Equity Residential California Privacy Notice

Effective Date: January 1, 2020

Table of Contents

  1. Overview
  2. Personal Information Under CCPA
  3. Your California Privacy Rights
  4. Additional California Notices
  5. Contact Us & Disability Access

Overview

This notice reflects our understanding of the law and our data practices as of the date posted. We may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”), and is a supplement to Equity Residential’s other privacy policies or notices. If there’s a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any privacy policy or notice of general applicability posted or referenced on our websites, apps, products, or services.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA. This Notice also covers rights California Consumers have under the CCPA, as well other notices to Californians required by other laws.

Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this Notice. Our Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department. Publicly available information is not treated as PI under the CCPA, so this Notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.

1. Personal Information Under CCPA

Consistent with the CCPA, this first section describes our personal information practices for the calendar year 2019. For our current practices see our privacy policies and any notices at the point of collection.

The CCPA defines eleven Categories of PI, listed below. For each type of PI, below we have provided examples to explain what the PI is, where we may obtain it from, and why we may collect it.

We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed below. We typically prohibit our service providers and vendors from using your PI for any purpose other than our business purpose that the service provider or vendor is helping us to achieve, or for their permitted business purposes such as security and fraud prevention.

As permitted by law, we do not treat de-identified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into de-identified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers.

Category 1: Identifiers

Examples: This may include but is not limited to: 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.

Sources: We collect Identifiers directly from you when you provide us information online, over the phone or through paper documents such as lease applications; from guest cards when you tour a community; from credit reporting agencies when you apply to live with us; from our websites with which you interact; in our notes and records we create about you; and from public sources of data such as government databases.

Business or Commercial Purpose for Collection: We collect Identifiers to provide you services and as otherwise related to the operation of our business. This includes:

  • processing your interactions and transactions with us (such as your payment of rent and fees), and managing those interactions and transactions (such as following up with you about a request to tour one of our communities);
  • performing services for you (such as service calls to your apartment home);
  • research and development (such as studying your use of community amenities to understand what you value);
  • quality assurance (such as reviewing your interactions with our leasing consultants to better our training);
  • security (such as monitoring our website for malicious or criminal activity); and
  • debugging or troubleshooting errors that may occur on our websites or mobile applications.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above. For example, if you take a self guided tour of one of our properties we may utilize a service provider to help verify your identity for security purposes; we may share PI with a service provider that we engage to help manage our response to resident service calls; we may engage service providers to consult with us and conduct research on our business which may involve review of PI in order to better our communities and services.

In addition, we place, and allow certain third parties to place, cookies or pixels on our websites and other online services which collect Identifiers from or about you or your device for the purpose of operating web sites and online services and for serving you with relevant content and advertisements about our communities.

Category 2: Personal Records

Examples: This may include information such as: physical characteristics or description, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.

Sources: We collect Personal Records directly from you when you provide us information about your interest in our communities, when you tour one of our communities, when you apply to lease with us and when you sign a lease with us, and in our notes and records we create about you. In addition, we may collect Personal Records about you from third parties such as credit reporting agencies.

Business or Commercial Purpose for Collection: We collect Personal Records from you to provide you services, processing and managing your interactions and transactions with us, and as otherwise related to the operation of our business, including:

  • Credit and background checks, for example, may include education, employment, and certain financial information collected in order to qualify you to enter into a lease at one of our communities.
  • Our leases require you to have certain insurance coverages, and we ask you to verify that information with us; we may provide Personal Records about you to your renter’s insurance company.
  • We also may maintain, or engage a service provider to maintain on our behalf, banking or credit/debit card information in connection with payment directions you have provided for rent, utilities, deposits, fees, or to facilitate security deposit refunds as needed.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above.

Category 3: Personal Characteristics or Traits

Examples: This may include, but is not limited to: sex, marital status, religion, veteran status, familial status, race, disability, gender identity, and creed.

Sources: To the extent we collect this type of PI, we do so from you directly.

Business or Commercial Purpose for Collection: We collect this type of information so that we can provide our services in accordance with applicable laws and regulations. For example:

  • We may inquire as to your veteran status where you have legal rights based on that status (for example, to terminate your lease without penalty when a deployment requires you to move).
  • We may inquire as to your disability when you request us to make an accommodation for you related to your disability.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above. For example, we may engage a service provider with expertise in a particular local government sponsored program in order to help us manage our participation in that program.

Category 4: Customer Account Details/Commercial Information

Examples: This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Sources: If we collect this type of PI, we do so from you directly, or we create it in our notes and records.

Business or Commercial Purpose for Collection: We may collect this type of PI in connection with services we provide you while you are living at one of our communities, in order to verify services were provided or to follow up with you about whether the services met your needs.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above.

Category 5: Biometric Information

Examples: This may include but is not limited to: genetic, physiological, behavioral, and biological characteristics, that can be used to establish individual identity, including but not limited to fingerprints, voiceprints, retina scans from which an identifier template can be extracted, and other physical patterns, and sleep, health, or exercise data, that contain identifying info.

We do not collect Biometric Information at this time.

Category 6: Internet Usage Information

Examples: This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.

Sources: We may collect Internet Usage Information from your device when you connect with a wi-fi system at one of our communities. It is not our practice to associate a device ID to a particular person. When you interact with our websites, we do use certain tracking services to gather information about your usage and about you (see above under Category 1: Identifiers).

Business or Commercial Purpose for Collection: We collect information about Internet Usage to better operate our web sites and online services, market our communities to you and to serve you advertisements about them. We also use this information for internal research and analytics about our business, such as determining what pages on our website are visited and how frequently visitors to our website ultimately sign leases with us.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above. In addition, we place, and allow certain third parties to place, cookies or pixels on our websites and other online services which collect Internet Usage Information from or about you or your device for the purpose of operating web sites and online services and for serving you with relevant content and advertisements about our communities.

Category 7: Geolocation Data

Examples: This may include, but is not limited to: precise physical location or movements and travel patterns.

We do not collect Geolocation Data at this time.

Category 8: Sensory Data

Examples: This may include, but is not limited to: audio recordings of customer care calls, electronic, visual, thermal, olfactory, or similar information.

Sources: We may record customer service calls and leasing or marketing calls that we have with you. Certain of our properties use video security technologies, and those videos may be stored for a period of time.

Business or Commercial Purpose for Collection: We record calls for training and quality assurance purposes. Video technologies are used for site security and guest check in and identification.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above.

Category 9: Professional or Employment Information

Examples: This may include, but is not limited to: professional, educational, or employment-related information.

Sources: We may obtain Professional or Employment Information from you as part of an application to live at one of our communities.

Business or Commercial Purpose for Collection: We collect Professional or Employment Information to provide you services and as otherwise related to the operation of our business. For example, we collect this information in order to qualify you to enter into a lease at one of our communities.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above. For example, if a government sponsored local program requires that Professional or Employment Information is submitted as part of participation in that program, we may engage a service provider to help us manage that program and in the course of that work may share PI with the service provider.

Category 10: Non-public Education Records

Examples: This may include but is not limited to: 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.

Sources: We may obtain Non-public Education Records from you as part of an application to live at one of our communities.

Business or Commercial Purpose for Collection: We collect Non-public Education Records to provide you services and as otherwise related to the operation of our business. For example, we may collect this information in order to qualify you to enter into a lease at one of our communities.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above. For example, if a government sponsored local program requires Non-Public Education Records submitted as part of participation in that program, we may engage a service provider to help us manage that program and in the course of that work may share PI with the service provider.

Category 11: Inferences from PI Collected

Examples: This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources: We may obtain information about consumer behavior from third party sources, such as data aggregators and firms that create marketing “segments” based on consumer characteristics or behaviors.

Business or Commercial Purpose for Collection: We may utilize marketing “segments” and inferences drawn based on those segments or consumer characteristics to inform our services and offerings to you.

Sharing PI: To the extent we draw Inferences, we may share such Inferences, but only with service providers we engage to assist us in providing services to you.

Sale of PI.

We do not believe that in 2019 we sold your PI as defined under the CCPA. We note, however, that there is not yet a consensus regarding how web site cookies and online tracking technologies, and the data they collect and share, should be treated under the CCPA. We do not believe that such activities are a sale by us of your personal information. However, see the Do Not Sell section in the CA Privacy Rights Section below for more information on how we reach this conclusion and what ways we provide you with information and choices regarding cookies on our web site and online services. Until such time as we change this policy by updating this Privacy Notice, we will treat PI collected as subject to a do not sell request. However, although there is not yet a consensus, we do not believe that the collection of data by third party cookies on our website and online services is a sale of your personal information by us. See our Privacy Policy for certain choices you have regarding cookies. We may also offer a cookie management tool that enables you to enable certain cookie preferences on your device.

See our Privacy Policy for certain choices you have regarding cookies. We may also offer a cookie management tool that enables you to enable certain cookie preferences on your device.

2. California Privacy Rights

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process. We will not fulfill your CCPA request to know or delete personal information unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our Consumer Rights Request form and respond to any follow up inquires we may make. You may also obtain information on how to make, and may submit, a request by calling our toll free number at (866) 869-5413.

If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided to verify your identity or authority only for such purposes, and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your social security number, driver’s license number or other government-issued ID number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us. We may also withhold PI, or retain it following a deletion request, as permitted or required by applicable law, or to protect the rights of others.

Your CCPA rights are as follows:

A.   The Right to Know

i.   Information Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties to whom we have shared your PI.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
    • The categories of your PI we have sold.
    • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

For the specific pieces of PI we have collected about you, see the Obtaining Copies of PI section immediately below.

To make a request, visit Consumer Rights Request form and following the instructions, or call us at (866) 869-5413. In either case, you will need to follow our instructions on how to enable us to verify you and respond to your request. If you are disabled and need special accommodation, please let us know.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

ii.   Obtaining Copies of PI

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. To make a request, visit Consumer Rights Request form and following the instructions, or call us at (866) 869-5413. In either case you will need to follow our instructions on how to enable us to verify you and respond to your request. If you are disabled and need special accommodation, please let us know by contacting us over the phone toll free at (866) 869-5413, via email at consumerprivacy@eqr.com, or by mail at Two North Riverside Plaza, Suite 400, Chicago IL 60606 Attention: Privacy Compliance.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

B.   Do Not Sell

We do not believe that we sell your PI as defined under the CCPA. Until such time as we change this policy by updating this Privacy Notice, we will treat PI collected as subject to a do not sell request. However, although there is not yet a consensus, we do not believe that the collection of data by third party cookies on our website and online services is a sale of your personal information by us. See our Privacy Policy for certain choices you have regarding cookies. We may also offer a cookie management tool that enables you to enable certain cookie preferences.

As explained in our Privacy Policy, we do not look for or recognize “do not track” signals, and do not believe they are relevant to your CCPA rights. We are not aware of any automated agent signals that are relevant to CCPA rights, but may recognize such technologies in the future if we become convinced of their legitimacy.

C.   Delete

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation:

  • to complete transactions and services you have requested or that are reasonably anticipated;
  • for security purposes; and
  • for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.

Note also that we are not required to delete your PI that we did not collect directly from you.

To make a request, visit Consumer Rights Request form and follow the instructions, or call us at (866) 869-5413. In either case you will need to follow our instructions on how to enable us to verify you and respond to your request. If you are disabled and need special accommodation, please let us know.

D.   Non-Discrimination

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

E.   Authorized Agents

You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority and of you. You can learn how to do this by visiting the agent section of our rights request portal at Consumer Rights Request form, or call us at (866) 869-5413.

F.   Our and Other’s Rights

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

3. Additional California Notices

In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

A.   Third Party Marketing and Your California Privacy Rights

Separate from your CCPA “Do Not Sell” rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:

We provide California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than with our affiliates, for such third parties’ own direct marketing purposes. California residents may exercise that opt-out, and/or request information about our compliance with the Shine the Light law, and obtain a disclosure of third parties we have shared information with in accordance with the law for their direct marketing purposes absent your choice (i.e., Company affiliates) and the categories of information shared, by contacting us consumerprivacy@eqr.com or by sending a letter to us at Two North Riverside Plaza, Suite 400, Chicago, IL 60606, (Attention: Legal Counsel). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

B.   Online Privacy Practices

For more information on our online practices and your California rights specific to our online services see our online Privacy Policy. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

  • Tracking and Targeting

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your browser for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our online Privacy Policy.

  • California Minors

Although our online service(s) are intended for an audience over the age of 18, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us consumerprivacy@eqr.com, detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

4. Contact Us & Disability Access

For more information on your California privacy rights, or for disability access assistance, contact us at (866) 869-5413, email us at consumerprivacy@eqr.com, or write to us at Two North Riverside Plaza, Suite 400, Chicago, IL 60606 Attention: Privacy Compliance.




Equity Residential CCPA Consumer Rights Request Form

The California Consumer Privacy Act gives California consumers several rights with respect to Personal Information that we collect, use, or share with others. As explained in our California Privacy Policy, those rights generally can be described as rights to know:

  • What types of Personal Information we have about you
  • Where we obtained that information
  • How we use that information
  • With what types of third parties we share that information

You also have the right to request a copy of your Personal Information, as well as the right to request that we delete Personal Information we have about you. If you want to exercise any or all of these rights, please complete this form. We will respond to your request as quickly as possible.

If you are an authorized agent making this request for someone else, please complete this form on behalf of the person for whom you are making the request and continue to the bottom of the form for further instructions.

If you have questions about this form or our process, please contact us, preferably by email at consumerprivacy@eqr.com. You may also contact us by telephone at 866-869-5413, or by regular mail at Equity Residential, Two North Riverside Plaza, Suite 400, Chicago, Illinois 60606 Attention: Privacy Compliance.

PLEASE COMPLETE THIS ENTIRE FORM AND HIT THE SUBMIT BUTTON

Tell us about you:

* Required Field

Note: We will attempt to match this information to our records. Please provide the same information that you have used in your previous interactions with us.

* I am a California State resident

 
* I am a current or former resident of an Equity Residential Community.

 
If your answer is yes, please provide the address and unit number for the Equity Residential Community where you most recently lived.

Tell us what you would like to know.

Under the CCPA, you have the right to request a portable copy of the Personal Information we have collected about you, subject to certain exceptions (for example, if we have your social security number or banking information, the law directs us not to send that to you).

If you want a copy of your Personal Information, after we verify your request the law requires us to obtain a signed affidavit from you, attesting under penalties of perjury that you are who you say you are.

Do you want a copy of your Personal Information?

Under the CCPA, you have the right to request that we delete all Personal Information we have collected about you, subject to certain exceptions (for example, if you are a current resident we cannot delete your Personal Information because we need it to continue our business relationship with you).

Do you want us to delete your Personal Information?

Under the CCPA, we are required to allow you to opt-out of the sale of your Personal Information, or to tell you that we do not sell your Personal Information. At this time, based on our understanding of the CCPA, Equity Residential does not sell Personal Information. If in the future we do, we will let you know and provide you with an opportunity to opt-out of such sale before we proceed to sell your Personal Information.

PLEASE REVIEW YOUR ANSWERS AND SELECTIONS ABOVE. ONCE YOU ARE SATISFIED THE FORM IS COMPLETE, PLEASE HIT THE SUBMIT BUTTON BELOW.

THANK YOU.

Authorized Agents:

Please provide the information below about yourself, and make sure you have answered the questions above on behalf of the person about whom you are making the request. We will require proof of your authority.

Basis for Authority