Effective Date: January 1, 2020

Last Reviewed On: January 1, 2020

EENHOORN LLC PRIVACY STATEMENT

This Privacy Statement describes how Eenhoorn LLC and its affiliates, subsidiaries, and trade names ("Company" "we" or "us") collects, handles and processes personally identifiable information including non-public personal information we obtain regarding individuals ("personal information") in connection with your access, purchase, rental or use of all of the properties owned by the Company ("Properties") and services, websites and applications offered by the Company ("Services").    

Please read this Privacy Statement carefully to understand our policies and practices regarding your personal information and how we will treat it.  If you do not agree with our policies and practices, your choice is to not access, purchase, rental or use our Services or Properties or provide any information in connection with them. By accessing, purchasing, renting or using our Services or Properties or providing any information in connection with them, you agree to this Privacy Statement. You also expressly consent to the processing of your personal information according to this Privacy Statement.

California Residents  

California residents may access the Company's Privacy Notice for California residents at https://eenhoorn.com/ccpa.

Information Collected by the Company

In connection with the Services and Properties, the Company may collect information about you, including but not limited to:

  • contact information (e.g., name, company name, address, city, state and ZIP code, email address and telephone number).
  • information provided or accessed in connection with our rental application including credit and criminal screening reports, rental history, social security number, driver license number, license plate number, vehicle identification number, date of birth, previous addresses, employment history and information, income and asset information.
  • your device data and how you interact with the Company's websites (e.g., IP address, browser type, and unique device identifier).
  • details of any payment transactions you carry out through the Services or Properties. 

This information may be collected directly from you when you provide it to us, or access, purchase, rent or use our Services or Properties.  We do not sell your personal information to third parties. Data we receive from other sources may be combined with the information you provide us, and may be used or shared for the following purposes stated below. 

The Company's Use of Information Collected

The personal information we collect may be used:

  • To fulfill or meet the reason you provided the information. For example, if you share personal information when you complete your rental application or ask a question about our Properties or Services, we will use that personal information to complete our application process or respond to your inquiry. If you provide your personal information to pay your rental fees or purchase a management service, we will use that information to process your payment and facilitate delivery. We may also save your information for these purposes.
  • To provide, offer, support, personalize, or develop our website, Properties, and Services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our website, Properties and Services, databases and other technology assets.
  • For testing, research, analysis, and product development to develop and improve our website, and related services.
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • in any other way we may describe when you provide the information.

We will not sell, share or rent the information gathered from the Services or Properties to others in ways that are different from what is disclosed in this Privacy Statement.  Personal information is only used for the purposes set forth above and for no other purposes.

The Company's Sharing of Information Collected (Categories and Purposes)

We may share your personal information in the following instances:

  • with our affiliates or subsidiaries
  • with service providers, and other third parties we use to support our business that that provide revenue management, resident screening, collections, leasing support, customer relationship management solutions and utility billing providers.
  • with Software/IT service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • with banks and credit card processors to the extent necessary for the Company to deliver the Services or Properties.
  • when we believe sharing is necessary to protect our rights, preserve safety, investigate fraud or other wrongdoing.
  • when required by law, which includes complying with any court order, law, or legal process, including responding to a government or regulatory request.
  • in connection with the sale, transfer or financing of the Company's business or its assets, including a bankruptcy proceeding or to our affiliates. 
  • to enforce or apply our agreements, including for billing or collection purposes.
  • for any other purpose disclosed by us when you provide the information.

Apart from the categories and purposes listed above, the Company will not share your personal information with other third parties for their independent use without your permission.

Information Security

We will use reasonable administrative, technical and physical security to protect the personal information we retain and to help ensure that it is used in accordance with this Privacy Statement.  We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless longer retention is required by law or for auditing purposes.

Cookies/Tracking Technologies

Our websites may use "cookies" and other tracking technologies to gather information about your interactions.  This information may include demographic data, browser type, IP address, pages visited, activities conducted on the page, and the day and time of your visit. We do not currently honor "do not track" signals from a web site browser. Please refer to your computer browser help instructions for more information on cookies and other related technologies and how to manage their use. If you refuse or delete cookies, you will need to repeat the process if you use another computer or change browsers. If you refuse or delete cookies, some of the functionality of our websites could potentially be impaired.  Please note that we use an analytics service, Google Analytics to gather information about our website visits. To learn more about Google Analytics, including opting out of Google Analytics, click here https://tools.google.com/dlpage/gaoptout?hl=en

Pages of our websites may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited those pages.  We may use this information to provide a better website user experience, and tailor our marketing communications.

Linked Sites

Our websites may contain links to other websites. The Company assumes no responsibility for, the content, privacy policies, or practices of any third-party websites.  You expressly relieve the Company from any and all liability arising from your use of any third-party website, or from the content of any third-party website.

Children’s Privacy

Our websites do not target or knowingly collect any information from individuals under the age of 18.

Information Request

You may request information from the Company regarding the personal information it collects from you and how it shares your personal information with third parties. We will endeavor to provide a copy of this information in a standardized format. You may make such a request by emailing [email protected] or calling us at 1-800-274-3994.

Eenhoorn LLC Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed on: January 1, 2020

This Privacy Notice for California Residents applies to Eenhoorn LLC's and its affiliates, subsidiaries, and trade names (collectively referred to as "Eenhoorn", "we", "us" and "our" in this Privacy Notice).  This Privacy Notice supplements the information contained https://eenhoorn.com/privacy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from  consumers within the last twelve (12) months:

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from the rental application forms you complete in connection with our properties.

Indirectly from you. For example, from observing your actions on our Website or obtaining background screening information (e.g., credit and criminal screening reports) in connection with our rental application.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share personal information when you complete your rental application or ask a question about our properties or services, we will use that personal information to complete our application process or respond to your inquiry. If you provide your personal information to pay your rental fees or purchase a management service, we will use that information to process your payment and facilitate delivery. We may also save your information for these purposes.
  • To provide, offer, support, personalize, or develop our website, properties, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our website, properties and services, databases and other technology assets.
  • For testing, research, analysis, and product development to develop and improve our website, and related services.
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers that provide revenue management, resident screening, collections, leasing support, customer relationship management solutions and utility billing providers.
  • Software/IT service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • with banks and credit card processors to the extent necessary for the Company to deliver the services or properties.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers that provide revenue management, resident screening, collections, leasing support, customer relationship management solutions and utility billing providers.
  • Software/IT service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information to any third parties and does not sell personal information pertaining to Minors under the age of 16.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting the personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1.   Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2.   Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3.   Debug products to identify and repair errors that impair existing intended functionality.
  4.   Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5.   Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6.   Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7.   Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8.   Comply with a legal obligation.
  9.   Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us via the methods noted above.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: 231 W Fulton Street, Grand Rapids, MI 49503.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-274-3994

Website: www.eenhoorn.com

Email: [email protected]hoorn.com

Postal Address:

Eenhoorn, LLC

Attn: Customer Service, 231 W Fulton Street, Grand Rapids, MI 49503

 

Accessing and Correcting your Personal Information

You can review and change your personal information by contacting us at [email protected] or calling us at 1-800-274-3994 where you can request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement, cause the information to be incorrect or prevent us from servicing your lease or performing any other legal or contractual obligation. 

Changes to our Privacy Statement

It is our policy to post any changes we make to our Privacy Statement on this page with a notice that the Privacy Statement has been updated on our website home pages. If we make material changes to how we treat our users' personal information, we will notify you through a prominent notice on our website home pages in addition to any legal requirements. The date the Privacy Statement was last revised is identified at the top of the page.