THE SITE IS NOT INTENDED FOR CHILDREN AND Town Commons DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF Town Commons LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO Town Commons THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).
TYPES OF INFORMATION COLLECTED
We collect two types of information: personally identifiable information and non-personally identifiable information. Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”). We also may collect information that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), user Internet Protocol (IP) addresses, browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data, information about you such as how you use the Site and your communication preferences, and other anonymous statistical data involving the use of our Site (“Non-Personally Identifiable Information”).
Personally Identifiable Information we collect may include your name, email addresses, postal addresses, ZIP codes, social security number, driver’s license number, prior addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name and password (if you choose to become a registered user of the Site or our products and services), emergency contact information, information about your pets, information about your vehicles including license plate numbers, and other information either desirable or necessary to provide quality services to our customers and visitors. We may also collect information about you such as your use of the Site and communication preferences.
You may choose not to provide your Personally Identifiable Information by not entering it on the Site; however you will not be able to use certain services and features if those services and features require Personally Identifiable Information in order to function.
How We Collect and Use Information
We may collect information in several ways by your use of this Site, as well as from forms you submit to us, personal correspondence, such as emails or letters that you send to us, information you include in an application you complete on the Site, information you provide when scheduling a property visit through the Site, or any other activity through which you identify yourself to us. When you visit the Site, our servers may log your IP address, the URL of your request and other information that is provided in the HTTP header. We may also ask you to voluntarily provide us with personal information on this Site: for example, while many of the features of the Site are available without registering, you may be asked to create an account on the Site if you desire to access certain features. Further, in some instances, we may ask you to provide personal information in order to perform screening services for property managers or owners. Although you may decline to voluntarily provide Personally Identifiable Information when asked, some features, products and services will be unavailable to you as a result.
If you choose to use the Refer a Friend email link to tell a friend about our site or a property listed on our site, we will ask for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Town Commons stores this information for the sole purpose of sending this one-time email (and tracking the success of our referral program).
To the extent we are able to do so, we may link your Non-Personally Identifiable Information with your Personally Identifiable Information. We may also link information collected online with information we collect offline or collected online by third parties.
Town Commons may use the information collected from you to provide services which you have requested from us: including, without limitation, sending your contact information to properties that you are interested in; sending your rental application to properties that you have selected; and enabling you to use the Resident Portal. We may also use your personal information to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits. Town Commons may use third-party service providers to send and distribute e-mail and to perform other marketing and support functions. We may use information we collect from you to improve the content of this Site, to enhance users’ experiences when visiting this Site, to analyze trends, administer the Site, gather demographic information the Site’s users, track user movements and to customize the content and layout of this Site for each individual user.
Sharing of Information COLLECTED
We also may share with third parties, including, without limitation, our corporate partners, aggregated demographic and statistical information that is not personally identifiable (including, for example, the number of users who searched for certain types of housing, the daily number of unique visitors to the Site, how many users clicked on a particular advertisement and how many users were using a certain internet service provider).
Town Commons also may disclose an individual’s personal information:
To a person who in the reasonable judgment of Town Commons is seeking the information as an agent of the individual.
In situations where sharing or disclosing your information is required in order to offer you products or services you desire; To a third party or parties, where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process.
Through the Site, Town Commons may make available areas that allow for user interaction, including blogs, forums, bulletin board services, chat areas, or other message and communications features. Some of these forums may require registration. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information.
How We Store Your Information
Town Commons is committed to protecting the security of any personal information you provide to us. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. In spite of these protections, Town Commons cannot guarantee the security of any data submitted over the Internet. After your information reaches Town Commons, however, it is stored on servers (or in the case of information received from you in person, in writing or over the phone, in physical storage areas) protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process your personal information in the United States or Canada or any other country in which we or our agents maintain facilities. By using the Site, you consent to the transfer of your information among these facilities, including those located outside your home country.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
In order to provide you with the products and services you request, answer questions you may have about the products and services provided, and for our own accountability to external regulatory bodies, we retain your information for a period deemed reasonable under the circumstances. Information stored in client and contact directories are more difficult to systematically destroy, so we remove such information from time to time when it appears we will no longer have a need to contact you, however we will promptly remove such information upon your written request. Paper files containing personal information are destroyed by shredding, and we destroy electronic information by deleting it. When we discard hardware that was used to store data, we ensure that the data is completely and permanently erased or that the hardware is physically destroyed.
ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION
You can see, review and change most of your personal information by logging into your account on the Site and editing your Account Profile or by contacting us at the addresses below. If your personal information changes or is inaccurate, you must change it promptly. If we disagree that certain information is incorrect, we will include a brief statement from you on the discrepancy and, if you want us to, we will forward your brief statement on your behalf to anyone who received the information from us.
In some instances, where requested by you and the Property Manager, we will use your personal information to conduct a screening process and/or produce a screening report or provide your information to a screening company in order to obtain a screening report for the Property Manager. The screening report may include credit information. Under the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), you may have the right to access, view and correct credit information relating to you held by a credit bureau by contacting the credit bureau.
There may be circumstances where your personal information is not accessible, reviewable or able to be modified by you through your Site account. With some exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you and we will also try to help you understand any information you do not understand (such as abbreviated data or technical language). We may need to confirm your identity before providing you with this access, and we reserve the right to charge a nominal fee for such requests. In some cases, we may require that your request to us for access be made in writing. If we cannot give you access, we will tell you within 30 days or as soon as reasonably practicable and provide you with a reason, as best we can, as to why we cannot give you access.
If we collected personal information on behalf of a third party we may have conveyed that information directly to the third party. If so, it may not exist as part of our own records and you will have to go to the third party to see the information.