PRIVACY POLICY - CALIFORNIA ADDENDUM
APARTMENT INVESTMENT AND MANAGEMENT COMPANY
Updated: January 1, 2020
This privacy policy addendum for California residents supplements the information contained in the privacy policy of Apartment Investment and Management Company (collectively, with its subsidiaries and affiliates, “Aimco,” “we,” or “us”) and applies solely to individuals who reside in the State of California. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this privacy policy addendum.
Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”) of various types and from various sources in the course of your engagement with us and our services. Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information excluded from the scope of the CCPA including personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, California Financial Information Privacy Act, or the Driver's Privacy Protection Act of 1994. Set forth below are the categories of personal information that we collected in the past 12 months, why we collect it, and the categories of sources from whom we collect it.
A. Identifiers (examples: real name, postal address, internet protocol address, email address, driver’s license number)
Categories of Sources You (directly or indirectly from independent listing services or third-party service providers to whom you provided information concerning our properties)
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (examples: name, signature, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.)
Categories of Sources You or your agent (directly or indirectly from independent listing services or third-party service providers to whom you provided information concerning our properties) Credit Reporting Agencies Insurance Company designed by you
C. Characteristics of protected classifications under California or federal law (examples: Age (40 years or older), race, color, religion, marital status, sex)
Categories of Sources You or your agent Credit Reporting Agencies Data Aggregators
D. Commercial information (Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Categories of Sources You or your agent Credit Reporting Agencies Data Aggregators
E. Biometric information (examples: fingerprint and facial recognition)
Categories of Sources You (when you sign-up for applicable access systems)
F. Internet or other similar network activity (examples: browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)
Categories of Sources You or your agent Automated collection and by third-party service providers H. Audio, electronic, visual, or similar information (examples: audio or video recordings)
I. Professional or employment-related information (examples: employment history. Some personal information included in this category may overlap with other categories.)
Categories of Sources You or your agent Credit Reporting Agencies
K. Inferences drawn from personal information (examples: consumer shopping preferences)
All personal information collected by us under the various categories listed above is collected for a variety of business purposes as set forth below. Business Purposes for collection of all categories of personal information:
to provide services which you have requested from us to verify your identity to fulfill or meet the reason for which the information is provided to process payments or perform a tenant screening to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits to improve the content of our websites or other services, to enhance users’ experiences when visiting our websites or using our services, and to customize the content and layout of websites for each individual user To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections For testing, research, analysis and product development As necessary or appropriate to protect the rights, property or safety of us, our clients or others To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, or any other transaction in which personal information held by us is among the assets transferred or constitutes relevant information for evaluation of the transaction As described to you when collecting your personal information or as otherwise set forth in the CCPA Sharing of Personal Information
We may disclose your personal information to a third party for a business purpose. Aimco does not sell personal information to third parties. We have disclosed to third parties the following categories of personal information for a business purpose in the past 12 months:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category C: Characteristics of protected classifications under California or federal law (age)
We disclosed personal information for a business purpose to the following categories of third parties in the past 12 months:
Our affiliates Service providers Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you Your California Privacy Rights
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You 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 or selling that personal information. The categories of third parties with whom we share that personal information. The specific pieces of personal information we collected about you (also called a data portability request). If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Deletion Request Rights
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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers 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 providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at:
888.227.9616 CCPAHelp@aimco.com Only you or a person registered with the California Secretary of State that you authorize 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. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected 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. 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 Timing and Format
We endeavor to respond to a verifiable consumer request within 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. 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 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 consumer 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Changes to Our Privacy Policy Addendum
We reserve the right to amend this privacy policy addendum at our discretion and at any time. When we make changes to this privacy policy addendum, we will notify you by email or through a notice on our website homepage
