PRIME PRIVACY POLICY
Updated: March 29, 2024
Prime Residential and Prime Finance (collectively, “Prime Group,” or “Prime,” “we,” “us,” or “our”) are committed to protecting the privacy of identifiable individuals through our compliance with this Privacy Policy. We have created this Privacy Policy to inform you of our policies regarding the collection, use and disclosure of personal information as well as the rights and choices you have associated with that information.
This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline in order to provide you access to rental housing, debt, preferred equity or similar financing or investment opportunities, as applicable (collectively, the “Services”). Such personal information may be collected in the following manners:
By accessing, visiting or using our Services, you acknowledge that you understand that your personal information will be processed as described in this Privacy Policy. If you do not feel comfortable with any part of this Privacy Policy, you should not use or access our Site or Services.
We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.
INFORMATION WE COLLECT AND HOW WE COLLECT IT
We may collect your personal information when you interact with our Site, mobile applications, with us over email or phone and at physical locations. Personal information is any information that directly or indirectly identifies, relate to, describes, or is reasonably capable of being associated or linked to you.
The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and Services, information from other sources to help us supplement our records, improve the personalization of our service to you, promote safety at our apartment communities, and/or detect fraud.
Information You Voluntarily Provide to Us. The personal information we collect on or through our Site or Services may include:
Information from Third Parties. We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, we may collect credit or identity information, as well as conduct civil and criminal background checks, which we use to help prevent and detect fraud or to ensure safety at our apartment communities.
Information Collected from Other Sources. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
Information Collected Automatically. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar tracking technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (“behavioral tracking”).
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Site or Services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site, to enhance your experience with the Site, to remember information you have already provided; and to provide a secure browsing experience during your use of our Site. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
The following types of cookies are used on our Site:
Managing Cookies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you choose to disable cookies in your browser, you can still use our websites, although your ability to use some of the features may be affected.
Managing Analytics. We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout. We use these analytics tools in restricted processing mode such that we do not share any personal information about your Site visitors with Google.
Managing Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the contact information in the “Contact Us” section below to notify us of your opt-out preference.
We may share or disclose your personal information in the following circumstances:
Please note that we may disclose, without restriction, aggregated or anonymized information about our users, which is information that does not identify any specific individual.
To provide Services to you, we may send you communications related to your transactions, security, or the administration of this Site. From time to time, we may also send you other messages or updates about Prime, our website, and promotions or other activities. If you do not wish to receive non-transaction/security-related communications from Prime Group, you may opt-out by clicking the “unsubscribe” link if available in the communication or contact us where specified in the “Contact Us” section, below.
Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws and regulations), resolve disputes and enforce our legal agreements and policies.
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer data, including personal information, to United States and process it there. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.
If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy.
Categories of Personal Information Collected, Used, and Disclosed
In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):
We generally do not collect biometric information and education-related information. For more information about the personal information we collect and how we collect it, please refer to Section 1 above.
Purposes for Colleting and Using Categories of Personal Information
We collect and use your personal information for the following business purposes:
For more information about the purpose of collecting and using the categories of personal information listed above, please refer to Section 3 above.
Your Rights
California residents have certain rights. Your rights in relation to your personal information are not absolute. Access to your rights may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons. , Subject to certain limitations or exceptions, California residents have the following rights:
We do not knowingly sell or share the personal information of any user under the age of 18.
We will not discriminate against you for exercising any of your rights. This means we will not: (a) deny your services; (b) charge you different prices or rates for goods or services, including granting discounts or other benefits or imposing penalties; (c) provide you a different level or quality of services; or (d) suggest that you may receive a different price or rate for services or a different level or quality of services.
Submitting a Rights Request
To exercise the rights described above, please submit a verifiable consumer request to us either by email at ccpainquiry@primegrp.com, and putting “California Rights Request” in the subject line or by contacting us at 888.457.0941.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This means that in making a request you may be required to: provide your email and phone number, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the personal information that is the subject of the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we are unable to verify your identity, we reserve the right to deny the request. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you choose to use an authorized agent to submit a request to delete, a requests to correct, or a request to know, we may require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with us. We will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4121 to 4130. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
How to Submit Opt-Out Requests. To exercise your right to opt-out of sales and targeted advertising, you can click on the cookie symbol in the lower left hand corner of our website, and slide the “Targeting Cookies” to off in the Privacy Preference Center pop-up. Please note that you may still receive generalized ads after opting out of targeted advertising.
You may also opt-out of sharing and sales by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Please note that the opt-out choice will only apply to your use of our Sites through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Sites to completely opt-out using this method.
We are committed to protecting your personal information from unauthorized access and use. To help protect your personal information, we implement and maintain appropriate technical, physical, and administrative safeguards. We aim to restrict access to your personal information solely to those employees and vendors who need to know that information to provide our Services to you. Our employees receive training to maintain the confidentiality, privacy, and security of your personal information.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
We do not offer Services to minors and do not intend to collect personal information from children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18. If an individual under the age of 18 has provided us with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.
The Site may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including third-party services. The Site may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Site or for the services or the privacy practices of third-party advertising companies. Once you leave this Site or our Services via a link, access a third-party service or click on an advertisement, you should check applicable privacy policies to determine, among other things, how related companies process personal information they may collect about you. This Privacy Policy applies solely to information collected by Prime.
We welcome your questions, comments, and concerns about privacy. If you have any questions or comments regarding this Privacy Policy please email us at ccpainquiry@primegrp.com or you can write to us at 600 Montgomery Street, Suite 1700, San Francisco, CA 94111.