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PII Defined.  As used herein, “PII” means information by which you can be personally identified and includes a person’s first name or first initial and last name in combination with any one or more items of identifying data, including: (a) social security number; (b) driver’s license number or government-issued identification number; (c) bank account number or credit or debit card number in combination with or without any required security code, access code, or password that would permit access to an individual’s financial account; (d) physical or email address; (e) age or date of birth; (f) number of children; (g) education, occupation or employment information; (h) telephone number; (i) real property purchased, leased, or rented by you; or (j) debit card or credit card balance, payment history or information pertaining to your credit, assets, income or liabilities. PII does not include publicly available information or any information that is lawfully made available to the general public from the federal, state or local government.
Collection and Transfer of PII.  When you apply to rent an apartment from us and during your residency with us, we will ask you to disclose certain PII on your rental application or other documents or areas of the Site. In the course of providing our services, carrying out our business and operations and seeking to improve the utility of the Site, we may transfer or share your PII to or with our offices, affiliates, and third-party service providers in the United States. Our affiliates and third-party service providers will be or are limited in how they may use any PII they are provided; specifically they may only use this PII in accordance with this Policy regardless of where it is transferred.
Use of PII.  PII will be collected, retained, shared, disclosed and used by us, our affiliates or our third-party service providers for our business purposes, including:
- confirming your identity;
- determining your eligibility to rent an apartment when you apply and determining that you continue to meet eligibility/suitability requirements during your lease term with us;
- completing the leasing process;
- requesting credit and background check reports in connection with leasing applications;
- contacting you in response to your inquiries, comments and suggestions or when otherwise necessary;
- tracking the activity of users and their use of the Site for business purposes and research, user and market analytics or Site improvement;
- for special promotions, contests or surveys regarding products and services provided by us, our affiliates or partners;
- completing rental payments or other transactions on the Site;
- providing rental services and building and/or leasing services;
- notifying Site visitors about updates to the Site;
- providing our third-party service providers or others such as independent contractors, credit reporting agencies, background check reporting agencies, collection agencies or prospective purchasers of the property or their agents and employees with PII as we believe necessary for our business purposes;
- investigating, preventing, or taking action regarding illegal activities, suspected criminal conduct, situations involving potential threats to the safety of any person, or violations of this Policy;
- as required by law or regulation or as may be requested by government authorities;
- in connection with any acquisition, merger, sale or other transfer of any portion of our business or property; and
- for collection of amounts you may owe.
Physical Storage and Access to PII.  We will keep PII you provide to us in our files. If you become a resident in our apartment community, we will keep PII in a resident file. If you do not become a resident, we will keep PII in a general file. The property owner, property manager and, if applicable, agents and employees of the foregoing, will have access to the files in accordance with this Policy and pursuant to security measures designed to safeguard any PII.
Site Security.  We have reasonable and appropriate security measures in place to attempt to protect against the loss, misuses, and alteration of your PII under our control. In all cases, we have taken reasonable steps to confirm that reasonable measures have been implemented for protection from unauthorized access. However, no location or security system is impenetrable, and we cannot guarantee the security of our premises, Site or databases or our electronic communications. In addition, transmissions to and from the Site are not encrypted. Accordingly, you should carefully consider whether to submit any sensitive PII that you would not want made public. You acknowledge and agree that your use of the Site is solely at your own risk.
Nothing contained in this Policy shall constitute a representation or warranty that PII will not be misplaced, duplicated or stolen and no liability is assumed with respect to any such occurrence.
Disposal of Records Containing PII.  It is our policy to dispose of business or customer records that contain PII by shredding, erasing or otherwise destroying physical or electronic media in a manner consistent with this Policy so that it cannot practicably be read or reconstructed. We may do so by contracting with a third-party engaged in the business of record destruction.
At this time, the Site does not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions. You can generally express your privacy preferences regarding the use of most cookies and similar technologies though your web browser. Look under the heading "Tools" (or similar heading) in your particular browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also generally set your browser to turn off cookies. Since cookies allow you to take advantage of some of the Site’s features, we recommend that you leave them turned on. If you block, turn off or otherwise reject cookies, some web pages may not display properly.
Children Under 13.  We do not collect or maintain information from persons we know are under the age of 13, and we do not permit persons under the age of 13 to become registered users of our Site. No part of our Site is structured to attract anyone under the age of 13. By using our Site you represent that you are not under the age of 13.
Consent and Opting-Out.   By using the Site and providing us with PII, you have consented to our contacting you by email to provide you with information relating to the property you inquired about and other services we or our third parties offer. You may opt out of any future commercial email messages from us by choosing the link with instructions on how to remove yourself from our email list. Please note that if you are a resident of one of our apartment communities and you opt out of receiving commercial email from us, you will continue to receive email from us regarding operational issues surrounding your apartment, your lease and/or your community.
Changes to the Policy.  We reserve the right, at any time, to add to, modify or remove portions of this Policy. Please check back to this page periodically to determine if the Policy has been changed. If this Policy is changed, the date listed below will be changed and we will post a notice to that effect on the Site’s home page for at least 30 days after the change. If you have provided us with your email address, we may (but are not required to) send you an email notifying you of the changes. Your continued use of the Site after any changes have been made will constitute acceptance of the revised Policy and consent to any terms contained in the revised Policy.
Operation in the U.S.; Use of English.  The Site is operated, in whole or in part, from the United States. By using the Site, regardless of where you live in the world, you consent to have any PII you provide through the Site transferred to and processed in the United States, and allow us to use and collect your PII in accordance with this Policy. Text on the Site may be published in languages other than English. In all instances, the English language version of any text, including this Policy, controls the legal impact and interpretation of the Site and its use.
Contact Us.  If you believe that we have acted inconsistently with this Policy or you would like any of your information modified or deleted from our database or you would like to opt out of any future communications, please notify us at the address below. We may take a reasonable period of time to respond. If you request the deletion or change of information on our system, such information may be retained for a period in our backup systems as a precaution against systems failures. Some information may be retained for longer periods as required by law, contract or auditing requirements.
If you have questions or comments about this Policy or the Site, you may contact Meredith Lewis, Golub Realty Services LLC, 625 North Michigan Avenue, Suite 2000, Chicago, IL 60611, or please send us an email at email@example.com. Please note: Only inquiries regarding this Policy can be answered at this address.
Policy last updated: April 12, 2016.