Privacy Policy
Last Updated: 12-13-2024
California Military Communities LLC (the “Company”) takes your privacy seriously. We want you to know how we collect, use, and share your personal information.
Privacy Policy
California Military Communities LLC, its affiliates and related entities, our apartment communities, or our Educational Foundation are committed to protecting the privacy of certain data that is collected from you and that you submit when you access this website or websites and applications under our operation and control (collectively, the “Site”). The nature of our business requires that at times we gather information that is of a personal nature and that you may wish to keep protected. This Privacy Policy (“Policy”) is intended to familiarize you with our policies for the gathering, use, maintenance and protection of personal information on the Site.
Please review this Policy carefully. California Military Communities LLC reserves the right to change its Policy at any time, in which event the Site will contain a notice of the change. Changes will be effective immediately upon posting to the Site. By accessing the Site, you are indicating your agreement to California Military Communities LLC’s Policy. If you have any questions or concerns about the Policy, please contact us using the information provided below.
For job applicants and employees residing in California, please click the the following links for information concerning your privacy rights.
Job Applicants in California Privacy Notice
Employees Residing in California Privacy Notice
What personal data we collect and why we collect it
In general, we collect several categories of personal information from a variety of sources, and we use this information in order to carry out our business functions and provide a high quality of service. Here are some specific examples of the kinds of personal information we collect.
Your contact information (e.g., name address phone number) when you want to contact to find a home or another purpose. We also may use this information to contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
Your work history and other personal information when you apply for a job with us.
Your contact and payment information when you donate to our Educational Foundation
If you apply for a scholarship, various personal information that is shared with the scholarship determination committee, including information such as household income and other financial aid you may have received.
If you are awarded a scholarship, your photo and some identifying information such as the name of your apartment community and school, may be shared on our websites, across our social media platforms, and in promotional materials sent to donors, unless you have specifically indicated to us that we do not have permission to do this.
When you leave a comment on the Site, the content of your comment(s), your email address IP address, and browser user agent string to help spam detection. We also may collect your profile picture, if available, and after approval of your comment, make it visible to the public in the context of your comment.
California Military Communities LLC also may compile statistical information concerning the usage of the Site. This information allows California Military Communities LLC to monitor the Site’s utilization and continuously improve its quality. Examples of this information would include, but not be limited to, the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. In order to compile this information, California Military Communities LLC may collect and store your IP address, your operating system version, your browser version, the pages you visit within the Site, the length of time you spend on pages within the Site, the site from which you linked to ours, search terms you used in search engines which resulted in you linking to the Site, etc. While all of this information can be associated with the IP address your computer had while you visited the Site, it may not be associated with you as an individual, or associated with any other information you may submit through the Site, or California Military Communities LLC may store about you for any other purposes.
California Military Communities LLC’s current website uses “cookies,” in connection with third party applications that are connected to our site, including the “Contact Us” and “Subscribe for the Latest Updates” call to action buttons. Cookies also allow us to understand how visitors come to our website from other websites, and to tailor content and navigation that assists visitors in finding the information they are looking for on the site. e “cookies” assist in compiling the statistical information mentioned above and to tailor certain pages of the Site for your browsing convenience. A cookie file can contain information such as the URL you came from, your computer’s IP address and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our Site that were viewed during a visit, and any search terms that you entered on our Site. This information generally is used for internal purposes, and we do not link your URL or IP address to any personal information. You have the option of setting your browser to reject cookies, but our Site may not function correctly if you do. Refer to the Help feature of your browser for information on disabling cookies.
Cookies on https://www.villagesatfortirwin.com/ enable visitors to our site to opt-in to receive additional information or to send us a comment. For example, if you leave a comment on our Site you are opting-into saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this Site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Personal information of children
The Site is not directed to children. California Military Communities LLC does not knowingly collect any personal information from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.
Disclosing your personal information
In general, we will not disclose your information for any purposes other than those in conjunction with the business activities requested of us unless otherwise permitted or required by law or by this Policy. In the course of our normal business activities, we may disclose collected information to both affiliates and non-affiliated entities, as we deem necessary.
We may disclose your personal information with services providers and contractors who help us provide the products and services, such as, payment processing, marketing and advertising, email, text and other communications, applications, business support, and website, software, platform, cloud, data storage and other technical services.
We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires all or part of the assets of our business.
How long we retain your data
We retain your personal information for as long as necessary to provide you products and services, as well as information you may request, and in accordance with the Company’s data retention schedule, unless we have de-identified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your personal information in a de-identified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their registration information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. If you are not a California resident, any rights under this paragraph will be carried out in a manner similar to comparable rights under the section below for California residents, except as otherwise expressly indicated.
California residents have certain specific rights concerning the personal information California Military Communities LLC collects about them. These rights are provided under the California Consumer Privacy Act, as amended (“CCPA”) and are summarized below. Except as expressly indicated, these rights are applicable only to California residents.
Right to Know. California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we disclose that personal information.
The categories of personal information we sold or disclosed for a business purpose.
The specific pieces of personal information we collected about you (also called a data portability request).
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.
Right to Delete. California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors, as applicable, to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.
Comply with a legal obligation.
Otherwise use your personal information, internally, in a lawful manner that is compatible with he context in which you provided the information.
Right to correct. California residents have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
[Rights regarding sale, sharing, and limiting use of sensitive personal information]
Exercising the Rights to Know, Delete, and Correct. To exercise the know, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Toll-free number: (833) 956-0099
• Email: privacy@tmo.com
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will verify your identity before responding to your request.
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Time and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt, except as provided above or as required under the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. Data portability request format will be determined upon request.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this CCPA Section. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. The right to nondiscrimination also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.
Safeguarding of Information.
No system for safeguarding personal or other information is 100% secure. However, we take a number of steps to reasonably safeguard the security of personal information obtained through the Site. Our data centers are maintained in a secure environment with appropriate security measures. Our employees are trained to understand the importance of confidentiality and are required to adhere to our privacy policies and procedures.
Contact information
If you have any questions or comments about this Policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: privacy@tmo.com; Postal Address: PO Box 90708, Camden, NJ 08101
Last updated: July 1, 2023
IMPORTANT INFORMATION
Use of this Website
If you do not want us to handle your personal information as described in this Privacy Policy, please do not use this website as it may be modified, relocated, and/or redirected from time to time (the “Site”).
Applicability
This Privacy Policy applies to the personal information of users of the Site and the Company’s services (“Consumers”). It does not apply to the Company’s employees, job applicants, contract workers, or others whose personal information the Company collects for purposes related to human resources. “Consumer” also does not include employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business. This Privacy Policy refers to all categories of Consumers collectively, except where the Privacy Policy applies only to a specific category of Consumer, e.g., current and prospective residents, in which case the relevant category is specified.
Personal Information
“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household.
Assistance for the Disabled
Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact mktg@tmo.com for assistance.
Children’s Online Privacy Protection Act Compliance
We do not collect any information from anyone under 13 years of age. The Site and the Company’s services are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Site.
Contents
Section 1 // What personal information we collect
Section 2 // The sources from which we collect your personal information
Section 3 // The purposes for which we use your personal information
Section 4 // How we share your personal information
Section 5 // California-specific information
Section 6 // Changes to this Privacy Policy
SECTION 1 // WHAT PERSONAL INFORMATION WE COLLECT
Identifiers, including: real name, alias, telephone number, Internet Protocol address, and email address. In addition, if you are a current resident, we may also collect your postal address, date of birth, Social Security number, and driver’s license number or state identification card number for identity verification purposes.
Characteristics of Protected Classifications Under California or Federal Law, including: applicants to affordable housing can voluntarily self-identify ethnicity. The Company uses this ethnicity information only, as required by law, to report to state and federal agencies regulating affordable housing.
Inferences, including: for current residents’, your self-reported interests, e.g., tennis, that you voluntarily provide to us for the purpose of arranging activities and finding other residents with similar interests.
Financial Information, including: your payment card number and associated payment information and bank account name and number, to facilitate payments to the Company.
Internet Activity Information, including: device identifier, browser information, operating system characteristics, Internet service provider, IP address, and information regarding your interactions with an internet website, application, or advertisement and other online behaviors.
Geolocation Data, including: rough geographic location from your IP address.
Sensory or Surveillance Data, including: if you are a current resident, footage from video recordings as part of a service request.
Professional or Employment-Related Information, including: the name and contact information for your employer and your current salary.
Commercial Information, including: if you are a current resident, your vehicle information, and interest in products and services which you identify in connection with joining a resident interest group.
SECTION 2 // THE SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION
The Company collects all the categories of personal information listed above from the individual him/herself, as voluntarily provided by that individual, via the Site, in person, or through forms and surveys embedded in the Site.
The Company also collects Internet Activity Information and Geolocation Data through automated technologies on the Site, e.g., cookies.
Do We Use Cookies?
Yes. Cookies are small files that the Site transfers to your computer’s hard drive through your web browser that enables the Site’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly.
SECTION 3 // THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
Business and Commercial Purposes
Performing property management and/or asset management services. Property management services include providing property rental, upkeep, maintenance, repair, and related services, determining rental eligibility, verifying resident information and identity, processing payments, and providing analytic services.
Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with Consumers, including service requests for current residents.
For community outreach and to build community.
With respect to prospective residents, for marketing and lead tracking.
Auditing related to a current interaction with the user and concurrent transactions, including, but not limited to, auditing compliance with the law.
Detecting security incidents.
Preventing, discovering, and investigating malicious, deceptive, fraudulent, or illegal activity or violations of this Privacy Policy or any applicable terms of service or terms of use for the Company’s services.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use.
Undertaking activities to verify or maintain the quality or safety of our rental property services, and to improve, upgrade, and enhance our rental property services.
Other Purposes
Compliance with the law.
To protect the rights, property, or safety of the Company, Consumers, or others.
SECTION 4 // HOW WE SHARE YOUR PERSONAL INFORMATION
No Sales
The Company does not sell personal information of any individuals.
Other Disclosures
For all categories of Personal Information:
The Company and certain of its related companies may work in concert to manage real estate properties and provide services to residents (the “Property Management Team”). The Company may share personal information with its Property Management Team for the business and commercial purposes listed above.
The Company may disclose personal information about service members to the U.S. military, upon the military’s request and as permitted by law.
The Company discloses personal information to vendors, as necessary for the business and commercial purposes listed above, including, but not limited to, unrelated property management companies, payment processing vendors, lead tracking vendors, and collections vendors, law firms, auditors, and consultants.
The Company discloses personal information to government agencies, law enforcement, and other parties as required by law and as necessary to protect the rights, property, or safety of the Company, its subsidiaries or related companies, employees, customers, and users.
The Company may share personal information with a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
SECTION 5 // CALIFORNIA-SPECIFIC INFORMATION
Your California Privacy Rights and How to Exercise Them
This California section applies only to the personal information of Consumers who are residents of California (“California Consumers”).
a. Your California Privacy Rights
Right to Know. California Consumers have the right to submit a verifiable request to know what personal information the Company collects, uses, discloses, and sells about them.
Right To Delete. California Consumers have the right to submit a verifiable request for deletion of their personal information that the Company has collected or maintains.
Right to Opt Out of Sale. California Consumers have the right to opt out of the sale of their personal information. California Consumers under the age of 16 must opt in to the sale of their personal information, or their parent or guardian must opt in on their behalf. As noted above, the Company does not sell personal information. In addition, the Company does not have actual knowledge that it sells the personal information of anyone under 16 years of age.
b. How to Exercise Your Rights
The Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights to know and to delete in the following ways:
Complete the online request form available here.
c. How We Will Verify Your Request
The processes that we follow to verify your identity when you make a request to know or a request to delete are described below. The relevant process depends on how and why the request is submitted.
If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:
Requests To Know Categories Or Purposes. If you request to know categories of personal information collected, sources, sales, or the Company’s business or commercial purposes for use of your personal information, we will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or information about products or services that you have purchased from us.
Requests To Know Specific Pieces Of Personal Information. We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we will require you to sign a declaration under penalty of perjury that you are the California Consumer whose personal information is the subject of the request.
Requests To Delete Personal Information. Our process for verifying your identity will depend on the sensitivity (as determined by the Company) of the personal information that you ask us to delete. For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above. For more sensitive personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.
We have implemented the following additional procedures when verifying the identity of requestors:
If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
d. Authorized Agents
If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at mktg@tmo.com.
e. The Company’s Non-Discrimination Policy
California Consumers have the right not to be subject to discriminatory treatment by the Company for exercising their privacy rights under the California Consumer Privacy Act, and the Company will not discriminate on that basis.
f. Tracking Users Over Time And Across Sites
We track your online activities over time and across websites or online services on an individually identifiable basis. For example, we may serve you advertisements on other websites based on what appeared to interest you on our Site. We do not allow third parties to use our Site to track your activities over time or across other websites.
Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Site, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.
SECTION 6 // CHANGES TO THIS PRIVACY POLICY
If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.
For More Information
For questions or concerns about the Company’s privacy policies and practices, please contact us at mktg@tmo.com.