Effective Date: December 31, 2022
How Do We Collect Personal Information
- From you. We may collect personal information and other information that you provide when you apply for a lease or an employment opportunity, create an account, or otherwise use our Services.
- From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.
- From third parties and publicly available sources. This includes personal information we collect from public sources including, but not limited to websites that enable social sharing, social media sites, and from our service providers, vendors, our affiliates, or other individuals and businesses.
- From you in person at a leasing office or in our buildings.
The Types of Personal Information We May Collect From You
Depending on how you interact with us, we may collect the following information:
- Contact Information such as your name, address, email address, telephone number, or other similar identifiers.
- Biographic and Demographic Information such as date of birth, age, gender, and photo.
- Financial and Payment Information such as information needed to process leasing applications including credit scores, credit card details, bank account number, financial information.
- Account Information such as a username and password, profile details you choose to provide, and feedback and reviews you may leave our Services.
- Biometric identifiers and biometric information including facial scans, fingerprints or other identifiers used to verify your identity and authorize you to rent a property from us.
- Internet Usage Information such as browsing history, search history, geolocation, IP address, and information regarding your interactions with AMLI online.
- Device information such as browser or device model and settings, operating system, and unique identifiers.
- Inferences such as inferences drawn from any of the personal information identified.
- Professional Information such as information about your job function and role, title, professional affiliations, employer, and employment history.
- Other Personal Information such as precise geolocation, Social Security Number, and passport number.
- Application and Communication Information such as information in your lease application, job application, or in your communications with AMLI, including interactions with us online and in-person. For those who signed up and previously consented to receive text alerts, this may include mobile telephone number, cell phone provider/carrier, and the date, time, and content of your messages.
- Professional Information such as information about your job function and role, title, professional affiliations, employer, and employment history and any other information that may be obtained from third-party background checks and feedback.
How We Use Your Personal Information
We may use your information for the following reasons, depending on your relationship with us:
- To communicate with you, such as when we respond to your inquiries and send you communications, including our newsletter, regarding our products and services.
- To process, with your authorization, your lease application or employment application, including verifying statements made on your application (e.g., rental, credit and employment history), performing background and credit checks, reviewing your lease for renewal, and enforcing your lease obligations.
- To confirm delivery of a job referral through our Services and to understand who submitted the referral.
- To facilitate housing rentals, including utilizing biometrics to verify your identity and make sure you are authorized to rent housing from us.
- To serve you targeted advertising or content.
- To provide, market, and develop our products and services, including to maintain our websites, troubleshoot, provide customer and technical support, conduct data analysis, test and research, and better understand the interests of our renters and website visitors who use our services and products.
- To conduct marketing research.
- To understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns).
- To maintain the safety, security, and integrity of our Services, for example, by authenticating users and providing account security and fraud detection. We may also use your information to monitor, detect, and prevent fraud and improper or illegal activity.
- To debug our systems, to secure our online services, including our network and websites, and to debug our online services.
- To send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
- To conduct market research and develop quality assurance, including to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
- To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
- To conduct internal business purposes, including for data analysis, audits, and enhancing our Services.
- To process your employment application, including verifying statements made on your application (e.g., credit and employment history) and performing background and credit checks.
How We Disclose Personal Information:
We may collect, use, retain, disclose, and store personal information collected from or about you with any of the following entities and for any of the following purposes:
- Service Providers and Advertising Partners. We may provide personal information to vendors, payment processors, contractors, identification and authentication providers (e.g., providers that process biometric data), business and service partners, or other third parties, such as advertising partners or other marketing partners who provide services to us, including analysis firms, advertisers, and others.
- Within the branches of our Company. We disclose data to other AMLI-branded branches of our company, including our construction branch and development branch.
- Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
- In connection with a merger, acquisition, or business transfer. If we sell all or a part of our company, are part of a merger, consolidation, restructuring, [sale of company stock], and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
- At your direction. We may disclose your personal information at your direction or with your consent.
- Collaborators. We may share personal information with collaborators with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities and promotions.
You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.
We use CCTV video recording at our properties to protect the physical security of our properties and residents in line with applicable laws.
Links to Third Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms, utility connection websites and rent easy-pay websites) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.
If you found us through a locator service, please note that locator services are independent contractors and are not our employees or agents. The companies may fill out guest cards, schedule visits or provide contact information. Locator services may have their own privacy policies. AMLI is not responsible for the privacy practices of these locator services.
Your Advertising Choices
When you use our Services, our third-party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Services and on third party websites.
These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.
Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, local Storage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history.
We and our partners may also use these technologies to gather personal information about how you view and use our Services and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.
Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising.
Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites. We do, however, respond to global privacy preferences when required by law.
Your Marketing Preferences
We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email.
You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly.
There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies or information relating to your leasing application or employment application.
Additional Information for Residents of California
What We Collected, Disclosed, and/or Shared/Sold
In the past 12 months, we have disclosed (or have enabled you to disclose) and have collected the following categories of Personal Information:
Sensitive Personal Information. We do not process “sensitive” Personal Information for purposes other than those specified in the CCPA (such as to provide the Services and for security purposes).
Data Retention. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
We may use this personal information for the following purposes, including commercial purposes:
- to operate, manage, and maintain our business;
- to provide Services;
- to accomplish our business purposes and objectives, including:
◦ developing, improving, repairing, and maintaining our Services;
◦ personalizing, advertising, and marketing Services;
◦ conducting research, analytics, and data analysis;
◦ maintaining our facilities and infrastructure;
◦ quality and safety assurance measures;
◦ conducting risk and security controls and monitoring;
◦ detecting and preventing fraud;
◦ performing identity verification;
◦ performing accounting, audit, and other internal functions;
◦ complying with the law, legal process, and internal policies;
◦ maintaining records; and
◦ exercising and defending legal claims.
Sources of Personal Information
We collect this personal information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; locator services; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Services. All sources of personal information collected are noted in the “How Do We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.
Your California Privacy Rights
If you are a resident of California, you may have the following rights with respect to any information about you that constitutes “personal information” under California law.
- Right to Know and Access Personal Information: You may request to access information we have collected and maintain about you. If your request is granted, we will provide you with a copy of the personal information we have collected and maintained about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Deletion of Personal Information: You may request that we delete the personal information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- “Do Not Sell or Share”: As noted above in this section, we disclose some categories of Personal Information in connection with certain types of advertisements that may be considered a “share” or “sale” under the CCPA. In order for you or your authorized agent to exercise this right, please visit please visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/).
- Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate personal information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.
To Exercise Rights:
In order to exercise your right to opt-out of the sale or sharing of your personal information, please visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/).
In order to exercise your other rights described above, please email us at Privacy@amli.com or call 833-756-0354. We may need to obtain information about you or your specific request in order to verify your identity and respond.
California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of an AMLI user, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identify.
Shine the Light Disclosure
We do not disclose personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by sending an email to LegalRiskManagement@amli.com or by sending a letter to AMLI Residential, 141 West Jackson Blvd., Suite 300, Chicago, Illinois, 60604. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.
International Data Transfers and Non-U.S. Residents
We are based and provide services in the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. We may need to send your personal information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected.
Updates to the Policy
How To Contact Us
We welcome all requests, suggestions and questions concerning our use of your personal Information. All such communication should be directed to LegalRiskManagement@amli.com.