California Consumer Privacy Act Notice Addendum

California Consumer Privacy Act Notice Addendum

In accordance with the California Consumer Privacy Act (“CCPA”), we are providing you with the following “Privacy Notice,” which explains the categories of personal information we collect from you, the purposes for which we use it, and your rights under the CCPA. For further details, please refer to our Privacy Policy.

This Privacy Notice applies to all personal information collected in connection with the leasing application process, including information collected during Phase I, Phase II and any additional stages that may follow.

The term “Personal Information” used in this Privacy Notice refers to the information that identifies you as an individual or relates to an identifiable individual.

1. Categories of Personal Information Collected

In connection with your application, we collect the following categories of personal information. Some personal information may be included in multiple categories.

  • Identifiers: Such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver’s license or state identification number, passport number, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute: Such as name, address, telephone number, Social Security number, driver’s license or state identification number, employment history, bank account number, income, and financial information.
  • Protected classification characteristics under California or federal law: Such as age, race, sex, ethnicity, military and veteran status, and dependent information.
  • Commercial information: Such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information: Such as information regarding a consumer’s interaction with our internet website application, or advertisement.
  • Audio, electronic or other similar information: Such as call recordings, call transcripts, and voice interactions
  • Professional or employment-related information: Such as current and past job history.
  • Education Information: Such as names of schools attended, dates of attendance, and degrees or certificates earned.

Sensitive Personal Information. Some personal information we collect may be considered “sensitive personal information” as defined under the CCPA. We do not “sell” or “share” (as defined under the CCPA) your sensitive personal information, and we do not use or disclose your sensitive personal information for purposes other than those described in this Privacy Policy and permitted under the CCPA. Sensitive personal information we may collect includes:

  • Government identifiers: Such as Social Security number, driver’s license or state identification number, or passport number
  • Financial account information: Such as bank account number, certain credit check information, and other financial information.
  • Demographic information: Such as race or ethnicity.
  • Health information: Such as about accessibility requirements.

2. Purpose of Personal Information Collection

We collect and use your personal information solely for the purpose of evaluating and processing your application. This includes:

  • Verifying your identity and income;
  • Obtaining consumer reports, credit reports and investigative consumer reports;
  • Conducting background and criminal history checks (strictly to the extent permitted by law);
  • Contacting current and prior landlords, employers, and references;
  • Responding to your inquiries and communicating with you regarding your application status;
  • To communicate with your regarding your application status, required documentation, income verification, related housing matters and housing opportunities, and to provide tenant services;
  • Complying with federal, state, and local legal obligations, including fair housing laws as well as mandatory reporting obligations;
  • To manage leases, renewals, and services provided to tenants or applicants; and
  • To streamline our application workflow and data authenticity, by using applicant and tenant data to train our internal artificial intelligence (AI) models. Please note that these models are used solely for internal business purposes such as streamlining application processing or detecting potential fraud. We do NOT use AI models to determine eligibility or housing outcomes. All decisions regarding eligibility, leasing, and housing assignments are made by qualified staff in accordance with applicable laws and program requirements. We do NOT use your personal information in AI models for marketing, or advertising, nor do we share your information with third parties for their own AI model training.

We may disclose your information to housing authorities, compliance agents, and property management companies, as required, for eligibility verification, compliance audits, and program reporting.

We do not use or disclose your personal information and sensitive personal information for any purposes beyond those outlined in this Privacy Notice or as reasonably required to provide affordable housing services.

We do not “sell” or “share” (as defined by the CCPA) your personal information.

You have the right to limit the use and disclosure of your sensitive personal information if we use your sensitive personal information for purposes beyond what is reasonably necessary to perform the requested services or provide the requested goods or other CCPA-purposes. You can make such request by clicking on the following link: Limit the Use of my Sensitive Personal Information.

3. Information Retention

We will retain each category of personal information for a period that is reasonably necessary to fulfill the purpose for which it was collected. We are legally required to retain certain application information to comply with applicable federal and state laws. If your application is approved, your information will be retained for the duration of your tenancy and as required by law. If your application is denied, your information will be retained for a period necessary to defend against legal claims or to comply with record-keeping requirements. Retention periods are determined based on the nature of the information collected, applicable housing program regulations, legal requirements, and operational needs. When personal information is no longer required, we securely delete or anonymize it in accordance with the applicable laws.