Last updated February 17, 2022
1. WHAT INFORMATION DO WE COLLECT?
Personal Information You Disclose To Us
We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, or when participating in activities on the Sites or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. Generally, we only collect personal information about employees and agents of our business partners, including without limitation building managers and residential and retail customer staff and associates who create an account with us pursuant to a service agreement executed separately between us and our business partners. We do not generally collect personal information directly from consumers. The personal information we collect can include the following:
Names and Contact Data – We may collect your first and last name, email address, postal address, phone number, and other similar contact data.
Login Credentials – We may collect password hints, and similar security information used for authentication and account access.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we may also collect information through cookies and similar technologies.
Information Collected From Other Sources
We may obtain information about you from other sources, such as the third-party companies we have contracted with to provide our services, as well as from other third parties. Examples of the information we receive from other sources include: email, physical address, and phone number.
In particular, we have collected the following categories of personal information, as defined and further described under the California Consumer Protection Act of 2018 (CCPA) from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES: name, postal address, email address, IP address|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80I).||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.
|NO (other than name address, and telephone number)|
|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).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|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.||NO|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|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.||NO|
2. HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:
We use the information we collect or receive:
- To facilitate account creation and logon process – If you choose to link your account with us to your Google account, we use the information you allowed us to collect from Google to facilitate account creation and logon process.
- To send administrative information to you – We may use your personal information to communicate with you about package deliveries or to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To protect our Sites – We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention)
- To enforce our terms, conditions, and policies.
- To respond to legal requests and prevent harm – If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other internal business purposes – We may use your information on an anonymized, aggregated basis for other internal business purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Sites, products and services.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share data based on the following legal bases, as described by the EU’s General Data Protection Regulation (GDPR):
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests, which are to provide our services and operate the Sites. This includes, for example, sharing your personal information with USPS or other parcel delivery systems for purposes of sending or receiving packages and other mail.
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose. Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of the contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and other Third-Party Service Providers: We may share your data with third part vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: package pick-up and delivery providers, building management, email delivery and customer service providers. We only make these business purpose disclosures pursuant to written contracts that describe the purpose, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.
- In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|A: Identifiers.||Service providers.||None.|
|B: California Customer Records personal information categories.||Service providers.||None.|
|C: Protected classification characteristics under California or federal law.||None.||None.|
|D: Commercial information.||Service providers.||None.|
|E: Biometric information.||None.||None.|
|F: Internet or other similar network activity.||Service providers.||None.|
|G: Geolocation data.||Service providers.||None.|
|H: Sensory data.||None.||None.|
|I: Professional or employment-related information.||Service providers.||None.|
|J: Non-public education information.||None.||None.|
|K: Inferences drawn from other personal information.||None.||None.|
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We share and disclose your information with certain authorized third-party service providers who have agreed to protect your information pursuant to written contracts with us or as follows:
- User Account Registration and Authentication: Google Sign-in
- Web and Mobile Analytics: Google Analytics
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We are a global organization, so we sometimes need to share your personal data with our other offices or with third party service providers and suppliers who are located in countries other than your own. Note in particular that if you are accessing our Sites from outside of the United States, your information may be transferred to, stored, and processed by us in our facilities and by those third-parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?’), in the United States, and other countries.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stores in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational and technical security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at .
10. WHAT ARE YOUR PRIVACY RIGHTS?
Right to Know and Data Portability
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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we 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.
- 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.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Rectify
You have the right to request that we rectify information you think is inaccurate or complete information you think is incomplete, though we may need to verify the accuracy of the new data you provide to us (the “right to rectify”). This right always applies.
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Rectify or Delete), we will review your request to see if an exception allowing us to retain the information 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know, Rectify or Delete
To exercise your rights to know or delete described above, please submit a request by contacting us via the contact information provided below.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient 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 sufficient 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.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
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 again at the contact information provided below.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), 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. If you do not have an account with us, 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 our receipt of your request. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Your right to withdraw consent
You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
11. WHAT ABOUT COOKIES AND TRACKING TECHNOLOGIES?
Cookies and similar technologies: Like most web browsers, ours is set to accept essential cookies by default. You can usually choose to set your browser to remove or reject non-essential cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites visit http://www.aboutads.info/choices/.
12. DO WE MAKE UPDATES TO THIS POLICY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
We have appointed a data protection officer for you to contact if you have any questions or concerns about your personal data. Our data protection officer can be contacted by writing us at the address below. If you have any questions or comments about this policy, you may email us at or by post to:
22 Marin Way
Stratham, NH 03885