Rentals, Inc. Privacy Policy (California Residents)

This California Privacy Policy describes how Rentals, Inc. and its subsidiaries, affiliates, and related entities (collectively, “Company,” “we,” or “us”) collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy notice at: https://www.rentalsinc.com/privacy-policy.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.

Personal Information Categories Chart

The chart below identifies which categories of personal information we collected from our consumers within the last 12 months[ and the expected retention period].

Sources of Personal Information

• Directly from you, such as from the forms or other information you provide to the Company.
• Indirectly from you, such as from your interactions with the Company’s websites.
• From our service providers, such as tenant screening vendors.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

• Develop, offer, and provide you with our products and services, including screening and leasing residential properties.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Protect our Company, employees, or operations.
• Administer and maintain the Company’s systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
  • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
  • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to third parties for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to engage third parties to support our business functions. For example, we may disclose your personal information to a property owner or property management company to process an application.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The chart below identifies the categories of entities to whom we have disclosed our consumers’ personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure’s business purposes.

Selling or Sharing Personal Information

We do not sell your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of:
  • personal information we collected about you;
  • sources from which we collected your personal information;
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
  • disclosed for a business purpose to each category of persons; and
  • sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.

For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct

To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by either:

• Emailing us at leasing@rentalsinc.com

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, email a copy of a signed letter authorizing your agent to discuss personal information to the contact above. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.

You do not need to create an account with us to submit a request to know, correct, or delete.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer's name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact privacy@rentalsinc.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, e-mail, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to review the current Privacy Policy in effect.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, please do not hesitate to contact us at:

Email: leasing@rentalsinc.com

If you need to access this Privacy Policy in an alternative format due to a disability, please contact leasing@rentalsinc.com.

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