PRIVACY POLICY

1. OUR PRIVACY PHILOSOPHY

At Tricon American Homes (“TAH”, “we”, “us” or “our”) we sincerely value the trust that you have placed in our business. We have adopted this privacy policy (the “Policy”) to affirm our commitment to maintaining the accuracy, confidentiality, and security of personal information. This Policy shall apply to personal information about you, our resident or our applicant, that we collect through our websites, applications and anywhere else Tricon American Homes may engage with you. This Policy explains how we collect, use, disclose and safeguard the personal information provided by you or a third party.

If you have any question about our Policy please contact us at the address set out in Section 8.

2. LIMITING THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION

Categories and Types of Personal Information We Collect

We collect the following categories and types of personal information:

  • Contact Information: your first and last name, home address and/or mailing address, past mailing address, email address, business phone number and cell phone number;
  • Other identifying information: social security number, official government documents, IP address, social media usernames, passwords and other security information for authentication and access;
  • Financial Information: payment, banking and other financial history information;
  • Demographic information: age, date of birth, household information, employment information and salary information;
  • Geolocation data;
  • Internet or other electronic activity: your browsing and click history, including information about how you navigate within our services and which elements of our services you use the most;
  • Commercial information: properties viewed on our website;
  • Preferences: details that you provide to us about any special needs of residents and occupants, including disabilities and health concerns; and
  • Inferences: inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.

 

Categories of Use

We use your personal information for the following purposes:

  • Transactional Purposes: We use your contact information, financial information, and commercial information to:
    • Establish your eligibility for tenancy;
    • Identify and communicate with you about matters related to our properties;
    • Assess your creditworthiness;
    • Process payments; and
    • Ensure the orderly management of properties entrusted to our care.

 

  • Analytical Purposes: We use your internet activity and browsing history and geolocation data to analyze preferences, trends and statistics.

 

  • Marketing Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, and inferences to:
    • Inform you of our new properties, products, services, opportunities and offers;
    • Provide you with targeted advertising; and
    • Provide you other information from and about us, including personalized marketing communications.

 

  • Maintenance and Improvement of Services and Website: We use your contact information, commercial information, and internet activity and browsing history to:
    • Provide and maintain functionality on our websites;
    • Handle your customer services requests, including direct your questions to appropriate individuals, investigate and address any of your concerns, and improve and monitor our customer support responses; and
    • Help us diagnose technical and service problems and administer our websites.

 

  • Security and Fraud Prevention: We use your contact information, audio and visual information, other identifying information, financial information, geolocation data, internet activity and browsing history, and inferences to protect the website, our company, our properties and others, and for, fraud detection, theft prevention, emergency response purposes, and legal compliance.

 

Sources of Personal Information

We collect information from the following sources:

We collect information directly from you. We collect personal Information directly from you.

We collect information about you from third parties. We may collect your personal information, financial information, demographic information and other identifying information from third party service providers, such as your credit reporting agencies, background check service providers, and if you submitted your personal data to us via a third party referral source, that third party referral source.

We collect information from you passively. We collect Internet or other electronic activity passively using tools like browser cookies, SDKs and other similar technologies. This activity is further described in the Cookies and Online Tracking section below.

Combining Information

We may combine personal information: (a) internally with other information collected and/or stored by our affiliates in relation to our different products and services offered by Tricon American Homes or one of its affiliates; and (b) with demographic information, publicly available records and other third-party information sources. We may use this information to provide you with a customized experience, to promote and properties and services available through TAH or its affiliates, or as otherwise permitted by this Policy.

When We Share Information with Third Parties

Parties Related to Your Obligations

We may share personal information with third parties, such as co-residents of your obligations under the terms of your residential lease agreement, or to any third-party payor of your obligations under the terms of your residential lease agreement or a related housing agreement. Because Tricon American Homes often owns properties together with other investors, we may share personal information with such investors for audit, management, legal, billing, strategy or administrative purposes including defending and enforcing our legal rights or the legal rights of third parties.

Our Service Providers

We may contract with companies or persons to provide certain services including for purposes of payment processing, data hosting and processing, website development, analytics, billing, leasing or similar services, fulfilling audit or reporting requirements financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets. We call them our Service Providers. We provide our Service Providers with the information needed for them to perform these services. We also ask our Service Providers to confirm that their privacy practices are consistent with ours.

Our Affiliates

We may share personal information with businesses controlling, controlled by, or under common control with Tricon American Homes.

Law Enforcement and Courts

In certain instances, we may disclose your contact information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to TAH or to others. We may also disclose your contact information when we believe the law or legal process requires it.

3. COOKIES AND ONLINE TRACKING

We may collect usage information from users of our services, including through the use of cookies, SDKs, and other similar technologies. Cookies are very small text files that are stored on your browser or device. Usage information collected from our Website and our applications may include your device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use. We may use this information for purposes including remembering your preferences and settings, determining the popularity of certain content, authenticating users, determining the effectiveness of any advertising campaigns, and analyzing the behaviour and interests of people (including traffic and trends) accessing our Website and applications. We may also allow others to provide analytics services (e.g. Google Analytics) and audience measurement services for us, to serve advertisements on our behalf on the Internet, and to monitor and report on the performance of those advertisements. These third parties may perform such services through the use of cookies, SDKs, and other similar technologies. By modifying your browser settings, you may be able to block cookies or otherwise adjust the use of cookies, although this may impair the functioning of certain TAH services. Our systems do not recognize browser “Do Not Track” signals, but several of our service providers who utilize these cookies on our Website enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/.

4. MONITORING AND RECORDING CALLS

For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded. If your call is subject to a quality assurance program, you will be so advised prior to speaking with a representative.

5. KEEPING YOUR PERSONAL INFORMATION ACCURATE

We make reasonable efforts to keep your personal information as accurate, complete and up to date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.

Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.

6. PROTECTING YOUR PERSONAL INFORMATION
To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard. We use modern technologies to ensure that your confidential information is not compromised. We keep electronic customer files in a secured environment with restricted access and use. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from our web sites, and you do so at your own risk.

7. CALIFORNIA CONSUMER PRIVACY RIGHTS

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with TAH.

CCPA Rights Requests

Right to Know and Right to Deletion

You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months:

You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:

  • Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
  • Security: to detect data security incidents;
  • Error Correction: to debug or repair any errors;
  • Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
  • Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

 

To submit a request to know or a request to delete, please click here. In order to verify your identity, we will send you a verification email. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof mailed to the address below so that it is received prior to the time the agent makes the request on your behalf. A request to know or a request to delete may alternatively be initiated by calling us at 844.8743.2661. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.

We Do Not Sell Your Personal Information

We do not and will not sell any personal information (as “sell” is defined in CCPA).

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.

8. ADDRESSING YOUR INQUIRIES AND CONCERNS

We are happy to provide you with a copy of this Policy and to discuss any of its content with you. Please direct all questions or enquiries about this Policy to:

Tricon American Homes
Attention: Privacy Compliance Officer
1508 Brookhollow Drive
Santa Ana, CA 92705
Email Address: privacy@triconah.com

9. UPDATING THIS POLICY

Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. Tricon American Homes reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the revision date at the bottom of this Policy.

We strive to evolve to meet our residents’ needs and expectations, and that means our rental homes and services may change and how we offer our rental homes and services may change. With that in mind, we review our privacy practices from time to time, and our information handling practices may change. If Tricon American Homes makes a material change to this Policy, we will post the updated Policy on our Website. We also may notify you by email or other electronic means.

If at any point you do not agree with the terms of this Policy, you must not use Tricon American Homes’ services or provide personal information to us.

10. THIRD PARTY LINKS

Our websites and such applications may contain links to third-party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third-party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use and disclose your personal information.

If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums, on our websites or other applications, your communications may be viewable by the public.

11. GOVERNING LAW AND PERSONAL INFORMATION IN OTHER JURISDICTIONS

This Policy and all related matters shall be interpreted and construed in accordance with the laws of the State of California.

Tricon American Homes may perform activities outside of your location by itself and through third parties. Personal information provided to us, our service providers, payment processors, affiliates and subsidiaries may be stored inside or outside of the United States. The use made by such third parties shall be in accordance with the terms of this Policy. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other states or countries.

Last revised: Monday, December 23, 2019