RealPage Rewards Privacy Policy and Notice at Collection
Effective Date: October 31, 2024
RealPage is committed to providing clear and concise information regarding our collection and processing of personal information. This Privacy Policy describes how RealPage and its subsidiaries (collectively, “RealPage,” “we,” “us” or “our”) collect, use, and disclose certain personal data in connection with the RealPage Rewards loyalty program (the “Rewards Program”) and provides our “Notice at Collection” to California residents under California law. By accessing the Rewards Program website(s) or enrolling in, accessing or otherwise utilizing the Rewards Program or related services (collectively, “Rewards Program Services”), you consent to the information collection and handling practices outlined in this policy.
NOTICE AT COLLECTION
The following notices are provided to California residents under California law:
- RealPage may collect personal information, including sensitive personal information, about consumers as described in Section I of this Privacy Policy.
- The purpose(s) for which the categories of personal information, including categories of sensitive personal information, are collected and used are described in Section IV of this Privacy Policy.
- RealPage does not sell or share personal information for cross-contextual behavioral advertising. RealPage may provide personal information to third parties as described in Section V of this Privacy Policy.
- RealPage intends to retain each category of personal information described in Section I of this Privacy Policy for as long as is necessary to fulfill the purposes described in this Privacy Policy, taking into account RealPage’s ongoing business needs for the applicable information, any applicable legal needs for the information and/or requirements under applicable law.
I. Personal Information Collection
RealPage collects and has collected within the preceding twelve (12) months the following categories of personal information in connection with the Rewards Program Services:
| Category | Examples |
Identifiers |
Note: Some personal information included in this category may overlap with other categories. |
Sensitive Personal Information |
Note: Some personal information included in this category may overlap with other categories. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e) |
Note: Some personal information included in this category may overlap with other categories. |
Commercial information |
|
Biometric information |
|
Internet or other similar network activity. |
|
Geolocation data |
|
Sensory data |
|
Inferences drawn from other personal information |
|
II. Personal Information Exceptions
Personal information does not include:
- Publicly available information.
- De-identified or aggregated consumer information.
- Information excluded from state privacy law scope, such as:
- 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.
III. Personal Information Sources
Rewards Program member and prospective member personal information is collected (i) from members and prospective members during enrollment in the Rewards Program or utilization of the Rewards Program Services, (ii) from property owners and property management companies who are customers of RealPage (collectively, “Customers”) via direct input into RealPage websites or software services or integration with Client software systems and third party service providers, (iii) from third party vendors who provide products, services, discounts and/or other benefits of Rewards Program membership, and (iv) indirectly from website analytics services integrated with RealPage websites or software services.
IV. Personal Information Use & Processing
The personal data we collect is used for a variety of purposes, including:
- Creating, maintaining, customizing and securing Rewards Program user accounts
- Exercising legal rights or defending legal claims
- Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RealPage’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by RealPage is among the assets transferred
- Fulfilling the purpose for which the personal information was collected and providing the requested Rewards Program Services
- Integration with your apartment community leasing and rents software
- Distribution of communications (including marketing communications) and legally required notices regarding the availability and status of Rewards Program Services
- Integration with your apartment community online resident portal
- Rewards Program Services product and website optimization, enhancement, and maintenance
- Compliance with local, state and federal laws and regulations
- Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations
More specifically, RealPage uses the following types of data for the indicated purposes:
Data Type |
Purpose/Use |
Identifiers & Contact Information: name, address, telephone number, and email address for the Rewards Program member |
Creating, maintaining, customizing and securing Rewards Program user accounts; providing the Rewards Program Services; communicating with Rewards Program members |
Credentials and Authentication Information: usernames, passwords, password hints and security questions |
Creating, maintaining, customizing and securing Rewards Program user accounts |
Technical Information: IP address, device and hardware specifications, and web browser type |
Rewards Program Services product and website optimization, enhancement, and security, support and maintenance |
Physical location (precise geolocation) for localized search/application functionality or Bluetooth-enabled application connectivity (where applicable) |
Fulfilling the purpose for which the personal information was collected and providing the requested Rewards Program Services |
Financial Account Information: bank account information, debit card information, credit card information, and other financial information associated with Rewards Program activity |
Fulfilling the purpose for which the personal information was collected and providing the requested Rewards Program Services |
Rental ledger data and payment history, record of services utilized, customer support records and communications, and similar personal identifiers associated with Rewards Program activities. |
Fulfilling the purpose for which the personal information was collected and providing the requested Rewards Program Services |
Voice call recordings from customer support operations. |
Fulfilling the purpose for which the personal information was collected and providing the requested Rewards Program Services; quality and training |
Information pertaining to an individual's interaction with Rewards Program Services websites, processes, and applications. |
Rewards Program Services product and website optimization, enhancement, and maintenance |
Profile reflecting a person’s preferences, characteristics, predispositions, behaviors, and personal identifiers associated with Rewards Program activities |
Rewards Program Services product and website optimization, enhancement, and maintenance |
RealPage 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. Additionally, RealPage processing of sensitive personal information is limited to activities necessary for the delivery and performance of Rewards Program Services.
V. Personal Information Disclosure
RealPage does not sell or share personal information for cross-contextual behavioral advertising, and no such activity has occurred in the prior 12 months.
RealPage may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors that support or integrate with the Rewards Program Services described in this policy (see chart below). RealPage only discloses personal information to the extent reasonably necessary to support Rewards Program Services requirements, or for the third-party vendors or service providers to perform 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 RealPage does not maintain direct control over the privacy policies and practices of Customers or any other third-party companies, agents, or contractors.
Category |
Third Party Disclosure |
|
Business Purposes |
Sales |
|
Identifiers |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Sensitive Personal Information |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Commercial information |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Biometric information |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Internet or other similar network activity. |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Geolocation data |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Sensory data |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
Inferences drawn from other personal information |
Service providers/vendors/RealPage subsidiaries/property owners and managers |
N/A |
VI. Personal Information Rights and Choices - State Privacy Rights
Certain state jurisdictions 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, along with Section VII below, describes your rights and explains how to exercise those rights if you are a legal resident of one of those states.
Accessing and Updating/Correcting Personal Information
You have the right to confirm whether or not RealPage is processing your personal data and, if so, to access such personal data. You may access and update or correct your information (as needed) by logging into your Rewards Program account or contacting our call center at: 1-844-489-1402. If you require verification that your requested changes have been completed, and such verification is not readily displayed in your Rewards Program account, you may request confirmation at the email address listed below (See Section XIX, “Contact Us”).
Data Portability and CA Residents’ Access to Specific Information Regarding Personal Information Use/Disclosure
You have the right to request a copy of the personal information collected about you in a readily useable format that is transferable to other entities, to the extent technically feasible (frequently referred to as “data portability”). If you make a data portability request, RealPage may be restricted from providing certain sensitive personal information in response to the request.
If you are a California resident, you also have the right to request a disclosure summarizing the collection, use, sale, sharing and disclosure to third parties of your personal information over the past 12 months, including:
- The categories of personal information about you that we collected, sold, shared or disclosed for a business purpose;
- The categories of sources from which the personal information was collected;
- Our business or commercial purpose for collecting, selling, sharing or disclosing the personal information.
- The categories of third parties to whom we disclose or sell, or with whom we share, that personal information.
- The specific pieces of personal information we have collected about you.
Deletion of Personal Information
You have the right to request that RealPage delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, unless a state privacy law exemption or one of the below exceptions applies, we will delete or de-identify (and direct our service providers and contractors to delete or de-identify) your personal information from our records. RealPage will not attempt to re-identify any personal information de-identified through this process or any other de-identified information in our possession.
Exceptions to Your Right to Deletion
We may deny your deletion request if retaining the information is reasonably necessary for RealPage or our service providers or contractors to:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide the Rewards Program Services that you requested or are reasonably anticipated by you within the context of our ongoing business relationship with you or your property owner or manager, or otherwise perform our contract with you or your property owner or manager.
- Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
- Debug Rewards Program Services to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion is likely to render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or our Customers and compatible with the context in which you provided the information.
- Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.
VII. How to Submit a Consumer Privacy Request
To exercise the access, correction, data portability, disclosure (CA residents) and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us toll-free at: 1-844-489-1402 or
- 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.
Certain state privacy laws may limit the number of requests for access and/or portability that you can make in a 12-month period (e.g., the limit is two under California law). Other states may require one free response per consumer in a 12-month period but allow us to either decline to act on a request or charge a reasonable fee to cover the administrative costs of responding to requests that are manifestly unfounded, excessive or repetitive.
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.
Process Used to Verify Consumer Requests
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.
Instructions for Authorized Agents
If you are an authorized agent making a request on behalf of a consumer, then in addition to information about the consumer, you may be required to submit your own contact information and evidence that the consumer gave you permission to submit the request on their behalf. Once our response to your verifiable consumer request is ready, our response will be sent to you at your designated email address.
VIII. Consumer Request Responses, Timelines and Appeals
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 us at 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.
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. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
If we deny your verifiable consumer request, you may appeal our decision by contacting us at privacy@realpage.com. We will respond to your appeal as described in this Section VIII.
IX. Personal Information Sales, Sharing and Profiling - Opt Out Rights
RealPage does not sell or share personal information for cross-contextual behavioral advertising or targeted advertising or process such personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers and no such activity has occurred in the prior 12 months. In the event that RealPage changes its practices and engages in the sale or sharing of personal information or in profiling 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.
RealPage utilizes cookies and tracking technologies as set forth in the Cookie Policy. Under some circumstances, these technologies may be deemed a “sharing” of personal information under applicable privacy laws. RealPage provides a Cookie Preference Center to allow you to opt out and customize the cookies presented on our websites and services.
X. 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.
XI. Other California Privacy Rights
The State of California also grants California residents privacy rights via laws unaffiliated with the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”). Those rights include the following:
California's "Shine the Light" law (California Civil Code §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.
XII. Notice to California Residents of Financial Incentives
In exchange for your enrollment in the Rewards Program, we may offer you rewards and/or benefits that may be considered “financial incentives” under California law. For example, you may have the ability to earn Rewards Program points (“Points”) for making certain qualified rent payments via your apartment community online resident portal, which may be redeemed for certain products, services, discounts and/or other benefits offered by third-party vendors.
In order to provide you with such rewards and/or benefits, we collect the categories of personal information described in Section I above to identify you as a member of the Rewards Program and provide you with relevant messaging and offers. The value of the personal information you provide is reasonably related to the value of the rewards and/or benefits provided to you. The value of personal information will vary slightly for each member depending on several factors, including but not limited to your Points-earning activity within the Rewards Program, our administrative and technical expenses associated with maintaining the Rewards Program, and the extent to which you take advantage of the Rewards Program’s various rewards and/or benefits.
The material terms of the Rewards Program may be found in the Rewards Program Terms and Conditions. You may opt in to the Rewards Program by enabling the feature and accepting the terms as presented in your resident portal. You may opt out of the Rewards Program at any time by requesting that RealPage delete your personal information, as set forth in Section VII above. If you request that RealPage delete your personal information, then your Rewards Program account, including any Points you may have earned, will be deleted, and you will no longer receive Rewards Program benefits because we will not be able to identify you as a Rewards Program member.
XIII. Disclosures to Colorado Residents regarding Bona Fide Loyalty Program
The Rewards Program may be considered a “Bona Fide Loyalty Program” under Colorado law. The following disclosures are provided to Colorado residents under Colorado law:
- We do not sell or process for targeted advertising any personal information collected through the Rewards Program.
- The categories of third parties that may receive your personal information are described in Section V above. We do not disclose your personal information to data brokers.
- The current list of Rewards Program partners, and the Rewards Program benefits provided by each such partner, is set forth at https://www.realpage.com/legal/rewards-partners/.
- In order to provide you with Rewards Program rewards and/or benefits, we collect the categories of personal information described in Section I above. We need your personal information to identify you as a member of the Rewards Program and provide you with relevant messaging and offers. If you request that RealPage delete your personal information, then your Rewards Program account, including any Points you may have earned, will be deleted, and you will no longer receive Rewards Program benefits because we will not be able to identify you as a Rewards Program member.
- We do not need your “sensitive data” (as defined under Colorado law) in order to provide you with Rewards Program rewards and/or benefits.
XIV. Cookies, Web Beacons, and Other Technologies - Do Not Track
When you access our Rewards Program 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 Rewards Program 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 Rewards Program Services or our website.
XV. Third Party Links to Other Sites
Our Rewards Program Services may include links to third party service providers contracted by RealPage or by our Customers. These linked services are operated by unaffiliated third parties that have separate and independent privacy policies, 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.
XVI. Data Security
RealPage 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. RealPage 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.
XVII. Children's Online Privacy
Our Rewards Program Services do not target or attract the attention of children under the age of 13 for the online collection of personal information. RealPage does not knowingly “sell” or “share” (as defined by applicable law) the personal information of consumers under the age of 16 in connection with the Rewards Program Services.
XVIII. Changes to Our Privacy Policy
RealPage reserves the right to amend this Privacy Policy at our sole discretion at any time. When we make changes to this Privacy Policy, 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 Rewards Program Services following the posting of changes constitutes your acceptance of such changes.
XIX. Contact Us
If you have any questions or concerns about this Privacy Policy 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