This Privacy Statement applies to information we collect:
Collectively, we refer to the websites, online services, property visits and offline interactions as “services.” This Privacy Statement describes what Personal Information we gather, how we use it, how it is shared and how you can access, delete, correct, change, and limit our use of it. If you are asked to submit registration details via this site, you may be requested to agree to additional terms regarding our use of your Personal Information, and those additional terms will apply in that context. Any additional terms will be provided for your review at the time of registration.
To provide you services, we collect or you may choose to provide Personal Information that may identify you or relate to you as an individual.
Depending upon the type of relationship you have with The 9, we may collect the Personal Information described in general terms below.
We may collect Personal Information through the following:
We may also collect “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data includes:
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|PURPOSE||DESCRIPTION OF ACTIVITIES||LEGAL BASIS|
|Engage with prospective residents||The activities associated with this purpose may include providing property tours and contacting prospective residents.||Legitimate interests for leasing an apartment, for example, communication regarding your property preferences|
|Applications and Contracts||The activities associated with this purpose may include collecting and processing applications or contracts and communicating with you regarding your application or account. Personal Information will be used to perform credit checks, background checks, or other screenings as necessary for The 9’s know your customer and anti-money laundering requirements.||Performance of a contract to initiate a lease or an employment relationship
Legitimate interests for ensuring prospective residents are financially solvent
Legal obligations, such as sanctions screenings, background checks, anti-money laundering screenings, and identity confirmation
|Operations and General Business||The activities associated with this purpose may include processing or communicating with residents about payments, performing debt collection, providing maintenance or other on-site services, and managing the property. Processing this information also helps us better understand how we can help prospective and current residents.
|Performance of a contract to fulfill your lease
Legal obligations relating to financial transactions, such as the obligation to maintain books and records.
|Marketing and Surveys||The activities associated with this purpose may include communicating with you about our properties and promotions and conducting resident surveys about your experience.||Consent, such as honoring communication preferences
Legitimate interests, such as providing advertisements for our similar products and services
|Security and Legal Obligations||The activities associated with this purpose may include detecting security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, as well as ensure the safety of our residents.||Legitimate interests to protect against malicious activity
Legal obligations relating to data protection and to report illegal activity and security incidents
We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.
We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of The 9 employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.
If The 9 goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Privacy Statement in place at the time of the transfer.
We provide you with options, information, and choices below to express your preferences.
Email Consent and Opt-out
Each of our commercial emails contain a link with instructions on how to remove yourself from our email list. Please note that if you are a resident of a The 9 property and you use this site and your property site, you will need to opt-out of your property site separately. You will also need to opt-out separately from any third-party sites you have registered with.
Cookies and Other Data
For information on your choices related to Cookies and Other Data, please see the Section on Cookies and Other Tracking Technologies, above.
Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Information
You may have the right under applicable privacy laws to request that The 9 inform you as to whether Personal Information relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, change, delete, restrict the use of, or object to the processing of your Personal Information that was previously provided to us. If you wish to exercise your rights, please visit our portals and complete one of the following forms. For your protection, we will verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.
For all other inquiries, or if you have any questions about the forms or our process, feel free to contact us at Privacy@Resident360.com or see the Contact Information section below.
The 9 takes reasonable technical and organizational measures to safeguard users’ Personal Information. While The 9 strives to protect your Personal information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online and therefore you must be aware of this risk.
We limit access to Personal Information to those individuals and organizations who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take precautions we deem reasonable to protect the security of users’ Personal Information. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injurious to the confidentiality of users’ Personal Information notwithstanding the actions we take to prevent this.
Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security when new technology becomes available. This includes use of software which encrypts (generally processed at 256 bits) or distorts data submitted to us relating to an online rental application or employment application.
If users have any questions about security, please contact us using the information in the “Contact Information” section.
We will retain your Personal Information for the period we believe reasonable to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
Our websites are not directed at children. We do not collect or maintain information at our sites from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our sites. By using any of our sites, you represent that you are not under 16 years of age. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable information through any of our websites, please contact us using the information in the “Contact Information” section.
In certain circumstances, we may use automatic decision-making to evaluate your credit against our required criteria. Credit-checking is a mandatory step in our application review process.
In certain circumstances, we will use automated means to conduct sanctions and PEP screenings and in some cases for background checks. This processing is in accordance with our legal obligations and legitimate interests and has meaningful human intervention before making final decisions that may impact your application.
Sanctions screening involves comparing applicants against public lists maintained by the US Office of Foreign Asset Control and other lists maintained by other Governments. We do this through a secure online service and the data used to undertake such searches includes your name, date of birth, and nationality. For common names, the system will sometimes return a result known as a “false positive.” A human analyst will then use additional data you provided, such as your address, to make a final decision about the match.
Individuals who reside in California and have provided their Personal Information to us may exercise their rights under the California Consumer Privacy Act (“CCPA”). California residents can find more information on exercising their rights under the CCPA by calling 1-877-862-2797.
Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.
In many instances, The 9 acts as a separate Controller (as defined in the GDPR) with property owners, who may also use the Personal Information we collect. Owners have the right to use certain Personal Information for their own purposes in accordance with your tenant agreement and in order to comply with their own legal obligations, including maintaining books and records. In other instances, The 9 may be a Processor (as defined in the GDPR) for certain Personal Information, acting on behalf of the owner to manage the property and provide resident services.
If you have any questions about this Privacy Statement, please contact us at privacy@Resident360.com.