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Privacy Policy / Safe Harbor Policy

 

 

MyBuilding, Inc. Privacy Policy

RealPage, Inc. and its group companies (collectively, “RealPage”, “we”, “our”, “us”) are committed to providing our product and service users (“clients”, “you”) with clear and concise information regarding our privacy policy and practices. This Privacy Policy describes in detail our policy and practices regarding the collection, use, and disclosure of client information by our subsidiary, MyBuilding, Inc., doing business as MyBuilding. By accessing our websites or utilizing our products and services, you consent to the information collection and handling practices outlined in this policy.

This Privacy Policy was last updated on April 21, 2015. We may change this Privacy Policy from time to time so please check back regularly to keep informed of any updates.

Scope

This Privacy Policy describes in detail our policy and practices regarding our collection, use, and disclosure of client information only. This Privacy Policy does not apply in respect of any data we process on behalf of our clients in the course of providing our products and services to them, including personal data relating to customers of our clients, and vendors which our clients have formalized business arrangements with. Any such individuals with questions about the uses of their data by our clients should contact the relevant client directly.

What information we collect

RealPage may collect various types of client information through our products, services, and websites. The information is gathered from your usage of our products and services, as well as from your entry of information on our websites. This collected information consists of two basic types of data: 1) personal information and 2) device information.

Personal information is information that can be used to uniquely identify you as an individual or contact you directly. This may include contact information such as your name, address, telephone number, and email address. For certain financial, health, or credit-based products and services, personal information may also include sensitive data such as payment data, credit records, social security numbers, date of birth, and account numbers. Personal information is only collected based upon your choice to provide it to RealPage through our products, services, and websites. You have the option to choose not to provide personal information to us; however, the lack of such personal information will typically prevent RealPage from providing the requested products or services to you.

If you provide us personal information about others, such as your customers and vendors with whom you have formalized business arrangements with, we will only use that information in accordance with your instructions and for the specific reason for which it was provided to us.

Device information is general information that does not permit direct association with you as an individual. When you browse RealPage websites, we may automatically collect device information such as your IP address, browser, internet connection speed, past web pages visited, and your link selections on our various website pages. This information may be used to: (1) manage and protect our websites, products, services, and users from fraudulent, abusive, or unlawful uses; and (2) help us research, develop, and improve our websites, products, and services. This type of information may also be aggregated or otherwise rendered anonymous for business and marketing uses by us or by third parties.

How we use the information

Your information will be used to enable us to provide you with the products or services you have requested from us. We may also process your information for operational and marketing purposes, so that we can improve our products and services to better meet our clients’ needs, as described further below.

Who has access to your data?

Except as explained in this Privacy Policy, RealPage does not sell, license, or share our users’ information outside the RealPage family of companies without the consent and authorization of the user whose information will be shared.

We may share your information within the RealPage family of companies, products, and services for operational and marketing purposes. The RealPage companies that access your information will do so in conformity with the practices described in this Privacy Policy. Sharing this information allows RealPage to provide you with the best customer service experience possible, provide you with the services you have ordered or requested, and notify you of the latest information regarding new or enhanced products, services, and promotions. RealPage may periodically send offers, promotions, and updates regarding RealPage products and services to current and potential users via e-mail. Every marketing e-mail RealPage sends contains instructions and procedures allowing you to opt out of additional marketing e-mails for that product or service.

In some circumstances, we use third-party companies, agents, and contractors to perform services on our behalf, such as website optimization, email distribution, processing credit card transactions, infrastructure and IT services, background screening, and other data processing or handling functions. In the course of engaging these third party services, RealPage only shares your information to the extent reasonably necessary for the third party to perform the services on our behalf. We do not permit these third parties to use or disclose your personal information except for the purpose of providing the services we request of them.

RealPage also reserves the right to disclose user information if we reasonably believe that such disclosure is necessary to (1) satisfy any applicable legal or regulatory requirement, (2) to respond to a governmental request, as required by law such as to comply with a subpoena, or similar legal process (3) enforce RealPage Terms of Use or investigate potential violations thereof, (4) to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of RealPage products, services, and websites, or (5) to protect our rights or property, or the safety or security of our customers, employees or data.

If RealPage enters into any business transition, restructuring, merger, sale, or other transferring of assets, we reserve the right to transfer user information, including all personal information, as part of or in connection with the transaction. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Cookies, Web Beacons, and Other Technologies

When you access our websites, products, and services, RealPage servers may place small text files (“cookies”) on your computer for recordkeeping purposes. Among other things, cookies enable RealPage to gather information about your activity on our websites, products, and services for the purposes of improving your online experience, remembering your preferences and settings, delivering advertising to match your preferences and interests, and for other similar customization purposes.

In addition to cookies, RealPage may utilize web beacons, clear gifs, or other technologies built into our websites, products and services to gather information on how users interact with and utilize various features. These technologies can help personalize your RealPage usage experience and help associate your interactions with our products and services to other information within your account. 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.

Most internet browsers provide controls that allow users to 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 RealPage websites, products, and services.

Third Party Advertisements and Links to Other Sites

Certain RealPage websites may include third party advertisements and links to other websites. These linked websites 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. Third party advertisers may also utilize cookies, web beacons, and similar technologies to collect information regarding your website interactions and activities. These third party technologies may be utilized by those entities to provided targeted advertising and web links based upon your activities and preferences. If you choose to interact with specific advertisers who advertise on our sites, the information you provide to them is subject to the conditions of their specific privacy policies and in no way covered by the practices described in this policy. RealPage cannot be responsible for the information handling practices of independent parties and encourages you to review their practices prior to information disclosure.

Other websites and Social Media Integration

RealPage websites, products, and services may include links to third party websites. If you access other websites from links provided on our websites, products and services, the operators of those websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from our Privacy Policy.

RealPage websites, products, and services may include the option of integration through third party social networking sites and related social media plug-ins or applications. When you integrate or link our websites, products, and services with your social media applications (e.g., Facebook, LinkedIn, MySpace, Google+, etc.), you authorize RealPage to have access to certain information from your social media profile (e.g., name, e-mail address, photo, gender, birthday, location, your list of friends, comments, etc.) to deliver the content or as part of the operation of the integrated application. We may also obtain non-personally identifiable information (e.g., content viewed, advertising viewed, etc.) from your interaction with our integrated content.

By choosing to integrate RealPage websites, product, and services with social media applications, you consent to the use of this information in accordance with our privacy policy. When you provide personal information to us through an integrated application, it may be publicly viewed by other members of these sites and RealPage cannot prevent further use of the information by independent third parties. For more information about how social networking sites handle your personal information and available privacy settings, please refer to their privacy policies and terms of use.
Mobile Applications and Location-based Services

Certain RealPage websites, products, and services offer mobile applications for access via smartphones and tablet devices. These applications are subject to the information handling practices outlined in this Privacy Policy.
RealPage mobile applications may include the option to provide you with helpful information based on where you are. To provide such location-based services, RealPage may collect, use, and share precise location data, including the real-time geographic location of your mobile device. This location data is collected anonymously in a form that does not personally identify you and is solely used by RealPage to provide and improve location-based products and services. If you wish to deactivate this feature, you can disable the location services on your mobile device.

Information Security

RealPage wants you to feel confident about using our products and services, and we are committed to protecting the personal information that we collect from our clients. We implement and maintain appropriate physical, administrative, technical and organizational measures to protect the personal information you provide us against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to sensitive personal information is authorized only for those who have a business need for such access, and sensitive records are retained only as long as reasonably necessary for business or legal purposes. RealPage strives to protect the user information that we collect and store, however, no security program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal information. RealPage maintains security incident response policies and procedures to handle incidents involving unauthorized access to private information we collect or store.

International transfers

RealPage, Inc. and its group companies have certified their compliance with the EU/US and Swiss/US Safe Harbor regimes to the US Department of Commerce for personal information that our clients transfer to us in the course of using our products and services. A copy of our Safe Harbor policy is available at http://activebuilding.com/product/activebuilding-condo/privacypolicy/.

Some of the third-party companies, agents, and contractors that we engage to perform services on our behalf may need to transfer your personal information internationally in order to provide their services, including to territories outside of the USA and Europe which may not have equivalent data protection regimes. However, where this is the case, we have implemented measures to safeguard your personal information in accordance with this Privacy Policy at all times.

Children’s Online Privacy

RealPage does not target children under the age of 13 for the collection of information online. Our products, services, and websites are not designed to attract the attention of persons under the age of 13.

Accessing and Updating Personal Information

In the event that your personal information becomes outdated, incomplete, or inaccurate, you may access and update your information by logging into your RealPage product or service account. If you require verification that your requested changes have been completed, and such verification is not readily displayed in your product or service account, you may request confirmation at the email address listed below (See “Contact Us”). You can also contact RealPage directly at the address below (see “Contact Us”) to ask us what personal information we hold about you.

Data retention

The time periods for which we retain your personal information depend on the purposes for which we use it. RealPage will keep your Personal Information for as long as is necessary for the purposes for which we collect it and, thereafter, for no longer than is reasonably necessary for internal reporting and reconciliation purposes pursuant to legal requirements and when we are required or allowed to do so under applicable law.

Privacy Policy Changes

As RealPage develops new products and services, updates or expands technologies, and develops new information uses, we reserve the right to update this Privacy Policy as necessary to reflect such changes. We recommend that you review this policy periodically for any changes that may have been made. Your continued use of RealPage products, services, and websites subsequent to any changes made after your initial consent means that you agree to be bound by those changes. The most current version of this Privacy Policy supersedes all previous versions.

Contact Us

If you have any questions or concerns about the RealPage Privacy Policy or its implementation, you may contact us at privacy@realpage.com or mail your written inquiry to:

RealPage, Inc.
Attn: Privacy (Legal)
4000 International Parkway
Carrollton, Texas 75007-1913

 

MyBuilding, Inc. Safe Harbor Policy

RealPage, Inc. and our wholly-owned subsidiaries are committed to providing our product and service users with clear and concise information regarding our privacy policy and practices. This Safe Harbor Policy (the “Policy”) describes in detail our practices regarding the collection, use, and disclosure of personal data that our clients may transfer to us from the European Economic Area (“EEA”) and Switzerland, for processing by us in the United States through our subsidiary, MyBuilding, Inc. (“MyBuilding” or “we” “our”, “us”), doing business as MyBuilding.

MyBuilding, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the certification page, please visit http://www.export.gov/safeharbor/.

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on the Safe Harbor Principles and associated frequently asked questions to enable United States companies to satisfy the EU legal requirement that adequate protection be given to personal information transferred from the EEA to the United States.

The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland (“FDPIC”) have agreed a similar set of Safe Harbor Principles and associated frequently asked questions to enable United States companies to satisfy the Swiss legal requirement that adequate protection be given to personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, MyBuilding adheres to the principles in both the US-EU and the US-Swiss Safe Harbor principles and frequently asked questions, collectively the “Safe Harbor Principles”.

Scope

This Policy applies to all personal information received by MyBuilding in the United States from its clients in the EEA and Switzerland.

Our Services

MyBuilding provides comprehensive property management software solutions to property owners and managers (our “clients”) in the multifamily, commercial, single-family, and vacation rental housing industries. Our on-demand product line covers the full spectrum of accounting, leasing, renters insurance, marketing services, utility management, purchasing, and other operational areas. In providing this suite of services, MyBuilding acts as a data processor under contract to our clients, the data controllers. As a data processor, MyBuilding does not own or control any of the personal data we process on behalf of our clients. All such personal data is owned and controlled by our clients. We are required to provide our products and services to our clients in accordance with their contractual provisions and instructions regarding data privacy, handling, and security.

Our policies and practices with respect to personal data our EU clients transfer to us are described below:

Notice

MyBuilding works with our clients to help them provide notice of data processing to individuals, including information concerning (1) the purposes for which personal information is collected and used; (2) a contact person to whom enquiries or complaints may be directed; (3) the types of third parties to whom personal information is disclosed; and (4) the choices and means that individuals are offered for limiting use and disclosure of personal information.

Choice

As a data processor handling personal data at the direction of our clients, MyBuilding has no direct relationship with the individuals whose personal data we process. If and when disclosure of personal data to a third party is necessary, MyBuilding works with our clients to help them inform individuals about the possibility of such disclosures and provide individuals with the choice and means of opting-out of or, in the case of sensitive personal data, opting-in to (a) such disclosures to third parties or (b) their personal information being used for purposes other than those for which it was originally collected or subsequently authorized by the individual.

MyBuilding only processes personal information for purposes that are compatible with those for which it was originally collected or as lawfully directed by our clients.

Onward Transfer

MyBuilding complies with the notice and choice principles as described above for all personal data disclosed or transferred to a third party.

Where MyBuilding uses third party agents to process personal data to help it perform its services, we only share personal data to the extent reasonably necessary for the third party to perform the services on our behalf. We do not permit these third parties to use or disclose the personal data we process on behalf of our clients, except for the purpose of providing the services we request of them. MyBuilding will not transfer personal data to any third party agent unless (a) that third party subscribes to the Safe Harbor Principles, (b) that third party is subject to the EU Data Protection Directive, or (c) MyBuilding has concluded an agreement with such a third party requiring that they provide at least the same level of privacy protection as do the Safe Harbor Principles.

If MyBuilding enters into any business transition, restructuring, merger, sale, or other transferring of assets, we reserve the right to transfer all product and service information, including all personal data, as part of or in connection with the transaction. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

NOTE: As set forth in the US Safe Harbor Principles, adherence to the Principles may be limited to the extent necessary to meet national security, public interest, or law enforcement requirements. Please be aware that in certain circumstances, it is possible that personal information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.

Information Security

MyBuilding implements and maintains appropriate physical, administrative, technical and organizational measures to protect the personal information you provide us against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to sensitive personal information is authorized only for those who have a business need for such access, and sensitive records are retained only as long as reasonably necessary for business or legal purposes. MyBuilding strives to protect the user information that we collect and store, however, no security program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal information. MyBuilding maintains security incident response policies and procedures to handle incidents involving unauthorized access to private information we collect or store.

Data Integrity

MyBuilding uses personal data only for the purposes compatible with its original collection or as subsequently authorized for use by the individual. MyBuilding will assist its clients as needed to ensure that personal data it processes is pertinent to its intended use, accurate, complete, and current.

Access

As a data processor handling personal data at the direction of our clients, MyBuilding has no direct relationship with the individuals whose personal data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should therefore direct his request to the MyBuilding client that transferred such data to MyBuilding for processing. The client will then provide access to the individual as determined under the applicable local data protection law. MyBuilding will assist its clients as needed to fulfill any such request.

Enforcement & Dispute Resolution

MyBuilding has in place mechanisms to verify ongoing compliance with the Safe Harbor Principles, and recourse for individuals to whom the data relate affected by non-compliance with the Safe Harbor Principles.

Individuals who wish to file a complaint or who take issue with MyBuilding’s EU Safe Harbor Policy should contact MyBuilding’s Privacy team at the addresses listed below. MyBuilding will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personal information by reference to the principles in this Policy.

For complaints that cannot be resolved between MyBuilding and the individual concerned, MyBuilding has agreed to participate in the Better Business Bureau EU Safe Harbor independent dispute resolution program. Individuals who submit a complaint or concern to MyBuilding but who do not receive acknowledgement from us or who think the complaint or concern has not been satisfactorily addressed should then contact the Better Business Bureau to participate in its dispute resolution procedure.

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor 3033 Wilson Boulevard, Suite 600
Arlington, VA 22201 U.S.A.
www.bbb.org/us/safe-harbor-complaints.

Contact

Individuals can request access or submit Safe Harbor policy inquiries by email at privacy@realpage.com or by writing:

RealPage, Inc.
Attn: Privacy (Legal)
4000 International Parkway
Carrollton, Texas 75007-1913