PRIVACY POLICY

Effective Date: July 1, 2020 

  1. Introduction and Overview.

 

This Privacy Policy describes how the American Realty Advisors family of companies (“ARA,” “we,” “our,” or “us”) collects, uses, and shares information about you, as well as your rights and choices regarding such information. It applies to any online location, including www.alaraunionstation.com, that links to this Privacy Policy (the “Service”) or offline location that makes this Privacy Policy available to you.

 

By using the Service or interacting with us offline, you agree to our Terms and Conditions and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

 

  1. Information Collection.

 

  1. Information You Provide.

 

We collect information about you when you use the Service or interact with us offline, including information you provide when you register for an account as a prospect, an applicant or resident, make rental payments or submit maintenance requests through the resident portal, submit an online application to rent an apartment, call or email us about renting an apartment or scheduling a tour, or access our website. The following is a list of the categories of information we collect and have collected in the last 12 months:

 

  • Identifiers, including your first and last name, email address, postal address, phone number, username, password, password hints, information for authentication and account access, social security number, driver’s license number, passport number, and any messages you choose to send to us (such as messages you choose to send to “contact us” on our website).

 

  • Demographic Data (including information protected by California or federal law), including your age, gender, employment information, and country.

 

  • Customer Records, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your rental payments. Customer records may also include proof of income, previous addresses, references, employer name, employment information, office telephone number, and other information necessary to consider your eligibility for tenancy.

 

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information. 

 

  1. Information Collected Automatically.

 

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect and have collected in the last 12 months include:

 

  • Internet Activity, including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.

 

  • Identifiers, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.

 

  • Commercial Information, including apartments you apply for, view and rent.

 

  • Inferences, including information about your interests and preferences.

 

We use various tracking technologies to automatically collect information when you use the Service, including the following:

 

  • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

 

  • Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account. 

 

  • Log Files, which are files that record events that occur in connection with your use of the Service.

 

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

 

  1. Information from Other Sources.

 

We also collect information from other sources. The following are the categories of sources we collect information, and have collected from in the past 12 months:

 

  • Consumer or users of the Service.
     
  • Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.

 

  • Publicly-available sources, including data in the public domain.

 

  1. Use of Information.

 

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include to:

 

  • Operate and manage our Service, including your registration and account (if any).
  • Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service.
  • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Monitoring and analysing trends, usage, and activities.
  • Conducting research, including focus groups and surveys.
  • Improving the Service or other ARA websites, marketing efforts, products and services.
  • Developing and sending you advertising, including marketing material, leasing specials, advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
  • Fulfilling any other purpose at your direction.
  • With notice to you and/or with your consent.

 

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

 

  1. Sharing of Information.

 

We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and may have shared information within the last 12 months, include the following:

 

  • Service Providers. We share information with entities that process information on our behalf for our business purposes. Service providers, including our property managers, assist us with services such as property management services, payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

 

  • Vendors. We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below. 

 

  • Affiliates. We share information with our related entities including our parent and sister companies for business purposes such as customer support, marketing, and technical operations. We also may share information with affiliates for commercial purposes.

 

  • Merger or Acquisition. We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

 

  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.

 

  • Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service.

 

  • Consent. We share information with notice to you and/or with your consent.

 

Notwithstanding the above, we, our vendors, and service providers may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

 

  1. Separate Entities Websites and Services.

 

We offer parts of our Service through websites, platforms, and online services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:

 

  • Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.

 

  • Brand Pages. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand pages) is treated in accordance with this Privacy Policy. Also, if you publicly reference us or our Service on social media (e.g., by using a hashtag associated with ARA or Alara Union Station in a tweet or post), we may use your reference on or in connection with our Service.

 

Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

 

  1. Analytics and Advertising.

 

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our services on other websites and services. For example, we may place ads through Google or Facebook that you view on their platforms as well as on other websites and services.

 

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you (“Interest-Based Advertising”).

 

We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include Interest-Based Advertising or other advertising technology activities, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the “Sharing of Information” section for more detail about the parties we have shared information with.

 

We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data or other datasets. For instance, we may use Facebook Custom Audiences.

 

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics and Interest-Based Advertising please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

 

  1. Your Rights and Choices.

 

    1. Account Information.

 

If you have an account with us (such as applicants or residents), you are unable to access, update, or remove certain information that you have provided to us through your own account. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for other business purposes.

 

    1. Tracking Technology Choices.

 

  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

 

  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and mobile app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

 

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

 

    1. Analytics and Interest-Based Advertising.

 

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/

 

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

 

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

 

    1. Email Communications.

 

You can opt out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of non-promotional emails, such as those about your account, transactions, servicing, or ARA’s ongoing business relations. Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.

 

  1. Right to Know and Delete.

 

If you are a California resident, you have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

 

  • The categories of personal information we have collected about you; 
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

 

To exercise any of these rights, please submit a request through our online form available at alaraunionstation.com or call our toll-free number 833-233-1104. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

 

  1. Right to Opt Out.

 

To the extent we sell personal information as the term “sell” is defined under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the right to opt out of the sale of their personal information by us to third parties at any time. You may submit a request to opt out by clicking Do Not Sell My Personal Information. You may also submit a request to opt out by calling our toll-free number at 833-233-1104.

 

  1. Authorized Agent.

 

California residents can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

 

  1. Right to Non-Discrimination.

 

California residents have the right not to receive discriminatory treatment by us for the exercise of any of their CCPA rights.

 

  1. Shine the Light.

 

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” section and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

 

  1. Children.

 

The Service is intended for a general audience, and is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected] We will remove the data to the extent required by applicable laws.

 

We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization.

 

If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

  1. Data Security.

 

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

 

  1. International Transfer.

 

We are based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

 

  1. Changes to this Privacy Policy.

 

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address. 

 

  1. Contact Us.

 

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

 

By email:

 

[email protected]

 

By mail:

 

Tiffany Dang

ALARA Union Station
1975 19th Street
Denver, CO 80202