2. The Types of Information You May Provide. User Information falls into two categories (i) Personal Information, and (ii) Anonymous Information, as defined below:
2.3. Personal Information. The term "Personal Information" means non-public information that could reasonably be used to identify a specific individual, including an individual's name, Social Security number, government-issued ID number, email address, telephone number or other contract information. Personal Information may also include an individual's resume, provided the resume includes the individual's Personal Information.
2.4. Anonymous Information. The term "Anonymous Information" means information that does not identify an individual, and may include statistical information concerning, for example, the pages on our website that users visit most frequently, or the on-post military communities that receive the most housing applications.
3. Your Responsibility for Providing Information.
3.1. Using Caution. You decide whether you wish to provide us with Personal Information; however, in certain instances if you do not provide us with Personal Information we will not provide the requested information, product or service. If we ask for Personal Information (such as a Social Security number or passport number) via the website, for example, we will do so by labeling the appropriate portion of the online form or submission area with the specific information we seek.
3.2. Disclosing Personal Information Where it is not Specifically Requested; Submitted Content. If we have not specifically asked for a Data Subject's Personal Information in a particular portion of an online form or submission area on a paper form, you should not provide it in that portion of the form or submission area. If you choose to disclose Personal Information to us where it is not specifically requested, that information will be treated and protected as we would any other publicly available information, and not as Personal Information.
4. Our Uses of Personal Information. We use Personal Information about Data Subjects only as provided in this Policy. We may collect information about Data Subjects at different points (for example, when you request information, submit housing applications to us or apply for jobs through our website), and use this information as follows:
4.1. Account Registration; User Names. In order to access information, products and services on our website that are limited to website registrants, we require that you complete a registration form. This form asks for certain Personal Information. We use the information a website registrants submits during the registration process to provide a website registrants with a user name and a password, and to allow the website registrants to gain access to password protected areas of the website. We also use Personal Information the website registrants submits to provide any of the services that we offer through the website or through other means.
4.2. Providing Information, Products or Services. We use Personal Information and other information submitted to provide Data Subjects with the information, products and services (such as housing services and maintenance services) that they have requested. For example, as the occupant of a home in one of our communities, you may submit a maintenance request through our website or in person, and we use the information you submit to provide the requested service.
4.3. Employment Applications; E-Verify. In the employment section of our website and through other public job postings, we may invite you to apply for employment opportunities with us by submitting your Personal Information, employment information, resume and other, similar kinds of information. We may use this information to evaluate your application and to determine whether you may be qualified for positions with us. Because we receive a large volume of applications, we do not guarantee that we will contact you after you submit an employment application. Additionally, it may be necessary or advisable for us to use Personal Information to verify employment eligibility through the E-Verify system.
4.4. Third-Party Information. We may ask you to provide Personal Information for third parties through the website or through other means (such as through paper forms); when we do so, we will use this information to help provide the information, products or services you have requested. In the employment section of our website, for example, we ask you to provide the name and email address of the person who referred you to us. We may use the information you provide to contact that person in connection with your job application. When we ask for this information, it will be protected under this Policy in the same way that we protect your Personal Information. Before you submit Personal Information about third parties to us, please be sure you have permission from the third party to share the information with us.
4.5. Verifying Identity. When you request a product, service or information from us, we may use Personal Information (and other information that we have about you) to verify your identity and to process your request. This is designed to further protect you and to reduce the threat of identity theft and fraudulent transactions.
4.6. Promotions; Submitted Content. We believe that your experiences with us can often act as the strongest promotion for our products and services. To promote and illustrate our products and services, we may wish to post on our website, or elsewhere, endorsements from, or other descriptions of experiences by, you, as well as comments, feedback and other information that you wish to share (collectively, "Submitted Content"). Submitted Content also includes any other information that does not otherwise constitute Personal Information. You agree that we may use and adapt your Submitted Content (including, but not limited to, your name, military rank (if applicable), state of residency, experiences with us and other provided feedback) for these purposes and without the need for compensation. Please review our Terms and Conditions of Use for more information on how we treat Submitted Content.
4.7. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, e-newsletters and other information to Data Subjects using provided Personal Information. For example, we may send Data Subjects information that we believe is relevant to them, including information about severe weather, neighborhood watch advisories, AMBER Alerts and surveys, all via email, automated voice and SMS text message. In certain circumstances we or our Vendors may ask Data Subjects to further confirm their consent to receiving these communications. Data Subjects may also incur, and shall be responsible for, all messaging and data fees charged by their service providers (such as their wireless carriers) in connection with their receipt of these communications. Data Subjects may opt out of receiving these communications as provided in Section 8 (Opting Out), provided, however, that there are certain communications for which Data Subjects cannot opt out. Please refer to Section 8 (Opting Out) for more details.
4.10. Other Uses. In addition to the uses specifically identified in this Section 4 (Our Uses of Personal Information), there may be instances where you request information, products and services from us that are not described in this Policy. We will use Personal Information that you submit in order to provide such information, products and services.
5. Anonymous Information. We use Anonymous Information to analyze the effectiveness of our website, to improve our products, services and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our services and the characteristics of visitors to our website, and may share Anonymous Information with third parties, including advertisers. Anonymous Information provided to third parties will not allow anyone to identify a Data Subject, or determine any Personal Information about the Data Subject. We may collect Anonymous Information through features of the software that supports our services, such as cookies or other means described below.
5.1. IP Addresses; Logs. Either directly, or through our hosting service provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer's name, the type and version of your web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our website is being used and for security and monitoring purposes.
5.2. Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website on a future visit. We may include cookies on our website and use them to recognize you when you return to our website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our services.
5.4. Click-Throughs. We may send email messages which use a "click-through URL" linked to content on our website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 8 (Opting Out).
7. Disclosures to Third Parties. We will not disclose Personal Information about a Data Subject to third parties without express consent, except in the circumstances specified below.
7.1. Vendors. We employ other companies to perform functions on our behalf or on a Data Subject's behalf, such as providing services related to our products and services, maintaining the website, collecting information, responding to and sending electronic mail and other communications (including, but not limited to, those described in Section 4.7 (Informational Notices and Bulletins)), or other functions necessary to our business (collectively, the "Vendors"). We may share Personal Information with our Vendors so that they can provide the services that we request from them. We will provide Vendors with only that Personal Information necessary to perform their functions, and we will not allow them to use Personal Information for any purpose inconsistent with this Policy. We require that our Vendors agree contractually to comply with privacy laws and to maintain protections for Personal Information that are consistent with this Policy.
7.2. Government Regulators. We are periodically required to disclose certain Personal Information to third parties, such as credit reporting agencies, and federal and state regulators, in order to do business with you.
7.3. Military Personnel. We disclose Personal Information to the United States Military as the military requires, by law or regulation in accordance with our reasonable interpretation of that law or regulation, or as necessary to provide the products and services that we have agreed to supply as part of our contracts with the military. We will not disclose more information than is necessary to comply with these obligations.
7.4. Affiliates. In order to provide Data Subjects with valuable product and service offerings, we share Personal Information with our affiliates. Our affiliates have agreed contractually to comply with privacy laws and to maintain protections for Personal Information that are consistent with this Policy. Data Subjects have the ability to "opt-out" of this information-sharing by following the directions provided in Section 8 (Opting Out).
7.5. E-Verify System. We will comply with the E-Verify program where applicable. Accordingly, it may be necessary or advisable for us to disclose Personal Information about Data Subjects to the federal government.
7.6. Questions of Harm. We may disclose Personal Information about Data Subjects on a case-by-case basis to attorneys, private investigator organizations or law enforcement agencies if we believe that: (i) the Data Subject is at risk of harm from another, or (ii) the Data Subject is harming or interfering (or will harm or interfere) with others, is violating (either intentionally or unintentionally) our Terms and Conditions of Use, or is otherwise violating legal obligations.
7.7. Legal. We will disclose Personal Information about Data Subjects to the extent we reasonably believe that we are required to do so by law. If we receive legal process requiring the disclosure of Personal Information about a Data Subject, we will attempt to notify the Data Subject via the email address we received for the Data Subject within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
7.8. Transfer of Ownership. We shall be entitled to transfer Personal Information to a third party in connection with a sale of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring party has agreed to safeguard Personal Information with protections that in all material respects are the same as, or more protective than, those set out in this Policy.
8. Opting Out. Because we respect privacy rights, we give Data Subjects the following choices of how they may opt out of receiving information from us:
8.1. Opting-Out of Updates. If we choose to send bulletins, updates, product offerings or other communications to Data Subjects, we will provide them with the ability to decline – or "opt-out of" – receiving such communications. Instructions for opting-out will be provided if and when we determine to send such communications and such instructions may be included in the communications themselves. Data Subjects will not be allowed to "opt-out" of formal notices concerning operation of our website and business or legal and other related notices concerning their relationship to us or the website and our business.
8.2. Opting-Out of Information-Sharing. Data Subjects may choose to opt out of our information-sharing with our affiliates. Making this decision will prevent us from sharing Personal Information with our affiliates, and this choice may limit our ability to offer certain information, services and products provided by our affiliates. To opt-out of our information-sharing with affiliates, please contact us as provided in Section 13 (Contact Us).
8.3. Opting-Out and Multiple Data Subjects. For products and services that were requested by a single Data Subject, but that apply to multiple Data Subjects or other individuals, we will treat an opt out by any Data Subject as applying to all Data Subjects (or others) covered by the products or service (for example, if you are the head of a household and opt-out under this Section, we will apply that opt-out decision to your family as well).
8.4. Opting-Out and Military or Government Personnel. Under certain circumstances, such as those specified in Section 7.3 (Military Personnel) or Section 7.5 (E-Verify System), it may be necessary for us to disclose Personal Information about a Data Subject to the Military or U.S. Government. In these situations, Data Subjects do not have the option to opt-out of these disclosures of their Personal Information.
9. Access; Removing Information. We provide Data Subjects with access rights to their User Information and provide them with the right, upon their request, to change, update or delete their information in accordance with our contracts with the Military and the law, as we reasonably interpret them. However, it may be impossible to remove this information completely, due to backups and records of deletions. Data Subjects may not remove de-identified, anonymous or aggregate data from our databases.
10. Security. We have put in place security systems, physical safeguards, technical safeguards and quality controls designed to prevent unauthorized access to, or disclosure of, Personal Information. Our security systems are structured to deter and prevent unauthorized users and others from accessing Personal Information we receive about Data Subjects. However, these safeguards are not fail-proof and, due to the nature of internet communications and evolving technologies, we cannot provide, and disclaim (to the extent permitted by law), any assurance that the information we receive about Data Subjects will remain free from loss, misuse or alteration by third parties who, despite our efforts, obtain unauthorized access. Moreover, you play a key role in protecting the security of information about you. For example, you should guard your password to our website and decline to allow others to use this password. In addition, you should close your browser when have finished viewing your information on our website to prevent others from viewing your Personal Information.
11. Website Participation by Children and Teens; Advisory. Our website is not directed at children and we will not accept or request Personal Information from individuals that we know to be under 13 years old. In accordance with the Children's Online Privacy Protection Act, if we learn that a child under 13 years old has provided Personal Information, we will delete this information from our databases in accordance with our deletion procedures set out in Section 9 (Access; Removing Information). If you are between 13 and the applicable age of majority, please review this Policy with your parent or guardian.
Name: Bill Culton
Address: 1405 South County Trail, East Greenwich, RI 02818
15. Do Not Track Notice. Our website does not change its behavior when receiving "Do Not Track" signals from browser software.
17. Copyright and Legal Notice. Copyright ©2015 Corvias Group, LLC. All Rights Reserved.