Rent Dynamics Privacy Policy

For Residents of California and certain other U.S. States: Notice at Collection

Simplified Business Group, LLC doing business as Rent Dynamics (“we,” “us,” “our”) is a subsidiary of Entrata, Inc.  We offer financial wellness products and services, including RentPlus, RentPlus Money, credit monitoring and identity protection, and financial education programs (collectively, the “Services”) to rental property residents who purchase Services directly from us (“Customers”), clients who are typically residential real estate property managers, owners, or operators (“Clients”), who use our Services to manage or provide services to their residents (“End Users”), and visitors to our websites (“Visitors”).

It is important to us that we provide transparency regarding our collection, use, and disclosure of information that relates to a person or that can be reasonably linked to a person (“Personal Information”).  This Privacy Notice governs our collection, use, and disclosure of Customers’, Clients’, and Visitors’ Personal Information in connection with the Services, including from the websites we control and that link to this Privacy Notice (“Sites”).  It also describes the available rights and choices in connection with our use of Personal Information.

Important: This Privacy Notice does not apply to End Users. Our privacy obligations with respect to End User Personal Information are governed solely by the agreements under which the Services are provided to our Clients and applicable law. Rent Dynamics generally has no direct relationship with End Users, and we merely host or process End User Personal Information on behalf of our Clients in our capacity as a service provider.  Our Clients, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their residents’ Personal Information.  If you are a resident (i.e., an End User) and you have any questions      about how your property manager (i.e., a Client using our Services) collects, stores, or uses your Personal Information, please contact your property manager directly.

The Rent DynamicsSites may contain links to other third-party websites.  The information practices and content of such third-party websites are governed by their own privacy notices.  We encourage you to review the privacy notices of such third-party websites to understand their information practices.

We will update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, and other factors.  We will let you know when we update this Notice by updating the “Last Updated” legend at the top or other appropriate means.  Any changes will become effective when we post the revised Privacy Notice on the Services.

We collect Personal Information in various ways, such as when you: visit the Sites, use the Services, enter into a transaction or contractual arrangement with us, sign up for our newsletters or request other information or promotional communications, contact our customer services, or in connection with your inquiries and communications with us.

We collect the following categories of Personal Information:

• Personal Identifiers, such as name, email address, alias, IP address, account name or login credentials, phone number, addresses, government-issued identifiers (for example, Social Security number), community or social media username, and account profile photo (if you connect your account with another service, such as Facebook or Google).
• Records Information,such as name, contact information, signature, email address, phone number, insurance information such as insured unit number, insurance policy number, policy coverage levels, lease period, and co-occupants (co-residents, co-tenants), financial information including financial account number, bank account number, credit/debit card numbers, employment information
• Commercial Information,such as rent and utility payment information, insurance information (insured unit and policy numbers, policy coverage levels), lease period, bank account number, credit or debit card numbers, credit information, financial account information (including transactions), business email, business telephone, transactions, account balances, billing information, a record of sales, purchases, and uses.
• Internet or Network Activity Information, such as browsing history, search history, interactions with our online properties or ads.
• Audio data,such as electronic content produced by individuals using our systems including online interactive and voice communications such as through email, phone, or network sessions.
• Employment Information, such as employer name or company affiliation, job title, work email address, and work phone number.
• Inferences that are drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics or behavior.

Sensitive personal information: Some Personal Information we collect is defined under certain laws as sensitive personal information.  Sensitive personal information we collect includes Social Security number, customer account log-in, financial account number, debit card number, and credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

We collect Personal Information from Customers, Clients, and Visitors when they provide it to us through our Services and Sites.  We may also receive information from third-party providers, including public databases, third party data providers, service providers, and advertising sources and from our parent company, Entrata, and other companies that are owned or operated by Entrata.

We use Personal Information for the following purposes:

To provide the Services. This includes:

• Administering, operating, maintaining, and securing our Services.
• Monitoring and analyzing trends, usage, and activities in connection with our Services.
• Administering Customer and Client account(s) or administering account access to our Services.
• Enforcing our Terms of Use and any other contractual terms and conditions that govern the relationship between Rent Dynamics and our Customers and Clients.

Marketing. This includes:

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
• Informing you about our various Services.
• Re-engaging you if you have expressed an interest in our Services.
• Contacting you to set up a demo as a prospective Client.

Improving, customizing, and personalizing our Services. This includes:

• Analyzing and improving the safety and security of our Services.
• Carrying out machine learning, data extracting, and loading data in data warehouses, to support our enterprise software, data access, modifications, and operations.
• Educating and training our workforce in data protection and customer support.
• Conducting research and surveys to develop new features and Services.

Operations and general business purposes (to keep the Services updated and relevant and to develop our organization).  This includes:

• Processing and completing transactions, and sending you related information, including alerts and notifications about your service, purchase confirmations, and invoices.
• Data analysis, for example, to improve the efficiency of the Services.
• Audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
• Fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• Promoting the safety and security of the Services, our users, and other parties.  For example, we may use information to authenticate users, facilitate secure payments, respond to legal requests or claims, investigate and protect against fraud, malicious or unauthorized access, and other illegal activities, and to demonstrate and verify compliance with our internal policies and procedures and applicable data and privacy security laws and regulations.
• Identifying performance trends with respect to specific products or services, including performance metrics and other indicators of basic product understanding trends and other metrics program metrics to identify user experience issues with the Services.
• Operating and expanding the Services.
• Accounting, record keeping, backup, and administrative purposes.

Communicating with you. This includes:

• Providing and improving our customer service.
• Facilitating communications generally in the context of our business activities.
• Tracking and responding to Customer and Client inquiries, reviews, or correspondence regarding the Services.
• Sending administrative information to Customers and Clients, such as changes to our terms, conditions, and policies.
• Responding to inquiries, for example, when prospective Customers and Clients send us questions, suggestions, compliments, or complaints, or request further information about our Services.
• Customizing and improving the content of our communications, websites, and social media accounts.

Use of De-identified Personal Information. “De-identified” means information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer.  We deidentify Personal Information to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.  Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

We disclose Personal Information that we collect to:

• Affiliates.  We may disclose Personal Information to our parent company Entrata, Inc. and any subsidiaries and affiliates within the Entrata corporate group to provide the Services.
• Clients.  We may disclose Customer Personal Information to a Client who has a business relationship with that Customer, in order to administer the Service.
• Service Providers.  We disclose Personal Information to our service providers who perform certain services necessary to run our business (for example, data hosting and development, data analysis, customer support, auditing, information technology, payments, sales, marketing, research and surveys, and other services).
• Third-Party Business Partners and Marketing Partners.  For example, we may disclose Personal Information to third parties to permit them to send you marketing messages, consistent with your choices.
• Credit Bureaus.  In connection with RentPlus, we report information about your rental payments to credit bureaus.  Late payments, missed payments, or other defaults on your account may be reflected in your credit report.
• Law enforcement, regulators, and other parties for legal reasons.  We may disclose Personal Information to comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
• Third parties in connection with a business transaction.  We may disclose Personal Information to a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Rent Dynamics’ assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or a similar proceeding in which Personal Information held by Rent Dynamics is among the assets to be transferred.
• Third parties to enforce our or others’ rights.  We may disclose Personal Information to external parties to the extent necessary to enforce or protect our or others’ rights, privacy, safety, or property (including our Terms of Use and any other agreements) or to investigate fraud or to protect the security or integrity of our Sites or any Services.

Our services are not intended for children. We do not knowingly collect Personal Information from children under the age of sixteen without authorization by a parent or guardian.  If you believe that we may have collected Personal Information from or about a child under the age of sixteen, please contact us in accordance with the How to Contact Us section below.

Some Services support payments and transactions with third parties.  If you activate this feature, you must provide certain information for identification and verification, such as your name, billing address, credit, debit or other card number, card expiration date, and CVV code.  This information is used solely to check your financial qualifications and collect payment from you. We do not store your payment information.  We use a third-party service provider to manage payment card processing.  Note that our third-party payment processors may retain this information in accordance with their own privacy policies and terms.  These processors are not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

“Other Information” is information that does not reveal your specific identity or directly relate to an identifiable individual.  We and our service providers may collect and use Other Information in a variety of ways, including:

• Your browser or device.  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version.  We use this information to ensure that the Services function properly.
• Cookies.  Cookies are pieces of information stored directly on your computer.  Cookies allow us to collect such information as browser type, time spent on the Services, pages visited, language preferences, and traffic data.  We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  If you do not want information collected using cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
• Pixel tags and other similar technologies.  We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about use of the Services and response rates.
• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps, and online services.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Advertising.  We may use third-party advertising companies to serve advertisements that may be of interest to you when you access and use our online services and other websites or online services.  You may receive advertisements on any of your devices, based on information relating to your access to and use of our Services and other websites or online services, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser, including through the use of pixel tags.  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to limit cross-app data sharing.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Privacy Notice.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information.

We seek to use reasonable organizational, technical, and administrative measures to protect your Personal Information.  No method of transmitting or storing data is completely secure, however.  You are responsible for keeping your username and password to access the Services confidential.  If you have a security-related concern, please contact us.

Where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS).

You may have various privacy rights under U.S. federal and state laws depending on where you live. Under most circumstances, your requests should be submitted to the property manager that operates your apartment community or rental property. As stated above, Rent Dynamics is a service provider for our Clients, and we do not control the collection, use, or disclosure of End Users’ Personal Information. However, if you are a Customer, Client, or Visitor (as defined in the Introduction above), requests should be submitted directly to Rent Dynamics as described below.

You may also opt out from receiving marketing-related emails from us.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the “Unsubscribe” option contained in any such email.  

Subject to applicable law, you may make the following requests:

1. Right to know and access your Personal Information. You may request the specific pieces of Personal Information we have collected about you and to know:
   • the categories of Personal Information we’ve collected or “shared”;
   • the categories of sources from which we collected such Personal Information;
   • the business or commercial purpose for collecting or “sharing” such Personal Information;
   • the categories of third parties to whom we disclosed or “shared” such Personal Information.

1. Right to correct Personal Information. You may request we correct any inaccurate information we have about you. We may request that you provide documentation to support your request.
2. Right to deletion of Personal Information. You may request deletion of Personal Information collected from you, subject to certain exceptions including that we need the Personal Information to:

1. complete a transaction or provide a Service you requested, service your account, or take actions reasonably anticipated within the context of our ongoing business relationship;
2. detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. comply with a legal obligation; or
4. otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
5. Non-discrimination right. We will not discriminate against you if you exercise any of the privacy rights described in this Notice.  

Submitting a request: To make a request, please send an email to dataprivacy@homebody.com, fill out this form, or call us toll-free at 1-877-577-0850.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information  subject to the request.  In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies.  We may need to request appropriate identification, depending on the sensitivity of the information requested, to verify your identity and protect against fraudulent requests.

Requests from authorized agents may be submitted via the same methods listed above.  Not all kinds of requests can be made by authorized agents in all states.  We may request proof of status as an authorized agent or require the consumer to directly verify their identity with us.

Appeals process: Subject to applicable law, you may appeal a denial of your request within a reasonable period after you have received notice of the denial.  You may file an appeal by contacting us at dataprivacy@homebody.com or calling us toll-free at 1-877-577-0850.

Where you have set up an account with us, it is your responsibility to keep your Personal Information up to date, and you may update your account profile information by logging in to your account. If you have an account with one of our Clients, please contact that Client for information on how to update your profile information.

Certain state laws provide the right to opt out of targeted advertising, including the “sharing” of your information for cross-context behavioral advertising. To request to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising, or any future processing for purposes of targeted advertising, complete this form. You may also opt-out by enabling a universal tool that automatically communicates your opt-out preferences through browser settings such as the Global Privacy Control (“GPC”).  For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes and which categories we “share” for purposes of cross-context behavioral advertising or targeted advertising in the twelve months preceding the date this Privacy Notice was last updated.

We do not “sell” Personal Information, as that term is defined under applicable law, including within the twelve (12) months preceding the date of this Privacy Notice.   Without limiting the foregoing, we do not knowingly “sell” or “share” the Personal Information of minors under the age of sixteen (16) years of age.

Subject to your consent where required by applicable law, we use sensitive personal information only as reasonably necessary to perform or maintain the Services you requested, to perform services on behalf of the business such as maintaining or servicing accounts, processing payments, to provide analytics services or similar services, to verify your information, to detect security incidents, resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for those actions, to ensure the integrity, security, and safety of our systems, to display first party, non-personalized advertising for short term transient purposes, to ensure customers and other peoples’ physical safety, to verify or maintain the quality or safety of service, improve, upgrade or enhance service, or other reasons that do not require an opt-out of this use under applicable laws.

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As described above, we also process Personal Information pertaining to End Users submitted by or for a Client to our Services.  To this end, if not stated otherwise in this Privacy Notice or in a separate disclosure, we process such Personal Information as a processor on behalf of our Clients (and their affiliates) who is the controller of the Personal Information (see the Introduction above).  We are not responsible for and have no control over the privacy and data security practices of our Clients, which may differ from those explained in this Privacy Notice.

If you have any questions or concerns related to our collection, use, or disclosure of Personal Information, please feel free to contact us at:

Attn: Legal Department

4205 Chapel Ridge Road

Lehi, UT 84043

dataprivacy@homebody.com