Effective Date: January 1, 2020
• via email or phone; and
• in person at our offices.
Please note that our Sites may contain links to third-party websites, such as social media pages. These links are intended for your convenience only. These third-party websites and services are not related to Prime and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage users to read the privacy policies of all websites they visit.
1. INFORMATION WE COLLECT AND HOW WE COLLECT IT
We may collect your personal information when you interact with our Site, mobile applications, with us over email or phone and at physical locations. Personal information is any information that relates to you, identifies you personally, or could be used to identify you including, but not limited to: your name, mailing address, email address, telephone number, or any other information.
The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and Services, information from other sources to help us supplement our records, improve the personalization of our service to you, promote safety at our apartment communities, and/or detect fraud.
Information You Voluntarily Provide to Us. The personal information we collect on or through our Site or Services may include:
• Contact information, such as your name, address, email, and phone number.
• Unique personal identifiers, such as SSN or TIN.
• If applicable, rental information, such as your rental application, employment history, financial records and other information and documents related to your tenancy.
• If applicable, loan information, financial statements and records (and related documents), and required verifications.
• If applicable, investor information, such as your subscription documents and related materials.
• Payment card information, wire instructions, transaction, bank or financial account information;
• Information you provide by filling in forms that we make available.
• Information you provide when you report a problem with our Site or an in-person location, a payment or other transaction with us by email, our Site, telephone, in writing or through other means.
• Records and copies of your correspondence (including email addresses), if you contact us.
Information from Third Parties. We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, we may collect credit or identity information, as well as conduct civil and criminal background checks, which we use to help prevent and detect fraud or to ensure safety at our apartment communities.
Information Collected from Other Sources. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
Information Collected Automatically. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• Details of your visits to our Site, including, but not limited to, traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our website, and the subject of the ads you click or scroll over.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Site or Services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site, to enhance your experience with the Site, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online Services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
• Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You can disable these cookies.
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera Mobile
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
3. HOW WE USE YOUR INFORMATION
• Providing the Services;
• Contacting you regarding the administration of the Services you use;
• Creating and managing your records and accounts in connection with your use of the Services;
• Facilitating financial transactions related to the Services you use;
• Providing you with notices about the Services you use;
• Carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;
• Notifying you about changes to our Site, our policies, terms or any Services we offer or provide though it;
• Sending you marketing and promotional emails;
• Responding to your questions or other requests;
• Allowing you to participate in the interactive features of the Services;
• Tailoring your experience on the Services and/or otherwise customizing what you see when you visit and use the Site;
• Saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Site);
• Tracking your return visits to and use of the Services;
• For research purposes, for marketing/promotional purposes and to provide anonymous reporting for internal and external clients and business partners;
• Accumulating and reporting aggregate, statistical information in connection with the Site, Services and user activity;
• Determining which features and services users like best to help us operate the Site, enhance and improve our Services, and display advertising and marketing information;
• Tailoring your experience on the Site and/or otherwise customizing what you see when you visit and use the Site;
• Keeping you secure and safe while using our Services, which requires us to process your personal information to combat spam, malware, malicious activities or security risks;
• Improving and enforcing our security measures;
• Responding to reviews, comments, or other feedback you provide us;
• Maintaining legal and regulatory compliance;
• Enforcing compliance with our policies;
• Protecting you, others and our business, including, without limitation, using information for fraud prevention;
• Providing to lenders or other counterparties in connection with our borrowing or other investments;
• For any other purpose disclosed to you prior to you providing us your personal information or which are reasonably necessary to provide the Services or other related products and/or services requested; or
• With your permission or upon your direction, we may disclose your personal information to interact with a third party for other purposes.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the contact information in the “Contact Us” section below to notify us of your opt-out preference.
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share or disclose your personal information in the following circumstances:
• Service Providers. We may employ other companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform service-related activities or assist us in analyzing how our Services are used. The Service Providers may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Within Our Organization. We may share your personal information with our subsidiaries and affiliates to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis. For example, we may share your information with our subsidiaries and affiliated companies to expand and promote our Services.
• Corporate Transactions. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Site users is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your personal information. To financial institutions and other counterparties in connection with making, holding, financing and disposing of our investments.
• As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, or safety of Prime or our customers or partners.
• Consent. We may disclose your personal information for any purpose with your consent.
Please note that we may disclose, without restriction, aggregated or anonymized information about our users, which is information that does not identify any specific individual.
5. COMMUNICATIONS PREFERENCES
To provide Services to you, we may send you communications related to your transactions, security, or the administration of this Site. From time to time, we may also send you other messages or updates about Prime, our website, and promotions or other activities. If you do not wish to receive non-transaction/security-related communications from Prime Group, you may opt-out by clicking the “unsubscribe” link if available in the communication or contact us where specified in the “Contact Us” section, below.
Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer data, including personal information, to United States and process it there. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.
8. YOUR CALIFORNIA PRIVACY RIGHTS
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third parties with whom we may share your Personal Information.
We generally collect the following categories of Personal Information about your when you use our Services:
• identifiers such as a name, address, unique personal identifier (e.g., SSN), email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
• protected classifications, such as gender;
• commercial information such as records of services purchased, obtained, or considered by you;
• Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• professional or employment-related information;
• your geolocation, to the extent you have configured your device to permit us to collect such information; and
• inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect biometric information, audio recordings of your voice, education-related information. For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems. To assert your right to know or your right to delete your Personal Information, please contact us at 888.457.0941 or by email at firstname.lastname@example.org. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
• Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
• Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
• Right to Access. You have the right to request access to a copy of the specific Personal Information we collected about you during the 12 months before your request.
• Right to Deletion. You have the right to request that we delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
• Right to Opt-Out of Sales. You have the right to opt-out of any sales your Personal Information. We do not sell any of your Personal Information.
9. DATA SECURITY
We are committed to protecting your personal information from unauthorized access and use. To help protect your personal information, we implement and maintain appropriate technical, physical, and administrative safeguards. Access to your personal information is restricted solely to those employees and vendors who need to know that information to provide our Services to you. Our employees receive training to maintain the confidentiality, privacy, and security of your personal information.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
10. CHILDREN’S PRIVACY
We do not offer Services to minors and do not intend to collect personal information from children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18. If an individual under the age of 18 has provided us with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.
11. CONTACT US