Legal Notice

This Website is owned and operated by Western National Group and its affiliates (Collectively “WNG”). WNG maintains the Website as a service to its visitors, clients and residents, subject to the following “Terms of Use” concerning the use of the Website. Your use of this Website is restricted to the content and materials expressly made available to you and is conditioned on your express agreement to abide by the Terms of Use. WNG reserves the right to modify content on the Website and these Terms of Use periodically without prior notice.

Privacy Policy

YOUR PRIVACY RIGHTS

Updated: January 1, 2020

1. GENERAL

This Privacy Policy describes how Western National Group and its affiliates (collectively, “WNG”) treats your personal information that WNG collects and receives from you through applications that run on mobile devices and tablets (“Applications”), this website and other WNG websites, and other online locations (collectively, the “Websites”), any Internet connectivity made available by WNG, other aspects of WNG’s business including offline and written documents and applications, and third parties.

2. ACCEPTANCE OF PRIVACY POLICY

Each time you submit a written application, or access, use, place an order on, or browse the Websites or Applications, you signify your acceptance of the then-current Privacy Policy. If you do not accept this Privacy Policy, you are not authorized to use the Websites or Applications and must discontinue use of the Websites and Applications immediately. If you provide your personal information to WNG through other aspects of WNG’s business including offline, or if you click on WNG’s digital advertisements on third party websites or applications, WNG asks you to review this Privacy Policy which also governs information collected through other aspects of WNG’s business including offline and digital advertising.

This Privacy Policy does not apply to the practices of companies that WNG does not own or control, or to people whom WNG does not employ or manage.

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 orders or 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.

WNG automatically receives and records non-personal information on our server logs from your browser as well as through other analysis of the Websites or Applications. WNG also may obtain non-personal information from you when you visit our offline locations, as well as from social media platforms, vendors and other third parties, such as Google, Inc. (“Google”) and the operators of other websites or applications that you have visited or used, some of which partner with WNG or with a display network or analytics service utilized by WNG, and may share information as permitted in such third party’s privacy policy. Non-personal information may also be obtained from inferences based upon the sites you visit, third party data, information you share on other websites, social media platforms and applications, or demographics derived from profiles you create, such as a Google profile.

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.

You can read the privacy policy that governs Adobe Marketing Cloud services at http://www.adobe.com/privacy/marketing-cloud.html; additional information regarding Adobe Systems Incorporated’s privacy practices can be found at http://www.adobe.com/privacy.html. Your privacy opt-out choices for the Adobe Marketing Cloud services are available at http://www.adobe.com/privacy/opt-out.html.

You can read Googles’ privacy policy, which applies to Google Analytics, at http://www.google.com/intl/en/policies/privacy/. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current browser https://tools.google.com/dlpage/gaoptout.

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.

Any WNG affiliate that receives your personal information may share it with other WNG affiliates for any purpose permitted under this Privacy Policy.

Your personal information will be intentionally disclosed or made available to third parties as follows:

A. Disclosures To Third Parties Assisting In Our Operations

WNG discloses or makes your personal information available for a business purpose to certain service providers who work on behalf of or with WNG including services and vendors related to, among others, renting apartments, payment processors, cable, telecommunications and utility providers, shippers and parcel vendors, advertisers, renter’s insurance providers, consultants and affiliates (“Service Providers”). The categories of personal information disclosed or made available to these Service Providers in the last 12 months include each of the categories identified in Section 3 above and are used to help WNG provide products and services to you, including but not limited to renting apartments, administering and processing payments, fulfilling orders, or communicating with you about offers or other information relevant to WNG.  By agreeing to this Privacy Policy and unless otherwise communicated, you acknowledge and agree with such disclosures or availability of personal information to Service Providers.

B. Disclosures to Third Parties To Provide Information To You About Their Products and Services

WNG provides, sells or makes your personal information available to selected third party entities, businesses or organizations that may use that information to contact you in order to  provide information to you about their products or services that we believe may be of interest to you or that are directly related to leasing of apartments and ancillary services. These third parties include, without limitation, on-site parcel box services, cable and telecommunications companies, and renter’s insurance providers.  The categories of personal information made available to such entities in the last 12 months are limited to personal identifiers such as name, address, email address and phone numbers.  By agreeing to this Privacy Policy and unless otherwise communicated, you acknowledge and agree with such disclosures of personal information to such third parties.

C. Disclosures Under Special Circumstances

WNG may provide information about you in response to or to cooperate with law enforcement, government requests, subpoenas, court orders or legal process; to respond to your requests for customer service or other information; to enforce the Terms of Use or the Acceptable Use Policy governing use of the Internet connectivity made available by WNG at WNG locations; to establish or exercise our legal rights or defend against legal claims; or to protect the safety or property of WNG or others. WNG also may provide information about you if WNG believes it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required or permitted by law.

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

Except as otherwise specified in this Privacy Policy, WNG does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt out” setting or feature that may be offered by your browser; however, WNG reserves the right to do so in the future.

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, sold or 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.
• You have the right to request the deletion of certain personal information collected or maintained by a business about you.
• You have the right to opt-out of the sale of your personal information collected by a business.

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 privacy@wng.com, 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 privacy@wng.com, 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.

10. CHILDREN

WNG is committed to protecting the privacy of children. The Websites and Applications are directed to persons 18 years of age or older.  WNG, the Websites and the Applications do not knowingly collect information from children under age 18. If you under age 13, you are not permitted to use the Websites or Applications or to submit any personally identifiable information to the Websites or the Applications. If you provide information to WNG through the Websites or Applications, you represent and warrant to WNG that you are 18 years of age or older. If you are 13 – 17 years of age, you may visit, browse and use the information on the Websites or Applications, but you may not submit any personal information to the Websites or Applications, and you represent and warrant to WNG that you have permission of your parent or guardian to use the Websites or Applications and any activities on the Websites or Applications, who agrees to this Privacy Policy and the Acceptable Use Policy governing use of the Internet connectivity made available by WNG at WNG locations, if applicable, on your behalf.  WNG will not knowingly sell the personal information of minors without affirmative authorization.  If we become aware that a Website or Application user is under age 18 and has provided personal information, we will remove his or her personal information from our files. If you are a parent or guardian and believe WNG may have inadvertently collected personal information from your child, please notify WNG immediately by sending an email, including the Website or Application or line of business to which your request pertains, to privacy@wng.com, by mail at P.O. Box 19528 Irvine, Ca 92623, Attn: California Privacy Request, or by calling 888-962-2737.

11. LINKS

On our Websites or Applications, you may have the opportunity to follow a link to other sites that may be of interest to you. Because these other sites may not be hosted or controlled by WNG, however, we are not responsible for the privacy practices of those sites or the content provided thereon. Collection Technology also may be used by some of those other sites. Therefore, the privacy policies with respect to these areas may differ from those applicable to the Websites or Applications and we encourage you to review the privacy policies of each of those other sites. This Privacy Policy only applies to information collected and maintained by WNG.

12. THIRD PARTY POSTINGS

From time to time certain third parties, such as vendors with whom WNG may have a business relationship, may post information on our Websites or Applications. WNG is not responsible for the content of these postings, or for ensuring that the third parties comply with this Privacy Policy.

13. CHANGES TO THIS PRIVACY POLICY

The Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the upper left corner of the Privacy Policy (“Last Revised Date”) for you to know when there has been a change. Accordingly, you should check the Privacy Policy on a regular basis for the most current privacy practices. Each time you access, use or browse the Websites or Applications, you signify your acceptance of the then current changes to the Privacy Policy applying to your personal information collected by us on and from the effective date of such changes to the extent required by law.  Any changes in the Privacy Policy will take effect upon posting.

14. GOVERNING LAW

This Privacy Policy shall be governed by, and will be construed under, the laws of the State of California, U.S.A., without regard to choice of law principles. Those who choose to access the Websites or Applications from locations outside of the United States do so on their own initiative, and are responsible for compliance with local laws if and to the extent local laws are applicable, including without limitation, all applicable laws, rules and regulations regarding the transmission of data exported from the United States or the country in which you reside. WNG may limit the availability or a Website or Application, in whole or in part, to any person, geographic area or jurisdiction, at any time in its sole discretion.

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

If you have any questions about this Privacy Policy or our Websites or Applications, please contact us at privacy@wng.com, by mail at P.O. Box 19528 Irvine, Ca 92623, Attn: California Privacy Request, or by calling 888-962-2737.  Please note that email communications may not be secure. Accordingly, you should not include personal or other sensitive information in your email correspondence to the Website, Application or WNG.