Mill Creek Residential Privacy Policy
Effective July 11, 2018

How Our Privacy Policy Applies
This Privacy Policy explains how we collect, use, and disclose the Personal Information You may provide to us through this Site via the Mill Creek Residential website found at www.MillCreekPlaces.com or through any residential portal or prospective resident portal (the “Site”), and other Personal Information that you provide to us offline or indirectly through third party advertiser sites. This statement may be revised from time to time, so please revisit this page to remain fully informed of our commitment (see “Changes to Privacy Policy” Section below).

By visiting our Site, you agree that we may treat your information in the ways we describe in this Privacy Policy. If you do not agree with any term of this Privacy Policy, you must refrain from using our Site and providing us with your Personal Information.

Types of Personal Information We Collect
We collect Personal Information and Usage Data through the Site.

“Personal Information” means any information by which You can be personally identified, such as Your name, address, age or date of birth, race or ethnicity, email address, number of occupants, Your occupation, employment information, salary, telephone number, education, the kind of service provided to You, social security number, username and password, real property purchased, leased, or rented, bank account number, debit card number, bank or investment account, debit card or credit card balance, payment history, and information pertaining to Your creditworthiness, assets, income or liabilities.

“Usage Data” means any information that we automatically collect about how you use the Site, but that alone cannot be used to identify you. Examples of Usage Data include your IP address, browser type, device type, and pages you visited. Tracking technologies, like cookies and web beacons, help us collect this Usage Data. To learn more about cookies and how to control them, please review the section on Data Collection Technologies.

When you make a payment through the Residential Portal, we collect information about your payment history and payment information.  Although we use a third-party payment processor to facilitate any payments made on our Site through the Residential Portal, we retain this information for accounting purposes and to respond to inquiries, communicate with you about your account, and for other business purposes.

We intend to implement this Privacy Policy in a manner consistent with applicable employment laws. To the extent that such applicable employment laws are in conflict with this Privacy Policy, we will act in accordance with such applicable employment laws.

How We Use and Disclose Personal Information
We collect, retain, and use Personal Information for the reasons stated below:

  • To complete the leasing process;
  • To request a credit report in connection with leasing applications;
  • To contact you in response to your inquiries, comments and suggestions;
  • To contact you otherwise when necessary;
  • To assist with management of your amenities and utilities, as listed in your lease;
  • For the specific purpose for which it was volunteered (for example, to receive notice from us, etc.);
  • To track our visitors’ use of the Site for internal market research;
  • To improve the Site and the services Mill Creek Residential promotes or provides through the Site or through other means;
  • For special promotions, contests or survey registrations;
  • To customize the content and/or layout of our Site for each individual visitor;
  • To ask for your participation in brief surveys and to provide the results thereof;
  • To process your responses to surveys, questions, or other requests;
  • To complete any purchases, payments, or other transactions you may perform at the Site;
  • To notify visitors about updates to the Sites or services;
  • To notify You about promotions, special offers, etc., regarding products and services provided by us or our affiliates or partners;
  • To be provided to third parties who provide services on behalf of Mill Creek Residential;
  • As required by law or regulation, or as requested by government authorities;
  • In connection with an acquisition, merger, sale or other transfer of all or any portion of our business; and
  • For our internal business purposes.

 

How We Share Your Personal Information
We may share your Personal Information as disclosed to you at the time we collect it, with your consent, and in the following circumstances:

  • Service Providers: We may provide your Personal Information to our services providers that help us run and manage our business, such as technology service providers, analytics providers, utility providers, screening companies, rental insurance companies, collections agencies, customer service providers, and our credit card processors.
  • Property Owners, Property Managers, and Other Subsidiaries or Trusted Affiliates: We may provide your Personal Information to other third parties with whom we have alliances in connection to providing our products or services, including, without limitation the owner of any property where you may apply or lease and the management company for such property.
  • Other Web Site Providers: We may provide your Personal Information to other website providers that create additional content for our Site, such as Entrada and Yardi.  Where the terms of the privacy policies or terms of use found on Entrada’s Web Site or Yardi’s Web Site conflict with the terms of our Privacy Policy, the terms of this Privacy Policy shall override.  Please see “Links to Third-Party Web Sites” below for more information.
  • Consumer Reporting Agencies: We may provide your Personal Information to consumer reporting agencies.  If you dispute the accuracy of the information provided, you should notify the consumer reporting agency and contact us regarding the dispute.  Please see “Contact Information” below for our contact information.
  • Prospective Landlords or Lenders: We may provide your Personal Information to prospective landlords or lenders who may request such Personal Information in connection with approval of any rental application or home purchase.
  • As Required By Law: We may disclose your Personal Information as required by law, such as to comply with a subpoena or similar legal process. Additionally, we may disclose Personal Information when we believe that disclosure is necessary to protect the safety and security of our property or the property or others. We may also disclose Personal Information in order to protect our rights, such as to investigate fraud or respond to a government request.
  • Corporate Transaction: In the event Mill Creek Residential is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Information as part of that transaction.

We do not disclose Personal Information to third parties for their marketing purposes.  We reserve the right to share aggregated or anonymized Personal Information with third parties for any lawful purpose.

Offline Collection of Personal Information
We may also collect Personal Information from you through means other than the Site.  This may include offline collections, such as when you submit a paper rental application, make a rent payment y check, or call or visit a Mill Creek Residential management office at a Mill Creek Residential property.  This Privacy Policy does not apply to Personal Information that you provide to us through means other than the Site.  However, if we combine the Personal Information we collect from you outside of the Site with Personal Information that we collect through the Site, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

Data Collection Technologies
We may use cookies, web beacons , and other technologies (collectively, “Data Collection Technologies”) to help us personalize and enhance Your experience on our Site.  Our Data Collection Technologies include:

  •  A cookie is a small string of text that is sent by our Site to your browser and then stored by your browser on Your computer’s hard drive. Our cookies allow us to personalize your experience on our Site, make your visit more convenient, and understand how you and others are using our Site so that we can improve your experience on the Site. We use cookies to identify repeat visitors to our Site and to determine the paths visitors take on our Site. We also use cookies to determine whether you visited our Site from a particular Internet link or advertisement. We commonly use conversion cookies to determine the amount of times people who click on ads from our Site also filled out a guest card or signed a lease.  Conversion cookie data may be used in combination with your Google account to link conversion events across different devices you use.  We do not use conversion cookies for interest-based ad targeting.  We do not use any cookies that store personal information or associate cookie information with personal information you may provide us.
  • Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity and for similar statistical measures.
  • Google Analytics. We use Google Analytics to helps us understand how users engage with our Services. Google Analytics uses cookies to track your interactions with our Services, then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. For more information on Google Analytics, visit https://support.google.com/analytics.

Most Web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. In order to create a profile on our Site you must have your cookies on.  To find out more information about cookies, visit www.allaboutcookies.org.

Do Not Track Signals
Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Site does not respond to “Do Not Track” signals and consequently, the Site will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

Data Security
The security of Your Personal Information is importance to us. We use encryption technology to protect data transmitted during the online lease completion process and for online payment of rent. Your browser will indicate when such encryption is activated (e.g., a padlock icon will be shown in Microsoft’s Internet Explorer).  No data transmission over the Internet can be guaranteed to be 100% secure.  Accordingly, and despite our efforts, we cannot guarantee or warrant the security of any information you transmit to us.

Your California Rights
California Civil Code Section 1798.83 gives California residents the rights to request certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We may share your Personally Information with affiliated third parties, some of which do not share the name of Mill Creek Residential, for their own direct marketing purposes. You may request information regarding the disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes by contacting us as noted below.

Persons Under 13 Years of Age
This Site is not intended for or directed to persons under 13 years of age.  We do not knowingly collect or maintain information at our Site from those we know are under 13, and we do not permit persons under 13 years of age to become registered users of our Site. If we become aware that we have collected information from an individual under 13 years of age, we will immediately delete such information.  No part of our Site is structured to attract anyone under 13. By using our Site you represent that you are not under 13 years of age.

Links To Third-Party Web Sites
Our Site may offer links to other Web sites which may have information policies and practices different from ours. We do not control and are not responsible for the privacy policies or practices or the content of any third party Web sites.  We encourage you to review the privacy policies of any third part website prior to providing them with your Personal Information.

Changes to the Privacy Policy
By using this Site, you consent to our collection and use of Personal Information. Mill Creek Residential reserves the right to change, modify, add or remove portions of this Privacy Policy from time to time. The amended Privacy Policy will be effective upon posting on the Site. Your continued use of the Site and/or the services means that you agree to the revised Privacy Policy and our use of your Personal Information in accordance with the revised policy. Mill Creek Residential may, but is under no obligation to, provide you notice of such modifications to this Privacy Policy via email or other communication.

Email Consent and Opt-Out
Your provision of Personal Information through any of our resident portal Sites constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to the property where you reside, and various services available to you at or through that property.

You may choose to opt out of receiving future commercial email messages from us. Each mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. Please note that if you are a resident of Mill Creek Residential and you opt out of receiving commercial email from us, you will continue to receive email from us regarding operational issues surrounding your apartment, your lease, and/or your community.

Non-U.S. Residents
The Site is intended for use in the United States of America only. All matters relating to our Site is governed by the laws of the State of Texas in the United States of America. If you visit our Site or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.  Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. Your provision of Personal Information to us will be handled in accordance with this Privacy Policy.

Access and Choice
You my access and modify the Personal Information we maintain about you by contacting us using the contact information below.  We will respond to your inquiry within a reasonable timeframe.

How To Contact Us
If you have questions or comments about this Privacy Policy or our privacy practices, please contact us at privacy@mcrtrust.com or by mail at:

JEFFREY D. KOK | CHIEF INFORMATION OFFICER
Mill Creek Residential
2001 Bryan Street | Suite 3275
Dallas, TX 75201