Privacy Policy

Last updated March 27, 2020

Introduction

This Privacy Policy sets out the privacy practices of The ConAm Group of Companies and its affiliates (“ConAm”, “Company”, “our”, “we”, or “us”) in relation to information that we may collect about you in the circumstances listed below.  This Privacy Policy is in addition to our Terms and Conditions.  

·       When you visit this domain, or any associated URLs owned or controlled by ConAm (collectively, the “Website”) or access our applications (“Apps”), and any content or features available on the Website or Apps;

·       Offline, in our interactions we may have with you;

·       When you apply for a job with ConAm;

·       In email, and through other electronic messages between you and us through the Website and Apps;

·       When you interact with our advertising and Apps on third-party websites and services, if those advertising or Apps include links to this Privacy Policy.

This Privacy Policy does not apply to information we collect in your capacity as an employee or contractor of ConAm. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By providing your information to ConAm either through the Website or otherwise, you signify that you consent to the use of information about you in accordance with this Privacy Policy, as posted here. If you do not agree with any term in this Privacy Policy, you should not access and use the Website or Apps and please do not otherwise provide us with any information about you.

The Privacy Policy may change from time to time. If we make changes, we will notify you, obtain your consent and take any other such measures as required by applicable law.

Information We Collect About You and How We Collect it

Information You Provide to us:

We collect information about you as follows:

·       By filling in forms on our Website or Apps including information you upload to our Website and information you provide at the time you register to use our Website or Apps, subscribe to our services or request further services;

·       When you communicate with us through any means or engage in any transaction on our Website or Apps;

·       When you have questions about or report a problem with our Website or services;

·       When inquiring about or applying for a job at ConAm;

·       When dealing with ConAm in your capacity as an investor or potential investor;

·       When engaging in search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies:

In addition, as you navigate through and interact with our Website or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please read below (Do Not Track) for information on how you can opt-out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data, however, it may include information about you, and we may maintain it or associate it with information about you that we collect in other ways or receive from third parties.

Technologies we use include:

Cookies (or browser cookies). A cookie is a small file that may be used, for example, to collect information about the Website and your browsing activity.  You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Specific information about how we use such technologies and how you can refuse certain cookies is set in our Cookie Policy.

Web Beacons. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, verifying system and server integrity).

Information Received from Other Sources

We may obtain information about you from other sources, such as public databases, social media platforms (Such as Facebook, Twitter, Instagram) as well as from other third parties, including affiliates and vendors. We are not responsible for the privacy practices of third parties and encourage you to read and understand how any third party or social media platform may use and share information about you. 

We do not purchase any information about individuals to perform targeted advertising or provide any special offer to customers.

Categories of information collected

We have in the last 12 months collected information about you via the means set out above:

·       Name, postal address, home address (current and previous), age or date of birth, email address, telephone number, number of children, vehicle information including license plate number, your occupation, employment information, education, driver’s license number, passport number, military ID, social security number or other tax or national identification number, information related to properties which you would like further information, or project;

·       Social Media Profile Information (Your name, gender, birthday, email, current city, state and country, user identification number for your contacts, profile picture URL, and any other information that you choose to make public);

·       Marketing leads and search results and links, including paid listings (such as sponsored links);

·       Any information you may submit to us in correspondence, using any means of contact.

In certain instances, we may need to collect additional or more detailed information.  In addition to the above categories of information, we have collected information about you in the last 12 months in the following contexts:

As an investor, we collect information about your assets, your income, transactional activity in your account, information about your product and service needs, investment experience, bank account details, wire transfer instructions, investor profile, details from passports or other government-issued documents including social security numbers or EIN’s, and authentication information for access to your account;

As an applicant to or member of an apartment community, we collect information about the property that you have purchased, leased or rented, your income, your creditworthiness, utility account information, any other tenants that you may wish to include on the lease, information about any pets, bank account details, maintenance requests, bank account details, credit card information, emergency contact and next of kin.

As a visitor to our Website or App user, we have collected details of your visits to our Website, traffic data, clickstream data, location data, logs and other communication data, the resources that you access and use on the Website such as your IP address, internet service provider, operating system and browser type;

As a job applicant, we have collected information we need to handle your application including your ability to legally work in the country for which you are applying for employment, information regarding your qualifications, references, professional licenses or resume information, personal and family details, criminal history (as permitted by law), medical and health screening details, and information with respect to career commencement and development including date of hire, employee category and full-time or part-time status.  Where permitted by applicable law, you will be given the opportunity to provide information on your gender, race, or ethnicity. We may gather this information from you for reporting and record-keeping requirements, but we will only use this information in accordance with applicable law and will not use it in making any employment decisions. Providing this information is strictly voluntary, and you will not be subject to any adverse action or treatment if you choose not to provide it. Such information will be kept in a confidential file separate from your application for employment.

How We Respond to Do Not Track Signals

Some web browsers may let you enable a “Do Not Track” feature that sends signals to the Website you visit, indicating you do not want your online activities to be tracked or engaged in other types of data collection. These are segments of computer code that communicate with a Website similar to cookies. However, this is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. This Website does not currently honor “Do Not Track” requests. If we do so in the future, we will describe how in this Privacy Policy.

How We Use Your Information

Below are the ways that we use information about you:

Offerings and Services that Interest you:

·       When you visit or do business on our Website;

·       When you make submissions to us;

·       When you request information from us;

·       Employment opportunities beyond the position you may have applied for;

·       When you contact us.

Marketing Communications  

·       To track our visitors' use of the Website for internal market research;

·       To improve the Website and the services ConAm promotes or provides through the Website or through other means;

·       To customize the content and/or layout of our Website for each individual visitor;

·       To notify you about updates to the Website or services;

·       Contact you about jobs that may be of interest to you;

·       Contact you about investments that may be of interest to you.

Professional Interactions – Customer Relationship Management

·       To communicate with you over phone or email;

·       To complete any leasing process;

·       To request a credit report in connection with leasing or job applications;

·       To process job applications;

·       To contact you in response to your inquiries, comments, and suggestions;

·       To contact you otherwise when necessary;

·       To complete any transactions you may perform at the Website;

·       To use certain de-identified and aggregated data for data analytics;

·       Document and report accidents, injuries and incidents;

·       To provide better service to customers.

Other Uses:

·       To develop and display content and advertising tailored to your interests and to measure its effectiveness;

·       To improve our Website and deliver a better and more personalized service, including by using information collected automatically to estimate our audience size and usage patterns, speed up your searches and recognize when you return to our Website;

·       To ensure safe and guaranteed services performance to you, upgrade and improve functionality of the services;

·       To store this information in aggregated and anonymized form so that it is not associated with any individual;

·       As otherwise permitted or required by law.

Third Parties with Whom We Share Your Information   

We share, and have shared over the last 12 months, information collected about you with selected third parties for our business purposes.  The categories of recipients (which maybe updated from time to time) include third party vendors, service providers, affiliates, contractors or agents who perform services for us or on our behalf and require access to such information to do that work, such as  IT service providers, organizations providing background checks, DMV record checks, and income verification, cloud service providers, application service providers, utility billing, marketing, advertising and communications agencies, auditors and tax professionals, payment processors, and data analytics providers.                                    

We also share information about you in the following contexts:

·       Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of the business to another company, resulting in a change of control of your information;

·       Employment Offers:  If you apply for employment with ConAm, some of the information you provide through our Website and services will be transferred into our internal human resources and related systems for use processing your application, which may involve sharing your information with select third parties for related purposes, including credit and background checks.  If you are offered and accept a position with us, some of the information you provide through our Website and services will be transferred into our internal human resources and related systems for use during your employment. By using our Website and services, you agree to such a transfer and use of your information;

·       Apartment Community: We may share or transfer your information in instances where you have an apartment community managed through ConAm or an application to lease an apartment managed by ConAm, including to:

o   Process your application, including credit and background checks;

o   Generate legal documents (e.g., lease paperwork, addendums, legal notices);

·       Allow websites to allow for online payments, communication, package tracking and maintenance request management;

·       Process and collect funds associated with payments (e.g., checks or money orders);

·       Generate utility billing and utility statements;

·       Engage in occupancy tracking and reporting;

·       Record interactions and communications during and after the leasing process;

·       Assist in collecting debts

Other Times: We may share information about you when we believe in good faith that such release is necessary to comply with law or legal process, including laws outside your state or country of residence; to protect our rights, property, or safety of our employees. 

Can I Opt-Out of Email Marketing?

Opt-out of email marketing: You can unsubscribe from our marketing emails at any time by clicking on an unsubscribe link in the emails that we send or by contacting us using the form provided at https://sq1compli.conam.com/sar if the link is not included in the marketing email you received. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. 

Is Your Information Transferred Internationally?

While you may be able to set up an account while located outside the United States, we do not operate outside the United States, in particular, we do not operate in the European Union or provide services or products to the European Union residents.  Our Website, Apps, and all of our data, including any information about you, are hosted on servers located in The United States. If you are using or accessing our Website or Services from outside of the United States, please be aware that your information will be transferred to, stored, and processed in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction. 

Is My Information Safe?

Please remember that we cannot guarantee absolute security as the Internet and methods of online transmission are not 100% secure. Transmission of information to and from our services is at your own risk. You should only access the services within a secure environment.

Do We Collect Information from Minors?  

Our Website and Apps are not directed to children under the age of 13. We do not knowingly collect information from children under the age of 13, nor do we knowingly distribute such information to third parties. If you are under 13, please do not give us any information about you.  If you believe that a child under the age of 13 has provided us with their information, please contact us as provided for below and we will seek to delete the information in our possession.

How Does the California Consumer Privacy Act Apply?

This section provides additional information in relation to any information we collect that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household (“Personal Information” under the California Consumer Privacy Act of 2018 (“the CCPA”)). 

Collection, Use and Disclosure of Personal Information

Over the last 12 months, we have collected the categories of Personal Information from California residents as set out in section 2 above and disclosed Personal Information for a business purpose as set out in section 4 above.  We may use or otherwise disclose Personal Information for the purposes set out above. 

ConAm does not sell Personal Information, as that term is defined under the CCPA. 

Rights

Where applicable, and subject to certain exceptions, you may have the following rights under the CCPA in relation to Personal Information that we have collected about you.  These rights are, to the extent required by the CCPA and subject to verification and any applicable exceptions:

 · Right to Know/Access: You may have the right to request that we disclose certain information to you about our collection and use of certain Personal Information about you as described below:

o   the specific pieces of Personal Information collected;

o   the categories of Personal Information collected;

o   the categories of sources from whom the Personal Information is collected;

o   the purpose for collecting the Personal Information; and

o   the categories of third parties with whom we have shared the Personal Information.

· Right to Delete: You may have the right to request that we delete the Personal Information.

·Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of the rights above.

In addition to the CCPA, California’s ‘Shine the Light’ law permits California Residents to request, once a year and free of charge, certain information regarding our disclosure of information about you to third parties for their direct marketing purposes. 

To make a request in relation to the rights described above, please use the contact information in section 10:

We will need to verify your identity prior to addressing your request.  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to Personal Information collected about you.  To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.  You may only make a verifiable consumer request for access twice within a 12-month period. 

Contact Us

If you have any questions about this Privacy Policy and our privacy practices, please contact us at:

Internet by completing the form accessible at https://sq1compli.conam.com/sar

Telephone +1 858 614 7200

Mail The ConAm Group of Companies,

3990 Ruffin Road,

San Diego, CA 92123