletins, updates, mobile notifications, or other marketing-related materials, we will provide you with the ability to decline – or “opt out” – of receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. For example, if you no longer wish to receive email messages from us, you can opt out of this service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 19 (Contact Us). Please understand that you will not be allowed to “opt out” of formal notices related to our Business, such as the operation of the Website and the App, and legal, and other related notices concerning safety (such as notices related to fire alarm testing, repairs, or other exigent circumstances) and your relationship with us.
10.4 Third Party Personal Information. To the extent that you provide Northland with Personal Information of third parties, you represent and warrant that you have permission from such third parties to provide us with their Personal Information.
11. Security. We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law. However, no information or communication system can be 100% secure, so Northland cannot guarantee the absolute security of your information. In addition, Northland is not responsible for the security of information that you transmit over networks that Northland does not control, including the Internet and wireless networks.
12. COPPA Advisory and Procedures. Our Services and this Website are not directed to children under 13 years old (each a “child,” as set forth in Children’s Online Privacy Protection Act (“COPPA”)). We understand, however, that there may be instances where a Tenant, as parent or guardian of a child, permits the child to access Services or otherwise directly provide us with information. For example, a Tenant may allow his or her child to submit a maintenance request. If we receive information that we know is from a child, we will use such information solely for purposes of fulfilling or responding to the specific request made by the child. You authorize Northland to collect and act upon, in that limited manner, information provided by your child (or children), including personal information (as such term is defined under applicable law), (a) by signing a lease with Northland and/or (b) by paying rent or other fees to Northland that relate to such Services. If you believe that we have received or collected information from your child in a manner with which you do not agree, please submit a deletion request and we will follow the procedures set out in Section 10.3 (Deleting Information) to delete the information.
13. Notice of Privacy Rights to California Residents.
13.1 Shine the Light Law. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.
13.2 California Consumer Privacy Act Disclosure. The California Consumer Privacy Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of Personal Information that we have collected about California residents. We use the term “resident” to refer to a California resident to whom the CCPA applies. Among other rights under the CCPA, as further set out in this Section, a resident may request that we (i) disclose to the resident Personal Information that we have about such resident (including Personal Information about you that is sold), and (ii) subject to certain exceptions, delete Personal Information that we have about such resident. A resident may request a copy of the following using the mechanism set out in Section 13.3 (Submission of a Consumer Request): (a) the categories of Personal Information we collected about such resident; (b) the categories of sources from which the Personal Information is collected; (c) the business or commercial purpose for collecting or selling the Personal Information; (d) the categories of third parties with whom we share such resident’s Personal Information; and (e) the specific pieces of Personal Information we have collected about such resident. Residents may submit a request for such information no more twice in any twelve (12) month period, and our disclosure of such requested information shall only cover the twelve (12) month period preceding our receipt of such request. Additionally, a resident may request that we delete such resident’s Personal Information using the mechanism set out in Section 13.3 (Submission of a Consumer Request). A resident’s rights as to such deletion requests are set out in Section 10.3 (Deleting Information).
13.3 Submission of a Consumer Request. We are in the process of implementing a web-based form and toll-free number for residents to submit a request to us to access or delete their Personal Information. In the interim, please submit such requests to the email address provided in Section 19 (Contact Us) or in person to a leasing agent. We will respond to your request within forty-five (45) days or as permitted by applicable law.
14. Feedback. We want to encourage your feedback. If you have a suggestion on how we can improve our Business or concerns you would like us to address, please contact us at the address set out in Section 19 (Contact Us). Certain states may provide you with additional avenues for lodging complaints. Please check with your state’s consumer protection authority.
18. Further Resources. If you wish further information concerning privacy policies in general, you should visit the following site: http://www.ftc.gov/privacy/index.html.
20. Do Not Track Notice. Our Website does not change its behavior when receiving “Do Not Track” signals from browser software.
22. Copyright and Legal Notice. Copyright ©2020 Northland Investment Corporation. All Rights Reserved.