Policy last updated: July 12, 2019
B. About Us
Our Data Protection Officer DPO, Jeremy Schmidt, can be contacted at email@example.com for additional information about Rent College Pads policy for using and storing personally identifiable information and data.
C. Collecting Personally Identifiable Information
By using the Website, you are consenting to allow Rent College Pads to collect, store, and use the following information:
- Information You Give Us: We collect personally identifiable information such as your name, email address, username, password, demographic information such as your gender and occupation, and other information you directly give us on our Website.
- Information We Get from Others: We may collect information gathered from third-party sites or sources you accessed, such as Facebook, Google, or Twitter. We may add third-party retrieved information to the information collected from you on our Website. Some third-party sites or sources may also provide us with information from your accounts to enhance and personalize your use of our Website. You have the right to modify your privacy settings and opt-out of providing certain information or receiving interest-based advertisements on those third-party sites our sources directly on their respective site.
- Passive Information Collected: We will not automatically log your personally identifiable information when you visit our Website. We do automatically collect usage data and computer operating information such as the operating system type, cookies, web beacons, browser type, browser language, the website you visited before browsing to our Website, pages you viewed, how long you spent on a page, access times, Internet protocol IP address, and other information about your use of and actions on our Website to customize your visit through technical means.
- Public Content: You can contribute to the Website in several different ways, including uploading photos, embedding videos, participating in forums, tagging products, filling out your public profile, and voting on other users contributions. We may store these contributions your Public Content, display them to other users, and use them for promotional purposes. Note that if you include personally identifiable information in your Public Content, it can be used and viewed by others. We are not responsible for the information you choose to include in your Public Content.
You may not disclose to us the personally identifiable information of another person, without first obtaining that persons express consent to both the disclosure and the processing of that personally identifiable information in accordance with this policy
D. Using your Personally Identifiable Information
Personally identifiable information submitted to us through our Website will be used for the purposes specified in this policy or as provided for on the relative Website page. Your personally identifiable information may be used for one or all of the following reasons:
- To operate, maintain, and improve our sites, products, and services
- To send information including confirmations, technical notices, updates, security alerts, and support and administrative messages and
- To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
Any personally identifiable information submitted by you for publication on our Website grants us a license to use your personally identifiable information.
You may modify your privacy settings to limit our use of your information on the Website by adjusting the Website privacy controls.
We will not, without your express consent, supply your personally identifiable information to any third party for their or any other third partyrsquos direct marketing or sale.
E. Sharing Your Personally Identifiable Information
We may share or sell your personally identifiable information as follows:
- We may share personally identifiable information to third parties with your express consent, including sharing personally identifiable information for third-party marketing uses subject to their third-party privacy policies.
- If you post Public Content on the Website, we may distribute such Public Content to a wider audience by sharing it or portions of it with third parties so that they can publish it on their own websites and media platforms. We allow you to access third party services, such as Facebook, Google, and Twitter, to share your selected Public Content with those services.
- Categories of third parties Rent College Pads may share your personal information with:
- Promotional Partners
- Testing, Research and Analysis Partners
If you make any personally identifiable information publicly available on the Website e.g., by posting a listing which contains personally identifiable information, anyone may see and use such information and we are not responsible for such use. The Website reserves the right to share any personally identifiable information you post on the Website with third parties with your prior consent. To the extent the Website does so, the subsequent use and disclosure of such information is subject to the privacy policies and practices of those third parties.F. Disclosing Your Personally Identifiable Information
G. International Data Transfers
The Website is hosted in the United States, and all or a portion of the Website may also be hosted on the cloud, or other similar distributed hosting platform. If you are accessing the Website from the European Union, Asia, or any other region with laws governing personal data collection, use, and disclosure that differ from United States laws, please note that you are transferring your personal data to a jurisdiction that does not have the same data protection laws as your home jurisdiction. By providing your personal data you consent to:
- the transfer of your personal data to the United States.
Under the General Data Protection Regulation GDPR, if you have provided consent for the processing of your personal information, you have the right to withdraw consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. You have the right to request access to and rectification or erasure of your personal information, as well as the right to restrict processing, object to processing, and under certain circumstances the right to data portability.
The following are your fundamental rights granted to users under GDPR:
- The right to be informed Rent College Pads will be completely transparent in how we are using your personal data, please refer to Section D above.
- The right of access Users of Rent College Pads have the right to know exactly what information is held about them and how it is processed.
- The right of rectification Users of Rent College Pads will be entitled to have personal data rectified if it is inaccurate or incomplete.
- The right to erasure This right affords users of Rent College Pads the ability to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
- The right to restrict processing Users of Rent College Pads have the right to block or suppress processing of their personal data.
- The right to data portability Users of Rent College Pads have the right to retain and reuse their personal data for their own purpose.
- The right to object in certain circumstances, users of Rent College Pads are entitled to object to their personal data being used.
- Rights of automated decision making and profiling The right for users of Rent College Pads to choose not to be the subject of a decision where the consequence has a legal bearing on them or is based on automated processing.
If you are a California resident, California Civil Code Section 1798.83 permits you to request free of charge information regarding the disclosure of your personal information by us to third parties for the third parties direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Rent College Pads does not share personally identifiable information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personally identifiable information to third parties for their direct marketing purposes by withholding consent.
Under the California Consumer Privacy Act of 2018, certain additional rights are granted to California residents, including:
- The right to access specific information and data portability rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Rent College Pads 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 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.
- The right to request that Rent College Pads delete any personal information.
You have the right to request that Rent College Pads 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 providers 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 sect 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 information39s deletion may likely render impossible or seriously impair the research39s 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.
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 either:
- Calling us at 414 882-4008.
- Contacting us at email@example.com
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.
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 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.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor39s identity or authority to make the request.
Personal Information Sales Opt-Out and Opt-In Rights
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 quotright to opt-outquot. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization the quotright to opt-inquot 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 may opt-out of future sales at any time.
To exercise the right to opt-out, you or your authorized representative may submit a request to us by visiting the following Internet Web page link:
Do Not Sell My Personal InformationAM2
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 in to personal information sales at any time by:
Opt-in to Sell Your Personal InformationAM3
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
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.
Information We Collect
The information collected by Rent College Pads is limited to the description of information listed in Section C titled ldquoCollecting Personally Identifiable Informationrdquo. This information is limited to the following categories of information:
Include any categories of personally identifiable information collected by RCP. This list needs to contain any of the 11 categories listed in the CCPA. The categories are: 1 identifiers, 2 Personal information categories listed in the California Customer Records statute, 3 Protected classification characteristics under California or federal law, 4 Commercial information, 5 Biometric information, 6 Internet or other similar network activity, 7 Geolocation data, 8 Sensory data, 9 Professional or employment-related information, 10 Non-public education information, and 11 Inferences drawn from other personal information. For a more thorough explanation of these categories, please see the attached memo.AM4
Disclosures of Personal Information for a Business Purpose
In the preceding twelve 12 months, Rent College Pads has disclosed the following categories of personal information for any of the business purposes described in Section D, ldquoUsing Your Personally Identifiable Informationrdquo:
Include any categories of personally identifiable information listed in the section titled ldquoInformation We CollectrdquoAM5
Sales of Personal Information
In the preceding twelve 12 months, Company has sold the following categories of personal information:
Include any categories of personally identifiable information listed in the section titled ldquoInformation We Collectrdquo that has been soled in the previous 12 monthsAM6 Utah Residents:
WE MAY CHOOSE TO DISCLOSE NONPUBLIC PERSONAL INFORMATION ABOUT YOU, THE USER, TO A THIRD PARTY FOR COMPENSATION. YOU MAY CHOOSE TO OPT-OUT OF SUCH DISCLOSURE TO THIRD PARTIES BY SENDING A WRITTEN REQUEST TO INFO@RENTCOLLEGEPADS.COM.
H. Retaining Personally identifiable information
Our data retention policies and procedures are designed to ensure that we comply with our legal obligations regarding the retention and deletion of personally identifiable information in accordance with all state and federal laws and regulations.
Personally identifiable information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Rent College Pads will keep data for a period of up to 5 years. Users may request Rent College Pads to delete their data or request an accounting of all personal data of theirs kept by Rent College Pads by sending an email to Jeremy Schmidt at firstname.lastname@example.org.
Notwithstanding the other provisions of this Section H, we will retain documents including electronic documents containing personal data:
- To the extent that we are required to do so by law
- If we believe that the documents may be relevant to any ongoing or prospective legal proceedings and
- To establish, exercise, or defend our legal rights including providing information to others for the purposes of fraud prevention and reducing credit risk.
I. Security Measures
We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personally identifiable information. All personally identifiable information provided to us will be kept on our secure password and firewall protected servers.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping the password you use for accessing our Website confidential we will not ask you for your password except when you log in to our Website.
If a data breach occurs: If our DPO determines that Personal Identifying Information has been accessed without authorization, Rent College Pads will report any confirmed or suspected situation to necessary parties immediately upon discovery, both orally and in writing, within 72 hours. If Rent College Pads reasonably believes a breach has or may have occurred, Rent College Pads will release a report to all users identifying:
- The nature of the unauthorized access, use, or disclosure
- The nonpublic information accessed, used or disclosed
- The persons who accessed, used, disclosed, and/or received nonpublic information if known
- What Rent College Pads has done or will do to mitigate any deleterious effect of the unauthorized access, use, or disclosure and
- What corrective action Rent College Pads has taken or will take to prevent future unauthorized access, use, or disclosure.
In the event of a suspected Breach, Rent College Pads will keep stakeholders informed regularly of the progress of its investigation until the uncertainty is resolved. To the extent possible, our DPO will also facilitate the process to warn the victims of the theft so that they can protect their credit and identity
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.
L. Third-Party Services
Our Website may contain links to third-party websites or services, such as third-party integrations, co-branded services, or third party-branded services Third-Party Services. Rent College Pads doesnt own or control these Third-Party Services. Through your interaction with such Third-Party Services you may be providing information directly to the Third-Party Service, Rent College Pads, or both. These Third-Party Services are required to have their own privacy and data collection policies. We encourage you to review those privacy policies.
While we encourage our business partners to adopt privacy policies and practices that build users trust and confidence in the Internet, we are not responsible for the privacy policies or practices of third parties or any of the content of web sites linked to the Website or any third-party products or services offered through the Website.
M. Updating Information
Please let us know if the personally identifiable information that we hold about you needs to be corrected or updated.
Most browsers allow you to refuse to accept cookiesfor example:
- in Internet Explorer version 10 you can block cookies using the cookie handling override settings available by clicking Tools, Internet Options, Privacy, and then Advanced
- in Firefox version 24 you can block all cookies by clicking Tools, Options, Privacy, selecting Use custom settings for history from the drop-down menu, and unticking Accept cookies from sites and
- in Chrome version 29, you can block all cookies by accessing the Customize and control menu, and clicking Settings, Show advanced settings, and Content settings, and then selecting Block sites from setting any data under the Cookies heading.
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website. You can delete cookies already stored on your computerfor example:
- in Internet Explorer version 10, you must manually delete cookie files you can find instructions for doing so at http://support.microsoft.com/kb/278835
- in Firefox version 24, you can delete cookies by clicking Tools, Options, and Privacy, then selecting Use custom settings for history, clicking Show Cookies, and then clicking Remove All Cookies and
- in Chrome version 29, you can delete all cookies by accessing the Customize and control menu, and clicking Settings, Show advanced settings, and Clear browsing data, and then selecting Delete cookies and other site and plug-in data before clicking Clear browsing data.
Deleting cookies will have a negative impact on the usability of many websites.