Last Updated: September 1, 2022
2. The Types and Categories of Personal Information We Collect
Identifiers such as your name, title, company/organization name, e-mail address, telephone and fax numbers, physical address (including street, city, state, postal code, and/or country), and date of birth.
Information provided when you register for an account to use the Site, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)
Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Leasing and Property Management Services Data
Information relating to leasing and underwriting activity including social security numbers, driver’s license numbers and financial information, bank account numbers, and credit/debit card numbers, credit and background checks, compliance with loan covenants, insurance claims management, and the sale of shopping centers.
Information related to your commercial transactions with us and details of payments to and from you, including purchase history and preferences and (limited) payment card information.
Business Contact Data
Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Information about your investments with us, including investment amounts and information provided by completing subscription documents for deals closed, your personal investment entities and their co-owners and beneficiaries, and tax related information in connection with your investments with us.
Marketing and Communications Data
Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network Data
Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.
Information you provide about our Online Services, which may include data gathered from any Ackermann surveys or reviews submitted by you.
Information about the general city, state, or region in which a user of the Site is located.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)
If you apply for a job with Ackermann, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Information collected offline including when you submit a paper application to rent or purchase an apartment or property, make a payment by check, or call or visit the management office.
3. Technical Data
When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:
Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
4. Sources of Information
We collect the personal information identified herein directly from you when you use our Online Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:
First Party / Direct Collection. We collect personal information directly from you when you use our Online Services (e.g., account registration, completing purchases, signing-up for subscriptions), when you provide feedback on our Online Services or a property, or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.
Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).
Third-Party Sources. We collect personal information from third parties, such as publicly available databases, background-check providers, social networking platforms, advertising companies, our service providers, and third-party references.
5. How We Use your Information / Purpose of Collection
We may use the personal information we collect about you in order to perform our Online Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Online Services, and our leasing and property management services, (ii) enable you to access and use our Online Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Online Services and our leasing and property management services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Online Services and our leasing and property management services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Online Services and our leasing and property management services to promote our business interests, (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Online Services, and other illegal activities, and (x) personalize our Online Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, Ackermann may collect and use your personal information for any other purpose for which we obtain your consent.
For the avoidance of doubt, you hereby agree that Ackermann may contact you via any means, including SMS/text message and email, to furnish you information regarding the Online Services, our leasing and property management services, or a commercial transaction.
6. Sharing Information / Third-Party Disclosures
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.
Affiliated or Subsidiary Companies. We may share your personal Information with our affiliated or subsidiary companies who require access to personal Information for business purposes related to your tenancy, investment, or to process any application, request, inquiry, or other information or personal information you submit via the 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.
Service Providers. We may share your personal information with companies that provide services on our behalf, such as our leasing and property management services companies; and entities that host, operate, and analyze the Site; conduct surveys and marketing on our behalf; process transactions; track and respond to consumer questions or complaints; and, perform analyses to improve the quality of our Online Services.
Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.
Business Restructuring. Circumstances may arise where for strategic or other business reasons Ackermann decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of Ackermann’s assets.
Legal Interest; Health and Safety. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, Ackermann may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with Ackermann, or request information from or otherwise engage with us, and such activities require Ackermann to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Ackermann to intentionally disclose your personal information to the service provider or third party.
7. Links to Other Websites; Your Direct Third-Party Disclosures
We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site may include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.
8. Data Retention and Localization
Ackermann is based in the United States and the personal information that we collect, and process is retained and stored in the United States. Our Online Services may only be used by individuals who are located in the United States of America.
We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE ONLINE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Online Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Online Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
10. No Data Collected from Children
11. Your Responsibilities
You are permitted, and hereby agree, to only provide personal information to Ackermann if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO ACKERMANN, YOU EXPRESSLY REPRESENT AND WARRANT TO ACKERMANN THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE ACKERMANN WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT ACKERMANN’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY ACKERMANN FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO ACKERMANN.
12. Updating Your Information
It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, the Site may provide you the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email) and you must do so, when such changes are warranted. If the Site does not contain such features, then you must directly notify Ackermann of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.
13. Email Marketing and Your Rights
You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify Ackermann, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.
14. California Privacy Rights
Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:
- Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and the third parties with whom we have shared your personal information.
- Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
- Data Portability: The right to request that Ackermann transfers, to the extent technically feasible, personal information in certain forms and formats.
- Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.
To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.
Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information under the CCPA, Ackermann will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. Ackermann will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.
Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt-out of the sale of their personal information. Ackermann does not sell your personal information to third parties for profit or other monetary or valuable consideration.
Third-Party Marketing. We do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes. If you have any questions or concerns about our marketing, please contact us in accordance with the “Contact Us” section listed below.
15. Nevada Privacy Rights
Ackermann does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.
16. Do-Not-Track Signals
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
17. Persons with Disabilities
18. Events, Video Teleconferencing, Support Services
Ackermann hosts and uses video teleconferencing platforms, text messaging, and telephone capabilities to facilitate conferences, meetings, training events, customer support, and other programs. We often use online platforms and solutions that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing and telephone customer support capabilities may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our video teleconferencing or telephone customer support capabilities, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
19. Changes to the Policy
20. Contact Us
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