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Effective Date: January 1, 2020
RealPage is committed to providing clear and concise information regarding our privacy policies and practices. This Privacy Statement for California Residents supplements the information contained in the RealPage Privacy Statement and applies solely to all visitors, users, and others who reside in the State of California (“residents” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. By accessing our website or utilizing RealPage Services, you consent to the information collection and handling practices outlined in this statement.
I. Personal Information Collection
RealPage Services involve the collection and processing of personal information for business purposes. RealPage Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (collectively deemed “personal information” under the CCPA). In particular, RealPage Services have collected the following categories of personal information from its Clients’ residents within the last twelve (12) months:
Note: Some personal information included in this category may overlap with other categories.
II. Personal Information Exceptions (Not Covered by CCPA)
Personal information does not include:
III. Personal Information Sources
RealPage collects the categories of personal information listed above from the following categories of sources:
IV. Personal Information Use & Processing
In providing the suite of RealPage Services, RealPage acts as a service provider under contract to our Clients1. As a service provider, RealPage does not control any of the personal information we process on behalf of our Clients. Our Clients collect and control all such personal information, and RealPage is required to provide our products and services in accordance with Clients’ contractual provisions and instructions regarding data collection, privacy, processing, and security.
1 RealPage offers direct-to-consumer services that collect personal data directly from residents. Unlike the majority of RealPage Services, these direct-to-consumer services do not operate on behalf of our Clients. These services include: eRenterPlan (insurance), eRenterDirect (insurance), Lease Terms Solutions (insurance), DepositIQ (insurance/surety bonds), and ResidentDirect (money transmission services). Each of these services has a separate privacy policy posted to their designated websites that outlines the privacy practices associated with the services.
Accordingly, we may use or disclose the personal information we collect for one or more of the following purposes:
RealPage will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
V. Personal Information Sharing & Disclosure
RealPage does not sell personal information collected through RealPage Services, and no such disclosure has occurred in the prior 12 months.
RealPage may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors that support or integrate with the RealPage Services described in this statement (See chart above). RealPage only shares personal information to the extent reasonably necessary to support RealPage Services requirements, or for the third party vendors or service providers to perform the services on our or our Clients’ behalf. We do not permit third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request of them. However, please note that RealPage does not maintain direct control over the privacy policies and practices of Clients or any other third party companies, agents, or contractors.
VI. Personal Information Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with CCPA guidelines. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information Regarding Personal Information Use/Disclosure and Portability
You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. Under most circumstances, this request for disclosure should be submitted to the property manager that operates your apartment community or rental property.As stated above, RealPage is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.
However, eRenterPlan, eRenterDirect, Lease Term Solutions, DepositIQ, and ResidentDirect consumer requests should be submitted directly to RealPage. In response to a verifiable consumer request for these services, we will disclose the following information for the applicable RealPage Services:
You also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, RealPage may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.
Deletion of Personal Information
You have the right to request that RealPage delete any of your personal information that we collected and retained, subject to certain exceptions. Under most circumstances, this request for disclosure should be submitted to the property manager that operates your apartment community or rental property. As stated above, RealPage is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.
However, eRenterPlan, eRenterDirect, Lease Term Solutions, DepositIQ, and ResidentDirect consumer requests should be submitted directly to RealPage.
Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:
We may deny your deletion request if retaining the information is necessary for RealPage or our service providers to:
VII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights
Under most circumstances, consumer requests should be submitted to the property manager that operates your apartment community or rental property. As stated above, RealPage is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.
However, eRenterPlan, eRenterDirect, Lease Term Solutions, DepositIQ, and ResidentDirect consumer requests should be submitted directly to RealPage. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
OR
Only you (or someone legally authorized to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
VIII. Consumer Request Responses and Timelines
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account where possible. If you do not have an account with us, or your existing account lacks a communication feature, we will deliver our written response to your designated email address.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
IX. Personal Information Sales – Opt Out Rights
RealPage does not sell personal information collected through RealPage Services, and no such activity has occurred in the prior 12 months. In the event that RealPage changes its practices and engages in the sale of information, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with CCPA requirements.
X. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
XI. Other California Privacy Rights
The State of California also grants California residents privacy rights via laws unaffiliated with the CCPA. Those rights include the following:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@realpage.com.
California’s Investigative Consumer Reporting Agencies Act (ICRAA – Civil code Section § 1786.10 -1786.40) requires certain privacy disclosures related to investigate consumer reporting agencies operations, including the following:
Personal information collected in connection with the provision of consumer reports and investigative consumer reports through our Resident Screening products (LeasingDesk and On-Site) is securely stored on servers located within the United States. This information may be made available to employees of RealPage or its affiliated companies who are located outside of the United States or its territories, solely for the purpose of performing their job duties and in accordance with applicable laws.
To obtain additional information about our privacy practices and policies in the event of a compromise of your personal information collected via our Resident Screening products, you can contact us via:
US Postal Service: RealPage Consumer Relations, 2201 Lakeside Blvd, Richardson, TX 75082
Email: privacy@realpage.com
Phone: 1-866-934-1124
XII. Changes to Our Privacy Statement
RealPage reserves the right to amend this privacy statement at our sole discretion at any time. When we make changes to this privacy statement, we will post the updated content to our applicable websites and services along with the effective date of the change. Your continued use of RealPage Services following the posting of changes constitutes your acceptance of such changes.
XIII. Contact Us
If you have any questions or concerns about this Privacy Statement or its implementation, you may contact us via the following methods:
Via US Postal Service at:RealPage, Inc.Attn: Privacy (Legal)2201 Lakeside Blvd.Richardson, TX 75082OR Via email at: privacy@realpage.com