Effective Date: January 1, 2024
This State Privacy Notice (“Notice”) applies to “Consumers” as defined under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (together, the “CCPA”), the Colorado Privacy Act, Chapter 603A of the Nevada Revised Statutes, and all laws implementing, supplementing or amending the foregoing, including regulations promulgated thereunder (collectively, “U.S. Privacy Laws”). Capitalized terms used but not defined in this Notice shall have the meanings given to them under U.S. Privacy Laws.
This Notice is designed to meet our obligations under U.S. Privacy Laws and supplements the general privacy policies of Stratos Management LLC and its affiliates (“Company,” “us,” “we,” or “our”) including, without limitation, our Website Privacy Policy. In the event of a conflict between any other Company policy, notice, or statement and this Notice, this Notice will prevail as to Consumers unless stated otherwise.
1. Notice of Data Practices
(a) PI Collection, Disclosure, and Retention - By Category of PI
(b) PI Use and Disclosure - By Processing Purpose
2. Your Consumer Rights and How to Exercise Them
(a) Right to Limit Sensitive PI Processing
(b) Right to Know/Access
(1) Categories (available for California Residents Only)
(2) Specific Pieces
(c) Do Not Sell / Share / Target
(d) Right to Delete
(e) Correct Your PI
(f) Automated Decision Making/Profiling
(g) How to Exercise Your Consumer Privacy Rights
(1) Your Request Must be a Verifiable Consumer Request
(2) Agent Requests
(3) Appeals
(h) Our Responses
3. Non-Discrimination/non-retaliation
4. Notice of Financial Incentive Programs
5. Our Rights and the Rights of Others
6. Additional Notice for California Residents
(a) California Minors
(b) Shine the Light
7. Contact Us
The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates, however, if materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection.
We may collect your PI directly from you (e.g., when you register for an account or when you otherwise provide us information online); from your devices such as when you connect with a wi-fi system at one of our communities (it is not our practice to associate a device ID to a particular person); over the phone; through paper documents such as lease applications; from guest cards when you tour a community; from video security systems at our properties; from credit reporting agencies when you apply to live in one of our communities; from our websites with which you interact; in our notes and records we create about you; from our affiliates; from our service providers; from public sources of data such as government databases; or from other businesses or individuals.
Generally, we Process your PI to provide you services and as otherwise related to the operation of our business, including for one or more of the following Business Purposes:
NO SMS CONSENT WILL BE SHARED WITH THIRD PARTIES OR AFFILIATES FOR MARKETING PURPOSES.
We may also use PI for other Business Purposes in a context that is not a Sale or Share under U.S. Privacy Laws, such as disclosing it to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”), to the Consumer or to other parties at the Consumer’s direction or through the Consumer’s action; for additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); as required or permitted by applicable law; to the government or private parties to comply with law or legal process; and to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”) (“Additional Business Purposes”).
We provide more detail on our data practices in the two charts that follow.
(a) PI Collection, Disclosure, and Retention - By Category of PI
We collect, disclose, and retain PI as follows:
Retention
Category of PI
1. Identifiers
Examples of PI Collected and Retained
Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, e-mail address, account name, or other similar identifiers.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: Third-Party Digital Businesses; Third-Party credit card and/or rewards program providers.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
2. Personal Records
Examples of PI Collected and Retained
Name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, insurance policy number, and financial information (e.g., bank account or credit card number). Some PI included in this category may overlap with other categories.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: Third-Party background check providers.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
3. Personal Characteristics or Traits
Examples of PI Collected and Retained
In some circumstances, we may collect PI that is considered protected under U.S. law, such as sex, marital status, veteran status, familial status, disability, age, gender identity, or creed, but only when that information is relevant for our Business Purposes. We abide by the legal requirements imposed under applicable law in regards to such information.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: Third-Party background check providers.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
4. Customer Account Details/Commercial Information
Examples of PI Collected and Retained
Records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
5. Internet Usage Information
Examples of PI Collected and Retained
When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, applications, or advertisements.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
6. Geolocation Data
Examples of PI Collected and Retained
If you use our systems or interact with us online we may gain access to the approximate, and sometimes precise, location of the device or equipment you are using or the location from which you are accessing our systems or facilities using Company-issued access devices.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
7. Sensory Data
Examples of PI Collected and Retained
We may collect audio recordings of customer support calls, video security footage, photographs, and other electronic, visual, thermal, olfactory, or similar information.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
8. Professional or Employment Information
Examples of PI Collected and Retained
Professional, educational, or employment-related information.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
9. Non-public Education Records
Examples of PI Collected and Retained
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, schedules, student identification codes, student financial information, or student disciplinary records.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Anywhere between 45 days or less and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Category of PI
10. Sensitive PI
Examples of PI Collected and Retained
Government Issued Identification Numbers (e.g., social security, driver s license, state identification card, or passport number)
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Generally between 135 days and up to 7 years following move out or sale of applicable property, or as otherwise stated below.
Financial Data (e.g., a credit card number in combination with any required security code)
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Not retained beyond processing an immediate payment transaction.
Unless Consumer saves for autopay purposes.
Precise Geolocation (any data that is derived from a device and that is used or intended to be used to locate an individual w/in a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet), such as when you use a Company-issued access device to access our facilities.
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Facility entry system data is generally retained between 60 days and 1 year, depending on the particular system. In use.
Health Information (PI collected and analyzed concerning a consumer s health, medical history, mental or physical health, diagnosis/condition, and medical treatment).
Categories of Recipients
Disclosures for Business Purposes:
Sale/Share: None.
Retention
Generally up to 7 years following move out or sale of applicable property, or as otherwise stated below.
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.