RealPage Privacy Shield Statement
Last updated: December 1, 2020
Update: On July 16, 2020, the European Union Court of Justice (CJEU) invalidated the EU-US Privacy Shield in its decision in Facebook Ireland v. Schrems (commonly referenced as “Schrems II”). As a result, RealPage is relying upon the EU Model Standard Contractual Clauses for all data collection, processing, and cross-border data transfers applicable to our product offerings in the European Union and United Kingdom. Additionally, RealPage remains an active participant in the Privacy Shield program and continues to comply with its obligations. In the event that the Privacy Shield program is recertified by European Union authorities at a future data, RealPage will revert to the program as the primary mechanism for GDPR compliance and update this Statement accordingly.
By accessing our websites or utilizing our products and services, you consent to the information collection and handling practices outlined in this statement.
I. Privacy Shield Participation
RealPage, Inc. and its U.S. subsidiaries1 (collectively “RealPage”) comply with the EU-U.S. and Swiss Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. RealPage has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms in this statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: https://www.privacyshield.gov.
For purposes of enforcing compliance with the Privacy Shield, RealPage is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield and RealPage’s certification, see the U.S. Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.
RealPage provides comprehensive property management software solutions to property owners and managers (our “Clients”) in the multifamily, commercial, single-family, and vacation rental housing industries. Our on-demand product line covers the full spectrum of accounting, leasing, marketing services, purchasing, and other operational areas. In providing this suite of services, RealPage acts as a data processor under contract to our Clients, the data controllers. As a data processor, RealPage does not control any of the personal data we process on behalf of our Clients. All such personal data is controlled by our Clients. We are required to provide our products and services to our Clients in accordance with their contractual provisions and instructions regarding data privacy, handling, and security.
Our Clients may administer our software solutions to their employee end users. This administration may include control over end user account access and functionality, as well as access and monitoring of end user data and activity. RealPage is not responsible for the privacy or security practices of our Clients, and this Privacy Shield Statement is not intended to cover those Client practices.
RealPage works with our Clients to help them provide notice of data processing to individuals, including information concerning (1) the purposes for which personal data is collected and used; (2) a contact person to whom enquiries or complaints may be directed; (3) the types of third parties to whom personal information is disclosed; and (4) the choices and means that individuals are offered for limiting use and disclosure of personal information.
As a data processor handling personal data at the direction of our Clients, RealPage has no direct relationship with the individuals whose personal data we process. RealPage processes personal data only for purposes that are compatible with those for which it was originally collected or as lawfully directed by our Clients. If and when disclosure of personal data to a third party is necessary, RealPage works with our Clients to help them inform individuals about the possibility of such disclosures and provide individuals with the choice and means of opting-out. If the personal data in question is necessary to provide a product or service, the choice to opt-out may preclude the further use of that product or service.
V. Collection of Personal Data
The personal data that we process on behalf of our Clients varies based on the products and services that Clients implement. We also process personal data as part of the Client sales and product support functions. As a general matter, RealPage processes the following types of personal data for our Clients:
- Contact Information: name, address, telephone number, and email address
- Personal Details: government-issued ID number, date of birth, passport number, and National Insurance Number
- Financial Account Information: bank account information and credit card information
- Credentials and Authentication Information: user names, passwords, password hints and security questions
- Technical Information: IP address, device and hardware specifications, and web browser type
- Usage Data: logging data that tracks service access, usage, performance metrics, and error reports
VI. Personal Data Usage
The usage of personal data that we process on behalf of our Clients varies based on the products and services that Clients implement:
OneSite Leasing & Rents: OneSite Leasing & Rents provides Clients with an accounting and leasing solution for purposes of managing their residential properties. Personal data is entered into OneSite for purposes of establishing valid tenant leases, establishing occupancy tracking functionality, and managing monthly rental payments and other property fees.
ActiveBuilding: ActiveBuilding provides Clients with an online tenant portal for purposes of managing tenant relations and communications. Personal data is entered into ActiveBuilding for purposes of creating tenant account profiles and secure, unique user accounts. Integration with OneSite Leasing & Rents allows tenants to review the terms and status of their leases, communicate with property management and other tenants, request maintenance services, receive announcements regarding property news and events, and setup online payment processing for purposes of electronically paying their lease rents and associated fees.
Leasestar Websites: Leasestar Websites provides Client with property websites for purposes of marketing individual residential properties and associated amenities. Prospective and current tenants are offered the ability to enter personal data into “Contact me” guest cards for purposes of communicating with Client personnel.
On-Site Leasing/Letting: On-Site Leasing/Letting provides Clients with online leasing/letting functionality that allows tenant prospects to search for residential unit availability and commence the leasing/letting application process electronically. Through an integration with the property website, prospective tenants enter personal data into the On-Site application for purpose of review and consideration by Clients. If Clients accept the rental application, the personal data is transferred to OneSite Leasing & Rents and ActiveBuilding for purposes of establishing the tenant rental ledger and account profile(s).
OneSite Facilities: OneSite Facilities provides Clients with online maintenance tracking and management functionality. Through an integration with both OneSite Leasing & Rents and ActiveBuilding, personal data is entered into OneSite Facilities by tenants for purposes of establishing maintenance service requests and directing those requests to the appropriate property management personnel for handling and resolution.
OneSite Payments: OneSite Payments provides Clients with the ability to accept and process online, electronic payments from tenants. Through an integration with both OneSite Leasing & Rents and ActiveBuilding, personal data is entered into OneSite Payments by tenants for purposes of establishing online payment processing accounts and submitting payment instructions.
YieldStar Business Intelligence: YieldStar Business Intelligence provides Clients with data analytics to support operational efficiency and maximize profitability. Through an integration with OneSite Leasing & Rents, personal data is aggregated and analyzed for property reporting and analysis related to demographics, marketing effectiveness, and other key operational metrics.
Kigo: Kigo provides Clients with a vacation rental booking and leasing solution for purposes of managing their residential properties. Personal data is entered into Kigo products for purposes of establishing valid vacation rental bookings and rental agreements, establishing occupancy tracking functionality, and managing vacation rental payments and other fees.
RealPage Sales and Product Support: Personal data is processed by RealPage during the sales, purchase, implementation, and support stages of product and service deployment. RealPage utilizes personal data to maximize product performance and quality, operate our business, and communicate with Clients.
VII. Disclosure and Onward Transfer of Personal Data
RealPage complies with the notice and choice principles as described above for all personal data disclosed or transferred to a third party.
RealPage may provide personal data to third-party service providers and vendors that perform tasks on our behalf to support the products and services described in this statement. We also share personal data among the RealPage-controlled subsidiaries identified in this statement for purposes of integrating our various product and service offerings. For example, personal data utilized for the purposes of processing payments may be shared between OneSite Leasing & Rents, ActiveBuilding, and OneSite Payments for purposes of providing an integrated payment solution to Clients and their tenants. This same process also necessarily involves disclosure and sharing the same personal data with banks and other financial entities that process payment transactions via the banking and credit card networks. We take reasonable and appropriate steps to ensure that third-party service providers and vendors process personal data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under the Privacy Shield RealPage may be liable for the onward transfer of personal data to third parties.
In addition, if RealPage enters into any business transition, restructuring, merger, sale, or other transferring of assets, we reserve the right to transfer all product and service information, including all personal data, as part of or in connection with the transaction.
Finally, RealPage will access, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary to:
- Comply with applicable law or respond to valid requests by public authorities, including law enforcement, national security agencies, or other government entities;
- Operate and maintain the security of our products and services; and
- Protect the rights and property of RealPage, including both intellectual property and physical systems infrastructure
VIII. Access Rights & Data Integrity
RealPage acknowledges the right of individuals to access their personal data. However, as a data processor handling personal data at the direction of our Clients, RealPage has no direct relationship with the individuals whose personal data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should therefore direct his or her request to the Client that transferred such data to RealPage for processing. The Client will then provide the necessary access to the individual as determined under the applicable local data protection law. RealPage will assist its Clients as needed to fulfill any such request.
IX. Data Security
RealPage implements and maintains appropriate physical, administrative, technical and organizational measures to protect the personal data 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 data is authorized only for those who have a business need for such access. RealPage strives to protect the personal data 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 data. RealPage maintains security incident response policies and procedures to handle incidents involving unauthorized access to personal data we process.
X. Questions or Complaints
Via US Postal Service at:
2201 Lakeside Blvd.
Richardson, TX 75082
Via email at:
RealPage has further committed to refer unresolved privacy complaints under the EU-US and Swiss Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your Privacy Shield complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
XI. Changes to This Statement
RealPage reserves the right to amend this statement from time to time consistent with the Privacy Shield’s requirements.
1 Privacy Shield certification applies to the following US affiliated entities: RealPage, Inc., ActiveBuilding LLC, and Kigo, Inc.