explains how we collect, use, maintain and disclose certain
personal information from current and prospective residents.
Personally Identifiable Information (“PII”) may be provided to us
by you on or through our website (the “Site”), by phone, by email,
in person or through other means, such as through third-party
service providers working with us.
As used herein, “PII” means
information by which you can be personally identified and includes
a person’s first name or first initial and last name in combination
with any one or more items of identifying data, including:
(a) social security number; (b) driver’s license number or
government-issued identification number; (c) bank account number or
credit or debit card number in combination with or without any
required security code, access code, or password that would permit
access to an individual’s financial account; (d) physical or email
address; (e) age or date of birth; (f) number of children; (g)
education, occupation or employment information; (h) telephone
number; (i) real property purchased, leased, or rented by you; or
(j) debit card or credit card balance, payment history or
information pertaining to your credit, assets, income or
liabilities. PII does not include publicly available information or
any information that is lawfully made available to the general
public from the federal, state or local government.
Collection and Transfer of PII.
apply to rent an apartment from us and during your residency with
us, we will ask you to disclose certain PII on your rental
application or other documents or areas of the Site. In the course
of providing our services, carrying out our business and operations
and seeking to improve the utility of the Site, we may transfer or
share your PII to or with our offices, affiliates, and third-party
service providers in the United States. Our affiliates and
third-party service providers will be or are limited in how they
may use any PII they are provided; specifically they may only use
this PII in accordance with this Policy regardless of where it is
Use of PII.
PII will be collected, retained,
shared, disclosed and used by us, our affiliates or our third-party
service providers for our business purposes, including:
confirming your identity;
determining your eligibility to rent an apartment when you apply
and determining that you continue to meet eligibility/suitability
requirements during your lease term with us;
Physical Storage and Access to PII.
- completing the leasing process;
- requesting credit and background check reports in connection
with leasing applications;
- contacting you in response to your inquiries, comments and
suggestions or when otherwise necessary;
- tracking the activity of users and their use of the Site for
business purposes and research, user and market analytics or Site
- for special promotions, contests or surveys regarding products
and services provided by us, our affiliates or partners;
- completing rental payments or other transactions on the
- providing rental services and building and/or leasing
- notifying Site visitors about updates to the Site;
- providing our third-party service providers or others such as
independent contractors, credit reporting agencies, background
check reporting agencies, collection agencies or prospective
purchasers of the property or their agents and employees with PII
as we believe necessary for our business purposes;
- investigating, preventing, or taking action regarding illegal
activities, suspected criminal conduct, situations involving
potential threats to the safety of any person, or violations of
- as required by law or regulation or as may be requested by
- in connection with any acquisition, merger, sale or other
transfer of any portion of our business or property; and
- for collection of amounts you may owe.
keep PII you provide to us in our files. If you become a resident
in our apartment community, we will keep PII in a resident file. If
you do not become a resident, we will keep PII in a general file.
The property owner, property manager and, if applicable, agents and
employees of the foregoing, will have access to the files in
accordance with this Policy and pursuant to security measures
designed to safeguard any PII.
Site Security. We have reasonable and appropriate security measures
in place to attempt to protect against the loss, misuses, and
alteration of your PII under our control. In all cases, we
have taken reasonable steps to confirm that reasonable measures
have been implemented for protection from unauthorized access.
However, no location or security system is impenetrable, and
we cannot guarantee the security of our premises, Site or databases
or our electronic communications. In addition, transmissions to and
from the Site are not encrypted. Accordingly, you should carefully
consider whether to submit any sensitive PII that you would not
want made public. You acknowledge and agree that your use of
the Site is solely at your own risk.
The Site may offer links to other sites for your convenience. Such
sites may have information, policies and practices different from
the Site. We do not control and are not responsible for the privacy
policies, practices and/or content of such third-party sites. We
encourage our users to be aware when they leave the Site and to
third-party site that collects PII.
Nothing contained in this Policy shall constitute a representation
or warranty that PII will not be misplaced, duplicated or stolen
and no liability is assumed with respect to any such
Disposal of Records Containing PII.
It is our
policy to dispose of business or customer records that contain PII
by shredding, erasing or otherwise destroying physical or
electronic media in a manner consistent with this Policy so that it
cannot practicably be read or reconstructed. We may do so by
contracting with a third-party engaged in the business of record
Cookies, Web Beacons, and Other Internet
We employ various technologies on
the Site to make your experience more enjoyable. We may directly or
through our vendors collect information through "cookies." Cookies
are small strings of text sent by the Site to your browser and then
stored by your browser on your computer's hard drive. Cookies help
us understand how you use our Site and other linked sites so that
we can personalize and improve your experience on the Site. We use
cookies to, among other things, identify your computer during a
particular visit to the Site and analyze visitor behavior. Most web
browsers provide you with the ability to accept or decline cookies,
as well as to be warned each time a cookie is being sent. In order
to create a profile on the Site, you must have your cookies turned
Web beacons are electronic files that are placed on a web site and
allow the website to count users who have visited that page or to
access certain cookies. There are also other methods used to
collect information about visitors to any website. At this time, we
information about the visitors to the Site in an aggregated form.
For instance, we may gather certain information such as the number
of unique visitors, the frequency with which they visit and pages
viewed. We look at the data in summary form, rather than on an
individual basis. We gather this information so it can, for
example, learn how many people visit the Site, see which pages are
the most viewed and identify which web sites are referring visitors
other internet technology to collect PII about you.
At this time, the Site does not recognize automated browser signals
regarding tracking mechanisms, such as "do not track" instructions.
You can generally express your privacy preferences regarding the
use of most cookies and similar technologies though your web
browser. Look under the heading "Tools" (or similar heading) in
your particular browser for information about controlling cookies.
You can set your browser in most instances to notify you before you
receive a cookie, giving you the chance to decide whether to accept
it. You can also generally set your browser to turn off cookies.
Since cookies allow you to take advantage of some of the Site’s
features, we recommend that you leave them turned on. If you block,
turn off or otherwise reject cookies, some web pages may not
Children Under 13.
We do not collect or
maintain information from persons we know are under the age of 13,
and we do not permit persons under the age of 13 to become
registered users of our Site. No part of our Site is structured to
attract anyone under the age of 13. By using our Site you represent
that you are not under the age of 13.
Consent and Opting-Out.
By using the Site and
providing us with PII, you have consented to our contacting you by
email to provide you with information relating to the property you
inquired about and other services we or our third parties offer.
You may opt out of any future commercial email messages from us by
choosing the link with instructions on how to remove yourself from
our email list. Please note that if you are a resident of one of
our apartment communities and you opt out of receiving commercial
email from us, you will continue to receive email from us regarding
operational issues surrounding your apartment, your lease and/or
Changes to the Policy.
We reserve the right,
at any time, to add to, modify or remove portions of this Policy.
Please check back to this page periodically to determine if the
Policy has been changed. If this Policy is changed, the date listed
below will be changed and we will post a notice to that effect on
the Site’s home page for at least 30 days after the change. If you
have provided us with your email address, we may (but are not
required to) send you an email notifying you of the changes. Your
continued use of the Site after any changes have been made will
constitute acceptance of the revised Policy and consent to any
terms contained in the revised Policy.
Operation in the U.S.; Use of English.
Site is operated, in whole or in part, from the United States. By
using the Site, regardless of where you live in the world, you
consent to have any PII you provide through the Site transferred to
and processed in the United States, and allow us to use and collect
your PII in accordance with this Policy. Text on the Site may be
published in languages other than English. In all instances, the
English language version of any text, including this Policy,
controls the legal impact and interpretation of the Site and its
If you believe that we have acted
inconsistently with this Policy or you would like any of your
information modified or deleted from our database or you would like
to opt out of any future communications, please notify us at the
address below. We may take a reasonable period of time to respond.
If you request the deletion or change of information on our
system, such information may be retained for a period in our backup
systems as a precaution against systems failures. Some
information may be retained for longer periods as required by law,
contract or auditing requirements.
If you have questions or comments about this Policy or the Site,
you may contact Meredith Lewis, Golub Realty Services LLC, 625
North Michigan Avenue, Suite 2000, Chicago, IL 60611, or please
send us an email at email@example.com. Please note: Only inquiries
regarding this Policy can be answered at this address.
Policy last updated: April 12, 2016.