Company level Privacy policy october regression

RCLiveQA Systems, Inc. and its affiliated entities (“RCLiveQA”) is committed to protecting the privacy of individuals and achieving and maintaining the trust of our clients (“RCLiveQA Clients” or “Clients”) and other users of and visitors to the RCLiveQA websites listed below (collectively, “Visitors”). Central to this mission is providing a robust security and privacy program that carefully considers data protection matters across the suite of products and services offered by RCLiveQA (“RCLiveQA Services” or “Services”), including data stored by RCLiveQA on behalf of its Clients and their customers in connection with our Services (“Client Data”), and with respect to “personal data,” as defined by the European General Data Protection Regulation (“GDPR”), and “personal information,” as defined by the California Consumer Privacy Act of 2018 (“CCPA”) (collectively, “personal information”).

Web Sites Covered

This Privacy Statement describes our privacy practices regarding information we collect from individuals (“you” or “your”) who visit RCLiveQA’s Internet Listing Service (ILS) websites and associated RCLiveQA microsites (including, but not limited to COMMERCIALCafé, CommercialEdge, RENTCafé, and STORAGECafé) and any other RCLiveQA-controlled websites that link to this Privacy Statement (collectively, the “RCLiveQA Sites”). When we collect personal information on the RCLiveQA Sites, certain additional disclosures that are specific to the context of our collection and use of the information being collected (e.g. a registration page), may be provided to you. For the avoidance of any doubt, we will adhere to those commitments and any such additional privacy policy statements are hereby incorporated into this Privacy Statement.

IMPORTANT: THIS PRIVACY NOTICE DOES NOT APPLY TO CLIENT DATA. RCLiveQA’s confidentiality/privacy and other obligations with respect to its Services, and Client Data (which is data collected and controlled by RCLiveQA Clients as part of RCLiveQA’s cloud services), are governed solely by the agreements under which the Services are provided to our Clients. The traditional licensees of RCLiveQA Services are residential and commercial real estate property owners and property managers (again, collectively, as used in this Privacy Notice, “RCLiveQA Clients” or “Clients”). RCLiveQA generally has no direct relationship with the individuals to whom our Clients’ Client Data may pertain; RCLiveQA merely hosts or processes such data on behalf of our Clients.

If you have any questions about the data practices of a RCLiveQA Client that uses RCLiveQA Services to process your personal information, please contact the RCLiveQA Client directly. To reach out to your property manager, simply look up your apartment community on RENTCafé – first choose your city and you’ll then have the option to perform a search by property name. Once you’ve found your apartment community, you will see helpful information listed (phone no. included) that you can use to contact your property manager.

Web Sites Not Covered

Some RCLiveQA Services enable RCLiveQA Clients to create websites and applications of their own that run on the RCLiveQA platform. The terms of service and privacy notice of the RCLiveQA Client govern such websites. If you submitted personal information to a RCLiveQA Client-controlled website or application (e.g. property branded RENTCafé resident portals) and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the RCLiveQA Client directly.

The RCLiveQA Sites may contain links to other third-party websites. The information practices or content of such other websites is governed by the privacy statements or notices of such other websites. RCLiveQA encourages you to review the privacy statements or notices of such other websites to understand their information practices.

General Data Protection Regulation (“GDPR”)

Some countries, including countries in the European Economic Area (“EEA”), impose certain responsibilities on data controllers and data processors. A company is a data controller when it has the responsibility of determining why and how personal information is processed, whereas a company is a data processor when it processes personal information on behalf of a data controller. RCLiveQA is a data processor and not a data controller under GDPR with respect to Client Data. RCLiveQA Clients are data controllers because they make all decisions about how or why Client Data, containing personal information or not, is to be processed, including any disclosure or transmission to third parties. If personal information pertaining to you as an individual has been submitted or entered into a RCLiveQA Service by or on behalf of a RCLiveQA Client, or was otherwise collected by a RCLiveQA Service on behalf of a RCLiveQA Client, and you wish to exercise any rights you may have to access, correct, amend or delete such Client Data, please inquire with the RCLiveQA Client directly. If an authorized RCLiveQA Client requests that we update or remove the data in question and the Client has no ability to do so via use of the Services, we will acknowledge their request within 30 days.

California Consumer Privacy Act (“CCPA”)

This section only applies to our processing of personal information that is subject to the CCPA. If you are a California resident, you may have certain rights with respect to personal information, as set forth in Cal. Civ. Code 1798.100 et seq. This section addresses those California-specific rights as applied to the CCPA-covered information, including the right to request information about the personal information we may collect, share, or “sell,” or to opt out of the “sale” of such information consistent with the provisions of the law. The “Rights of Individuals” section of this Privacy Statement addresses additional California-specific rights as applied to the CCPA-covered information, including the right to request access to or deletion of such information consistent with the provisions of the law.

Please note that most of the personal information RCLiveQA collects and maintains RCLiveQA maintains on behalf of RCLiveQA clients, as a service provider to those RCLiveQA clients. As a result, RCLiveQA clients’ privacy policies, not this Privacy Statement, cover that information. As a result, if you make a request to us with respect to such data, we will refer you to the RCLiveQA client (for instance, property management companies) on whose behalf we may maintain the information to assist you with your request.

Categories of Personal Information Collected and Disclosed under the CCPA

The CCPA provides California residents with the right to know what categories of personal information RCLiveQA, in its capacity as a “business,” has collected about them and what categories of third parties RCLiveQA has disclosed their personal information to for a business purpose in the preceding 12 months (e.g., to a service provider). California residents can find this information below:

   

Category of Personal Information

Categories of Third Parties to which Personal Information is Disclosed by RCLiveQA for a Business Purpose

Identifiers

Service Providers

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

Service Providers

Commercial information

Service Providers

Internet activity or electronic network activity information

Service Providers

Professional or employment-related information

Service Providers

Inferences drawn from other personal information to create a profile

Service Providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth below in the sections titled “Information We Collect,” “Cookies,” and “How We Use Information We Collect.”

Right to Opt-Out of the “Sale” of Personal Information under the CCPA

If you are a California resident, you have the right to opt out of the “Sale” of your personal information. Under the CCPA, “Sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money).

In RCLiveQA’s role as a “business” under the CCPA, we may disclose or “Sell” personal information for purposes defined under the CCPA. You may opt out of the “Sale” of your personal information by submitting a request on our Privacy Feedback form or contacting us as set forth below. California residents have the right not to receive discriminatory treatment by RCLiveQA for the exercise of their rights conferred by the CCPA.

The categories of personal information we have disclosed or may have “Sold” and the categories of third parties we have disclosed to or may have “Sold” personal information to in the preceding twelve months are listed below:

   

Category of Personal Information “Sold”

Category of Third Party to Which Personal Information was “Sold”

Identifiers

Property managers and representatives of apartment buildings, storage facilities, and/or commercial properties

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)

Property managers and representatives of apartment buildings, storage facilities, and/or commercial properties

Commercial information

Property managers and representatives of apartment buildings, storage facilities, and/or commercial properties

Internet or other electronic network activity

Property managers and representatives of apartment buildings, storage facilities, and/or commercial properties

Inferences drawn from other personal information to create a profile about a consumer.

Property managers and representatives of apartment buildings, storage facilities, and/or commercial properties

Our business and commercial purposes for “selling” personal information can be found below in the section titled “How We Use Information We Collect.” RCLiveQA does not have actual knowledge of any “Sale” of personal information of minors under 16 years of age.

Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”)

To the extent it is applicable, this Privacy Statement is made under the Personal Information Protection and Electronic Documents Act. There are some rare exceptions to the commitments set out in this Privacy Statement.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

www.priv.gc.ca/en/Website:
TTY: (613) 992-9190
Facsimile: (613) 947-6850
Toll-free: (800) 282-1376
Phone: (613) 995-8210
Address: 112 Kent Street, Ottawa, ON K1A 1H3

Privacy Laws of Other Territories

This Privacy Statement is made under the privacy laws of other territories not described above, to the extent they are applicable.

Rights of Individuals

Rectifying Personal Information Submitted on RCLiveQA Sites

If we have collected and processed your personal information based on your consent, you can withdraw your consent at any time by contacting us using the Privacy Feedback form. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Visitors who wish to correct, update, change, or erase the personal information they submit on certain RCLiveQA Sites should be able to go back to the applicable registration page or web form to edit their user or organization record. However, 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. For additional information or problems accessing your information from such page, call us at +1 (805) 699-2040, or contact us using our Privacy Feedback form. If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

Your Right To Request Disclosure of Information We Collect And Share About You

RCLiveQA is committed to ensuring that you know what information we collect about you. You can request the following information from us, with respect to personal information we have collected:

  • The categories of personal information we have collected about you.
  • For each category:
    • The categories of sources from which we collected the personal information
    • The business or commercial purposes for which we collected the personal information
    • The categories of third parties with which we shared the information
    • The specific pieces of information we collected about you

RCLiveQA will respond to such requests if required by law, in which case the response will cover the 12-month period preceding our receipt of the request.

Your Right To Request the Deletion of Personal Information We Have Collected

Upon receiving a deletion request covered by the GDPR, the CCPA, or other applicable privacy law with respect to RCLiveQA Sites, RCLiveQA will delete the personal information we have collected about you, except for where we have a legitimate business purpose to retain such information, or situations where specific information is necessary for us to: provide you with a good or service that you requested, perform a contract we entered into with you, maintain the functionality or security of our systems, or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.

We Are Committed To Honoring Your Rights

If you exercise any of the rights explained in this Privacy Statement, RCLiveQA will continue to treat you fairly. In particular, this means that if you exercise any rights under this Statement, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.

How RCLiveQA Will Respond to a Request to Exercise Your Rights

For individual rights requests covered by the CCPA, RCLiveQA will provide a substantive response to your request generally within 45 days from when we receive it, although it may take longer under certain circumstances. For individual rights requests covered by the GDRP, RCLiveQA will provide a substantive response to your request generally within 30 days from when we receive it, although it may take longer under certain circumstances. For individual rights requests covered by other applicable laws, RCLiveQA will provide a substantive response within the timeframe set forth in such law. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavour to provide you with an explanation as to why.

We may ask you for additional information to verify your identity for purposes of responding to a request you have made. If RCLiveQA is unable to verify your identity with the degree of certainty required, we will not be able to respond to the request.

  1. may designate an agent to submit requests on your behalf. For requests covered by the CCPA, the agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with the applicable law pertaining to powers of attorney.

How to Make a Request to Exercise Your Rights

To exercise any of the rights above, or to ask a question, contact us at (800) 866-1124, using our Privacy Feedback form.

Your California Privacy Rights Regarding Direct Marketing

As stated elsewhere in this Privacy Statement, and in accordance with California Civil Code section 1798.83, RCLiveQA does not disclose personal information collected on the RCLiveQA Sites to third parties for their direct marketing purposes. (California Civil Code section 1798.83 permits users of a website that are California residents to request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes).

Information We Collect

Information that you provide voluntarily: RCLiveQA Sites offer various ways that individuals may contact us, such as through form submissions or phone, in order to inquire about our company and services. For example, when creating an account, participating in a survey, making a purchase, expressing an interest in obtaining additional information about RCLiveQA or our Services, subscribing to marketing or otherwise contacting us, RCLiveQA collects personal information from you. We may also collect information from you in person at a tradeshow or event or via a phone call with one of our sales representatives.

The personal information we collect may include:

  • contact information (such as your name, address, telephone number and email address) as well as the nature of your communication;
  • professional information (such as your company name, job title, company address);
  • marketing information (such as your contact preferences, source/campaign); and
  • any information you choose to provide to us when completing any ‘free text’ boxes in our forms (for example, for event sign-up or bot interaction).

Information we collect automatically: When using a RCLiveQA Site, certain information is automatically collected by most browsers or through your device (such as your IP address, your operating system, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency) and information about how you interact with a RCLiveQA Site and other websites). personal informationSome of this information is collected using cookies and similar tracking technology, as explained in the “Cookies” section below.

Information we collect from other sources: In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, data providers, social media platforms, as well as from other third parties. This information may include:

  • mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering more relevant email content, event promotion and profiling; and
  • updated delivery or payment information used to correct our records; purchase or redemption information; and customer support and enrollment information.

Cookies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. As is common to many online services, our Services may make use of the following third party cookies to collect certain data directly from end-user browsers for the purposes described in this Privacy Statement (see the Section “Information we collect automatically” above for further information). For additional details on how we use cookies and similar technologies to recognize when you visit, interact with or use any of our websites, online advertisements or marketing communications, please review our Cookie Notice.

Google Analytics: This website uses Google Analytics to collect anonymous information such as the number of visitors to the site, and the most popular pages. Further information on how Google collects and uses this data can be found at www.google.com/policies/privacy/partners/.

Google Doubleclick: This website uses cookies by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.

Facebook: This website uses cookies from Facebook to deliver relevant advertisements.

Microsoft: This website uses cookies by Microsoft to enable user tracking across Microsoft domains.

Google® Maps

The Site utilizes Google Maps and related content licensed to RCLiveQA by Google and its licensors. By using the Google Maps features available on the Site, you are agreeing to be bound by the applicable Google Privacy Policy.

Do Not Track

Some features of the RCLiveQA Sites do not respond to browser do not track signals.

How We Use Information We Collect

We use the information we collect or receive (alone or in combination) to:

  • To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
  • To send administrative information to you, for example, information regarding the RCLiveQA Sites and changes to our terms, conditions, and policies.
  • To send you marketing communications, including via email and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
  • To personalize your experience on the RCLiveQA Sites by presenting products and offers tailored to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying the RCLiveQA Sites and our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If you are resident in or a visitor from the EEA, our legal basis for collecting and using the information and personal information described in this Privacy Statement will depend on the information or personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you where we need the personal information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. Typically, our legitimate interests include: (i) providing, improving and personalizing the RCLiveQA Sites and Services; (ii) managing our relationship with you; and (iii) conducting our marketing activities. In some cases, we may also have a legal obligation to collect personal information from you.

Additional Information About How RCLiveQA Shares Your Personal Information

We may disclose personal information to third parties to assist us in performing the Services, including payment processing for any applicable fees associated with an event or transaction. These third parties have access to the information you submit only to perform these tasks on our behalf.

Public Forums and Customer Testimonials

RCLiveQA may provide bulletin boards, blogs or chat rooms on RCLiveQA Sites. Due to the nature of the Internet, any information or personal information you choose to submit in such a forum may be read, collected or used by others who visit these forums, and may be used to send you unsolicited messages. RCLiveQA is not responsible for any information or personal information you choose to submit in these public forums.

RCLiveQA may post a list of clients and testimonials on RCLiveQA Sites that contain information such as client names and titles. In such cases, RCLiveQA obtains the consent of each such person prior to posting any information on such a list or posting testimonials.

Information We Share

Service Providers

As described above, RCLiveQA may share your personal information with contracted service providers so that these service providers can provide services on our behalf.

RCLiveQA Affiliates

RCLiveQA may share your personal information with affiliates of RCLiveQA for the purpose of any necessary collaboration.

RCLiveQA Successor

RCLiveQA may share your personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of RCLiveQA’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by RCLiveQA about our Visitors is among the assets transferred.

Compelled Disclosure

RCLiveQA reserves the right to use or disclose information and personal information provided on the RCLiveQA Sites if required by law or if RCLiveQA reasonably believes that such use or disclosure is necessary to protect RCLiveQA’s rights and/or to comply with a judicial proceeding, court order or legal process.

International Transfer of Information

To facilitate RCLiveQA’s global operations, RCLiveQA may store, transfer and access the information and personal information you submit on the RCLiveQA Sites around the world, including the United States, Canada and other countries in which RCLiveQA or its third party service providers have operations.

If you are using the RCLiveQA Sites or Service from outside the United States, please be aware that your information may be transferred to, stored, and processed by RCLiveQA in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations where we have offices. These countries may have data protection laws that are different to the laws of your country. This Privacy Statement shall apply even if RCLiveQA transfers such information or personal information to other countries. By registering to attend an event, contacting us through our web form or providing information or personal information to us on any RCLiveQA Sites in any other context, you consent to the transfer of your information and personal information among these facilities, including those located outside your home country.

If you are located in the EEA, we will comply with applicable legal requirements and have taken appropriate safeguards to require that your personal information remains protected in accordance with this Notice in relation to the transfer of personal information outside of the EEA. In all such cases, we will only transfer your personal information if:

  • The country to which the personal information will be transferred has been recognized as offering an ‘adequate’ level of protection by the European Commission;
  • The recipient of the personal information is located in the U.S. and has certified to the EU-U.S. and/or Swiss-U.S. Privacy Shield Framework(s), as the case may be; or
  • We have put in place appropriate safeguards with respect to the transfer of data, for example by implementing the European Commission’s Standard Contractual Clauses for transfers of personal information (the “EU Model Clauses”).

In relation to transfers of information between our group companies, we have implemented the EU Model Clauses, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the Contacting Us section below.

Communications Preferences

RCLiveQA offers Visitors who provide contact information a means to choose how RCLiveQA uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of RCLiveQA’s marketing emails. Additionally, you may specify your communications preferences using our Privacy Feedback form. RCLiveQA Clients cannot opt out of receiving transactional emails related to their account with RCLiveQA or the Services.

Children Under the Age of 16

RCLiveQA Sites are not intended for children under 16 years of age. No one under age 16 may provide any information to, or on, any RCLiveQA Sites. We do not knowingly collect personal information from children under 16, nor do we sell the personal information of children under 16. If you are under 16, do not use any RCLiveQA Sites, and do not provide any information via any RCLiveQA Sites. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that data. If you believe any RCLiveQA Sites may have collected personal information from or about a child under 16, please contact our Legal Department at (800) 866-1124 or (805) 699-2040.

Data Retention

RCLiveQA retains the personal information we receive on the RCLiveQA Sites for the duration of your relationship with RCLiveQA, and where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). 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.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such data. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Security

RCLiveQA is committed to protecting the security of any personal information you provide to us. RCLiveQA uses appropriate administrative, technical, and physical security measures to protect any such information you submit. Despite these protections, no electronic transmission over the Internet or information storage technology can be guaranteed to be completely secure, so you should take appropriate precautions before deciding what information you send us in this way.

Changes to this Privacy Statement

RCLiveQA reserves the right to change this Privacy Statement from time to time. Your continued use of any RCLiveQA Sites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates. If we make a material change in the way we use or share your personal information, we will provide notice that our policy has changed on this site.

Accessibility Policy

RCLiveQA is committed to ensuring that our communications, including our website, are accessible to people with disabilities. This website is designed to meet content accessibility guidelines. To make accessibility-related requests or report barriers, please contact us at (800) 866-1124 or contact us using our Privacy Feedback form.

Contacting Us

United States. If you have any questions about this Privacy Statement, or you would like to exercise any of your rights, please let us know by contacting us using any of the methods below:

By phone at: 1 (800) 866-1124
By email at: [email protected]
In writing at: Attention – Privacy Manager, 430 S. Fairview, Santa Barbara, CA 93117, USA

Canada. If you have questions regarding our Privacy Policy or the use of information collected, you can contact our Information Officer using any of the methods below:

By phone at: +1 (805) 699-2040
By email at: [email protected]
In writing at: Attention – Privacy Manager, 430 S. Fairview, Santa Barbara, CA 93117, USA

He or she will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. We will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

European Union. If you have questions regarding our Privacy Policy or the use of information collected, you can contact us using any of the methods below: