This web site (the “Web Site”) is provided by Trinity Management Services and its affiliates, subsidiaries and related entities (“Trinity,” “we,” “our” or “us”). This Privacy Policy describes our privacy practices with regard to information about you that could reasonably be used to identify you personally or that is associated with information that identifies you (“Personal Information”); provided, however that we do not treat Unique IDs (defined below) as Personal Information except to the extent required by applicable law. Unless specifically stated otherwise, this Privacy Policy applies only to Personal Information that we gather or collect via the Web Site and any other Trinity web site or online service that posts a link to this Privacy Policy. It does not apply to any Personal Information collected offline. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Web Site at any particular time.
PLEASE REVIEW THE TERMS OF THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT CONSENT TO OUR PRACTICES AS STATED HEREIN, DO NOT CONTINUE USE OF OUR WEB SITE. YOUR USE OF THE WEB SITE REPRESENTS ACCEPTANCE OF OUR PRIVACY POLICY AND AGREEMENT TO OUR TERMS OF USE , WHICH GOVERN YOUR USE OF THE WEB SITE.
You should read this entire Privacy Policy, but here is a partial list of some of the key topics. Any capitalized terms have the meanings given to them where defined in the Privacy Policy.
We ask you for, and use Tracking Technologies (defined below) to detect, information about you, and third parties may also do so in connection with our Web Site (defined below). As examples:
Third parties, including advertisers and advertising services providers, may collect information about you. They may use Tracking Technologies in connection with our Web Site, which may include the collection of information about your online activities over time and across third-party sites or services. Their privacy policies, not ours, govern their practices.
We do not monitor or take any action with respect to so-called browser do not track signals, but you have certain other options regarding tracking and/or targeting.
We associate Tracking Technologies with your device so we can send you ads about us when you are on other sites, however, you may have certain opt-out options.
Your CA Privacy Rights: California residents have certain rights regarding our sharing of certain personal information with our affiliates for direct marketing.
You consent to our practices detailed in our Privacy Policy. Each time you use the Web Site, the version of our Privacy Policy then posted will apply to that use, subject to Section 11, so check for updates each time you access the Web Site.
1.1 Active Information Collection
We may collect Personal Information from you at various places and through various mechanisms on the Web Site. This may include, for example, when you fill out and submit forms (such as forms requesting information needed to consider you for apartment rentals or potential employment opportunities), when you initiate payments to us through the Web Site, when you participate in promotions, contests, or sweepstakes on the Web Site, when you post to any interactive forum, bulletin board, chat room that we may make available on the Web Site, when you register for e-mail communications, and when you submit a survey response, question or request to the Web Site using a form or the e-mail address links on the Web Site.
1.2 Passive Information Collection
When you visit the Web Site, we automatically collect certain information about your activities (“Web Site Usage Information”). Web Site Usage Information is information about your device, including browser and device identifiers such as IP address (“Unique ID”), and information about how our visitors use and navigate the Web Site. This includes, for example, the number and frequency of visitors to each web page, the length of their stays, the type of browser each visitor is using to view the Web Site (for example, Internet Explorer, Firefox), the type of operating system each visitor is using, (for example, Windows 10, Mac OS X), the domain name of each visitor’s Internet service provider (for example, AT&T, Charter, Comcast, Cox, Time Warner, Verizon), the visitor’s IP address and/or device ID, the address (or “URL”) of the web site that the visitor came from before visiting the Web Site, which pages were visited on the Web Site, what was clicked on, and certain other available information. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which our web servers use to identify where to send the information your computer requests. When you request pages from the Web Site, our servers log your IP address as well as information about your activities on those pages.
To collect this Web Site Usage Information, the Web Site and any e-mails sent to you by the Web Site (or otherwise by Trinity) may utilize cookies, web beacons, embedded scripts or other tracking technologies now and hereafter devised (“Tracking Technologies”).
Cookies. A cookie is a data file placed on a device when it is used to visit the Web Site. A Flash cookie (or locally shared object) is a data file placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. To identify local shared objects on your computer and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs,” “Pixel Tags,” or “Web Bugs”) may be included in our Web Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Web Site, to monitor how users navigate the Web Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Web Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Web Site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of UID. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household).
In addition, third parties may use Tracking Technologies in connection with the Web Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Web Site and accept that our statements under this Privacy Policy regarding our practices do not apply to the Tracking Technologies or practices of such third parties.
Also, various third parties are developing or have developed signals or other mechanisms known as “do not track signals”. For instance, some browsers may have such signal options, though they differ as to if the signal is set as default or must be turned on by the user. Further, there is not yet an industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these signals or other mechanisms, though we may consider doing so if an understandable and practical standard is developed and widely adopted.
Some third parties may offer you certain choices regarding their Tracking Technologies practices associated with our Web Site. For example, you can find information on choices regarding analytics and interest-based advertising is Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out or other choice options. One way to potentially identify Tracking Technologies on our Web Site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. We are not responsible for the completeness or accuracy of this tool.
1.3 Offline Collection from You
Trinity may also collect Personal Information from you through means other than the Web Site. This may include offline collection, such as when you submit a paper application to rent an apartment, make a rent payment by check, or call or visit the management office at an Trinity property. It may also include e-mails that you send to us separate from the Web Site. This Privacy Policy does not apply to Personal Information that you provide to us through means other than the Web Site. However, to the extent we combine the Personal Information we collect from you outside of the Web Site with Personal Information that we collect through the Web Site, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.
1.4 Information Collected from Other Sources
We may receive Personal Information about you from other sources. For example, if you are applying for an apartment, condo, corporate housing, or employment, either via the Web Site or offline, we may obtain information from third parties about your creditworthiness, among other information, as part of the application process. This Privacy Policy does not apply to Personal Information about you that we receive from other sources. However, we may combine the information we receive from these other sources with Personal Information we collect through the Web Site. In those cases, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.
1.5 Children
We are a general audience service and do not use the Web Site to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under thirteen (13) years of age, you are not permitted to use the Web Site and should not send any information about yourself to us through the Web Site.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at (415) 864-1111.
California minors should see Section 5.2 regarding requests to remove content they have posted.
2. Use of Personal Information
We retain and use Personal Information to: (1) provide you with services or process transactions that you have requested; (2) communicate with you regarding information, features or offers that we believe will be of interest to you; (3) respond to your questions or other requests; (4) contact you with regard to the Web Site; (5) process or communicate with you about applications, payments or changes to your account information; (6) process other information or Personal Information that you submit through the Web Site; (7) conduct user surveys; (8) contact you regarding a sweepstakes, contest or promotion in which you have participated, and (9) fulfill other purposes disclosed at the time you provide your Personal Information. We may also use the information you provide to improve the Web Site or Trinity’s services, to customize your experience on the Web Site, to serve you specific content, or for any other purposes not inconsistent with this Privacy Policy or prohibited by applicable law.
3. Sharing of Personal Information with Third Parties
We do not share your Personal Information with third parties for those third parties’ (other than our affiliates) for such third parties’ own direct marketing purposes without your consent. We may share non-personally identifiable information, such as Web Site Usage Information or other aggregated user statistics, with third parties without restriction. In addition, we may share your Personal Information as set forth in this Privacy Policy, in any manner in which you expressly consent via the Web Site, or in the following circumstances:
3.1 Affiliated or Subsidiary Companies
We may share Personal Information with our affiliated or subsidiary companies who require access to Personal Information for business purposes related to your tenancy or to process any application, request, inquiry, or other information or Personal Information you submit via the Web Site, and for our affiliates’ own marketing purposes. This includes the owner of any community where you make application or where you lease, as well as the management company for such community.
3.2 Third parties providing services on our behalf
We may share your Personal Information with third parties who perform services on our behalf or on behalf of the owner of one of our properties, or give them access to collect it. This includes, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. These third parties may have access to Personal information in order to provide these services to us or on our behalf. These third parties may also receive, or be given access to collect, Web Site Usage Information and other non-Personal Information for their own use.
3.3 Legal Requirements and Law Enforcement
We may disclose Personal Information when we believe in good faith that the law requires it; at the request of governmental authorities conducting an audit or investigation (except as prohibited by applicable law); pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Web Site and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Web Site, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
3.4 Sweepstakes and Promotions
If you choose to enter a sweepstakes, contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.
3.5 Corporate Change
We reserve the right to disclose and transfer your Personal Information in connection with a corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change, including for transaction due diligence. For instance, when a potential buyer is interested in purchasing one of our properties, we may provide the potential buyer with information about the property and the tenants who live there, which may include your Personal Information. Upon the sale of the property in which you live, all of your Personal Information may be transferred to the purchaser.
3.6 Equal Employment Opportunity Reporting
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
4. Non-Personal Information
We may share non-Personal Information, such as aggregated user statistics, with third parties. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. Except where prohibited by applicable law, we may share your Unique IDs with third parties along with data (other than Personal Information) related to you and your activities as non-Personal Information under this Privacy Policy.
5. California and Connecticut Residents
5.1 Your California Privacy Rights
We may from time to time elect to share certain information about you collected by us on the Web Site with our affiliates for their own direct marketing purposes. We will not, however, share your personal information with third parties other than our affiliates for their direct marketing purposes without your consent. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2015 will receive information about 2014 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing at: Trinity Residential, Two North Riverside Plaza, Chicago, IL 60606 (Attn: Legal Dept. – CA Privacy Request). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address or mail address.
5.2 California Minors
Any California residents under the age of eighteen (18) who have registered to use the Web Site, and who have posted content or information on the Web Site, can request that such information be removed from the Web Site by contacting us as set forth in Section 13 below. When making such a request, the minor must state that the minor personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.
5.3 Connecticut Residents
Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
6. Exercising Choices Regarding Analytics and Advertising
Trinity may use Google Analytics, Adobe Analytics or other web site providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Trinity analyze how users use the Web Site. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by Google Analytics, Adobe Analytics and other web site providers on servers in the U.S. (or elsewhere) and these web site providers may use this information for purposes such as evaluating your use of the Web Site, compiling statistic reports on the Web Site’s activity, and providing other services relating to Web Site activity and other Internet usage. Trinity only retains aggregated data from Google Analytics and Adobe Analytics. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their websites or tailor their online ads for you.”
Trinity may engage and work with third parties to serve advertisements on Trinity’s behalf on the Web Site, and/or on Third Party Services, and to provide analytics about the performance of Trinity’s ads. Some information about your browsing of the Web Site and certain Third Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Web Site and certain Third Party Services. Trinity may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising” (collectively, “Interest-based Ads”). We may participate in online advertising networks and exchanges that display Interest-based Ads to you on Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of the Web Site.
Certain companies we work with to serve Interest-based Ads participate in the Digital Advertising Alliance (“DAA“) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads on the ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges we work with to serve Interest-based Ads may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Further, opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This selective opting out will affect this Web Site and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expect that ad networks we directly engage to serve you Interest-based Ads will do so as well, though we cannot guaranty their compliance.
7. Updating Your Information
Depending on the functionality associated with the Web Site feature you are using, you may be able to update certain of your Personal Information on the Web Site. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Please note that in accordance with our routine corporate recordkeeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information. California minors should see Section 5 regarding requests to remove content they have posted.
8. Data Security
While we take reasonable steps to secure your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information or other information on the Web Site, or on other servers or databases to which the information may be transferred, can be guaranteed to be completely secure. Please consider this prior to submitting your Personal Information to us via the Web Site.
9. Third Party Content and Services
The Web Site may include functionality that allows certain kinds of interactions between the Web Site and a third-party web site, platform, tool, application or other service, and accessing or display of third-party content via the Web Site (“Third Party Services”). The use of Third Party Services may involve the third-party operator thereof (“Third Party Operator”) providing certain information, including Personal Information, to us. For example, when you register with the Web Site, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Web Site, or otherwise link accounts. In addition, you may be able to access our Web Site, your account and/or Web Site content via a third party platform, site, app or other service, and those Third Party Operators may collect Personal Information and other data about you in connection therewith, and may provide some or all of it to us (e.g., the third party may handle the billing of transactions for us via the Third Party Service and then tell us what you purchased so we can process the transaction).
If we offer and you choose to use Third Party Services to access or use our Web Site, the Third Party Services may send Personal Information about you to us. If we discontinue use of any Third Party Service (e.g., your Facebook or any other account as an access mechanism for the Web Site), you consent that we may nevertheless retain any Personal Information, and other information and data, we may have already received in connection therewith in accordance with this Privacy Policy.
In addition, we may provide Third Party Services’ interfaces or links on the Web Site to facilitate your sending a communication from the Web Site. For example, we may use third parties to facilitate e-mails, tweets, “likes,” content submissions or postings of comments on Facebook or other social media platforms. We may also enable access to or display of third party content via the Web Site, that is actually being served or published by the third party, and such third party may be collecting data from you in connection with that content. These third parties may collect and retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy.
The Web Site may contain content that is supplied by a Third Party Operator, and those third parties may collect Web Site Usage Information, including Unique ID, when such content is served to you. Third Party Services may also be available via the Web Site. We are not responsible for the data collection and privacy practices employed by such third parties or their services and they may be collecting data about you and may be sharing it with us and/or others. These third parties and their services may also associate their Tracking Technologies with you, track you across sites and time, serve you their own ads (including Interest-based ads) and may or may not have their own published privacy policies. When you use Third Party Services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third party privacy policies before using such Third Party Services in connection with our Web Site. We are not responsible for the availability, completeness or accuracy of such third parties’ policies or notices.
10. Links to Other Web Sites
The Web Site may contain links to other web sites whose information practices may be different from ours. You should consult the specific privacy policies posted on these sites when linking to them. We are not responsible for the availability, completeness or accuracy of such third parties’ policies or notices.
11. Privacy Policy Changes
We reserve the right to prospectively alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Web Site, so review the Privacy Policy each time you visit and discontinue use of the Web Site if you do not consent. However, we will continue to use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless we receive your consent to the new or revised policy.
12. Consent to Transfer
The Web Site is operated in the United States. Your Personal Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Web Site or providing us with your information, you consent to this transfer.
13. Questions
If you have any questions about this Privacy Policy, you may contact us by phone at (415) 864-1111.