YOUR PRIVACY RIGHTS
Updated: January 1, 20201. GENERAL
3. COLLECTION OF INFORMATION
A. PERSONAL INFORMATION
WNG collects personal information about you. The categories of information collected about you include, without limitation, identifiers such as your first and last name, home address, email address, IP address, online identifier, telephone numbers, Social Security number, driver’s license number, state identification number, gender and password, as well as other personal information including insurance policy number, employment and employment history, education information, credit or debit card number or other financial information, billing and shipping information, and financial and credit worthiness information that is not otherwise publicly available.
WNG collects personal information about you whenever you provide information to WNG or transact business with WNG, use WNG’s products or services, rent, or lease property from WNG or applications for same, request information or materials, create or update a profile, place ordersor make purchases or rent payments, communicate with us about orders or other questions, or visit the Websites or use the Applications. When, for example, you register to request information in person, or on a Website or Application or make purchases on a Website or Application, you submit personal information. Once you provide such personal information, you are not anonymous to us.
WNG may combine personal information collected as described above with information available from other sources (such as other platforms, Service Providers, analytics services, offline records or publicly available information). If the combined information, or any other non-personal information that WNG collects about you, is maintained, used or shared in a manner that associates it with your name, contact information (online or offline), we will treat such information as personal information.
B. NON-PERSONAL INFORMATION
Non-personal information refers to data and information that does not personally identify you as the individual to whom the data or information relates, which may include data and information that (i) is aggregated (that is, relates to a group of individuals) by WNG or a third party (“aggregated non-personal information”), or (ii) is not linked to personal contact information (“de-identified non-personal information”). In either case, non-personal information does not personally identify the individual to whom the information or data collected relates. Non-personal information may include, without limitation, your Internet Protocol (“IP”) address, your media access control (MAC) address, Collection Technology information (as described below), the pages you request, type of computer or device you use, the operating system you use (e.g., Microsoft Windows, Mac OS, Google Chrome OS, iOS or Android), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer or Safari), the domain name of the Internet service provider, your activities while visiting or using the Websites or Applications and the content you access or view, the time of your visit to or use of the Websites or Applications, the pages you visit and the time spent on the pages, your general geographic location such as the city from which your computer or device is connecting to the Internet, your computer’s or device’s precise geographic location when Wi-Fi is enabled and it is within range of or using Internet connectivity made available by WNG, information regarding the websites you visit prior to and after visiting the Websites or using the Applications, information regarding your Internet location when you see WNG’s ads and whether you click on such ads, information regarding your age, gender and interests with respect to products and services and information collected through our security systems and cameras.
i. Cookies and other “Collection Technology”
Non-personal information may be collected in a variety of ways, but Collection Technology is often used. “Collection Technology” refers to cookies, web beacons, pixels, gifs, tags and other technologies that collect information in similar ways. Collection Technology such as a cookie may store a piece of data on your browser or device, while other forms of Collection Technology may identify your browser or device and/or collect information through other means. When you visit the Websites or use the Applications or visit another website or application your browser or device may be exposed to Collection Technology and Collection Technology may be stored on your browser or device. WNG may come to acquire non-personal information about you upon collection of the non-personal information or some time thereafter.
You may delete and/or refuse the use of certain Collection Technologies by selecting the appropriate settings on your browser. You may use the Websites or Applications even if you choose to refuse or delete such Collection Technologies; however please note that this may affect your ability to use the full functionality of the Websites or Applications, and may impact our ability to customize the Websites or Applications for you.
ii. Analytics Services
The Websites or Applications may use analytics services provided by third parties, such as the analytics services of Adobe Marketing Cloud and Google Analytics, among others. These analytics services use Collection Technology to collect and store information about you and your use of the Websites and Applications, which may include the personal and non-personal information described above.
Analytics services also may offer certain advertising features, which the Websites or Applications may utilize. For example, the Websites or Applications may use these advertising features of Google Analytics:
(a) “Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Websites or Applications. WNG uses such non-personal information in the same manner as WNG uses other non-personal information as described below.
(b)“Remarketing with Google Analytics” to place ads on other sites directed to people who have visited the Websites or used the Applications.
(c) “Google Display Network Impression Reporting” to report how people’s interactions with WNG ads relate to their visits to the Websites or use of the Applications.
(d) Integrated services that require Google Analytics to collect data via Collection Technology, such as advertising cooking and identifiers.
You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings https://www.google.com/settings/ads.
4. USE, SHARING AND DISCLOSURE OF PERSONAL INFORMATION
WNG and its Service Providers (defined below) use your personal information for the purpose of leasing apartment units, providing products or services to you and carrying out the purposes for which you provided the information. In addition, WNG and its Service Providers use your personal information to improve our products and services, communicate with you, administer and process payments, attend to tasks relating to your transactions with WNG, provide customer service, update account information, inform you of products or services that may be of interest to you, customize the content or functionality of Websites and Applications to your preferences, present you with targeted content and advertisements as further described in Section 5 below, forward updates, announcements, and newsletters, respond to your communications, and communicate with you about the Websites, the Applications, Communications Services, and other activities related to the Websites or Applications. You authorize WNG to transmit email and direct mail to you, call you, send push notifications to your device, send you text messages, and otherwise contact you concerning these matters. WNG limits access to personal information to those WNG employees and Service Providers who we believe reasonably need that information to perform the tasks described above.
Your personal information will be intentionally disclosed or made available to third parties as follows:
A. Disclosures To Third Parties Assisting In Our Operations
B. Disclosures to Third Parties To Provide Information To You About Their Products and Services
C. Disclosures Under Special Circumstances
D. Major Transactions
WNG reserves the right to transfer any and all information, including without limitation personal information, to any WNG affiliate or a third party or successor in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our business or operations (including without limitation in connection with bankruptcy or any similar proceedings).
5. USE, SHARING AND DISCLOSURE OF NON-PERSONAL INFORMATION
WNG and its Service Providers may use your non-personal information in a variety of ways, such as to administer the Websites, improve the Websites, improve navigation of the Websites and Applications upon your return visit, improve the products and services we offer, analyze and develop advertisements and advertising campaigns, provide you with special offers and promotions and determine their effectiveness, customize the content or functionality of Websites and Applications to your preferences, and analyze trends and site usage.
WNG also may use non-personal information to present you with targeted content and advertisements (including on third party websites) based on your past visits to the Websites and non-personal information collected over time by us and third parties, and to determine the effectiveness of and optimize the content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how those interactions relate to your visits to the Websites. If you prefer not to receive targeted advertisements from us, as described above, please click on the following link: http://www.aboutads.info/choices. Please note that you still may receive standard advertisements from us and targeted advertisements from third parties after clicking the link. You may need to re-click the link if you delete Collection Technology or use a different computer or browser.
WNG may share or disclose your non-personal information with or to employees and Service Providers who WNG reasonably believes need such information to perform the tasks described in this Section 5. WNG also may use, disclose or share your non-personal information in any other way it desires. If any aggregated non-personal information or de-identified non-personal information becomes identifiable to a person, WNG will treat such information as Personal Information. We will ask our contracting parties to agree to keep the aggregated non-personal information and de-identified non-personal information in its aggregated or de-identified form.
6. RESPONDING TO “DO NOT TRACK” SIGNALS
7. PROTECTION OF PERSONAL INFORMATION
WNG stores personal information using industry standard, reasonable and technically feasible physical, technical and administrative safeguards against foreseeable risks, such as unauthorized access.
Please be aware that the Websites and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond WNG’s control. WNG is not responsible for the acts and omissions of any third parties.
WNG cannot guarantee the security of the information on and sent from the Websites. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of WNG to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal information, neither WNG nor any of our Service Providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.
8. NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS
As described in Section 4 above, personal information collected by WNG may be accessed, soldor disclosed for a business or commercial purposes to Service Providers and third parties. If you are a California resident, you have certain rights with regard to the handling of your personal information.• You have the right to request that a business disclose to you personal information that the business collects, sells, or discloses for a business purposes, about you.
A business may not discriminate against you for exercising any of these rights including that it can not deny, charge different prices or provide a different quality of goods or services to you.
Some of your personal information may also be sold to third parties which may be used for their own direct marketing purposes. California residents may request and obtain certain information regarding such disclosure, if any, of personal information to third parties for their direct marketing purposes. WNG has adopted a policy of not selling your personal information to third parties if you request that we do not do so (“Right to Opt-Out”).
To exercise any of the above rights or to get additional information, you should submit a verifiable consumer request to WNG either via email at [email protected], by mail at P.O. Box 19528 Irvine, Ca 92623, Attn: California Privacy Request, or by calling 888-962-2737. When contacting us, please indicate your name, address, email address, name of the WNG property at which you are or were a resident or at which you applied, which Website, Application or line of business to which your request pertains, and to what personal information your request pertains. WNG reserves the right to request additional information about you in order to verify your identity. WNG may utilize a two-step confirmation process prior to deletion of information.
In some circumstances, you may designate an authorized agent to make a request on your behalf. To do so, WNG requires that you first verify your own identity and then provide written permission for the authorized agent to act on your behalf. WNG reserves the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Please note that there is no charge to you related to requests for controlling the sharing of your personal information or for processing this request.
9. CORRECTING OR REMOVING YOUR PERSONAL INFORMATION/OPT OUT
To review or change your personal information collected by WNG, please send your request, including the Website or line of business to which your request pertains, to [email protected], by mail at P.O. Box 19528 Irvine, Ca 92623, Attn: California Privacy Request, or by calling 888-962-2737. If you want to unsubscribe from an email list of WNG, please let us know by following the “Unsubscribe” instructions that are included in each promotional email from WNG. Please note that such requests may take up to ten (10) business days to become effective. You may not opt out of receiving communications regarding your purchases, transactions, dealings with the Websites or Applications, or technical information about the Websites or Applications.
12. THIRD PARTY POSTINGS
14. GOVERNING LAW
Personal information collected through the Websites or Applications and other aspects of WNG’s business may be stored and processed in the United States or any other country in which WNG or its affiliates, subsidiaries or Service Providers maintain facilities. By using the Websites or Applications, you expressly consent to any such transfer of information outside of your country.
15. CONTACT US