Privacy & Security

Effective Date: January 1, 2023

RealPage is committed to providing our product and service users with clear and concise information regarding our privacy policies and practices. This Privacy Statement describes how RealPage and its subsidiary, Multifamily Internet Ventures, LLC d/b/a PolicyValidator, ("PolicyValidator", "we", or "us") collect, use, and disclose certain personal data for our 3rd party insurance tracking service. By accessing our website or utilizing our PolicyValidator service, you consent to the information collection and handling practices outlined in this statement.

I. PolicyValidator Services and Scope

PolicyValidator provides a secure website for apartment residents to upload and validate their renters insurance policies in accordance with the requirements established by their apartment community property management. We collect and processes personal information as a service provider to property owners and management companies. The PolicyValidator service provides processing and evaluation of the uploaded insurance policies, with notification and reporting on policy compliance with the apartment owners and/or managers designated mandatory minimum insurance lease requirements. Review of uploaded policies will include, but not be limited to, (i) verification of adherence to designated minimum insurance requirements, (ii) matching of named insured(s) with designated resident(s), (iii) confirmation of policy coverage dates, and (iv) confirmation of proper interested party designations. This Statement does not apply to the privacy or security practices of any third party.

II. Personal Information Collection

PolicyValidator has collected the following categories of personal information necessary to provide our Insurance Services in the preceding twelve (12) months:

Note: Some personal information included in this chart may overlap with multiple categories.

III. Personal Information Exceptions

Personal information does not include:

• Publicly available information from government records.
• De‐identified or aggregated consumer information.
• Information excluded from state privacy law scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

IV. Personal Information Sources

Personal information is collected directly from service users via the PolicyValidator website and associated customer support communication channels (email and phone support).

V. Personal Information Use & Processing

The personal information collected by PolicyValidator is used for a variety of purposes, including:

• Finding and accessing your apartment community to obtain required liability limits
• Reviewing the policy start and end dates to ensure proper coverage during move in/renewal
• Reviewing Liability limits to meet your minimum requirement
• Notifying your apartment community if lease requirements are not met
• Integration with apartment community leasing and rents software, including Interested Party cancellation and lapse notifications
• Distribution of communications regarding the status of the uploaded policy
• Integration with your apartment community online resident portal

PolicyValidator will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

VI. Personal Information Disclosure

PolicyValidator does not sell or share personal information, and no such activity has occurred in the prior 12 months.

PolicyValidator may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors that support or integrate with the services described in this statement (see chart below). PolicyValidator only discloses personal information to the extent reasonably necessary to support PolicyValidator service requirements, or for the third-party vendors or service providers to perform the services on our or your behalf. We do not permit third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request of them. However, please note that PolicyValidator does not maintain direct control over the privacy policies and practices of any third-party companies, agents, or contractors.

VII. Personal Information Rights and Choices - State Privacy Rights

Certain state jurisdictions (California, Virginia, Colorado, Connecticut, and Utah) provide their legal residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with statutory guidelines. This section describes your rights and explains how to exercise those rights. Please be advised, the nature of PolicyValidator services and applicable regulations may exempt a significant portion of the personal information collected from the scope of state privacy rights.

Accessing and Updating Personal Information

In the event your personal information is determined to be outdated, incomplete, or inaccurate, for questions or to update your information please contact us at policyhelp@realpage.com.

Access to Specific Information Regarding Personal Information Use/Disclosure and Portability

You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. In response to a verifiable consumer request for these services, we will disclose the following information for the PolicyValidator services:

• The categories, specific types, and sources of personal information we collected about you.
• Our business purpose for collecting the personal information.
• The categories of third parties with whom we share that personal information and the purpose for the disclosure.

You also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, PolicyValidator may be (i) restricted from providing certain personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.

Deletion of Personal Information

You have the right to request that PolicyValidator delete any of your personal information that we collected and retained, subject to certain exceptions. Please note: Under most circumstances, this request for disclosure should be submitted to the property manager that operates your apartment community or rental property. As stated above, PolicyValidator is merely a service provider to your property manager, and we do not control the collection, use, and disclosure of your personal information.

Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:

We may deny your deletion request if retaining the information is necessary for PolicyValidator or our service providers to:

1. Complete the transaction for which we collected the personal information, provide the PolicyValidator services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug PolicyValidator services 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. 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.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or your property manager.
7. Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

VIII. Submitting Consumer Requests - 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 Via the secure webform linked here

Only you (or someone legally authorized 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 confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

IX. Consumer Request Responses and Timelines

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@realpage.com. We endeavor to respond to a verifiable consumer request within forty‐five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, 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 where possible. If you do not have an account with us, or your existing account lacks a communication feature, we will deliver our written response to your designated email address.

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.

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.

X. Personal Information Sales and Sharing - Opt Out Rights

PolicyValidator does not sell or share personal information, and no such activity has occurred in the prior 12 months. In the event that PolicyValidator changes its practices and engages in the sale or sharing of personal information as regulated by law, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with regulatory requirements.

XI. Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law, we will not engage in any of the following practices in response to your exercise of privacy rights:

• 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.

XII. Other California Privacy Rights

The State of California also grants California residents privacy rights via laws unaffiliated with the CCPA/CPRA. Those rights include the following:

California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@realpage.com.

XIII. Cookies, Web Beacons, and Other Technologies - Do Not Track

When you access our Insurance Services or our website, our servers may place small text files (“cookies”) on your computer for recordkeeping purposes. Among other things, cookies enable us to gather information about your activity on our website for the purposes of improving your online experience, establishing secure user accounts, remembering your preferences and settings, and for other similar customization purposes.

In addition to cookies, our Insurance Services and our website may utilize web beacons, clear gifs, or other technologies to gather information on how users interact with and utilize various features. For example, these technologies can identify popular pages, viewing patterns, click-through, conversion rates, and other information that can be used to improve, monitor, and operate our websites, products, and services.

A detailed summary of our cookie and similar technology usage is set forth in our Cookie Policy

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers, and our sites are not currently set up to respond to those signals. Most internet browsers provide controls that allow users to directly manage or disable the placement and usage of cookies on their computer. Please note that disabling cookies may deactivate or otherwise restrict certain features of our Insurance Services or our website.

XIV. Third Party Links to Other Sites

Our Insurance Services may include links to third party service providers contracted by Clients. These linked services are operated by unaffiliated third parties that have separate and independent privacy statements, terms of use, and related notices or disclosures regarding information handling practices. We cannot be responsible for the information handling practices of independent parties and encourage you to review their practices prior to information disclosure.

XV. Data Security

PolicyValidator implements and maintains appropriate physical, administrative, technical and organizational measures to protect the information we process against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to personal information is restricted and authorized only for those who have a business need for such access. PolicyValidator strives to protect the personal information that we process; however, no security program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal information. We maintain security incident response policies and procedures to handle incidents involving unauthorized access to personal data we process.

XVI. Children's Online Privacy

PolicyValidator services do not target or attract the attention of children under the age of 13 for the online collection of personal information.

XVII. Changes to Our Privacy Statement

PolicyValidator reserves the right to amend this privacy statement at our sole discretion at any time. When we make changes to this privacy statement, we will post the updated content to our applicable websites and services along with the effective date of the change. Your continued use of our Insurance Services following the posting of changes constitutes your acceptance of such changes.

XVIII. Contact Us

If you have any questions or concerns about this Privacy Statement or its implementation, you may contact us via the following methods:

Via US Postal Service at:

RealPage, Inc.
Attn: Privacy (Legal)
2201 Lakeside Blvd.
Richardson, TX 75082

OR Via email at: privacy@realpage.com