Last Updated: 02/28/2020

This Privacy Notice for California Residents (“CA Privacy Notice”) supplements the information contained in our Privacy Policy and applies to all visitors, users, and others who reside in the State of California (”consumers” or “you”) who use our websites or other Services (as defined and described in the Privacy Policy). Veritas Investments, Inc. and its affiliated entities, RentSFNow, Inc., and Greentree Property Management Inc. (collectively, “Veritas”, “we”, or “us”) have adopted this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. With respect to users who are California residents, this notice is incorporated and made a part of our Privacy Policy, and the terms of this CA Privacy Notice shall control with respect to California residents in the event of any inconsistency between our Privacy Policy and this CA Privacy Notice. Where we use capitalized terms in this CA Privacy Notice that are not expressly defined, those terms have the meaning provided in the Privacy Policy.

I. Information We Collect

Our Websites and related Services (as defined in the Privacy Policy) collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect through our Services, and have collected during the last twelve (12) months, the following categories of personal information:

Category	Description / Examples	Collected?
A. Identifiers.	A real name, Internet Protocol address, email address, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

For purposes of this CA Privacy Notice, personal information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information that is excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or personal information covered by certain privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our users or their agents. For example, from forms you complete on our websites or the resumes you upload.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
• Indirectly from Partners. For example, from forms or registrations on our partner or affiliate websites or submissions you make to websites, such as certain apartment listing website, with whom we have agreements.

The ways that we collect the foregoing information are set forth in greater detail in our Privacy Policy under the heading “How we collect personal information.”

II. Use of Personal Information

We may use the categories of personal information we collect as set forth above for the following business purposes:

Category	Purposes
A. Identifiers.	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Undertaking activities to verify or maintain the qualify or safety of, and to upgrade and enhance, our products and services. Auditing related to a current interaction with consumers using the Services Advertising, marketing and selling the Services Short-term transient use
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. Auditing related to a current interaction with consumers using the Services Advertising, marketing and selling the Services Short-term transient use
C. Protected classification characteristics under California or federal law.	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. Short-term transient use
D. Commercial information	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Short-term transient use
F. Internet or other similar network activity.	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. Auditing related to a current interaction with consumers using the Services Short-term transient use
H. Sensory Data	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. Short-term transient use
I. Professional or employment-related information.	To provide our Services to customers and other users, including renters and prospective renters. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Short-term transient use
K. Inferences drawn from other personal information.	To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. Undertaking activities to verify or maintain the qualify or safety of, and to upgrade and enhance, our products and services. Short-term transient use

In addition, we may use information in any of the categories described above:

• As described to you and consented to by you when collecting your personal information or as otherwise set forth in the CCPA.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or to otherwise comply with legal obligations applicable to us.

These uses of data, including personal information are described in greater detail in our Privacy Policy, in particular under Sections 3 through 5 of our Privacy Policy. We 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.

III. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information as set forth in this Notice, subject to your right to opt-out of those sales (see “Personal Information Sales Opt-Out and Opt-In Rights in Section IV.E, below).

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed personal information in the following categories for the business purposes identified above:

Category	Disclosed To
A. Identifiers.	Service providers (including analytics providers, ILS Vendors and other advertising providers, and IAAS providers and consumer reporting agencies) and affiliated Veritas entities
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Service providers and affiliated Veritas entities
D. Commercial information	Service providers (including property management-related providers) and affiliated Veritas entities
F. Internet or other similar network activity.	Service providers (including ILS Vendors) and affiliated Veritas entities
H. Sensory Data.	Service providers (property support, maintenance and security service vendors)
I. Professional or employment-related information.	Service providers and affiliated Veritas entities
K. Inferences drawn from other personal information.	Service providers and affiliated Veritas entities

IV. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we have collected about you. 
• The categories of sources for the personal information we collected about you. 
• Our business or commercial purpose for collecting or selling that personal information. 
• The categories of third parties with whom we share that personal information. 
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

To make a request to have your personal information disclosed you can make a request for the information using the following link and follow the instructions on the resulting page.

B. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. 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 by contacting us as follows:

(1) calling us at 1-877-845-0011, (2) writing to us at Veritas Investments, attn: Risk Management, 2443 Fillmore Street, #380-2009 San Francisco, CA 94115, or (3) filling out this form. Only you, or a person registered with the California Secretary of State that you authorize 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.

If you wish to register a person to operate on your behalf, you must inform us by contacting our customer services team and validating your identity so that the identity of the authorized person may be recorded.

 

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 enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

D. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within forty-five (45) days of receipt of your request. We will deliver our written response by mail or electronically, at your option. 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. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

 

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.

E. Personal Information Sales Opt-Out and Opt-In Rights

In the last 12 months, we have not sold personal information. However, if you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales, including but not limited to those between 13 and 16 years of age, may opt-out of future sales at any time as described herein.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and submitting a request here: Do Not Sell My Personal Information.

 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

F. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• 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.

G. California Shine the Light Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, and to prevent future disclosures for direct marketing purposes of your Personal Information. To make such a request, please contact us using the contact information provided below.

V. Changes to this Notice

We reserve the right to amend this CA Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update this notice’s effective date. If as a business we intend to use your personal information for a purpose that was not previously disclosed in the privacy policy or in the notice at collection, we shall directly notify your of this new use and obtain explicit consent from the consumer to use it for this new purpose.

VI. Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in the CA Privacy Notice and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:

 

• Send us a message via our website: https://www.greentreepmco.com/contact/
• Call our customer services team at 1-877-845-0011