RealPage Privacy Statement for California Residents

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:

II. Personal Information Exceptions (Not Covered by CCPA)

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

III. Personal Information Sources

RealPage collects the categories of personal information listed above from the following categories of sources:

• Resident personal information is collected (i) from Clients’ residents during enrollment in or utilization of RealPage Services, (ii) from Clients via direct input into RealPage Services or integration with Client software systems and third party service providers, and (iii) indirectly from credit reporting agencies/bureaus, payment processors/gateways/banks, and website analytics services integrated with RealPage Services.
• Client employee personal information is collected (i) from Client’s employees during setup of RealPage Services user accounts, and (ii) from Client during activation and implementation of RealPage Services.

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:

• To fulfill the purpose for which the personal information was collected and provide the requested RealPage Services.
• To integrate with apartment community services offered by RealPage or third party service providers contracted by Clients.
• To distribute communications and legally required notices regarding the status of RealPage Services via phone, email, and SMS text.
• To provide RealPage Services maintenance, enhancement, research, development, security, support, and website optimization.
• To maintain compliance with federal and state laws related to software-as-a-service, background screening, financial institutions, and money services businesses.
• To create, maintain, customize, and secure RealPage Services user accounts.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RealPage’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by RealPage is among the assets transferred.

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:

• The categories, specific types, and sources of personal information we collected about you.
• Our business purpose for collecting the personal information.
• The categories of third parties with whom we share that personal information and the purpose for the disclosure.

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:

1. Complete the transaction for which we collected the personal information, provide the RealPage Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug RealPage Services to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or your property manager.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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:

• Calling us toll-free at:
  • For eRenterPlan and eRenterDirect: (888)512-4204
  • For Lease Term Solutions (AssetProtect and LeaseProtect): (888)814-6950 – Select Option 1
  • For DepositIQ: (877)684-4039 – Select Option 3
  • For ResidentDirect: (844)530-5785

OR

• Via the secure webform linked here

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:

• Provide sufficient information that allows us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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 Disclosure: United States or Overseas

  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.

• Additional Information Regarding RealPage Resident Screening Privacy Practices

  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 75082

OR Via email at: privacy@realpage.com