PRIVACY POLICY NOTICE

Westland is committed to protecting your privacy. This notice describes our privacy policy, including how we collect and use your personal data, the rights you have, and control you can exercise in relation to it.  By visiting www.westlandreg.com, you are accepting the practices described in this Privacy Notice.  This Privacy Notice was last updated on November 13, 2019.

• Who We Are
• Categories of Data Collection and Usage
• Your Communications With Us
• How We Use Your Personal Data
• Our Reasons For Using Your Personal Data
• Legitimate Interests
• With Whom Do We Share Your Data?
• Personal Data About Others
• Security
• Where Your Information Will Be Held
• How Long Do We Keep Your Data?
• Your Rights
• Right to Object/Opt-Out of Sale of Data
• Direct Marketing
• Cookies
• Links to Third Party Websites
• Children
• Changes to This Notice
• Requests for Accessible Information
• How to Contact Us

Who We Are

Westland Real Estate Group is a group of real estate entities that lease multifamily residential, retail and manufactured home community spaces through entities and affiliates, each of which is its own multifamily housing or retail space provider.  Westland does not itself provide multifamily housing, retail space or other services directly.  The term "Westland” means one or more real property lessor, including Westland Real Estate Group and its affiliated entities (also "we"/"us"/"our"). Any reference to a Westland "location" means any office, facility, complex, community, or retail space. 

Personal data may be collected by each member of Westland Real Estate Group, or through an affiliated entity.  If you have any questions about Westland's use of your personal data, please use the following contact:

Email:              [email protected]
Postal Mail:      Privacy Act Compliance

Westland Real Estate Group
520 W. Willow Street
Long Beach, CA 90806

Webform:         www.westlandrealestategroup.com/privacy

Telephone:      (310) 639-7130
 

Categories of Data Collection & Usage

We will collect the following personal data:

• Contact information: your name, mailing address, unit number, telephone number(s) (including home, office and mobile phone numbers as applicable), and email address; the same information may also be recorded for emergency contacts or those who share the premises (e.g. roommates); if submitted for a commercial lease your position, role, and company or organization name is also recorded;
• Business information: data identifying you in relation to matters on which you instruct us or in which you are involved;
• Your logon ID and password: for access to Westland’s Tenant Portal (if applicable) and/or online leasing platforms;
• Information from public sources: information obtained from housing assistance provider information, application related background check results, directories or internet publications;;
• Information in connection with background check investigations, disputes or proceedings: where this is necessary to conduct the background check, or to investigate proceeding and disputes relating to reported misconduct or incidents;
• Notes/Memoranda: to record significant information on communications you have made while at our offices or related to your use of our space;
• Subscriptions/preferences: when you subscribe to receive updates or information as well as consent preferences to help us identify which materials you are interested in receiving;
• Social media: posts, Likes, tweets and other interactions with our social media presence;
• Technical information: [when you access our website and technology services] IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug−in types and versions, operating system you are using (e.g. Vista, Windows XP, MacOS, etc), device type, hardware model, MAC address, unique identifiers and mobile network information;
• Online data: [when you access this website and our technology services] information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails.

Westland does not collect personal data about your online activities across third party websites or online services;[1]

• Special categories of personal data: such as disability or similar requirements for accommodations or modifications. If you do not provide this information, we may not be able to respond to your particular needs related to a request for a reasonable accommodation or modification;

The above data will be provided to us by you or screening providers who assist us with our applicant’s background checks.

Your Communications With Us

Westland may also collect information that you choose to provide in communications with us. Please do not send us confidential information with an expectation of privacy through the Tenant Portal.  You are not entitled to any expectation of privacy in the information you provide in communications to Westland.  Such communications may be disclosed to others consistent with Westland’s business needs, including without limitation related to its managing of rental space, disclosures made to vendors providing support to or services at a property, legal proceedings, and to provide notices prior to signing, while effective and after termination of a lease agreement.

How We Use Your Personal Data

We use your personal data for the following purposes:

• Service provision: providing rental space and services including the Tenant Portal and access to commonly shared amenities;
• Business relationship: managing and administering our relationship with you (and for commercial tenants your company or organization), including keeping records about business contacts, services and payments so we can customize our services for you, develop our relationship and target our marketing and promotional campaigns;
• Communication: sending emails and other messages to keep you informed of the status of requests for services, developments and notices regarding the leased property, and billing;
• Surveys and feedback: including directed requests for feedback, as well as responses answering issues and concerns which may arise;
• Background checks and legal compliance: initial background checks and continuing due diligence (other crime prevention and detection laws and regulatory requirements) which may involve automated screening checks to ensure that tenants and contacts are genuine and to prevent fraud or crime and we may not be able provide rental space or services if you do not provide the information we need to do these checks;
• Website monitoring: to check the website and our other technology services are being used appropriately and to optimize their functionality;
• Site security: to provide security to our communities and other premises (confirming you are authorized to enter with an access card or gate code upon entry of equipped buildings and gates);
• Online security: protecting our information assets and technology platforms from unauthorized access or usage and to monitor for malware and other security threats;
• Regulatory: compliance with our legal and regulatory obligations including auditing and reporting requirements;
• Borrowing: providing bulk information and financial data to lenders who require disclosures in order to provide or administer mortgage loans on the real property where the leased space is situated;
• Managing suppliers and vendors: who deliver products and services to our properties, communities and leased spaces, such as repair or maintenance contractors;
• Legitimate interest: to pursue the legitimate business interests listed in the “Legitimate Interests section of this policy below.

Our Reasons for Using Your Personal Data

We will process your personal data for a number of reasons:

• you have given us consent: for example where you share details for particular purposes;
• it is necessary to comply with legal, lending or regulatory obligations: for example disclosure to law enforcement when served with proper legal process, or in order to comply with requests from housing assistance payment boards and authorities;
• it is necessary to protect your interests or those of another person: for example, in medical emergencies;
• you have made the data public: for example, where you have published it on social media;
• it is necessary to deal with legal claims: for example evictions, collections or restraining orders;
• processing is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual. Our legitimate interests are listed in the next section.

Legitimate Interests

We have legitimate business interests in:

• conducting background checks for new applicants;
• providing rental services;
• managing our business and relationship with you or your company or organization;
• understanding and responding to inquiries and client feedback;
• understanding how our clients use our services and websites;
• identifying what our clients want and developing our relationship with you, your company or organization;
• improving our services and offerings;
• receiving information from other Westland entities for transfer requests or other internal services;
• enforcing our lease, website terms of use, and other terms and conditions;
• ensuring our systems and premises are secure;
• managing our vendors, contractors and service providers, including in relation to maintenance requests;
• complying with requirements of mortgage lenders;
• ensuring debts are paid, including for debt collection after move-out;
• operating suppressors to exclude you from direct marketing if you unsubscribe;
• sharing data in connection with acquisitions and transfers of our business.

With Whom Do We Share Your Data?

We share your information as with others as follows:

• Westland entities: including their management, staff and contractors in order to provide rental services;
• Vendors: who support our business including IT and communication suppliers; marketing companies; backup and database service providers; maintenance, repair and real property improvement contractors; pest control operators; and onsite security guard service providers. Our suppliers have to meet minimum standards as to information security and they will only be provided data in line with their function;
• Shared service centers: operated by Westland or third parties including for initial application background checks, database storage, IT cloud servers, marketing, and insurance services;
• Law enforcement bodies and our regulators: or other competent authorities in accordance with legal requirements or good practice;
• Appropriate parties in the event of emergencies: in particular to protect health and safety of our tenants, staff, communities and properties;
• Your company or organization: in relation to us providing real property rental services;
• Screening service providers: so that we can comply with legal obligations in relation to the prevention or protection of crime, and initial tenant application screening;
• Advertising networks and analytics service providers: to support and display information on our website, apps or social media tools;
• Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganization;
• Other delegates: where your name will appear on the attendee list for events you plan to attend.

Personal Data About Others

In some cases, you may provide personal data to us about other people (for example: for individuals your employers and emergency contacts; for businesses your customers, directors, officers, shareholders or beneficial owners).  By submitting that information, you are representing that you have ensured that you have given those individuals an appropriate notice that you are providing their information to us and have their consent to provide that disclosure.

Security

We will hold your information securely in line with physical, technical and administrative security measures. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.  However, the transmission of information via the internet is not completely secure.  Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted and any transmission is at your own risk. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

Where will your information be held?

We are a regional real estate group, so your information may be transferred out of your local jurisdiction or state.  Data protection laws vary from state to state and those applicable in California, Nevada and elsewhere are not equivalent to those applicable in other jurisdictions. Westland will take steps to protect your information in line with locally applicable data protection requirements.

How long do we keep your data?

We generally keep your information as needed to provide our rental spaces and associated services, as well as to maintain compliance with federal and state tax filing requirements. This may depend on a number of factors such as whether you, or your company or organization, are an existing lessee or have interacted with recent rental space listings, recently filed an application, or collection efforts are ongoing related to a past debt. We will retain your information as necessary to comply with legal, accounting or regulatory requirements. Typical retention periods will be at least 7 years for past tenants and applicants.

Your Rights

If you are a consumer that has sought or obtained rental services from one of our California entities, or in certain other jurisdictions where similar rules apply, you have certain rights in relation to your information. The availability of these rights to California consumers and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances.  If you would like to exercise, or discuss, any of these rights, please contact the relevant Data Privacy contact as listed in this Policy above.  All of that information is included in this Privacy Policy Notice, and the categories of personal information that is collects, uses, or discloses, is available on our website or by contacting the Data Privacy contact listed above either by email or first class mail.  The categories of information are also available and methods of collection during the preceding twelve (12) months is also available by calling the telephone numbers that are used by Westland to interact with consumers in California at (310) 639-7130.  When a consumer is submitting a verifiable request to delete, designating an authorized agent, or accessing a consumer’s specific personal information, the requestor will be requested to provide verification.  Confirmation of such requests and designation of the verifying information that is required to consider the request will be made within 10 days, and will fully respond to the request within a reasonable period of time.  Despite a request to delete, we may be entitled to continue storing or processing such information based on our legitimate interests, where relevant to Westland’s legal claims, or where relevant for legal, lending or regulatory purposes.

• Know:  consumers are entitled to request that Westland disclose the categories of personal information it collects, uses, discloses or sells.  Westland refers to requests to know that seek disclosure of specific pieces of information about a consumer as a request for access.   
• Access: consumers are entitled to ask us if we are processing their data and, if we are, consumers can request access to their personal data. If you are a consumer, this enables you, to receive a copy of the personal data we hold about you and certain other information about it.  In each such case, the person whose specific information is sought must provide information verifying that the identity of the individual requesting information is the same as the individual making the request, and an individual’s full social security number, driver’s license number, or other government-issued identification number, financial account number, health insurance or medical identification number, account password, or security questions and answers will not be provided; the individual may be directed to Westland’s secure self-service portal to access and receive a portable copy of their personal information;
• Delete: consumers are entitled to ask us to delete or remove personal data in certain circumstances by submitting a verifiable request. There are also certain exceptions where we may refuse a request to delete, for example, where the personal data is required for compliance with law, in connection with claims, or to process requests for service or to rent property.  Any request to delete will not result in the deletion of personal information from archived data or back-up systems, and a copy of the consumer’s request to delete such information that may reference a portion of that personal information will be retained. Any request to delete will require a two-step verification from the consumer, including the initial request to delete, and a second confirmation that the consumer wishes to delete the information;
• Nondiscrimination: Westland does not engage in discriminatory treatment based on a consumer’s exercise of the privacy rights conferred by the CCPA;
• Transfer: you may ask us to help you request the transfer certain of your personal data to another Westland entity;
• Authorized Agent: consumers may request to designate an authorized agent to make a request under the California Consumer Protection Act on their behalf;
• Consent: where we are processing personal data with consent, you can withdraw your consent.

If you want to exercise any of these rights, please contact the Data Privacy contact set out in this Policy above, in writing at the relevant email address.
 

Right to Opt Out of Sale of Personal Information

Westland does not sell personal information, and has no intention of selling personal information. 

To the extent Westland revises its business practices, CONSUMERS HAVE A RIGHT TO OPT OUT OF THE SALE OF THEIR PERSONAL INFORMATION, and may do so by clicking the “Do Not Sell My Personal Information” link, which is contained on the bottom of Westland’s homepage.  Additionally, if Westland changes it practices, all California consumers who have previously clicked the “Do Not Sell My Personal Information” link will be included as consumers who have opted-out of the sale of information.  Additionally, if Westland changes it practices, an electronic communication will be provided to all California consumers not presented on the “opt-out” list that: 1) describes the right to opt-out of the sale of their personal information, 2) a link to and identification of the webpage where you will be able to submit an opt-out request as well as instructions describing the offline method to submit a request to opt-out, 3) any proof required when a consumer uses an authorized agent to exercise their ability to opt-out; and 4) a link or URL to the privacy policy.  California consumers may also submit opt-out requests in writing to the Data Privacy contact listed above.

Direct Marketing

As described above, you can opt-out of receiving direct marketing from us at any time.  We may use the information you give us on our website or other means for direct marketing purposes to provide emails and other messages to keep you informed of rental space opportunities or our services.  You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by contacting the Data Privacy contact that is listed above on this notice.

Cookies

We use cookies that identify your browser. They collect and store information when you visit our website about how you use it through which it is possible to record your use of the website, as well as provide you with a better service and experience when browsing and for analytics. The personal data we collect through these technologies will also be used to manage your session.

For more information about cookies and how we use them, please see our: Cookie Notice.

Links to Third Party Websites

Our website and other communications may, from time to time, contain links to and from the websites of others.  The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

Children

We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us.

Changes to This Notice

This notice may be changed from time to time.

If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.  To the extent that you are reviewing an offline copy of this notice, the most current copy of this notice is available online at www.westlandrealestategroup.com/s/privacynotice.pdf

Requests for Accessible Information

Westland has attempted to produce this notice in a format accessible to prospective tenants, prospective residents, tenants or residents with disabilities.  To the extent that you are unable to access, or unable to fully access this notice, please contact us as set out at the top of this notice and Westland will attempt to provide access in an alternative format.

How to Contact Us

If you would like more information about the way we manage personal data that we hold about you, or have questions or concerns about Westland’s privacy policies and practices, please contact us as set out at the top of this notice.

Westland Industries Inc