Last Updated: January 1, 2020
Definition of Personal Information
For the purposes of this Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably linked , directly or indirectly, with a particular individual or household.
Personal Information does not include publicly-available information from governmental sources. Information that is provided in the aggregate or that is de-identified is not Personal Information.
Personal Information We May Collect About You – Sources and Categories of Information
Sources of Collection
This section describes the sources from which we may have collected Personal Information about you in the last 12 months, and which we may continue to collect, whether on our behalf or on behalf of our clients:
When you visit the Sites or interact with use in other ways, such as when you request information about our Services or information we provide to the public; visit the Sites; transmit information through the portal we maintain on behalf of our association clients when, for example, you pay association fees, request documents and certificates, submit other inquiries, call or otherwise engage with the customer service center.
Categories of Personal Information Collected
This section describes the categories of Personal Information we may have collected about you in the past 12 months. Included are categories that describe employee as well as client data. It also describes the categories of Personal Information we may continue to collect:
- Contact information, such as name, physical addresses, email addresses and other contact information, emergency contacts, account number and password, drivers’ license or state identification information, social security number, information about the vehicles parked at the communities we manage, and IP addresses.
- Unique device and online identifiers, such as device IDs, browsing history and other similar identifiers
- Protected class information, such as gender, age, disability status, citizenship, medical condition, physical or mental disability information collected in the employment context (not from job applicants)
- Educational and professional background information, such as work histories, employer information, educational history that would be found on a resume
- Audio or visual information, such as recordings of your calls to the customer service center we operate on behalf of our clients; CCTV recordings of you in the public areas on those properties on which our clients operate security cameras
- Internet or other electronic network activity, such as information regarding your browsing history, visits to and interaction with our Sites, information about visits to our social media accounts
How We Use Personal Information We Collect
With respect to each of the categories of Personal Information above, this section describes the reasons we may have collected and used such information in the past 12 months and why we may continue to collect and use it.
Provide You with Services on Behalf of Our Clients: We use your Personal Information to provide a full range of property management services to our clients, including: management of facilities, public grounds and common areas in communities; contacting you and responding to your requests and inquiries; facilitating sales and leasing/rentals; processing payments; responding to requests for documentation associated with the association or ownership/leasing/rental of real property within each community; providing marketing; facilitating the operation of association boards of directors; providing customer service; operating a call-in center; distributing newsletters and similar materials; compliance with applicable laws, regulations or codes of practice.
Provide You With Additional Services: In addition, we collect Personal Information in order to market and provide information about our Services and company; improve the Sites by, among other things, understanding who and how they are used; compliance with applicable laws, regulations or codes of practice.
Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection. We may use Personal Information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.
Compliance with Laws and to Protect Ourselves: We use your Personal Information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your Personal Information if a government agency or investigatory body requests. We may also use your Personal Information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Marketing and Recruiting: We use Personal Information to inform you about the Company and the services we offer. We may also use your Personal Information to send you information about career opportunities.
Employment and Human Relations Functions: We use Personal Information in connection with our hiring, employment and job training activities.
Debug and Identify Errors: We use your Personal Information to debug and identify and repair errors that impair existing intended functionality.
Statistical Analysis and Research: We may use your Personal Information for statistical analysis and research purposes including analyzing performance.
In addition, we may use your Personal Information in the aggregate and in a de-identified manner to create case studies, and/or to determine residents' demographics and preferences. By doing so, we are better able to deliver to you relevant information that you may find to be helpful and informative.
Third Parties With Which We Have Shared Personal Information
In the last 12 months, we have shared the Personal Information described above with the following categories of third parties for business purposes, whether our own or those of our clients:
- Our internet, IT, and telecommunications service providers
- Our payroll administrators, client relationship management services, payroll processors
- Service Providers such as banks, accounts and lawyers and entities that provide printing, mailing or communications services providing services on our behalf
Looking forward, we may also continue to share the same categories of Personal Information with the same categories of third parties as described above.
We Do Not Sell Your Personal Information
In the last 12 months we have not sold any Personal Information. We do not and will not sell Personal Information.
Additional Information Regarding Our Collection, Use
and Sharing of Personal Information
With respect to each of the categories of Personal Information we collect as noted above, we may also collect and share Personal Information with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to the Sites, or the public. We may also share Personal Information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not comply with automated browser signals regarding tracking mechanisms, which may include "do not track" instructions.
California Data Privacy Rights
If you are a California resident, you may have certain rights with respect to Personal Information as set forth under California law and explained below.
Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own marketing purposes.
CCPA Rights of Individuals
This section addresses rights provided to California residents under the California Consumer Privacy Act of 2018 (“CCPA”) regarding the Personal Information we collect. Those rights include the right to know about the Personal Information we collect, the right to request that we delete it and the right to request that we refrain from selling any Personal Information (the “CCPA Rights”). The CCPA Rights are described in greater detail below.
Your Right To Request Disclosure of Information We Collect and Share About You
You can request the following information from us, with respect to the Personal Information that we have collected about you in the 12 months prior to our receipt of your request:
- The categories of Personal Information we have collected about you.
- The categories of sources from which we collected your Personal Information
- The business or commercial purposes for which we collected the Personal Information
- The categories of third parties with which we shared the information
- The categories of Personal Information we have disclosed or shared for a business purpose
- The specific pieces of Personal Information we collected
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon request, we will delete the Personal Information we have collected about you that is covered by the CCPA, situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
We Do Not Sell Personal Information
We do not and will not sell Personal Information to third parties.
We Are Service Providers to Our Clients
When we collect and process Personal Information on our clients, we act as their “service provider,” as that term is defined in the CCPA. We do not disclose, use or retain any of the Personal Information we collect when collecting or processing Personal information on behalf of our clients for any purpose other than the specific purpose of performing the services specified in our contracts with our clients.
This means that the Company does not own the Personal Information we collect on behalf of our clients (i.e., your homeowners’ or condominium association). Please be advised that homeowners/condominium associations are not subject to CCPA (and therefore are not required to provide CCPA Rights), as they are not-for-profit entities. Nevertheless, you may always review the information in your Resident Portal.
Exercising Your Rights and How We Will Respond
For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
Verification of Identity – Access or Deletion Requests
If we are unable to verify your identity with the degree of certainty required based on the type of information or action you are requesting, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us or not and the nature of the information your require, which we will endeavor to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for Household Information
There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above.
If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
Our Commitment to Honoring Your Rights
Personal Information of Minors
The Company’s Websites are not intended for children under the age of 16. We do not knowingly collect or sell Personal Information of children under 16. To protect their privacy, children under the age of 13 are prohibited from using any Company’s Website.
Third Party Sites
From time to time, we may advertise certain third party services through the Company’s Websites which we feel will be helpful or relevant to you (collectively, “Third Party Services”). Third Party Services may include, but are not limited to, banking and financial services, insurance-related services, payment processing services and property management-related services.
When you click on a link for a Third Party Service, your Web browser will be re-directed to the third party provider of the Third Party Service that you selected. Third party providers may have privacy policies that are different than this Policy, and you should read carefully the privacy policies of those vendors prior to releasing any of your information to them, financial or otherwise.
Third Party Services may also require you to agree to certain terms and conditions of use (collectively, “Third Party Conditions”) before using or accessing those services. Often, Third Party Conditions describe and govern how third party providers use your Personal Information, so you should read carefully all Third Party Conditions prior to releasing any of your information to such third party sites.
We do not endorse, warrant or guaranty the nature, scope, quantity, availability or quality of any Third Party Services. We make you aware of such services for your convenience. If you have any questions, comments or concerns about any Third Party Service, you are instructed to contact directly the vendor offering the service.
We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Accuracy & Access
Your Personal Information is accurate to the extent that you provide it correctly and accurately to us or to the party collecting such information. Errors that you make when entering your Personal Information may result in erroneous information in the Company’s database. We provide residents with the ability to review and/or correct their information, as described below.
To protect your privacy and security, we may take reasonable steps to verify your identity, such as requiring a password and user ID, before we permit any changes to be made to the Personal Information in Our database. To view and change the Personal Information that you directly provided to us, contact us using the information provided below..
The Company is committed to ensuring that our communications, including our website, are accessible to people with disabilities. This website is designed to meet content accessibility guidelines. To make accessibility-related requests or report barriers, please contact us at [email protected]
ATTN: Privacy Officer
c/o FirstService Residential
1855 Griffin Rd.
Dania Beach, FL 33004
When contacting the Privacy Officer please be sure to provide your name, your physical address, your email address, your phone number (if you wish to be contacted by telephone) and a description of the question or issue that you wish to have resolved.