RXR URBAN LIVING RXO LLC
RESIDENT EXPERIENCE OFFICER AND MOBILE APPLICATION PRIVACY POLICY
Last Updated January 22, 2020
RXR Urban Living RXO LLC, a Delaware limited liability company (“Company,” “we,” “us,” or “our”), has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that Personal data, and your choices concerning our data practices.
Through our resident experience officer service, including our mobile application (the “App”), we make available certain services in connection with rental and occupancy of residential apartment units (each a “Unit,” and the building in which such Unit is located may be referred to as the “Building”) in multi-family apartment properties owned and/or managed by affiliates of the Company. The services may include rent payment processing for your Unit, arranging for third party cleaning services to clean your Unit, concierge services (such as arranging for restaurant reservations, allowing third party service providers that you have engaged to enter your Unit, Delivery Services (as defined in the Terms of Service)), maintenance request services, and other similar services. Such services, including the App, are referred to collectively in this Privacy Policy as the “Service”.
This Privacy Policy explains what Personal Data (defined below) we collect in connection with the Service, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service, which is available in the “Legal – Terms of Service” section on our App.
Before using the Service or submitting any Personal Data to Company, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not download the App or otherwise use the Service.
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
Personal Data You Provide: We collect Personal Data when you (a) contact the RXO (as defined in the Terms of Service), including to (i) make a reservation at a restaurant, (ii) request that the Cleaning Provider (as defined in the Terms of Service) render cleaning services, (iii) request Delivery Services, and (iv) request that a Service Provider be granted access to your Unit in order to render services; (b) submit a maintenance request through the Service; and (c) request any other Services made available through the Service. Additionally, we may receive Personal Data from Third Party Sites (as defined below), such as Yardi, that are linked with the Service. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include (a) your name, (b) phone number, (c) Unit number and Building, (d) the financial information necessary to ensure payments can be processed by our Payment Processor(s), and (e) such other information as you may elect to input into our App or share through the App, such as any user-generated content including photographs. In addition to this Privacy Policy and our Terms of Service, information related to your purchases or selected services is also processed according to Payment Processor’s services agreement and privacy policy.
Personal Data We Receive Automatically From Your Use of the Service: When you use, use and interact with the Service, we may receive certain information about your use or interactions. For example, we may monitor the number of people that access and use the Service, peak hours of visits, which services and features are used and which devices people use to access the Service, broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
● Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
● Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, your location, the actions you take, and the time, frequency and duration of your activities.
Tracking and Do Not Track Signals: Our Service currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
We may use Personal Data for the following purposes:
• To provide the Service;
• To modify or improve the Service or to develop new services;
• To market the Service or any of our other services;
• To combine the Personal Data collected through the Service with other Personal Data that we collect or possesses and to use the resulting data for purposes described in this Privacy Policy;
• To respond to your inquiries, comments, feedback or questions;
• To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To maintain and improve the content and functionality of the Service;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails you receive by clicking the unsubscribe line in any commercial email you receive from us. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
• Vendors, Business Partners and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, cleaning and other professional service providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services web analytics services and other services. In addition, we may collaborate with business partners to provide the Service to you. These parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the Security standards we apply to your Personal Data.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
• Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Company. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.
We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
Please update your information on your account or contact us if you need to change or correct your Personal Data.
Our Service is not directed to children who are under the age of 18. Company does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Company through the Service please contact us and we will endeavor to delete that information from our databases.
The Service may contain links to other websites not operated or controlled by Company (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites.
Please contact the Third Party Sites directly for information on their privacy practices and policies.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.
The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at support@rxrurbanliving.com.