Privacy Policy
This privacy policy (the “Privacy Policy” or “Policy”) of Westminster Management/Westminster
Pillar Management (“Company,” “we,” “us,” or “our”) describes our privacy practices regarding
personal information we collect, including from persons (“you” or “your”) who access our
property’s RentCafe Resident Portal website or our related mobile applications that may be
available for download (collectively, the “Site”). To access the Privacy Policy of RentCafe,
please visit: https://www.rentcafe.com/apartments/privacypolicy.aspx.
PURPOSE.
The purpose of this Privacy Policy is to inform you about the types of personal
information we gather about you, including personal information gathered when you visit the
Site, and personal information we may receive from third parties or affiliates in addition to that
online information, how we may use that information, whether we disclose that information to
anyone, and the choices you have regarding our use of, and your ability to correct, the
information. This Policy does not cover information that is exempted from privacy policy
notification requirements, including information about employees, contractors, job applicants
and information processed exclusively in the context of a business person acting in a business
capacity.
THE SITE IS NOT INTENDED FOR CHILDREN AND COMPANY DOES NOT
KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM
CHILDREN UNDER THE AGE OF 13. IF COMPANY LEARNS THAT A CHILD UNDER
THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO
COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO
DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH
INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE
SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY
OTHERWISE BE REQUIRED BY LAW).
YOUR CONSENT AND POLICY CHANGES.
PLEASE READ THIS ENTIRE PRIVACY
POLICY CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT
QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION,
INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT
AUTHORIZED TO USE THE SITE.
Company may amend this Privacy Policy from time to time. We will post those changes on the
website or update the Privacy Policy date below. In certain cases, you will be notified via email
or by a notice on our website.
PERSONAL INFORMATION COLLECTED IN THE PAST 12 MONTHS
We collect, process and store various types of Personal Information. For purposes of this Policy,
“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 consumer or household. It does not include de-identified or aggregate information, or
public information lawfully available from governmental records.
Personal Information we collect may include: your name, email addresses, postal addresses,
postal codes, user Internet Protocol (IP) addresses, social security/insurance number, driver’s
license number, prior addresses, monthly rent paid at prior residences, employers, job titles,
income, telephone numbers, credit card information, bank account information and routing
numbers, date of birth, gender, age, marital status, user name and password (if you choose to
become a registered user of the Site or our products and services), emergency contact
information, information about your pets, information about your vehicles including license plate
numbers, biometric information or biometric identifiers (if you choose to schedule a self-guided
tour and/or use our identity verification services), when a smart device is on or off; when a door
is locked, unlocked, opened, or closed; the unit with which the door is associated (if you choose
to use Smart Home or the Home IQ Device(s) or Home IQ Hub), and other information either
desirable or necessary to provide quality services to our residents and visitors. We may also
collect information about you such as your use of the Site and communication preferences.
Your Personal Information may be retained for as long as you use the Site or our products and
services. Retention periods may be extended if we are required to preserve your personal
information because of litigation, investigations and other similar proceedings, or if a longer
retention period is required or permitted by applicable law.
We do not and will not sell your Personal Information.
Additional Information about How We Collect and Share your Personal Information
With respect to each of the categories of data 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; with contracted service providers; or otherwise to
protect the rights, property, safety, or security of our business, third parties, visitors to our
websites and mobile apps, or the public. With respect to biometric information or biometric
identifiers, we may disclose such data to our technology service providers for the purpose of
verifying your identity. 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.
PERSONAL INFORMATION WE WILL CONTINUE TO COLLECT
We will continue to collect the same categories of Personal Information listed above, for the
same purposes.
USE OF COOKIES AND OTHER TECHNOLOGIES.
Like many other website operators,
Company may use cookies to customize content specific to your interests and track your use of
the Site. “Cookies” are text files that are placed on your computer and may be used to store your
personal information. In addition to cookies, Company may use other now known or later
developed technologies, to assist Company in observing the behavior of users visiting the Site.
These technologies access individual user information but the information is used only to
compile aggregated statistics about the Site’s usage.
Our service providers may use cookies and those cookies may be stored on your computer when
you visit our website.
This Site uses Lead Attribution or Marketing Attribution to assess the conversions of different
channels that generate leads.
This Site uses Google Analytics (and in the future may use other similar sites or services), a web
analytics service provided by Google, Inc. (“Google”), to better assist Company in understanding
how the Site is used. Google Analytics will place cookies on your computer that will generate
information that we select about your use of the Site, including your computer’s IP address. That
information will be transmitted to and stored by Google. The information will be used for the
purpose of evaluating consumer use of the Site, compiling reports on Site activity for Company’s
use, and providing other services relating to Site activity and usage. Google may also transfer
this information to third parties where required to do so by law, or where such third parties
process the information on Google’s behalf. The use of cookies by Google Analytics is covered
by Google’s privacy policy: https://www.google.com/policies/privacy/.
You can choose to delete existing cookies, allow or block cookies, and set preferences for certain
websites in your browser’s settings. Please note you may not be able to use the full functionality
of the Site if you choose to block all cookies.
EMAIL AND TEXT MANAGEMENT.
You may receive emails and texts from Company for
a variety of reasons. We respect your desire to manage email and text correspondence. If you
have an account with Company on the Site, you can select your preferences through your
account settings. You can also manage your receipt of certain types of communication by
following the instructions included in the email we send you. Please note that, even if you
unsubscribe from certain email correspondences, we may still need to email you with
information relating to your unit, the management of the property, and other important
transactional or administrative information.
THIRD-PARTY WEBSITES.
This Privacy Policy applies solely to information collected by
Company. This Privacy Policy does not apply to other websites that are accessible through this
Site, including but not limited to any third-party websites.
ACCESSING, REVIEWING AND CHANGING YOUR CONTACT INFORMATION.
As an account holder, you can see, review and change most of your contact information associated
with your Account Profile by logging into your account and editing your Account Profile. For
assistance, you may contact us using one of the methods listed below. With some exceptions,
you have the right to see what Personal Information we hold about you. We can help you identify
what records we might have about you. We may need to confirm your identity before providing
you with this access, and if we cannot verify your identity with the degree of certainty required,
we will not be able to respond to your request. If we cannot give you access, we will tell you
within 45 days of receipt of your request and provide you with a reason, as best we can, as to
why we cannot give you access.
PERSONAL INFORMATION OF MINORS.
Our Sites are not directed to minors under the
age of 16 and we do not knowingly collect Personal Information from minors. We may collect
Personal Information of minors, provided by parents or guardians, in connection with the
application and rental of a unit, or the provision of property management services. We do not
sell the Personal Information of minors.
CALIFORNIA RESIDENTS’ RIGHTS.
The California Consumer Privacy Act (CCPA) may
apply to California residents whose Personal Information is collected by landlords of a certain
size or that meet other criteria. If the CCPA applies to us, California residents may request to
know about Personal Information collected about them and request deletion of that Personal
Information. These rights are subject to certain exceptions, including without limitation, for
Personal Information subject to the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act.
If we are subject to the CCPA, you can learn more about these rights and our processes for
consumer requests by contacting us using one of the methods listed below. If you exercise any of
the rights afforded to you by the CCPA, we will continue to treat you fairly.
Right to request disclosure of information we have collected about you
If the CCPA applies to us and to your information, you can submit a request to us for the
following personal information we have collected:
- The categories of personal information we’ve collected about you.
- The categories of sources from which we collected the personal information.
- The business or commercial purposes for which we collected or sold the personal
information.
- The categories of third parties with which we shared the personal information.
- The specific pieces of personal information we collected about you.
- The categories of personal information (if any) that we have sold about you, the
categories of third parties to which we sold that information, and the category or
categories of personal information sold to each third party.
- The categories of personal information that we disclosed about you for a business purpose.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Right to request the 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, unless a relevant exception to the right to deletion applies.
Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not
respond to browser or do not track signals.
ACCESSIBILITY.
We are committed to ensuring that our communications are accessible to
people with disabilities. To make accessibility-related requests or report barriers, please contact
us using one of the methods below.
ACCEPTABLE USE.
You agree you will not modify, tamper with, reverse engineer,
decompile, or otherwise attempt to discover the source code for, any Site or related hardware or
software associated with the Site.
CONTACTING US.
If you have questions regarding our Privacy Policy or the collection or use of your Personal
Information, you can contact us using any of the methods below:
By email at: marketing@wmapts.com
Canada.
To the extent it is applicable, this policy is made under the Personal Information
Protection and Electronic Documents Act. There are some rare exceptions to the commitments
set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the
administration of the privacy legislation in the private sector. The Commissioner also acts as a
kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be
reached at:
Address: 112 Kent Street, Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: (800) 282-1376
Facsimile: (613) 947-6850
TTY: (613) 992-9190
Website: www.priv.gc.ca/en/
Updated: August 2 2022a