Last updated: January 1, 2020
Scope Of This Policy
THIS PRIVACY STATEMENT DOES NOT APPLY TO CLIENT PROVIDED DATA.
Information We May Collect
Personal Information. “Personal Information” is information that does or can identify you as an individual and/or relates to an identifiable person, including but not limited to:
- Contact information (Postal address(es), email address, telephone number)
- Social Security Number
- Date of birth, age, gender
- Government identity information including driver’s license or passport information
- Personal details to verify your identity, such as mother’s maiden name and security question responses
- Payment and financial information such as credit/debit card information or financial account information
- Credentials such as user name and password
- Resident or social media account ID, if applicable
- Education Information
- Employment Information
- IP address
- Device information
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags, and other technologies
Unless specifically requested, we ask that you not send us, and you not disclose, any sensitive Personal Information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background, on or through the Sites or otherwise to us.
Other Information. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Aggregated, de-identified information
How We May Collect Information
We and our service providers may collect information in a variety of ways, including:
- From you.
- Through the Site: We may collect Personal Information through the Sites, e.g., when you create an account or make a payment, or engage in any other type of transaction with us. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Sites to, among other things, track the actions of users of the Site (including email recipients), measure the success of our marketing campaigns and compile statistics about usage and response rates.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How Information May Be Used
We may use your information for a variety of purposes, including:
- Completing payment transactions;
- Site demographics;
- Data analysis and research;
- Improving and developing the Site and our products and services;
- Responding to and fulfilling your requests;
- Providing customized content through features of the Site;
- Providing you promotional or informational materials;
- Managing marketing campaigns; and
- Complying with legal obligations and resolving disputes.
How Information May Be Disclosed
Your Personal Information may be disclosed:
- To our service providers who provide services such as website hosting, data analysis, payment processing, fraud prevention and risk management, credit reporting services, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- To our Clients and partners, including property managers, landlords, homeowners’ associations and others on whose behalf we process transactions including rental payments, association fees and dues, and other transactions.
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our social media pages), if applicable. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
- To a third party in the event of any 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).
We also may collect, use and disclose your information as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
Third Party Services
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps.
Company implements and maintains appropriate physical, administrative, technical, and organizational measures to protect the Personal Information we process against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to Personal Information is authorized only for those who have a business need for such access. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose Personal Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use of your Personal Information:
In the event your personal information is determined to be outdated, incomplete, or inaccurate, you may access and update your information by logging into your Company account. Where the processing of your Personal Information is based on your previously given consent, you have the right to withdraw your consent at any time by deactivating your Company account. If you require (i) verification that your requested changes have been completed (and such verification is not readily displayed in your account), or (ii) assistance with your account deactivation or consent withdrawal, you may request customer support at the email address listed below (See “Contact Us”).
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking on the “unsubscribe” link in such emails.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, delete, change, or suppress your Personal Information:
*California residents, please refer to the California Residents section below.
If you who wish to review, correct, update, change, or delete the Personal Information that you have previously provided to us, you may go back to the applicable registration page or web form to edit your user or organization record or you may contact us by email at email@example.com or mail at:
9330 Scranton Road, Suite 450
San Diego, CA 92121
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we will need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and/or as required by applicable law.
Please note that we may need to retain certain information for recordkeeping, reporting, and/or auditing purposes, including but not limited to compliance with laws relating to anti-money laundering and counter-terrorist financing, and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a lease payment, you may not be able to change or delete the Personal Information provided until after the completion of such payment). There may also be residual information that will remain within our databases and other records, which will not be removed.
Please note that some of the information voluntarily submitted that is not Personal Information, such as a response to a poll or a survey, is typically aggregated and thus not correctable, updatable, changeable, or erasable.
Use of Services By Minors
The Sites are not directed to individuals under the age of thirteen (13). We do not knowingly collect Personal Information from children under sixteen (16). No one under age sixteen (16) may provide any information to, or on, any Sites. If we learn we have collected or received Personal Information from a child under sixteen (16) without verification of parental consent, we will delete that data. If you believe any Sites may have collected Personal Information from or about a child under sixteen (16), please contact us at the address listed below (See “Contact Us”).
Jurisdiction And Cross-Border Transfer
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Company retains the Personal Information we receive on the Sites for the duration of your relationship with Company, plus a reasonable period thereafter as necessary to fulfill the purposes described above. Retention periods may be extended if we are required to preserve your Personal Information because of litigation, investigations, and other similar proceedings, or if a longer retention period is required or permitted by applicable law.
9330 Scranton Road, Suite 450
San Diego, CA 92121
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. We may share your Personal Information with our affiliates for direct marketing, but we do not sell it to or share it with unaffiliated third parties. You may request a list of our affiliates by contacting us at Company, LLC, 9330 Scranton Road, Suite 450, San Diego, California 92121. You may make one (1) request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please allow up to thirty (30) days for a response.
Additionally, the California Consumer Protection Act (“CCPA”) provides California residents with specific rights regarding their Personal Information including the right to request that a business disclose what Personal Information it collects, uses, discloses, and sells.
Access and Deletion Rights
You have the right to request that Company disclose to you certain information to you about the collection and use of your Personal Information over the last twelve months. Once we receive and confirm your verifiable consumer request (see Exercising your CCPA Rights), we will disclose to you:
- The categories and specific pieces of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we sold or disclosed your Personal Information for a business purpose, including identifying the Personal Information categories that each category of recipient obtained.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you any 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA- permitted financial incentive that we offer will reasonable relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Exercising Your Access and Deletion Rights
To exercise your access and/or deletion rights, please submit a verifiable consumer request to us by:
- Visiting us at paylease.com
- Calling us at 858-281-6089
- Emailing us at firstname.lastname@example.org
Only you, or your authorized agent who you have authorized to act on your behalf, may make a verifiable request related to your Personal Information.
You may only make a verifiable request for access twice within a twelve (12) month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority (and/or your authorized agent’s identity or authority) to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use the personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.