CRC Companies LLC and its subsidiaries, related companies, and affiliated companies (“Company”) takes your privacy seriously. We want you to know how we collect, use, disclose, and retain your personal information.
Assistance For The Disabled
Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact ccparequest@crccompanies.com for assistance.
This Privacy Policy explains:
What categories of personal information we collect
The categories of sources from which we collect this personal information
The purposes for which we use your personal information
How we may disclose your personal information
How we protect the personal information we collect
How long we keep your personal information
Additional information for California tenants
Changes to this Privacy Policy
Notice at Collection for California Tenants:
Company collects the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 6. As described in more detail in Section 7(A)(2), we may “sell” or “share” your personal information, as California law defines those terms. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide Company with personal information about other California tenants, you are responsible for providing this notice to them.
We do not collect information from anyone under 13 years of age. The products and/or services we provide, together with our Site, are all directed to individuals who are at least 13 years old. If you are under the age of 13, you are not authorized to use our services or the Site.
Scope
This Privacy Policy applies to the personal information of individuals (“you”, “your”, or “yours”) collected by Company, including the personal information collected when you visit our website https://www.crccpartnersllc.com as it may be modified, relocated and/or redirected from time to time (the “Site”). This Privacy Policy does not apply to the personal information of individuals in their capacity as prospective, current, or former employees, contract workers, board members, or owners of Company, or their emergency contacts, dependents, or beneficiaries.
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Other web sites
The Site may contain links to other web sites not operated or controlled by us (“Third Party Sites”). The policies and procedures we describe here do not apply to Third Party Sites. The links from the Site do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
1. WHAT CATEGORIES OF PERSONAL INFORMATION WE COLLECT
Identifiers, for example: real name, alias, telephone number, Internet Protocol address, and email address. In addition, if you are a current, former, or prospective tenant, we may also collect your postal address, date of birth, Social Security number, and driver’s license number or state identification card number for identity verification purposes.
Commercial Information, for example: if you are a current tenant or prospective tenant, your vehicle information and interest in products and services which you identify in connection with joining a tenant interest group.
Other Personal Information:
Financial Information, for example: your record of payments and late fees.
User Content, includes content you submit when you contact customer service, make service requests, or otherwise contact Company. This may include recordings you create, including audio recordings or voicemail you submit in connection with customer service.
Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the call or text (SMS or MMS) message and phone numbers.
Characteristics of Protected Classifications Under California or Federal Law, for example: applicants to affordable housing can voluntarily self-identify their ethnicity. The Company uses this ethnicity information only, as required by law, to report to state and federal agencies regulating affordable housing.
Internet or Other Electronic Network Activity Information, for example: information about your usage of the Site, such as the pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted, internet protocol (IP) address, browser plug-in types and versions, device identifier, Internet service provider, and operating systems and platform.
Geolocation data, for example: rough geographic location from your IP address.
Sensory or Surveillance Data, for example: footage from surveillance cameras or voicemails and recordings as described above in “User Content” and for current tenants, footage from video recordings as part of a service request.
Professional Information, for example: the name and contact information for your employer and your current salary, business contact information, and title.
Inferences, for example: For current tenants or prospective tenants, we may make inferences based on your self-reported interests, e.g., tennis, that you voluntarily provide to us for the purpose of arranging activities and finding other tenants with similar interests.
Do We Use Cookies?
Yes. Cookies are small files that the Site or our service provider transfers to your computer’s hard drive through your Web browser that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly.
Google Analytics
We use cookies provided by Google Analytics, a service provider, to assist us in better understanding our Site visitors. These cookies collect data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site. Based on this information, Google Analytics compiles aggregate data about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Web Beacons
We include small graphic images or other web programming code, called web beacons (also known as "pixel tags", “web bugs” or "clear GIFs"), on the Site. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of users across the Site. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Rejecting cookies using browser settings may not stop web beacons from tracking you.
Tracking Across Time and Different Sites
The Site tracks your online activities over time and across websites or online services on an individually identifiable basis. For example, we may serve you advertisements on other websites based on what appeared to interest you on our Site. We do not allow third parties to use our Site to track your activities over time or across other websites.
2. THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION
You, for example, when you visit our Site, provide information in relation to your tenancy, complete forms or surveys, or when you otherwise provide information directly to us.
Service providers, for example, analytics providers, IT, system administration services, software providers, and other third-party vendors, including but not limited to unrelated property management companies, payment processing vendors, lead tracking vendors, and collections vendors, law firms, auditors, and consultants, to assist us in providing current and prospective tenant services and meeting our business needs and contractual and legal obligations.
Affiliated companies, for example, so that we can assist Company’s subsidiaries, related companies, and affiliated companies in providing you with products or services.
Automated technologies, for example, browsing activity collected by automated technologies on the Site.
Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
Public sources, for example, public databases.
Marketing/advertising companies, for example, from social media platforms, consumer research companies, and analytics or marketing/advertising companies.
Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.
Acquired entity, if Company acquired another entity, Company might collect personal information from that entity.
3. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
We use the categories of personal information we collect for one or more of the purposes below:
Providing Products and Services, including:
Performing property management and/or asset management services. Property management services include providing property rental, upkeep, maintenance, repair, and related services, determining rental eligibility, verifying tenant information and identity, processing payments, and providing analytic services.
Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with Consumers, including service requests for current tenants.
For community outreach and to build community.
To improve our products and services, develop new products and services, and conduct research on further improvements.
To enhance your experience using our products and services and to personalize your online experience.
Support and Marketing, including:
With respect to prospective tenants, for marketing and lead tracking.
For customer and tenant support.
To respond to any requests, queries, suggestions, feedback, or comments you may have.
To send you marketing information about our products and services, including notifying you of marketing events, membership and rewards programs, promotions, and sweepstakes, with your consent in accordance with applicable law.
To inform you of any changes to the services, your account (if applicable), this Privacy Policy, or any other policies or terms in relation thereto.
To perform operations to maintain the services, including to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
Monitoring, Security, and Compliance, including:
Auditing related to a current interaction with the user and concurrent transactions, including, but not limited to, auditing compliance with the law.
Detecting security incidents.
Preventing, discovering and investigating malicious, deceptive, fraudulent, or illegal activity or violations of this Privacy Policy or any applicable terms of service or terms of use for the Company’s services.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use.
To administer and protect our business and our Site (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
To protect the rights, property, or safety of Company, you, or others.
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries, related companies or affiliated companies.
To report suspected criminal conduct to law enforcement and cooperate in investigations.
To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
To ensure compliance with applicable laws and regulatory obligations.
Incidental Purposes: Any incidental purposes related to, or in connection with, the above.
4. HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION
Company discloses personal information as necessary for the purposes described in Section 3 above to the following categories of external recipients:
Service providers and vendors: Company discloses your personal information to service providers and vendors, including unrelated property management companies, payment processing vendors, lead tracking vendors, and collections vendors, law firms, auditors, and consultants, for the purposes above to assist us in meeting our business needs and contractual and legal obligations.
Affiliated companies: Subsidiaries, related companies, and affiliated companies within Company may work in concert to manage real estate properties and provide services to tenants, for example, to provide you with our products and services.
Marketing partners: Company may disclose your personal information to our marketing and analytics partners, including social media platforms, to help us market or obtain feedback about our services, perform data analytics, and while using cookies and other automated technologies on the Site.
Third parties: For example, we might disclose personal information to lawyers to assist us with legal compliance or to business partners to assist us in providing services to you.
Government or administrative agencies: For example, Company may report unlawful activity to law enforcement.
Public: Company may disclose personal information to the public as part of a press release, for example, to announce the winner of a sweepstakes if required by state law.
Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others.
Corporate Transactions: We reserve the right to disclose and transfer your personal information, including your personal information:
To a subsequent owner or co-owner.
In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.
5. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT
The security and confidentiality of your personal information is important to us. We have technical, administrative, and physical security measures in place to protect your personal information from unauthorized access or disclosure and improper use.
For example, we use Transport Security Layer (TSL) encryption to protect the data collection forms on our Site. In addition, we restrict access to your personal information. Only employees who need the personal information to perform a specific job (for example, a customer service representative) are granted access to personal information. Employees with access to personal information are kept up to date on our security and privacy practices.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to close your browser after you have completed your visit to the Site.
Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal information.
6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We retain your personal information for the duration of the customer relationship, if any. Otherwise, we retain personal information as needed for the purposes for which it was collected and longer as necessary to comply with legal, administrative, or procedural requirements, for example, a litigation hold.
7. ADDITIONAL INFORMATION FOR CALIFORNIA TENANTS
A. Information About Disclosures of Personal Information
1. Disclosures for Business Purposes
Company has disclosed each of the categories of personal information listed in Section 1, above, for the following “business purposes”, as that term is defined under the California Privacy Rights Act (“CPRA”), in the last 12 months:
Service providers: For the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in Section 3, above.
Auditors, lawyers, consultants, and accountants engaged by Company: For the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on Company’s behalf.
Affiliated companies: To other companies within the Company family of companies for the business purposes of (1) auditing compliance with policies and applicable laws, (2) helping to ensure security and integrity, (3) debugging, (4) short-term transient use, (5) performing services on behalf of Company, (6) internal research, and (7) activities to maintain or improve the quality or safety of a service or device.
2. Sales and Sharing
We do not “sell” your personal information as most people would understand that term, meaning that we do not disclose your personal information to any third party in exchange for a monetary payment. However, we may allow third parties described as “Marketing partners” in Section 4, above, to receive certain personal information about you, including the following categories listed in Section 1, above: (1) Identifiers (e.g., name, email address, phone number); (2) Internet or Other Electronic Network Activity Information (e.g., cookies, IP address, and other information about your usage of the Site; and (3) Professional Information (e.g., business contact information, title, and employer name).
The Company discloses this information in order to evaluate and improve our services, to enhance our marketing and advertising efforts and better reach individuals with relevant ads and content, and to analyze and solicit feedback about our services. These activities may be defined as a "sale" of personal information or as a disclosure of personal information to third parties for cross-context behavioral advertising (“sharing”), under California law.
To be clear, we do not sell or “share” your sensitive personal information, and we have no actual knowledge that we have sold or “shared” the Personal Information of children under 16 in the last 12 months, nor do we have any intention to do so.
3. Aggregated and Deidentified Information
We may aggregate and/or deidentify information, use it internally, and disclose to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.
“Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.
“Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be the data point that an unidentified visitor first entered the Site through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.
B. Your California Privacy Rights
Subject to applicable law, California tenants have the following rights:
Right to Know: You have the right to submit a verifiable request for specific pieces of your personal information and for information about Company’s collection, use, and disclosure of your personal information. In addition, you have a right to know the categories of personal information about you that Company sold or shared for cross-context behavioral advertising and the parties to which those categories were sold or shared. Please note that the CPRA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, California tenants generally just have a right to know categories, for example, categories of third parties to which personal information is disclosed, but not the individual third parties.
Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.
Right to Opt out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context behavioral advertising. You may also implement a browser setting or extension to communicate your selling and sharing preferences automatically to the websites you visit. We honor your right to opt out when signaled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC or learn more, you can visit the Global Privacy Control page here. If you choose to use the GPC signal, it will only apply to the browser or device you are currently using; you will need to download and turn it on for any other supported browsers and/or devices you use. Please note that in some circumstances, you may also need to submit a request using the opt out link below in order to properly identify you and opt-out of the sale or sharing that is not linked to your browser or device.
C. How to Exercise Your Rights
Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
To opt out of the disclosure of your personal information for purposes of cross-context behavioral advertising (“sharing”) or the sale of your personal information, click here: Do Not Sell or Share My Personal Information.
D. How We Will Verify Your Request
We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.
E. Authorized Agents
You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.
In the alternative, you can provide a power of attorney compliant with the California Probate Code.
F. Company’s Non-Discrimination Policy
Company will not unlawfully discriminate against you for exercising your privacy rights under the California Privacy Rights Act.
8. CHANGES TO THIS PRIVACY POLICY
If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.
For More Information
For questions or concerns about Company’s privacy policies and practices, please contact us at ccparequest@crccompanies.com.
