Last Updated: September 10, 2020
- provide Personal Information through this Site via the Mill Creek Residential website found at https://www.MillCreekPlaces.com or through any residential portal, prospective resident portal or online payment portal (the “Site”);
- provide Personal Information to us offline; and
- provide Personal Information indirectly through third party advertiser sites.
Types of Personal Information We Collect
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.
The categories of Personal Information that we collect from you depend on your interactions and engagement with us. For example, we collect:
- Direct Identifiers, such as your name, address, date of birth, social security number, drivers’ license number and information, gender, age, IP address, online identifiers, email address, phone number, payment card or financial account numbers and related information required to process payments, and other similar identifiers. We collect this information to verify your identity and information, screening potential residents, collections activity, communicate with you, process your payments, and provide you with access to your resident portal account.
- Commercial Information, such as the property, leases and services purchased from us, real property purchased, rented or leased from others, insurance information, and number of occupants. We collect this information to maintain client records, identify trends in our client relationships, processing insurance claims, screening potential residents, collections activity, and conduct business analytics.
- Internet Activity Information, such as your browsing history, search history, cookies, browser and device type, and information regarding your interactions with pages you visit on the Sites. We collect this information to understand your use of the Sites and your Account and for targeted marketing and lead management.
- Professional and Employment-Related Information, such as information about your current employment, salary, professional degrees and certifications, and education background. We collect this information to verify your identity, perform background and regulatory compliance checks, and other related processes.
- Profile Information, such as information about your preferences and characteristics. We collect this information in order to understand your preferences and tailor our services and communications to you.
How We Use and Disclose Personal Information
In addition to the purposes for collection described above, we also collect each category of information for the purpose of maintaining our client relationship with you and performing services, which include:
- Onboarding you as a client, maintaining or servicing your account, processing and fulfilling your requests, and other activities that are part of our property, leasing and service offerings;
- Conducting verification and background checks as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks;
- Taking steps to improve our provision of property, leasing and services to you, including to run analytics, improve our artificial intelligence tools, assess the quality of our services, and for other related internal business purposes;
- Confirming your balances, payment history, information pertaining to your creditworthiness, assets, income or liabilities, and managing other aspects of your financial transactions, which includes requesting a credit report in connection with leasing applications;
- Sending you messages promoting our property leasing products and services. You may opt-out of receiving certain promotional e-mail messages from us as described in the “Opt-out” section below;
- Administering and improving our Sites, including to measure the effectiveness of the Sites, to customize the content and/or layout of our Site for each individual visitor, help diagnose problems with our server, see where Site traffic is coming from, to identify our Site users, to track our visitors’ use of the Site for internal market research and to notify visitors about updates to the Sites or services;
- Complying with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims;
- Fulfilling any other purpose described in our agreements with you;
- To complete the leasing process;
- To contact you in response to your inquiries, comments and suggestions;
- To contact you 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 improve the services Mill Creek Residential promotes or provides through the Site or through other means;
- For special promotions, contests or survey registrations;
- 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 you about promotions, special offers, etc., regarding products and services provided by us or our affiliates or partners; 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.
- 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 transfer, assign, or disclose your Personal Information as part of that transaction.
Data Collection Technologies
- 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.
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 https://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.
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. Except to the extent provided by law, we are not responsible or liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Sites and our services.
Your California Privacy Rights
We provide California residents the privacy rights required under applicable law, including the California Consumer Privacy Act and Shine the Light law, as further described below.
California Individual Privacy Rights:
- The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:
- Within the preceding 12 months, we have collected the categories of Personal Information detailed in the “Personal Information We Collect” section above.
- We have not sold Personal Information in the preceding 12 months. We do not sell the Personal Information of minors under 13 without the consent from the minor’s parent or guardian. We do not sell the Personal Information of minors under 16 years old without the minor’s own consent.
- We have disclosed the following categories of Personal Information in the preceding 12 months: contact information; professional and employment information; resident information; payment information; lease information; all Personal Information related to the lease and administration of a property; date of birth; social security number; drivers’ license number and information; gender; age; IP address; online identifiers; email address; property, leases and services purchased from us; real property purchased, rented or leased from others; insurance information; browsing history; search history; cookies; browser and device type; information regarding your interactions with pages you visit on the Sites; and information about your preferences and characteristics.
- The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request as permitted by law under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why such request was denied.
- The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of the Sites or our services or properties.
You may exercise your right to know and your right to deletion two-times a year free of charge. To exercise your right to know or your right to deletion, contact us at 1.833.624.8170 or complete our “California Consumer Request” form available here.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. We may request additional information about you so that we can match the information you provide to information we already maintain about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
Shine the Light: California Civil Code Section 1798.83 gives California residents the rights to request from us once per calendar year certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We may share your Personal 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 at Privacy@MCRTrust.com.
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.
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.
Access and Choice
You may access and request modification of 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
JEFFREY D. KOK | CHIEF INFORMATION OFFICER
Mill Creek Residential
5910 N. Central Expressway
Dallas, TX 75206