Last updated January 31, 2020
1. Types of Information We Collect
We collect both "Personal Information" and "Anonymous Information" about our users.
"Personal Information" is information that can be used to contact or identify you or individuals about whom you enter information as part of your application on our Website or Services, such as first name, last name, social security number, email address, phone number, driver’s license number, state identification number, street address, e-mail address, gender, username and/or email address in combination with a password or security questions and answers, banking account numbers or credit/debit card numbers, even without a security code, access code, or password if the account could be accessed without such information, as well as information that is linked to the forgoing information.
"Anonymous Information" is information that cannot be used to contact or identify an individual and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Website and Services, such as usage data, to the extent that information is not linked to your Personal Information.
Users can access and browse a majority of the Website without disclosing Personal Information, although, like most websites, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier ("UDID") and/or your mobile operating system.
a. Voluntarily submitted information
We collect Personal Information that you voluntarily provide to us during your use of the Website and Services, including when you subscribe to our listings, fill out the Contact Us form, submit a question through the Website, contact an agent, schedule a tour of an available apartment, submit an application, make payments, submit notes through the Services, or otherwise manage your account with us through the Website.
b. Information collected via technology
- We may collect information from your use of the Website and Services, including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name. If you are using a mobile device, Eagle Rock may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use tools such as cookies to gather information as well. "Cookies" are small pieces of information that a website sends to your device while you are viewing the website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. A "Pixel" is a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported.
- Geolocation data: If you access the Services through a mobile device, we may access, collect, monitor and/or remotely store "geolocation data."
- We use third party services, such as Google Analytics and Google Search Console, to track and analyze online behavior data of Users. In particular, we utilize features of Google Analytics called "Remarketing," "Demographics and Interest Reporting" and "Ad Words." These services enable us to use Google Analytics’ third-party audience data help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Website and Services, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
- If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.
2. How We Use Your Information
a. Personal Information
We may use your Personal Information for the following representative purposes:
- Schedule an apartment tour for you
- Email Users and brokers with current apartment listings
- Send communications and administrative emails
- Process and evaluate information provided by you through the application and screening process and contact you regarding the same
- Process information uploaded by you to the Website and Services
- Process application fees, rent payments, late charges, utility fees, and other payments
- Personalize and tailor the features, performance and support of the Website and Services
- Send you promotional/marketing information, newsletters, offers or other information from us or on behalf of our sponsors or partners
- Perform internal operations, including fraud detection
- Prepare reports on rental activity, availability, and performance of the properties
- Analyze, benchmark and conduct research on user data and interactions with the Website or Services
b. Anonymous Information
We may use Anonymous Information for the following representative purposes:
- Perform internal operations on the Website and Services
- Improve the Website and Services and customize the user experience
- Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns
3. How We Share and Disclose Information
In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.
a. Service Providers
b. Compliance with Laws, Law Enforcement and Safety
We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend Eagle Rock’s or a third party's, rights or property.
c. Aggregated Anonymous Information
Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users ("Aggregated Anonymous Information"). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.
d. Business transactions
4. Your Choices
5. Updating Your Personal Information
You may revise your Personal Information by contacting us directly at email@example.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
This Website and Services are not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at firstname.lastname@example.org so that we may delete and remove such information from our system.
7. Security and Data Retention
We are very concerned with safeguarding your information. We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. All submissions you make through our resident application and Resident Portal are encrypted. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or
9. California Privacy Rights
Under California’s "Shine the Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at email@example.com.
10. Contact Us