Effective Date: March 22, 2022
WHAT THIS POLICY GOVERNS
WHAT INFORMATION WE COLLECT
Town Branch receives two types of data about you: (a) “Personally Identifiable Information” – that is, information from which an individual can be identified, such as your name, email address, home address, and telephone number, that you may provide when using some of the Site’s features; and (b) “Tracking Data”, which is automatically collected from every visitor to our Site (collectively, “Personal Information”). Our collection of Personal Information is described in more detail below.
PERSONALLY IDENTIFIABLE INFORMATION
We collect and store information from you when you submit forms or applications on our Site, contact us through phone or email, respond to surveys, or utilize a resident or client portal account. Although you are not required to share any Personal Information with us, declining to provide such information may limit our ability to provide services to or communicate with you.
RESIDENTIAL APPLICANTS AND LEASE GUARANTORS
Anyone applying to live at one of our communities or to guarantee a lease for another person applying to live at one of our communities will be asked for information needed to process an application, including: (a) name, (b) address, (c) telephone number, (d) email address, (e) social security number, (f) date of birth, and (g) your preferences regarding your future apartment. We will use this information to process the application and also to contact the applicant and/or guarantor.
Any resident of one of our communities has provided Town Branch with Personally Identifiable Information, including: (a) name, (b) address, (c) telephone number, (d) email address, (e) social security number, (f) and date of birth. We will use this information to complete your resident profile and also to contact you regarding your residency with us. We will share only your name, telephone number, and email address with potential roommates in your apartment and also with third party vendors who provide resident services at your community, like utility billing, valet trash or package services, or marketing services on behalf of Town Branch.
Anyone submitting a form on this site to obtain more information about Town Branch our any of our communities will be asked for information needed to provide the requested information, including: (a) name, (b) address, (c) telephone number, and (d) email address. We will use this information to contact you for marketing and solicitation purposes.
Anyone submitting a form on this site to obtain more information about Town Branch’ management, development, or consulting services will be asked for information needed to provide the requested information, including: (a) name, (b) address, (c) telephone number, and (d) email address. We will use this information to contact you for marketing purposes regarding potential business opportunities.
Those applying for employment with Town Branch will be asked for Personally Identifiable Information, including: (a) name, (b) address, (c) age or date of birth, (d) email address, (e) occupation, (f) employment information, (g) telephone number, (h) educational background and (i) Social Security/national insurance number, (j) credit checks, (k) background checks and (l) employment verification. Where legally required, we will obtain your consent before undertaking these checks. Once a candidate accepts a position, the candidate may be asked to complete further online details. This may include an invitation to self-identify ethnicity or race. This information is only collected in relation to positions in some jurisdictions and we do this to meet government reporting requirements. Provision of this information by candidates is voluntary and it is not collected where it would be unlawful for us to do so.
Also, we may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward to us your email address and other information about you so that we may contact you as requested. This may include information about you provided to us by your college or university in accordance with their policies on sharing of personal information.
TRACKING DATA AND ANALYTICS
Tracking Data consists of information we collect automatically from each Visitor, such as browser type, operating system, Internet service provider, IP address, and referring page or site. Tracking Data may include information such as the pages you visit and features you use, the total number of your Site or page visits, your search terms, and the average time you spend on a page or area of the Site.
Town Branch uses Tracking Data to create aggregate reports on visitor demographics, Site traffic patterns and user behavior, and may provide these reports to advertisers and other third parties.
We may combine the Tracking Data we collect from you with your Personal Information and use the combined information for our own customer research and marketing purposes, such as to identify which Site users we think are most likely to lease an apartment in the near-term. We may share the results of that research with third parties, but we will not share the combined information with any third party for its own marketing or other use.
There are a number of different types of cookies, however, our website uses:
Functionality – Town Branch uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and your location. A mix of first-party and third-party cookies are used.
Advertising – Town Branch uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
Analytics – Town Branch may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the Sites and enable us to improve the way they work. Analytics cookies collect information about how you use the Sites, for instance, which pages you go to most. The information allows us to see the overall patterns of usage, help us record any difficulties users may have while using the Sites and show us whether or not our advertising is effective.
Town Branch reserves the right to use an Advertiser to serve such advertisements in the future. If so, please be advised that such Advertisers may place cookies in your browser’s cookie file, which would enable such Advertisers to record which ads your browser has seen, and which Site pages you may have been viewing when the ads were delivered. Such cookies would only be able to be viewed by the applicable Advertiser(s), and not by Town Branch.
HOW WE USE INFORMATION WE COLLECT
Town Branch uses your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and services, including analysis of Site activity;
- To inform you about services and products available from Town Branch;
- To authorize access to our Sites and services;
- To provide, maintain, administer or expand the services, or for other internal purposes to support, improve or enhance our business and the services we offer;
- To offer and administer programs;
- To customize or tailor your experience of the services;
- To administer content, or other Site features;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, and other offers or promotions, and to deliver pertinent emails;
- To improve our Site and services;
- To secure our services;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- To respond to and support you regarding your use of the Sites and services;
- To comply with all applicable legal requirements;
- To perform data analysis and testing;
- To resolve disputes;
- To improve products and services; and
- To otherwise fulfill the purpose for which the information was provided.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our users.
We use information collected from cookies and other technologies, to improve your experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
YOUR FAILURE TO PROVIDE PERSONAL INFORMATION
Your provision of Personal Information is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Information, you may not be able to access and use our services, or parts of our services.
Town Branch may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into 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 for the purposes set forth in the contract.
Town Branch does not sell your information, however, it may be necessary to share your information with third parties in certain business or legal circumstances, as detailed below.
Town Branch works with third parties who provide services that may include, but are not necessarily limited to, website hosting, data analysis, email services, and other services of an administrative or technical nature. Town Branch reserves the right to share Personal Information collected on this Site with those third parties for the purpose of providing such services.
We attempt to notify consumers about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are over-broad, vague or lack proper authority, but we do not promise to challenge every demand.
We may disclose your Personal Information in the event of a business transfer. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that Town Branch itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.
Town Branch takes reasonable measures in accordance with applicable laws to safeguard users’ Personal Information. While Town Branch strives to protect your Personal Information and therein your privacy, we cannot guarantee the security of any information. Such information is provided to us at your own risk. Our policies do not extend to the general operation of the Internet, which is beyond our control.
We limit access to Personal Information to employees who will reasonably need to receive such information to perform their jobs and provide our services to you, but we take precautions we deem reasonable to protect the security of users’ Personal Information. We inform our employees of the sensitivity of the data submitted to us and instruct them to handle it with care to limit improper access by third parties. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be harmful to the confidentiality of users’ Personal Information.
HOW LONG WE STORE YOUR DATA
We determine the appropriate retention period for Personal Information on the basis of the amount, nature and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
YOUR RIGHTS AND CHOICES
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your Personal Information. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law and upon your request, we will provide you with copies of your Personal Information, make reasonable efforts to remove your Personal Information from our active databases or correct any erroneous information. To make this request, email us at email@example.com. In accordance with applicable law, and to help protect your privacy and security, we will take steps to verify the identity of any individual making such a request. Such information will be corrected or deactivated as soon as reasonably possible. We reserve our right to deny a deletion request when we must maintain your information for the purpose of completing transactions; upholding legal obligations; maintaining security and existing functionality; and allowing for internal, expected, and lawful uses based on your expected relationship with our business.
EUROPEAN PRIVACY RIGHTS
The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom, provide European and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area and the United Kingdom, you may have the following rights:
The right to access. You have the right to request copies of your Personal Information from Town Branch. We may charge you a small fee for this service.
The right to correction – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete any information you believe is incomplete.
The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
The right to restrict or object to processing – You have the right to request that we restrict the processing of your Personal Information, or fully object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer your data to another organization, or directly to you, under certain conditions.
The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
The right to lodge a complaint with a supervisory authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you would like to exercise any of these rights, please contact us via email at firstname.lastname@example.org or write to us:
The Site or services are not intended for use by children. We do not intentionally gather Personal Information about visitors who are under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at email@example.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
HOW TO CONTACT US
If you have any questions or concerns about this Policy, our Terms and Conditions, or how your own information has been collected or used, please contact us via email at firstname.lastname@example.org, or by mail or telephone at:
CHANGES TO POLICY
We reserve the right to make changes to this policy at any time without notice. Although we may notify you of updates via any contact information provided, we are not required to do so. It is your responsibility to review this policy for modifications each time you visit the Site, which will be indicated by the “last revised on” date at the top of this page. Your continued use of the Site is considered an acceptance of any and all changes to this policy.