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Privacy Policy

Effective Date: January 1, 2023


Legacy Property Management California Inc is committed to providing clear and concise information regarding our collection and processing of personal information. By accessing our website or utilizing Legacy Property Management California Inc software services (collectively, “Legacy Property Management California Inc Services”), you consent to the information collection and handling practices outlined in this policy.


I. Personal Information Collection

Legacy Property Management California Inc collects and processes personal information as a service provider to property owners and management companies (collectively, “Clients”). This personal information includes a broad range of data elements and may pertain to Clients’ residents, prospective renters, current and prospective Clients, and Client employee end users of Legacy Property Management California Inc Services.

In particular, Legacy Property Management California Inc Services have collected the following categories of personal information from our Clients regarding their residents, prospects, and/or employee end users within the last twelve (12) months.

  

II. Personal Information Exceptions

Personal information does not include:

  • Publicly      available information from government records.
  • De-identified      or aggregated consumer information.
  • Information      excluded from state privacy law scope, like:
    • health or       medical information covered by the Health Insurance Portability and       Accountability Act of 1996 (HIPAA); and
    • personal       information covered by certain sector-specific privacy laws, including       the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA)       or California Financial Information Privacy Act (FIPA), and the Driver’s       Privacy Protection Act of 1994.


III. Personal Information Sources

Legacy Property Management California Inc collects the categories of personal information listed above from the following sources:

  • Resident and  prospective renter personal information is collected (i) from      Clients’ residents during enrollment in or utilization of Legacy Property      Management California Inc Services offered on behalf of Clients, (ii) from      Clients via direct input into Legacy Property Management California Inc      Services or integration with Client software systems and third-party      service providers, and (iii) indirectly from credit reporting      agencies/bureaus, payment processors/gateways/banks, and website analytics      services integrated with Legacy Property Management California Inc      Services.
  • Client and  Client employee end user personal information is      collected (i) from Client’s employees during setup of Legacy Property      Management California Inc Services user accounts, and (ii) from Client      during activation and implementation of Legacy Property Management      California Inc Services.


IV. Personal Information Use & Processing

In providing the suite of Legacy Property Management California Inc Services, Legacy Property Management California Inc primarily acts as a service provider under contract to our Clients1. As a service provider, Legacy Property Management California Inc does not control any of the personal information we process on behalf of our Clients. Our Clients collect and control all such personal information, and Legacy Property Management California Inc is required to provide our products and services in accordance with Clients’ contractual provisions and instructions regarding data collection, privacy, processing, and security. Where Legacy Property Management California Inc is providing services as a data controller, a separate privacy policy is provided exclusively for such services at the point of data collection.

Accordingly, we may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill the purpose for which the personal information was collected and provide the requested Legacy Property Management California Inc Services.
  • To integrate with services offered by Legacy Property Management California Inc or third-party service providers contracted by Clients.
  • To distribute communications and legally required notices regarding the status of Legacy Property Management California Inc Services via phone, email, and SMS      text.
  • To provide Legacy Property Management California Inc Services maintenance, enhancement, research, development, security, support, and website optimization.
  • To maintain compliance with federal and state laws related to software-as-a-service, background screening, financial institutions, and money services businesses.
  • To create, maintain, customize, and secure Legacy Property Management California Inc Services user accounts.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Legacy Property Management California Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Legacy Property Management California Inc is among the assets transferred.

Legacy Property Management California Inc will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Additionally, Legacy Property Management California Inc processing of sensitive personal information is limited to activities necessary for the delivery and performance of Legacy Property Management California Inc Services on behalf of our Clients and end users.


V. Personal Information Disclosure

Legacy Property Management California Inc does not sell personal information collected through Legacy Property Management California Inc Services, and no such disclosure has occurred in the prior 12 months.

Legacy Property Management California Inc may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors that support or integrate with the Legacy Property Management California Inc Services described in this statement (see chart below). Legacy Property Management California Inc only discloses personal information to the extent reasonably necessary to support Legacy Property Management California Inc Services requirements, or for the third-party vendors or service providers to perform the services on our or our Clients’ behalf. We do not permit third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request of them. However, please note that Legacy Property Management California Inc does not maintain direct control over the privacy policies and practices of Clients or any other third-party companies, agents, or contractors.

  

VI. Personal Information Rights and Choices – State Privacy Rights

Certain state jurisdictions (California, Virginia, Colorado, Connecticut, and Utah) provide their legal residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with statutory guidelines. This section describes your rights and explains how to exercise those rights.


Accessing and Updating 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 Legacy Property Management California Inc Services account or contacting your property manager. If you require verification that your requested changes have been completed, and such verification is not readily displayed in your Legacy Property Management California Inc Services account, you may request confirmation at the email address listed below (See “Contact Us”).


Access to Specific Information Regarding Personal Information Use/Disclosure and Portability

You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. Under most circumstances, this request for disclosure should be submitted to the property manager that operates your apartment community or rental property. As stated above, Legacy Property Management California Inc is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.

However, if you have a direct relationship with Legacy Property Management California Inc, consumer requests should be submitted directly to Legacy Property Management California Inc via the approved channels listed in Section VII below.

In response to a verifiable consumer request for these services, we will disclose the following information for the applicable Legacy Property Management California Inc Services:

  • The categories,      specific types, and sources of personal information we collected about      you.
  • Our business      purpose for collecting the personal information.
  • The categories      of third parties with whom we share that personal information and the      purpose for the disclosure.

You also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, Legacy Property Management California Inc may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.


Deletion of Personal Information

You have the right to request that Legacy Property Management California Inc delete any of your personal information that we collected and retained, subject to certain exceptions. Under most circumstances, this request for deletion should be submitted to the property manager that operates your apartment community or rental property. As stated above, Legacy Property Management California Inc is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.

However, if you have a direct relationship with Legacy Property Management California Inc, consumer requests should be submitted directly to Legacy Property Management California Inc via the approved channels listed in Section VII below.

Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:

We may deny your deletion request if retaining the information is necessary for Legacy Property Management California Inc or our service providers to:

1. Complete the transaction for which we collected the personal information, provide the Legacy Property Management California Inc Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug Legacy Property Management California Inc Services to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or our Clients.

7. Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.

8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


VII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights


Under most circumstances, consumer requests should be submitted to the property manager that operates your apartment community or rental property. As stated above, Legacy Property Management California Inc is merely a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.

However, if you have a direct relationship with Legacy Property Management California Inc, consumer requests should be submitted directly to Legacy Property Management California Inc. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at:      949-495-4674

OR

  • Email us at:      info@LegacyPropManagement.com

  

Only you (or someone legally authorized to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to confirm your identity as the      person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.


VIII. Consumer Request Responses and Timelines

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please info@LegacyPropManagement.com. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account where possible. If you do not have an account with us, or your existing account lacks a communication feature, we will deliver our written response to your designated email address.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  

IX. Personal Information Sales and Sharing – Opt Out Rights

Legacy Property Management California Inc does not sell personal information collected through Legacy Property Management California Inc Services, and no such activity has occurred in the prior 12 months. In the event that Legacy Property Management California Inc changes its practices and engages in the sale of personal information as regulated by law, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with regulatory requirements.

  

X. Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law, we will not engage in any of the following practices in response to your exercise of privacy rights:

  • Deny you 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.


XI. Other California Privacy Rights

The State of California also grants California residents privacy rights via laws unaffiliated with the CCPA/CPRA. Those rights include the following:

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@LegacyPropManagement.com.


XII. Cookies, Web Beacons, and Other Technologies – Do Not Track

When you access Legacy Property Management California Inc Services or our website, our servers may place small text files (“cookies”) on your computer for recordkeeping purposes. Among other things, cookies enable us to gather information about your activity on our website for the purposes of improving your online experience, establishing secure user accounts, remembering your preferences and settings, and for other similar customization purposes.

In addition to cookies, the Legacy Property Management California Inc Services and our website may utilize web beacons, clear gifs, or other technologies to gather information on how users interact with and utilize various features. For example, these technologies can identify popular pages, viewing patterns, click-through, conversion rates, and other information that can be used to improve, monitor, and operate our websites, products, and services.

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers, and our sites are not currently set up to respond to those signals. Most internet browsers provide controls that allow users to directly manage or disable the placement and usage of cookies on their computer. Please note that disabling cookies may deactivate or otherwise restrict certain features on Legacy Property Management California Inc Services or our website.

  

XIII. Third Party Links to Other Sites

 Legacy Property Management California Inc Services may include links to third party service providers contracted by Clients. These linked services are operated by unaffiliated third parties that have separate and independent privacy statements, terms of use, and related notices or disclosures regarding information handling practices. We cannot be responsible for the information handling practices of independent parties.


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