CONSUMER PRIVACY POLICY Last Updated: December 23, 2019 

INTRODUCTION 

Woodmont Real Estate Group (“we” or “us” or “our”) respects the privacy of consumers consistent with the requirements of the California Consumer Privacy Act of 2018 as amended (“CCPA”), including users of our website and those who contact us electronically, telephonically or in person in connection with the potential or actual rental of a housing unit and/or related services and opportunities (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.wres.com including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) or provide us with personal information by other means. Please read this Privacy Policy carefully.  If you do not agree with the terms of this Privacy Policy, please do not access the Site, telephone us in response to an advertisement or provide us with any personal information electronically, telephonically, in person or by any other means.  

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy.  Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.  

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site or provision of personal information after the date such revised Privacy Policy is posted.   

CATEGORIES OF PERSONAL INFORMATION COLLECTED 

We may collect personal information about you in a variety of ways. The personal information we may collect on the Site or when you communicate with us about a potentially available rental housing unit, or when you apply for or rent a housing unit includes the following categories of personal information.  The sources from which the information is collected is also identified below. 

Personal Data  

Personally identifiable information, such as your real name, alias, postal address, email address, telephone number, social security number, driver’s license number, passport number, or other similar identifiers, professional or employment-related information, including income, and education information that you voluntarily give to us when you contact us regarding a rental housing unit, apply for a rental housing unit, rent a rental housing unit, register with the Site, or when you choose to participate in various activities related to the Site, such as contact forms, availability and pricing inquiries, online chat and message boards, electronic payments, and/or request or access services relating to a rental housing unit. 

You are under no obligation to provide us with personal information of any kind on the Site; however, your refusal to do so may prevent you from using certain features of the Site or prevent us from communicating with you.  Some categories of personal information will be required if you decide to apply for or rent a rental housing unit which we manage (See Data Relating to Application for or Rental of a Housing Unit below). 

In addition to your voluntarily providing this information, telephonic marketing systems and computer servers may collect personal contact information such as your name, email address and telephone number for marketing purposes.  

Derivative Data  

Information our servers automatically collect when you access the Site, such as aliases, unique personal identifier, online identifier Internet Protocol address, your browser type, your operating system, your access times and interaction with the Site, your browsing history, such as the pages you have viewed directly before and after accessing the Site, and geolocation data. 

Data Relating to Application for or Rental of a Housing Unit 

In addition to the Personal Data described above, if you decide to apply for or rent a rental housing unit at a property we manage, we may also collect personal information bearing on your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living from a consumer reporting agency subject to regulation under the Fair Credit Reporting Act.  Such information is not subject to the provisions of this Privacy Policy or the CCPA so long as it is not used, communicated, disclosed or sold except as authorized by the federal Fair Housing Act. 

We may also collect information from public records such as past eviction actions, prior landlords or similarly-situated individuals, which information may help us ascertain the likelihood that you will comply with the terms of your lease agreement and applicable laws.

Aggregate Information  

We may collect and track the total number of visitors to the Site, the number of visitors to each page of the Site, Third Party Web Sites (defined below) linked to and other aggregated data collected through our services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information.  We may use such information for purposes such as analyzing trends, administering the Site, and to understand how users interact with the Site.

USE OF YOUR INFORMATION  

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  Specifically, we may use information collected about you via the Site, telephonically or in person to:  

• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions, the Site and properties we manage to you.  

• Allow you to access amenities, Site features and request service. 

• Assist law enforcement and respond to subpoena. 

• Compile anonymous statistical data and analysis for use internally or with third parties.  

• Create and manage your account. 

• Email you regarding business-related communications. 

• Enable user-to-user communications. 

• Generate a personal profile about you to make future visits to the Site or interactions with our team members more personalized. 

• Increase the efficiency and operation of the Site. 

• Monitor and analyze usage and trends to improve your experience with the Site. 

• Notify you of updates to the Site. 

• Offer new products, services, and/or recommendations to you. 

• Perform other business activities as needed. 

• Provide electronic payment alternatives. 

• Request feedback and contact you about your use of the Site.  

• Resolve disputes and troubleshoot problems. 

• Respond to product and customer service requests. 

• Send you a newsletter. 

• Solicit support for the Site. 

DISCLOSURE OF YOUR INFORMATION 

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:   

By Law or to Protect Rights  

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction. 

Third-Party Service Providers  

We may share your information with third parties that perform services for us or on our behalf, including third-party utility billing providers, package/locker service providers, insurance trackers and brokers, valet trash providers, concierge service providers, cable companies, payment processing, data analysis, email delivery, in-person delivery, hosting services, customer service, and marketing assistance.   

Marketing Communications 

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law. 

Third-Party Advertisers  

We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.  

Affiliates  

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. 

Business Partners  

We may share your information with our business partners to offer you certain products, services or promotions.  

Other Third Parties 

We may share your information with advertisers, owner(s) of the rental housing unit(s) in which you showed interest or rented, and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law, including cable companies, insurance companies, phone companies, internet service providers and the like.  

Sale or Bankruptcy  

If we, or the owner of the rental housing unit(s) in which you expressed interest, reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we or the property owner go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy. 

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly. 

TRACKING TECHNOLOGIES 

Cookies and Web Beacons 

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons; however, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. 

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. If we use cookies, information on how we use cookies, will be contained in the Cookie Policy posted on the Site, which is incorporated into this Privacy Policy.  

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings. 

Internet-Based Advertising 

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives.  This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. 

Website Analytics  

We may also partner with selected third-party vendors, such as Google Analytics, and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors; however, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor’s site. 

THIRD-PARTY WEBSITES 

The Site may contain links to third-party websites and applications of interest, including property sites, advertisements, service providers, job boards, and external services, that are not hosted by us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site. 

SECURITY OF YOUR INFORMATION 

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. 

POLICY FOR CHILDREN 

We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests.  Neither the Site nor our services are intended for children under the age of 18. We do not target our services or this Site to children under 18. We also do not knowingly collect personally identifiable information from children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.  

CONTROLS FOR DO-NOT-TRACK FEATURES   

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.  

OPTIONS REGARDING YOUR INFORMATION 

Emails and Communications 

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by contacting us using the contact information provided below. 

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.  

CALIFORNIA PRIVACY RIGHTS The CCPA, codified at California Civil Code Section 1798.100 et seq., permits our users who are California residents to request and obtain from us, no more than twice in a twelve-month period and free of charge, information about:  (1) the categories of personal information we collected about the user, (2) the categories of sources from which the personal information is collected, (3) the business or commercial purpose for collecting the personal information, (4) the  categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information we collected about you. Information will be provided within 45 days of receiving a verifiable consumer request. 

In the preceding 12 months, we have collected the personal data referenced above, which has been used and disclosed in the manner described above and for the purposes described above.  

The CCPA defines “selling” and “sold,” to mean “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” Cal. Civ. Cod § 1798.140(t). Some of the disclosures identified above may be considered “selling” under this definition.  You have the right, at any time, to direct us not to sell your personal information.  This right is referred to as the right to opt-out.   

If you are a California resident and would like to make a request for disclosure or exercise your right to opt-out, please submit your request by using the contact information provided below, which includes two or more designated methods for submitting requests for information including a toll-free telephone number, although we would encourage you to make your request in writing via either electronic or U.S. mail. We will not discriminate against you for exercising any of your rights under the CCPA.  

In addition, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

CONTACT US 

If you have questions or comments about this Privacy Policy, or wish to make any requests with respect to your personal information, please contact us at: 

Woodmont Real Estate Services Attn:  Privacy Policy Administrator 1050 Ralston Avenue  Belmont, CA  94002 privacy@wres.com 833-906-2156 www.wres.com

You may also view the RealPage Privacy Policy Here.