Tortoise Community Management (referred to herein as “Tortoise Community Management”, “we”, “us”, or “our”), recognizes the importance of protecting the privacy of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“Personal Information”), particularly our consumers or users (referred to as “you” or “your” in this Privacy Statement).This Privacy Statement applies to information we collect:
through Tortoise Community Management websites operated by Tortoise Community Management and its affiliates;
through other websites and online services that we own, operate, or make available and that link to this Privacy Statement;
when you apply or rent at one of our properties, or through other offline interactions (on-site property visits);
when you apply for a job with Tortoise Community Management;
when you engage with us as a third-party vendor or contractor;
through other general inquiries we receive (including postal mail, electronic mail, telephone requests, and in person).
Collectively, we refer to the websites, online services, property visits and offline interactions as “services.” This Privacy Statement describes what Personal Information we gather, how we use it, how it is shared and how you can access, delete, correct, change, and limit our use of it. If you are asked to submit registration details via this site, you may be requested to agree to additional terms regarding our use of your Personal Information, and those additional terms will apply in that context. Any additional terms will be provided for your review at the time of registration.
The Personal Information We Collect
How and Where We Collect Your Personal Information
Cookies and Other Tracking Technologies
Why We Use Your Personal Information
How and When We Share Your Personal Information
Your Privacy Preferences and Rights
Other Important Provisions
Contact Information
THE PERSONAL INFORMATION WE COLLECT
To provide you services, we collect or you may choose to provide Personal Information that may identify you or relate to you as an individual.
Depending upon the type of relationship you have with Tortoise Community Management, we may collect the Personal Information described in general terms below.
HOW AND WHERE WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal Information through the following:
COOKIES AND OTHER TRACKING TECHNOLOGIES
We may also collect “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data includes:
WHY WE USE YOUR PERSONAL INFORMATION
PURPOSE | DESCRIPTION OF ACTIVITIES | LEGAL BASIS |
---|---|---|
Engage with prospective residents | The activities associated with this purpose may include providing property tours and contacting prospective residents. | Legitimate interests for leasing an apartment, for example, communication regarding your property preferences |
Applications and Contracts | The activities associated with this purpose may include collecting and processing applications or contracts and communicating with you regarding your application or account. Personal Information will be used to perform credit checks, background checks, or other screenings as necessary for Tortoise Community Management’s know your customer and anti-money laundering requirements. | Performance of a contract to initiate a lease or an employment relationship Legitimate interests for ensuring prospective residents are financially solvent Legal obligations, such as sanctions screenings, background checks, anti-money laundering screenings, and identity confirmation |
Operations and General Business | The activities associated with this purpose may include processing or communicating with residents about payments, performing debt collection, providing maintenance or other on-site services, and managing the property. Processing this information also helps us better understand how we can help prospective and current residents. | Performance of a contract to fulfill your lease Legal obligations relating to financial transactions, such as the obligation to maintain books and records. |
Marketing and Surveys | The activities associated with this purpose may include communicating with you about our properties and promotions and conducting resident surveys about your experience. | Consent, such as honoring communication preferences Legitimate interests, such as providing advertisements for our similar products and services |
Security and Legal Obligations | The activities associated with this purpose may include detecting security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, as well as ensure the safety of our residents. | Legitimate interests to protect against malicious activity. Legal obligations relating to data protection and to report illegal activity and security incidents. |
HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION
We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.
We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of Tortoise Community Management employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.
BUSINESS TRANSITIONS
If Tortoise Community Management goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Privacy Statement in place at the time of the transfer.
YOUR PRIVACY PREFERENCES AND RIGHTS
We provide you with options, information, and choices below to express your preferences.
For all requests and inquiries, or if you have any questions about the forms or our process, feel free to contact us at info@tortoisecm.com.
SECURING INFORMATION
Tortoise Community Management takes reasonable technical and organizational measures to safeguard users’ Personal Information. While Tortoise Community Management strives to protect your Personal information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online and therefore you must be aware of this risk.
We limit access to Personal Information to those individuals and organizations who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take precautions we deem reasonable to protect the security of users’ Personal Information. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injurious to the confidentiality of users’ Personal Information notwithstanding the actions we take to prevent this.
Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security when new technology becomes available.
RETENTION
We will retain your Personal Information for the period we believe reasonable to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
CHILDREN’S PRIVACY
Our websites are not directed at children. We do not collect or maintain information at our sites from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our sites. By using any of our sites, you represent that you are not under 16 years of age. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable information through any of our websites, please contact us using the information in the “Contact Information” section.
PROFILING AND AUTOMATIC DECISION-MAKING
In certain circumstances, we may use automatic decision-making to evaluate your credit against our required criteria. Credit-checking is a mandatory step in our application review process.
In certain circumstances, we will use automated means to conduct sanctions and PEP screenings and in some cases for background checks. This processing is in accordance with our legal obligations and legitimate interests and has meaningful human intervention before making final decisions that may impact your application.
Sanctions screening involves comparing applicants against public lists maintained by the US Office of Foreign Asset Control and other lists maintained by other Governments. We do this through a secure online service and the data used to undertake such searches includes your name, date of birth, and nationality. For common names, the system will sometimes return a result known as a “false positive.” A human analyst will then use additional data you provided, such as your address, to make a final decision about the match.
We may also use third parties to serve tailored advertisements that may interest you. To serve these advertisements, those third parties place a cookie or other tracking technology on your browser to profile your access and use of our online services. For more information about Tortoise Community Management’s use of Cookies and how to manage your cookie preferences, see the section on Cookies and Other Tracking Technologies, above. If you would like more information about this practice, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.
NOTICE TO CALIFORNIA RESIDENTS
Individuals who reside in California and have provided their Personal Information to us may exercise their rights under the California Consumer Privacy Act (“CCPA”). California residents can find more information on exercising their rights under the CCPA or by calling 1-877-862-2797.
NOTICE TO RESIDENTS OF CERTAIN STATES
Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.
CONTROLLER & DATA PROCESSOR
In many instances, Tortoise Community Management acts as a separate Controller (as defined in the GDPR) with property owners, who may also use the Personal Information we collect. Owners have the right to use certain Personal Information for their own purposes in accordance with your tenant agreement and in order to comply with their own legal obligations, including maintaining books and records. In other instances, Tortoise Community Management may be a Processor (as defined in the GDPR) for certain Personal Information, acting on behalf of the owner to manage the property and provide resident services.
UPDATES TO THIS PRIVACY STATEMENT
Any changes we make to this Privacy Statement will become effective upon posting. If we change our Privacy Statement, we will advise users of those changes through a general description at the top of this Privacy Policy and may also post these details to other places we deem appropriate. If we are legally permitted to do so, we may also email you.
CONTACT INFORMATION
If you have any questions about this Privacy Statement, please contact us at
info@tortoisecm.com.
4400 Keller Avenue, Suite 140, PMB 312 Oakland, CA 94605