1. Possible Personal Information Collected
Personal information is:
(1) Information in a consumer report; or
(2) An individual’s first name or initial and last name in combination with any of the following:
(a) Birth date;
(b) Social security number or other government issued identification number;
(c) Mother’s maiden name;
(d) Unique biometric data (fingerprint, voice print, retina image);
(e) Unique electronic identification number our routing code;
(f) Telecommunication access devices including debit or credit card information; or
(g) Financial institution account or information.
(h) E-mail address
A consumer report is a report related to a person’s credit worthiness, credit standing, credit capacity, character,
general reputation, personal characteristics, or mode of living prepared by or obtained from an agency that
collects such information such as a credit reporting agency.
2. Method By Which Personal Information is Collected
This company obtains personal information in the following ways:
(1) In consumer reports from reporting agencies to which this company subscribes in connection with lease
applications, loan applications, or for other reasons that the consumer may authorize this company to obtain;
(2) In lease applications a prospective tenant completes;
(3) In other real estate related forms the customer or client completes in or related to a transaction; and
(4) In tax reporting forms that the customer or client is required to complete and which are given to this
(5) At our website.
When completing the forms required above, the customer or client may send the information to this company by
mail, fax, personal delivery, or by e-mail. Customers or clients may occasionally provide personal information
to this company or its agents by other means such as telephone calls, fax messages, or e-mail messages in order
expedite a transaction in which the customer or client is involved. Changes in person information must be
submitted in writing.
3. How and when is the personal information used?
Personal Information from Prospective Tenants: The personal information that prospective tenants provide to
this company is primarily used to obtain consumer reports (credit checks). It may also be used to perform
background checks and rental history searches. The information in the consumer reports may be discussed with
landlords for whom this company manages property. This company also reports information to credit reporting
agencies and uses personal information to complete those reports. Personal Information from Owners of
Page 2 of 3
Properties Managed by the Company: When this company acts as a property manager for a property owner, the
company uses the property owner’s personal information only:
(a) To deliver the required management services
(b) To file any required reports with governmental agencies (for example, the IRS)
(c) To establish ACH deposits; or (d) for other purposes the property owner may authorize, such as providing
Personal Information from Clients: When this company represents a person (buyer, seller, landlord, or tenant) in
a transaction the agent servicing the client may, on the client’s behalf and at the client’s instruction, convey
personal information he or she provides to the agent to service providers (for example, mortgage lenders and
title companies) as those service providers may require for the products or services the client needs or requests.
If this company represents a prospective tenant in a lease transaction, the personal information may, on the
tenant’s behalf and with the tenant’s knowledge, be discussed with and provided to landlords or their agents.
This company and its agents exercise reasonable discretion when discussing any personal information with
4. Methods By Which The Personal Information is Protected
Written files in this company are kept under lock and key. Electronic records are protected under an access
name and password assigned to persons in this company. This company and its agents exercise reasonable
discretion when discussing any personal information with others and releases personal information to others
only as described by this policy. This company does not permit its employees or agents to make copies of
consumer reports or records of insurance claims. The consumer reports retained in the company’s files are not
to be accessed in the future as a convenience to customers or clients. The individual agents that work with this
company are independent contractors and the agent with whom a customer or client works with may maintain a
separate transaction file. The company instructs its agents to not permit other persons to access the personal
information in files the agents maintain. The company instructs its agents to protect the personal information in
the agents’ files in the same manner as described in this policy.
5. Access to Personal Information?
The following persons have access to personal information in this company’s files:
(1) The agent or broker who is servicing or coordinating the transaction;
(2) The office manager to whom the agent reports; and Property Manager, Assistant
Property Manager, and Receptionists
(3) Application processors;
(4) Employees who need to access the information to assists agents, brokers, accountants, office manager in
processing or performing a task.
(5) Property owners for whom the company manages properties.
Personal information from a buyer, seller, landlord, or tenant may be discussed with others (such as mortgage
lenders or prospective landlords) only as is reasonably necessary to negotiate or close the transaction or to
provide the services the customer or client seeks from this company. This company may, at the customer’s or
client’s request, provide personal information to service providers in a transaction such as a title company or
mortgage company if it is necessary to expedite or complete a transaction. If the company is required by law to
allow others to access the personal information in the company’s files, the company will comply with the law
(for example, compliance with court orders, subpoenas, or governmental investigations). The company will also
allow law enforcement agencies access to personal information in order to cooperate with such investigations.
Page 3 of 3
6. Disposal of Personal Information
Personnel are not to destroy documents without permission of management. The company uses reasonable
measures to dispose of personal information. Personal information is usually disposed of by shredding or
burning documents, erasing electronic files by means that make the files unreadable or undecipherable, or by
eradicating personal information from documents or electronic files in ways that make the personal information
7. Erroneous Records:
If this company erroneously reports information to a consumer reporting agency, the company will act to
correct the information in the company’s records and request the reporting agency to correct the information in
its records promptly after the company has learned and determined that the report was in error. If this company
maintains an erroneous record that a consumer has issued a dishonored check, the company will promptly delete
the record after the company and consumer agree that the information is in error or after the consumer provides
the company with a law enforcement agency report stating that the dishonored check was not authorized.
Notice: This Company asks any person who provides personal information to this company or one of its
agents to identify the information at that time as “personal information.”