UPDATED May 30, 2020
Important to Note:
Kensington Suites provides its website for use by our Clients, which are typically residential and commercial real estate property managers and property owners. Our Clients use our website and its platforms for many purposes, such as to manage the leasing lifecycle, and to facilitate communication with their End Users. Kensington Suites platform providers typically has no direct relationship with our End Users; those platform providers simply process and store our End Users’ Personal Information (“Client Data”) on our behalf, as their service provider, while the Clients are responsible for the processing. Any use of Client Data by us is carried out pursuant to an agreement (and/or our applicable Terms of Service) in place between our platform provider(s) and our Client(s).
If you, as an End User, have any questions or concerns about the data handling practices of Kensington Suites using our Platform Providers to process and store your personal information, please contact Advanced Management Group, our property management company, directly at (702) 699-9261.
Finally, our website may contain links to other third-party websites. The information practices and content of such third-party websites are governed by their own privacy notices. We encourage you to review the privacy notices of such third-party websites to understand their information practices.
WHAT INFORMATION WE COLLECT AND WHY
We may collect Personal Information in various ways, such as when you: enter into a transaction or contractual arrangement with us; participate in Kensington Suites programs or activities; provide data at industry events and trade shows; visit our facilities or we visit you at your offices; contact our customer services; or in connection with your inquiries and communications with us. We may also collect Personal Information from other sources, including the Client, data companies, publicly accessible databases, and joint marketing partners.
We have created the following table to help you understand the categories of Personal Information that we are responsible for, and process:
|Categories of Personal Information:||Specific Types of Personal Information:||Source:||Why We Collect It – Our Purposes|
|Client Personnel Information||
Contact Information: First and last name, email address, employer, phone number (work), physical address (work), job title.
Marketing Preferences and Customer Service Interactions: Marketing preferences; responses to voluntary surveys.
Operational Data: Transactions, sales, purchases, uses, supplier information, credentials to online services and platforms, and electronic content produced by individuals using company systems, including online interactive and voice communications such as blog, chat, webcam use, and network sessions.
|Directly from our Clients and Client Personnel||
Communicate with Clients and Client Personnel for the purpose of supporting our contractual relationship. This includes:
1. Informing Clients about our various Platforms and solutions, and providing access to our Platforms where the Client enters into an agreement with us.
2. Providing back-end access to the Platforms for Clients and Client Personnel
3. Tracking and responding to Clients’ inquiries, reports, reviews or correspondence regarding products and services.
4. Administering Client account(s).
5. Providing and improving our customer service.
6. Facilitating communications generally in the context of our business activities.
7. Sending administrative information to Clients, such as changes to our terms, conditions and policies.
9. Continuously improving, customizing and personalizing our Platforms.
10. Analyzing and improving the safety and security of our Platforms.
11. Supporting internal operations, including CRM and Client technical support.
12. Connecting with vendors via APIs to allow vendors to provide specific services directly to Clients.
13. Providing Clients and Client Personnel with access to our App Store’ (if applicable) to allow Clients to directly enable external applications.
14. Carrying out machine learning, data extracting and loading data in data warehouses, in order to support various enterprise software, data access, modifications, operations, and provide access to third parties via secure integrations.
|Prospective Client Personnel Data||First and last name, email address, employer, phone number (work), physical address (work), job title.||Directly from Prospective Client Personnel.||
Contact prospective Clients in order to set up demos of our Platforms. This includes:
1. For marketing purposes, such as re-engaging with prospective Clients who have expressed an interest in our Platforms.
2. Administering account access to our Platforms.
3. Responding to inquiries, for example, when you send us questions, suggestions, compliments or complaints, or when you request further information about our services
Contact Information: Name.
|Directly from End Users in response to voluntary surveys.||Platform improvement and marketing purposes (to Potential Clients).|
HOW WE USE PERSONAL INFORMATION
We do not use Personal Information for purposes that are materially different to the purposes for which they were originally collected, as set out in Section 2. If these purposes change in the future, we will provide you with notice and a request to consent to (or an opportunity to opt-out of) this new use where so required by applicable law.
“Do Not Track” Notice: “Do Not Track” is a preference that you can set in your browser to let websites you visit know that you do not want them collecting certain information about you. Kensington Suites does not currently respond to, or honor, Do Not Track signals or requests from your browser.
HOW WE DISCLOSE PERSONAL DATA
We will not disclose any personal information that we collect from you to any external parties except as indicated below (for CCPA purposes, all of the below categories of data recipients are classified as Service Providers or Third Parties, as those terms are defined):
1. Our Affiliates. We may disclose personal information to any of our subsidiaries and affiliates within our property management group (Advanced Management Group). Specifically, if our clients utilize our applicant screening service, we will share personal information with our screening service. Additionally, if you utilize our renters insurance agent, we will share personal information with our insurance solutions provider.
2. Service Providers. We may disclose personal information to our service providers who perform certain services necessary to run our business (for example, data hosting and development, data analysis, customer service, auditing and other services), provided that these service providers have entered into legally binding agreements with us to protect the personal information shared, limit their use, retention, and disclosure of the personal information, and assist us with our compliance requirements.
3. Legal Request. We may disclose personal information to comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
4. Business Transfer. We may disclose personal information to a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kensington Suites assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which personal information held by Kensington Suites are among the assets to be transferred.
We do not knowingly collect personal information from children under the age of seventeen (17) without authorization by a holder of parental responsibility. If you believe that we may have collected personal information from or about a child under the age of seventeen (17), please send an email to firstname.lastname@example.org with the subject line “Personal Data of a Minor.”
HOW WE PROTECT YOUR PERSONAL INFORMATION
We seek to use commercially reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a username and password (either as a Client or an End User) to access our Platforms, you are responsible for keeping this information confidential and preventing unauthorized access to your account. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
If applicable, where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS).
RETAINING YOUR PERSONAL INFORMATION
We retain personal information for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law. The criteria used to determine our retention periods include:
1. The length of time we have an ongoing relationship with you or our Client, and provide the use of our Platforms to you or our Client (for example, for as long as you have an account with us or keep using the Platforms);
2. 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); or
3. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
KEEPING YOUR INFORMATION UPDATED
Where you have set up an account on one of our Platforms through our Clients, it is up to you to keep your personal information up to date. If you are unable to update your personal information, please contact our relevant Client with which you have a primary relationship. If our Client is unable to assist you, we will endeavor to assist our Client with updating your information.
INFORMATION FOR CALIFORNIA CONSUMERS
The information and rights in this section apply specifically to California residents.
In compliance with the California Consumer Privacy Act (“CCPA”), Kensington Suites does not sell, trade, or rent any Personal Information, nor have we done so in the preceding twelve months. Kensington Suites has not sold the Personal Information of minors under 16 years of age without first attaining affirmative authorization.
California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Currently, Kensington Suites does not disclose Personal Information to third parties for their direct marketing purposes. Thus, upon receipt of such a request by a California consumer, and as required by California state law, we will respond with either (1) a confirmation that we have not disclosed any Personal Information to third parties for their direct marketing purposes in the previous calendar year, or (2) if our practices have changed, provide a list of all third parties to whom Personal Information was disclosed for their direct marketing purposes in the preceding calendar year, whichever is relevant. California consumers may request further information about our compliance with this law by emailing us at email@example.com.
Under the CCPA, California consumers have various rights regarding the Personal Information that Kensington Suites clients collect and process using Kensington Suites platforms.
California consumers have the right to:
1. Request disclosure of the categories and specific pieces of Personal Information that a Business has collected about you.
2. Request disclosure of the categories of third-party sources, if any, from which a Business has collected Personal Information about you.
3. Disclosure of the Business or Commercial Purpose(s) for which your Personal Information has been collected.
4. Receive a list of the categories of third parties with whom a business has shared your Personal Information.
5. Request that a business delete any Personal Information that it has collected from you (subject to exceptions).
6. Not be discriminated against by a business (e.g. charged different rates, provided different levels of service, denied goods or services, or suggested any of the preceding) for exercising any of the individual rights granted above.
7. Designate an authorized agent to exercise any of the individual rights granted above, on your behalf.
8. Opt-out of the sale of Personal Information, if applicable.
To exercise any of your rights as a California consumer, you should contact the Client with which you have a direct relationship, or contact Kensington Suites directly if your relationship is only with us (e.g. personnel of our Clients or our potential Clients) by sending an email to firstname.lastname@example.org.
Before complying with your request, Kensington Suites may need to verify that it is you that is making the request. To accomplish this, you (or your authorized agent) may be requested to (1) confirm specific pieces of Personal Information that Kensington Suites already know about you, or (2) provide Kensington Suites with appropriate identification depending on the sensitivity of the information requested. California consumers are limited to two requests for Personal Information per twelve-month period.
END USERS’ PERSONAL INFORMATION
Kensington Suites is responsible for what we do with the Personal Information we collect, directly or through Provider Platforms, about their End Users. If our Clients utilize our payment processing functions, your payment information may be processed via third party payment processors in accordance with such payment processors’ terms and policies. We transmit your complete payment information when you initiate a payment through our Platforms. We collect this information only so that we can pass it along to our payment processors, which you agree to use by submitting a payment through our preferred Platform. Where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS).
If you have any questions or complaints related to our practices with respect to the collection, use, or disclosure of personal information, please feel free to contact our management company at:
Advanced Management Group
4496 South Pecos Road
Las Vegas, Nevada 89121