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 Trinity, 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.
HOW AND WHERE WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal Information through the
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,
Trinity 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
• Cookies. We collect certain data from cookies, 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. 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.
Cookies are necessary for the website to function
and cannot be switched off. 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.
Cookies also allow us to monitor website traffic
and sources so we can measure and improve the performance of our
sites. 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
Cookies may be set through our site by our advertising partners, and may be used by those companies to build a profile of your interests to show you relevant advertisements 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.
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, where
applicable, when you enter any of our websites.
WHY WE USE YOUR PERSONAL INFORMATION
DESCRIPTION OF ACTIVITIES
Engage with prospective residents
The activities associated with this purpose may include providing property tours and contacting prospective residents.
Legitimate interests for leasing an apartment, for example, communication regarding your property preferences
Applications and Contracts
The activities associated with this purpose may include collecting and processing applications or contracts and communicating with you regarding your application or account. Personal Information will be used to perform credit checks, background checks, or other screenings as necessary for the Company’s know your customer and anti-money laundering requirements.
Performance of a contract to initiate a lease or an employment relationship
Legitimate interests for ensuring prospective residents are financially solvent
Legal obligations, such as sanctions screenings, background checks, anti-money laundering screenings, and identity confirmation
Operations and General Business
The activities associated with this purpose may include processing or communicating with residents about payments, performing debt collection, providing maintenance or other on-site services, and managing the property. Processing this information also helps us better understand how we can help prospective and current residents.
Performance of a contract to fulfill your lease
Legal obligations relating to financial transactions, such as the obligation to maintain books and records.
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.
• Company 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 Trinity employees, residents, guests and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.
In the unlikely event Trinity 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.
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 Trinity 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.
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 Trinity 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.
Please submit your request using the link or email address in the Contact section below.
Trinity takes reasonable technical and organizational measures to safeguard users' Personal Information. While the Company 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. 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 data submitted to us relating to an online rental application or employment application.
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
Our websites are not directed at children. We do not collect or maintain information from those we know are under 16. By using any of our sites, you represent that you are not under 16 years of age.
NOTICE TO CALIFORNIA RESIDENTS
Individuals who reside in California and have provided their Personal Information to us may exercise their rights under the California Consumer Privacy Act (“CCPA”).
NOTICE TO RESIDENTS OF CERTAIN STATES
Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.
Last Revision: 05/21/2021