PRIVACY POLICY

1. Summary of Key Points

• Collection: We collect name, contact details, and other Personal Data related to our commercial, employment, and residential relationships.
• Use: We use Personal Data to operate and improve our websites and other Services, perform transactions, register residents, authenticate registered users to secure areas of our websites, assess job and resident applicants, respond to inquiries, manage accounts and maintain business operations, provide relevant marketing, and to fulfil other business and compliance purposes.
• Disclosures: We disclose Personal Data for certain purposes, such as to our third-party providers of services as necessary to operate and improve our websites, perform transactions, register residents, respond to requests, and to fulfil other business and compliance purposes.
• Marketing choices: You have control over how we use Personal Data for direct marketing.
• Cookies: We use cookies on our website, and provide choices on use of cookies, including third party targeting and advertising.
• Data subject rights: Depending on where you reside, you may have certain rights to request access, correction, deletion, that we stop selling or sharing your Personal Data, that we do not use your Personal Data for targeted advertising, or other actions regarding your Personal Data, to the extent provided by applicable law.
• Information security: We maintain reasonable technical and organizational measures designed to protect Personal Data from loss, misuse, alteration, or unintentional destruction.
• Geography / Target Markets: All of our business, properties and operations are located within the United States, and our Services are not targeted to, and we do not market our properties, to residents outside of the United States of America.
• Contact us: Please contact us as detailed below with any questions.

 

2. How We Collect Personal Data

We may collect information about you through various means, including:

• Directly from you, both online (e.g., website, email) and offline (e.g., phone);
• Through your use of our websites or related online services; and
• From other third-party sources and social media platforms that you may use to engage with us, as well as from our affiliates, and/or to supplement information we already possess.

 

3. Types of Personal Data we Collect

We may collect the following categories of Personal Data:

• Profile Information: Name, title, company, region, job responsibilities, phone number, mailing address, email address, contact details, and any other profile information that you submit to us.
• Resident Information: Data provided by resident applicants in connection with residential opportunities (e.g., name, date of birth, email address, contact information, government identifiers, guarantor information, bank information, income, debt, criminal history (where permitted), employer information).
• Registration Information: Newsletter and/or other alert requests, subscriptions, and downloads.
• Marketing Information: Data about individual participation in product interests, query information, and preferences, including for feedback and research purposes.
• Job Applicant Information: Data provided by job applicants or others on our websites or offline means in connection with employment opportunities (e.g., name, resume, education history, employment history, certifications, salary requirements, government identifiers, contact details, work status authorization and references).
• Transaction Information: Where applicable to our relationship, billing and payment information, transaction history, and related performance data.
• Communications: Any interactions with us, such as via email, mail, phone, social media or offline (e.g., in person).
• Usage Information: Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our website as described below. Note, however, we do not consider such information to be Personal Data except where we link it to you as an individual or where applicable law provides otherwise.

 

4. Online Usage Information including Cookies

We use and allow certain third parties to use cookies, web beacons, scripts and similar tracking technologies (collectively, “cookies”) on our website.

What are cookies? Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at www.allaboutcookies.org. Web beacons and scripts may work in conjunction with cookies or independently to help track user activity and website functionality.

How do we use cookies? We use cookies to provide the website and services, gather information about your usage patterns when you navigate this website in order to enhance your personalized experience, and to understand usage patterns to improve our website, products, and services. We also allow certain third parties to place cookies on our website in order to collect information about your online activities on our website over time and across different websites that you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest-based advertising, and to analyze the effectiveness of such advertising.

Cookies on our website may include the following categories:

• Strictly Necessary Cookies: These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
• Analytical/Performance Cookies: These allow us to recognize and count the number of users of our website and understand how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser. We may use Google Analytics, and you can see below for how to control the use of cookies by Google Analytics.
• Functional Cookies: These improve the functional performance of our website and make it easier for you to use. For example, cookies are used to remember that you have previously visited the website and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to our website. You can delete these cookies via your browser settings.
• Targeting Cookies: These record your visit to our website and the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the website and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to our website. You can delete these cookies via your browser settings. See below for further details on how you can control third party targeting cookies.

What are your options if you do not want cookies on your device? You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this website, and you may be required to re-enter your log-in details. Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.

To learn more about the use of cookies for Google Analytics and to exercise choice regarding such cookies, please visit https://tools.google.com/dlpage/gaoptout . The add-on available at the referenced link prevents the Google Analytics JavaScript (gtag.js, analytics.js) that is running on the Websites from sharing information with Google Analytics about visit activity and is specific to each browser running on each device from which you may visit the Website. The add-on is specific to Google Analytics as described above, and does not prevent data from being sent to the Websites themselves, or opt you out of every analytics service universally.

To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile application.

 

5. How we Use Personal Data

We use the above categories of Personal Data for the following purposes:

• Perform our Services to you, including with respect to any transactions, interactions and responding to your inquiries (categories of data can include Profile Information, Registration Information, Transaction Information, Communications and Usage Information).
• Assess, register and maintain potential and current residents (categories of data can include Profile Information, Resident Information, Transaction Information, Communications).
• Manage your accounts and maintain our business operations (all categories of data described above are included).
• Evaluate and improve our Services, such as to make them more intuitive and easy to use, and conduct research regarding customer services (categories of data can include Usage Information, Profile Information, Registration Information).
• Protect the security and effective functioning of our website and information technology systems (categories of data can include Profile Information, Registration Information, Transaction Information, and Usage Information).
• Analyze and enhance our communications and strategies, and provide relevant marketing (categories of data can include Profile Information, Registration Information, Resident Information, Usage Information, Transaction Information, and Marketing Information).
• Address our compliance and legal obligations and exercise our legal rights (all categories of data described above are included).
• Consider individuals for employment and contractor opportunities and manage on-boarding procedures (categories of data primarily include Job Applicant Information, and other categories to the extent relevant).

We may also use or share data in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and improvement of our Services.

 

6. When We May Disclose Personal Data

We may transfer Personal Data with the following categories of recipients:

• Advertising: Limited Usage Information (e.g., IP address, pageview, etc.) may be collected through third party online tools such as cookies, as described above. As explained above, you can take certain steps to prevent such collection.
• Affiliates: We may share Personal Data among our group of affiliates and subsidiaries, as necessary for the purposes identified above.
• Service providers: We may share Personal Data with our service providers, acting as data processors, so they can perform functions on our behalf and under our instructions for the purposes identified above (e.g., information technology services, human resources and resident management services, marketing, statistical analysis). We may likewise share Personal Data with our auditors for the performance of audit functions, and with advisors for the provision of legal, tax and other advice, with business partners to operate our business, and with financial institutions in connection with payment and other transactions. We require such parties to process such Personal Data only on our behalf. A limited number of service providers will act as businesses in their own right and/or data controllers and will be contractually obligated to comply with applicable data protection laws, rules, and regulations.
• Business reorganization: In the event we undergo a business transaction such as a merger, acquisition, or sale or other transfer of all or a portion of our assets, your Personal Data may be among the assets transferred. We will make reasonable efforts to have the acquirer of your Personal Data comply with applicable law and use your Personal Data consistent with this policy.
• Other mandatory disclosures and legal rights: We will share Personal Data (i) where mandated or permitted by applicable law, regulation or legal process, such as to comply with any subpoena, court order or other legal process, or other governmental request; (ii) in connection with an investigation or suspected or actual fraudulent or illegal activity; or (iii) to establish or protect our legal rights, property or safety, or the rights, property, or safety of others, or to defend against legal claims.
• With your direction or consent: In some instances we may share your Personal Data at your direction or consent, such as to process or facilitate a particular transaction or service that you request.

Note that we do not share text message program enrollment or consent with third parties for their own purposes. Where appropriate, we will limit sharing of your Personal Data in accordance with the choices you have provided to us and consistent with applicable law.

 

7. Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as business communications or administrative notices, when appropriate.
• Text messages: If you affirmatively consent to receive text messages from us and enroll in such a program, you will receive updates via text unless you opt-out of the text message program. These messages may be unencrypted. Message frequency may vary based on the Services. If at any time you would like to stop receiving text message notifications, please text “STOP” in reply to our message, we will send you a reply message to confirm that you have been unsubscribed and you will no longer receive messages from us. If you want to join again, just sign up as you did the first time and we will start sending messages to you again. If at any time you forget what keywords are supported, just text “HELP” back to us and we will respond with instructions on how to use our service as well as how to unsubscribe.
• Cookies: Web browsers may offer users the ability to disable certain cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
• Targeted Advertising: We may potentially work with advertising partners who collect information about your online activities and provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising.

 

8. State-Specific Notices

Certain privacy laws may provide additional rights with respect to the collection and use of Personal Data collected by businesses: (i) provide a copy of the individual’s information; (ii) correct information that is incorrect or incomplete; (iii) delete the Personal Data (subject to a number of legal exceptions); (iv) not sell Personal Data to a third party (excluding qualified service providers); (v) not engage in third party targeted advertising; (vi) not engage in impactful profiling activities with the Personal Data; and (vii) not use sensitive Personal Data except for the reasons provided. Note that we do not generally provide a financial incentive in return for the collection or use of Personal Data (except where disclosed with relevant terms at the time of collection), and do not share Personal Data to third parties for their own direct marketing purposes. It can be unlawful to discriminate against an individual for exercising such rights.

Due to our size, locations and operations, we may not be subject to any particular state’s privacy laws, but you can submit such requests to us at DataProtectionOfficer@articlestudentliving.com with a reasonably detailed email regarding the nature of your request, and the phrase “Data Subject Request” in the subject line. You may designate an authorized agent to submit a request on your behalf the same way. We will endeavor to fulfill any obligations that are legally required, otherwise we will respond to such requests in our discretion. Note that we will generally impose reasonable steps to verify your identity before responding to such requests.

If you are unsatisfied with our final response to your request, you may lodge a complaint with a detailed email to DataProtectionOfficer@articlestudentliving.com. Please include “Internal Appeals Process” in the subject line of your written complaint, and we will acknowledge your complaint within 10 working days of receipt. If we do not resolve the complaint to your satisfaction, you may be entitled in some states to lodge a complaint with your state’s Attorney General, consumer protection or privacy protection agency.

Under California’s “Shine the Light” law, California residents may submit a request once per calendar year for information about Personal Data that we shared with other businesses for their own direct marketing uses. Please contact us at DataProtectionOfficer@articlestudentliving.com to make such a request, with “Request for California Privacy Information” in the subject line and in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response. We may ask for additional information to verify your identity.

 

9. Information Security

We maintain reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or unintentional destruction. However, due to the nature of the Internet, no security measure can guarantee against compromise. We cannot guarantee that online communications will be completely free from unauthorized access by third parties such as hackers, and your use of our Services demonstrates your assumption of this risk. We will make any legally required disclosures in the event of any compromise of Personal Data. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

 

10. International Considerations

Our Services are intended for use in the United States, and all of our business, properties, and operations are located within the United States. If you use our Services from outside the United States, you acknowledge and agree that we may transfer your information to and from the United States, including countries that may not guarantee the same level of protection of Personal Data as the one in which you reside. Those who access our Services from outside the United States do so on their own volition and are solely responsible for compliance with applicable local laws.

 

11. Children

We do not knowingly collect Personal Data online from children under the age of 13, and will endeavor to promptly delete any such information upon discovery.

 

12. Consequences of not Providing Personal Data

You are not required to provide Personal Data to us, but various aspects of our Services may be unavailable to you without your information. For example, if you do not provide certain Personal Data, we may not be able to respond to your requests, perform a transaction with you, review your application, or provide you with marketing that we believe you would find valuable.

 

13. Use of AI and Automated Decision-Making Technology (ADMT)

We may train and use AI tools with your Personal Data for certain business purposes, such as to analyze customers’ experiences and activities with us, to improve the efficiency, quality, and speed of our business operations, to support communications with customers (such as a chatbot), to generate business content, and to provide more personalized experiences and targeted marketing, but we don’t use AI tools or other automated decision-making without human intervention, including profiling, in a way that is believed to produce an adverse material or unlawful effect concerning you or otherwise significantly affect you.

 

14. How Long do We Retain Personal Data

We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us and upon request, we will securely delete such data in accordance with applicable law. For Personal Data that we collect and process for other purposes, as described above, we retain such Personal Data in accordance with our Records Retention and Protection Policy, and typically, for no longer than the period necessary to fulfil the purposes outlined in this policy, and as otherwise needed to address tax, corporate, compliance, employment, litigation, and other legal rights and obligations.

 

15. Third Party Websites and Integrations

Our Services may contain links and references to other websites and services including social media (e.g., LinkedIn, Instagram, Twitter, Facebook) that are operated by unaffiliated third parties. This policy does not apply to such third-party websites. When you click a link to visit a third-party website, you will be subject to that website’s privacy practices. We encourage you to familiarize yourself with the privacy and security practices of any linked third-party websites before providing any Personal Data on those websites.

 

16. Changes to this Policy

We may update this policy from time-to-time as our Services and privacy practices change, or as required by law. The effective date of this policy is posted above, and we encourage you to check this policy for any updates. We will post the updated version on our website, and ask for your consent to the changes if legally required.

 

17. Contact Us

If you have questions or comments regarding this policy or our privacy practices, or to make any request concerning your Personal Data, please contact us by mail to: Article Student Living, 311 N. Green St., Ste. 850, Chicago, IL 60607; or via email to DataProtectionOfficer@articlestudentliving.com.