Bolld Real Estate Management Inc., and all of its subsidiaries (the “Company” or “BOLLD REAL ESTATE MANAGEMENT INC.”) is committed to protecting our visitors’ and members’ privacy. This Privacy Policy (“Policy”) describes the types of information BOLLD REAL ESTATE MANAGEMENT INC. may collect and how we may use that information to better serve visitors and members while using our Website (the “Website”) and the services offered by BOLLD REAL ESTATE MANAGEMENT INC. (collectively, “Services”).

  1. THE PERSONAL INFORMATION WE COLLECT

To provide you services, we collect or you may choose to provide Personal Information that may identify you or relate to you as an individual.

Depending upon the type of relationship you have with Bolld Real Estate Management Inc., we may collect the Personal Information described in general terms below.

  • Contact Information such as name, postal address, email address, date of birth, picture, and emergency contact details.
  • Other Personal Identifiers such as user/account name, social security number, taxpayer identification number, driver’s license number, passport number, identity card or student card, and resident identification number.
  • Financial and Insurance Information such as bank account/credit card number, rent payment details, insurance policy number, credit history, sanctions and other financial or tax documentation.
  • Demographic Information such as age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status, in each case subject to applicable laws. In certain jurisdictions, you may also choose to share with us any disabilities or other health-related restrictions so that we can provide you with adequate accommodations.
  • Commercial Information such as records of products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, and rent amount.
  • Internet or other electronic network activity information through the use of our websites such as browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, and internet postings. For more information please review the Cookies and Other Tracking Technologies section.
  • Sensory data such as pictures, videos, and sounds.
  1. HOW AND WHERE WE COLLECT YOUR PERSONAL INFORMATION

We may collect Personal Information through the following:

  • Online Services. We collect Personal Information when you interact with our Online services which may include, but are not limited to, searching for an apartment, communicating with us, applying for a job, posting to social media pages, or participating in a survey.
  • Property Owners. Our residential properties may be owned by other investors who share personal information with us for the purposes of managing the property and providing you services.
  • Property Visits and Offline Interactions. We collect your Personal Information when you visit our properties, attend events hosted at our properties, and/or inquire about housing directly with our properties.
  • Other Sites and Third Parties. We may use separate sites for the processing of applications and agreements and to assist our residents and service providers with other tasks which are required or helpful to them, such as paying rent online. We also use separate sites for booking corporate or flexible stays. We may also receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward us your email address and other information about you so that we may contact you as requested and in accordance with applicable law.
  • Due Diligence. When you provide services to Bolld Real Estate Management Inc. as a third-party vendor/contractor, we will collect certain information through our discussions with you, from documents that you may deliver to us, and in the ordinary course of our business relationship.
  • Other Sources. We collect Personal Information from other sources, such as public databases or credit agencies.

Where legally required, we will obtain your consent before collecting or processing your Personal Information.

  1. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may also collect “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data includes:

  • Your browser or device. We collect certain data through your browser or automatically through your device, such as your operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the online services (such as the apps) you are using. We use this data to ensure that the online services function properly.
  • IP Address. We collect your Internet Protocol (IP) address which is a number that is automatically assigned to your computer whenever you are using the Internet. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Bolld Real Estate Management Inc. collects IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our sites. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We may seek to link your IP address to your identity when we feel it is necessary to protect our sites and other users from harm and to prevent criminal misconduct.
  • Aggregated Data. We may aggregate data that we collect and this aggregated data will not personally identify you or any other user.

Cookies, Pixels, and other similar technologies. We collect certain data from cookies, pixel tags, web beacons, and other technologies (“Cookies”) which are pieces of data stored directly on your device or browser and may, in certain jurisdictions, be considered Personal Information. Cookies may be set by us and called first-party Cookies. We also use third-party Cookies for our advertising and marketing efforts, to measure the success of our marketing campaigns, and to compile statistics about usage of the online services. See the section on PROFILING AND AUTOMATIC DECISION-MAKING below.

  • Strictly Necessary Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these Cookies, but some parts of the site will not work.
  • Performance Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
  • Functional Cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these Cookies, then some or all of these services may not function properly.
  • Targeting Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. These work by uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.
  • Social Media Cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these Cookies you may not be able to use or see these sharing tools.

Most browsers are set up to accept Cookies. If you want to change your cookie preferences, you can do so through your browser settings or by updating your Cookie preferences via our cookie banner, where applicable, when you enter any of our websites.

  1. WHY WE USE YOUR PERSONAL INFORMATION

We use information that we collect about you or that you provide to us, including any personal information: (a) to present the Application and the Website and their contents to you; (b) to provide you with information, products and services, including information about contests or promotions and other forms of direct marketing, availability of Bolld Real Estate Management Inc. Services and other services that may be offered to members by Bolld Real Estate Management Inc. partners from time to time and to inform you about changes to Services; (c) to provide you with notices about your account, including for billing and other purposes; (d) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (e) to notify you about changes to the Application, the Website and products or services; (f) to allow you to participate in interactive features on the Application or the Website; (g) to assist us with improving and enhancing Services and optimizing operations and allocation of resources; (h) to provide you with the most up to date application and features and to assist with troubleshooting; (h) to help maintain the integrity of the data that is collected, stored and used by us; (i) for historical, statistical or research purposes; (j) to evaluate candidates who apply for job postings through the Website; (k) To fulfill any other purpose for which you provide it; (l) in any other way we may describe when you provide the information.

We may use your information to contact you about our own and third parties’ goods and services that may be of interest to you. Our primary goal in collecting information is to provide you with an enhanced experience when using Services.

  1. HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.

  • Bolld Real Estate Management Inc. Affiliates. We disclose your Personal Information and Other Data with our affiliated companies as necessary to communicate with you, provide you services, fulfill our contract with you and to accomplish our business purposes.
  • Service Providers. We disclose Personal Information and Other Data to third parties who perform services such as hosting our websites, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice.
  • Property Owners. We disclose Personal Information to the Owners of the properties we manage. Owners may use your Personal Information for their own purposes and legal obligations and are therefore considered separate data controllers for multiple processes during your tenancy journey.
  • Partners. We disclose Personal Information and Other Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.

We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of Bolld Real Estate Management Inc. employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.

  1. BUSINESS TRANSITIONS

If Bolld Real Estate Management Inc. goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Privacy Statement in place at the time of the transfer. If required by law, we will separately notify you of such transfer.

  1. YOUR PRIVACY PREFERENCES AND RIGHTS

We provide you with options, information, and choices below to express your preferences.

Email Consent and Opt-out

Each of our commercial emails contain a link with instructions on how to remove yourself from our email list. Please note that if you are a resident of a Bolld Real Estate Management Inc. property and you use this site and your property site, you will need to opt-out of your property site separately. You will also need to opt-out separately from any third-party sites you have registered with.

Cookies and Other Data

For information on your choices related to Cookies and Other Data, please see the Section on Cookies and Other Tracking Technologies, above.

Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Information

You may have the right under applicable privacy laws to request that Bolld Real Estate Management Inc. inform you as to whether Personal Information relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, change, delete, restrict the use of, or object to the processing of your Personal Information that was previously provided to us. If you wish to exercise your rights, please visit our portals and complete one of the following forms. For your protection, we will verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

For all other inquiries, or if you have any questions about the forms or our process, feel free to contact us at the Contact Information section below.

  1. SECURING INFORMATION

Bolld Real Estate Management Inc. takes reasonable technical and organizational measures to safeguard users’ Personal Information. While Bolld Real Estate Management Inc. strives to protect your Personal information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online and therefore you must be aware of this risk.

We limit access to Personal Information to those individuals and organizations who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take precautions we deem reasonable to protect the security of users’ Personal Information in accordance with applicable law. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injurious to the confidentiality of users’ Personal Information notwithstanding the actions we take to prevent this. Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security when new technology becomes available. This includes use of software which encrypts (generally processed at 256 bits) or distorts data submitted to us relating to an online rental application or employment application.

If users have any questions about security, please contact us using the information in the “Contact Information” section.

  1. RETENTION

We will retain your Personal Information for the period we believe reasonable to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the services to you
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)
  1. CHILDREN’S PRIVACY

Our websites are not directed at children. We do not collect or maintain information at our sites from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our sites. By using any of our sites, you represent that you are not under 16 years of age. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable information through any of our websites, please contact us using the information in the “Contact Information” section.

  1. DATA TRANSFERS – INTERNATIONAL USERS

Bolld Real Estate Management Inc. is a global company and as a result, we may, subject to law, transfer Personal Information and Other Data collected in connection with our services, to entities in countries where data protection standards may differ from those in the country where you reside. If you provide Personal Information to us, it may be transferred to and processed in the U.S. or other countries.

  1. PROFILING AND AUTOMATIC DECISION-MAKING

In certain circumstances and subject to applicable law, we may use automatic decision-making to evaluate your credit against our required criteria. Credit-checking is a mandatory step in our application review process.

In certain circumstances and subject to applicable law, we will use automated means to conduct sanctions and PEP screenings and in some cases for background checks. This processing is in accordance with our legal obligations and legitimate interests and has meaningful human intervention before making final decisions that may impact your application.

Sanctions screening involves comparing applicants against public lists maintained by the US Office of Foreign Asset Control and other lists maintained by other Governments. We do this through a secure online service and the data used to undertake such searches includes your name, date of birth, and nationality. For common names, the system will sometimes return a result known as a “false positive.” A human analyst will then use additional data you provided, such as your address, to make a final decision about the match.

We may also use third parties to serve tailored advertisements that may interest you. To serve these advertisements, those third parties place a cookie or other tracking technology on your browser to profile your access and use of our online services. For more information about Bolld Real Estate Management Inc.’s use of Cookies and how to manage your cookie preferences, see the section on Cookies and Other Tracking Technologies, above. If you would like more information about this practice, please visit https://thenai.org/opt-out/ and https://youradchoices.com/.

  1. DATA PROTECTION RIGHTS UNDER GDPR

Bolld Real Estate Management Inc. is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:

  • Right to information, Art. 15 of the GDPR
  • Right to correction, Art. 16 of the GDPR
  • Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
  • Right to limit processing, Art. 18 of the GDPR
  • Right to data transmissibility, Art. 20 of the GDPR
  • Right to object, Art. 21 of the GDPR

To exercise your right, please contact us as indicated in the “Contact Us” section below.

  1. PRIVACY DISCLOSURES FOR CALIFORNIA RESIDENTS “CCPA”

This section applies to you if you are a resident of the state of California and provides additional information about how we collect, use, disclose and otherwise process Personal Information of individual residents of the state of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). In addition to our Personal Information processing activities relating to our Services, this section also addresses Personal Information we may process offline.

For purposes of this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available from government records, that is aggregated such that it is not capable of being associated with you, or that is otherwise excluded from the CCPA’s scope. This section also does not apply to information relating to our employees, contractors, applicants and other personnel.

  1. CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so we encourage you to review it periodically. If you continue to visit Bolld Real Estate Management Inc. or use our Products after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New uses of personal information. From time to time, we may desire to use personal information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected personal information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses, before those changes become effective, as may be required by law.

  1. CONTACT INFORMATION FOR PRIVACY ISSUES

855-266-8588