2. Types of Information We Collect. We collect the categories of information described in this Section 2 (Types of Information We Collect).
2.1. Personal Information. We use the term “Personal Information” to mean any information that identifies you as an individual, and any other information we associate with it. Personal Information that we may receive from you includes:
- Your name, email address, and password;
- Other contact information, including a physical address and phone number;
- Lease application information;
- Information about your spouse;
- Your payment and billing information;
- Information or feedback you provide in communications with us, such as through our Website or via social media, email, or text messages;
- Your transactions with us.
2.2. Online Activity Information. We collect technical and device-related information through our Website and third party analytics tools we use (collectively, “Online Activity Information“). Sometimes Online Activity Information can be associated with your Personal Information. If any statutes, regulations, and any other laws that apply to the Services establish that Online Activity Information constitutes Personal Information, and such applicable law applies to information we collect from you, then we will treat the Online Activity Information as Personal Information.
2.4. Disclosing Personal Information Where it is not Specifically Requested. If we have not specifically asked for your Personal Information in a particular portion of an online form or submission area on a paper form, then you should not provide any Personal Information in that portion of the form or submission area.
3. How We Collect Personal Information. As set out in this Section 3 (How We Collect Personal Information), we may collect information at different points when you use our Services (for example, when you request information, submit housing applications to us, or apply for jobs through our Website), including when you fill out a housing application or submit a maintenance request. In some instances, we may also receive information about you from third parties, such as our service providers.
3.1. Account Registration; User Names. In order to access information, products, and services on our Website that are limited to registered users, we require that you complete a registration form. This form asks for certain Personal Information.
3.2. Website Visitors. As a Website visitor, you decide whether to provide us with your Personal Information. We allow you to visit our Site and review other information about our Services without revealing your identity or otherwise providing Personal Information. In that case, the only information that we collect from your visit will be Online Activity Information or Anonymous Information.
3.3. Contacting Us. You can contact us with questions or comments using the contact methods available on our Website, using the information provided in Section 16 (Contact Us), or submitting a written request to us. In order to communicate with us, you must provide certain Personal Information. We may use Personal Information and other information submitted to provide you with the information, products and services (such as housing services and maintenance services) that you have requested. For example, as the occupant of a home in one of our communities, you may submit a maintenance request through our Website or in person, and we use the information you submit to provide the requested service.
3.4. Employment Applications; E-Verify. In the employment section of our Website and through other public job postings, we may invite you to apply for employment opportunities with us by submitting your Personal Information, employment information, resume and other, similar kinds of information. Regardless of the method you choose to submit your employment application to us – for example, if you send us an employment application by email – we will treat the Personal Information you provide to us in such application as if you provided such Personal Information to us via our Website. Because we receive a large volume of applications, we do not guarantee that we will contact you after you submit an employment application. Additionally, it may be necessary or advisable for us to use Personal Information to verify employment eligibility through the E-Verify system.
3.5. Verifying Identity. When you request a product, service, or information from us, 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.
3.7. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, e-newsletters, and other information to you using provided Personal Information. For example, we may send you information that we believe is relevant to them, including information about severe weather, neighborhood watch advisories, AMBER Alerts, and surveys, all via email, automated voice messages, and SMS text message. In certain circumstances we or our Vendors may ask you to further confirm their consent to receiving these communications. You may also incur, and shall be responsible for, all messaging and data fees charged by their service providers (such as their wireless carriers) in connection with their receipt of these communications. You may opt out of receiving these communications as provided in Section 9 (Your Choices Regarding Your Personal Information; Opting Out), provided, however, that there are certain communications for which you cannot opt out. Please refer to Section 9 (Your Choices Regarding Your Personal Information; Opting Out) for more details.
3.8. Surveys. We may initiate surveys on our Website, through the mail, or by other means, and we may request Personal Information from you in connection with such surveys. You are free to choose whether you participate in this type of survey. Survey information will be used for purposes of monitoring or improving the use and appeal of our Website, improving our homes and services, or for other business purposes.
4. How We Collect Online Activity Information and Anonymous Information. We collect Online Activity Information and Anonymous Information to analyze the effectiveness of our Website, to improve our products, services, 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 of users participating in our services and the characteristics of visitors to our Website, and may share this information with third parties, including advertisers. We may collect Online Activity Information and Anonymous Information through features of the software that supports our services, such as cookies or other means described below.
4.1. IP Addresses; Logs. Either directly, or through our hosting service provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from, 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.
4.2. Cookies. A cookie is a small amount of data, which is sent to your browser from a website’s computers and stored on your computer’s 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 on a future visit. For example, we may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies. Cookies must be enabled on your web browser, however, you may need to enable cookies if you wish to access certain personalized features of our services.
4.3. Tags. We may use so-called “pixel tags” – small graphic images (also known as “web beacons,” “single-pixel GIFS,” or “Web bugs”) – for purposes such as: (i) to tell us what parts of our Website have been visited; (ii) in connection with advertisements we may include on the Website; (iii) to measure the effectiveness of searches you perform on our Website; and (iv) for other purposes. Pixel tags also enable us to send email messages in a format that you can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users and others. These technologies provide us with Anonymous Information, Online Activity Information, and, in certain instances, Personal Information.
4.4. Click Throughs. We may send email messages which use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications.
5. How We Use the Information We Collect
- To provide you with the Services you request (on the Website, by phone, in person, or otherwise) including, for example, to process your housing application, to provide maintenance services, and to provide you with other services that we make available in our communities;
- To allow you to post Submitted Content, such as photographs and other reviews, and participating in surveys and questionnaires;
- To respond to your inquiries;
- To customize and enhance your use of our Services;
- To provide communications that might interest you, including marketing messages and to inform you of products and services that we think would be appealing to you, whether the products or services are provided by us or by others, and whether the products or services are available via our Site or via a third party;
- To verify your identity and to securely process requests for Services;
- To perform analytics, quality control, market research, and to determine the effectiveness of our Services;
- To create potential sales contacts (“Leads”);
- To perform internal administration, auditing, operation, and troubleshooting for our Services; and
- To share the information with third parties strictly as permitted in Section 8 (How We Share Your Information) below.
7. Other Essential or Internal Uses of Information. We may also use information we collect as we believe to be necessary or appropriate for certain essential purposes, including:
- To comply with applicable law and legal process;
- To respond to requests from public and government authorities;
- To detect, prevent, or investigate potential security incidents or fraud;
- To facilitate the functionality of the Website;
- To enforce our terms and conditions;
- To protect our operations or those of our affiliates;
- To protect our rights, privacy, safety or property, security and/or that of our affiliates, you, or others; and
- To allow us to pursue available remedies or limit the damages that we may sustain.
8. How We Share Your Information. We will not disclose Personal Information about you to third parties without express consent, except in the circumstances specified below.
8.2. Government Regulators. We are periodically required to disclose Personal Information to third parties, such as credit reporting agencies, and federal and state regulators, in order to do business with you.
8.3. Military Personnel. We disclose Personal Information to the United States Military as the military requires, in accordance with our reasonable interpretation of applicable law, or as necessary to provide the products and services that we have agreed to supply as part of our contracts with the military. We will not disclose more information than is necessary to comply with these obligations.
8.5. E-Verify System. We will comply with the E-Verify program where applicable. Accordingly, it may be necessary or advisable for us to disclose Personal Information you to the federal government.
8.6. Questions of Harm Legal Process. We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigators, where it is necessary, or where we have a good faith belief that it is necessary:
- To comply with legal process;
- To protect and defend our rights and property, including the Website, other Services, and associated content;
- To protect against misuse or unauthorized use of our Website, other Services, and associated content;
- To protect the personal safety and property others or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
- To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.
While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.
8.7. Corporate Transaction. We may transfer to a third party all of the information that we have collected, including any Personal Information, in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
8.8. Lead Generation. Notwithstanding the above, we may access certain Personal Information, limited to your name, job title, company name, company size, address, phone number, email address, behavior at virtual and live events, and behavior on the Website, in the creation of our Leads. We may sell and share that certain Personal Information to the third parties that purchase our Leads in the context of cross-behavioral advertising.
9. Your Choices Regarding Your Personal Information; Opting Out.
9.1. Unsubscribing to Marketing Communications. If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, then 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 16 (Contact Us).
9.2. Discretionary Account Information. To allow appropriate control over Personal Information, you can view, change, or update discretionary information that you have previously submitted either by contacting us as provided in Section 16 (Contact Us) below or by accessing your account on our Site (if such functionality is available to you).
9.3. Access, Deletion, and Do-Not-Sell Requests. CIS IS CURRENTLY IMPLEMENTING INTERNAL CHANGES TO FULFILL REQUESTS SUBMITTED UNDER THIS SECTION 9.3 (Access, Deletion, and Do-Not-Sell Requests). UNTIL SUCH CHANGES ARE COMPLETED, CIS MAY NOT BE ABLE TO FULFILL CERTAIN REQUESTS. CIS WILL NOTIFY THOSE MAKING A REQUEST IF SUCH REQUEST IS IMPACTED BY ONGOING INTERNAL CHANGES.
We provide the following additional rights with respect to your Personal Information:
9.3.1. Copy of Personal Information. You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you.
9.3.2. Deletion of Personal Information. You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected.
9.3.4. Submission of Requests. You can submit any of these requests by clicking here: Information Requests, by contacting us at1-833-gotoCIS, or by visiting us at one of our offices. You may authorize another person (your “Agent”) to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it. Please be advised that these requests are unrelated to an opt-out of marketing communications, which can be done as provided in Section 9.1 (Unsubscribing to Marketing Communications) above.
9.3.5. Response to Requests. Please be advised that CIS will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please contact us as provided in Section 16 (Contact Us).
10. Accuracy and Minimization of Data; Data Retention. 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 retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (a) the duration of our relationship with you; (b) the existence of a legal obligation as to the retention period; and (c) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
12. Website Participation by Children and Teens; Advisory. Our Website is not directed at children and we will not accept or request Personal Information from individuals that we know to be under 13 years old. If you are 16 years of age or older, you have the right to direct us not to sell your Personal Information at any time. We do not and will not sell Personal Information of individuals we actually know are less than 16 years of age unless we received affirmative authorization from the individual who is between 13 and 16 years of age, or the parent or guardian of an individual less than 13 years of age, to opt-in to the sale of their Personal Information. Upon the receipt of this request to opt-in, we will inform the minor of the right to opt-out later and of the process for doing so.
13. Notice of Privacy Rights to California Residents. The following provisions of this Section 13 (Notice of Privacy Rights to California Residents) apply if you are a California resident.
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. CIS makes the following disclosures regarding the California Consumer Privacy Act:
13.2.1. No Financial Incentives. CIS does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send promotions and other offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. CIS does not offer financial incentives to deter customers from making such requests. CIS will not discriminate against any customer for exercising their privacy rights, including those provided by applicable law.
13.2.2. Customer Reporting. CIS will endeavor to report customer request metrics when they become available.
13.2.3. Job Applicants. If you are a job applicant submitting Personal Information to CIS in connection with an application for employment, you will be provided with a privacy notice regarding how we handle such information as part of the application process.
13.2.4. Questions. If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 16 (Contact Us).
15. Feedback. If you have a suggestions on how we can improve or issues and concerns that you would like us to address, please contact us as set out in Section 16 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.
21. Copyright and Legal Notice. Copyright ©2023 Corvias Infrastructure Solutions, LLC. All Rights Reserved.