Privacy Policy

Last Updated: July 12, 2024

This privacy policy (“the Privacy Policy”) of MG Properties Group details the privacy practices regarding information we collect from persons or entities (“you” or “your”) who access our property’s RENTCafé Resident Portal website or our related mobile applications that may be available for download (collectively, the “Site”). To access the Privacy Policy of RENTCafé, please visit: https://www.rentcafe.com/apartments/privacypolicy.aspx.

This policy further explains the rights of California residents, regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA).

PURPOSE. The purpose of this Privacy Policy is to inform you about the types of information we gather about you, including information gathered when you visit the Site, and information we may receive from third parties or affiliates in addition to that online information, how we may use that information, whether we disclose that information to anyone, and the choices you have regarding our use of, and your ability to correct, the information. Company strives to help visitors of the Site protect their privacy while using our Site.

THE SITE IS NOT INTENDED FOR CHILDREN AND COMPANY DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF COMPANY LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).

YOUR CONSENT AND POLICY CHANGES. PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION, INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE SITE.

We may update and make changes to this policy, so we encourage you to review it periodically. By using the Site after the effective date of any modification to the Privacy Policy, you expressly consent, without qualification, to the collection, use and disclosure of information, including Personally Identifiable Information (that you previously provided or later provide), as described in the new Privacy Policy.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

2. Personal Information We Collect About You. We collect two types of information: personally identifiable information and non-personally identifiable information. Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”). We also may collect information that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data, information about you such as how you use the Site and your communication preferences, and other anonymous statistical data involving the use of our Site (“Non-Personally Identifiable Information”).

Personally Identifiable Information we collect may include, but is not limited to: your name, email addresses, postal addresses, postal codes, user Internet Protocol (IP) addresses, social security/insurance number, driver’s license number, prior addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name and password (if you choose to become a registered user of the Site or our products and services), emergency contact information, information about your pets, information about your vehicles including license plate numbers, and other information either desirable or necessary to provide quality services to our customers and visitors. We may also collect information about you such as your use of the Site and communication preferences.

You may choose not to provide your Personally Identifiable Information by not entering it on the Site; however, you will not be able to use certain services and features if those services and features require Personally Identifiable Information in order to function.

In the preceding 12 months, we have collected the following categories of consumer personal information:

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email, and/or via our website and app. However, we may also collect information from the following categories of sources:

• Your application to lease an apartment, as well as all forms/documents that you fill out when you lease your apartment with us;
• Publicly accessible sources (e.g., property records);
• Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers;
• Third party with your consent (e.g., your bank);
• Cookies on our website;
• Automated information collection;
• Our IT systems, including:

• Door entry systems and reception logs;
• Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and

4. USE OF COOKIES AND OTHER TECHNOLOGIES. Like many other website operators, Company may use cookies to customize content specific to your interests and track your use of the Site. “Cookies” are small text files that are placed on your computer or other device by websites that you visit, and may be used to store your personal information. Cookies are widely used in order to make websites and other applications work, or work more efficiently, and help them remember certain information and recognize your internet browser. Cookies may last until you close your browser (“session” cookies) or over repeat visits (“persistent” cookies).

We use cookies and similar technologies to:

• Assist you in efficiently and safely navigating and experiencing our services;
• Enable you to register, login, provide feedback and otherwise interact with our services;
• Store and honor your preferences and settings;
• Measure and analyze usage and performance data; and
• Assist us with promotional and marketing efforts (including interest-based advertising).

If you access any of our services subject to a contract between us and you, cookies and similar technologies will be used as necessary for the performance of that contract and for our legitimate business operations related to providing the service.

In addition to cookies, Company may use other now known or later developed technologies, to assist Company in observing the behavior of users visiting the Site. These technologies access individual user information but the information is used only to compile aggregated statistics about the Site’s usage.

Third Party Cookies. This Site uses Google Analytics (and in the future may use other similar sites or services), a web analytics service provided by Google, Inc. (“Google”), to better assist Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for Company’s use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. The use of cookies by Google Analytics is covered by Google’s privacy policy: https://policies.google.com/privacy.

How to manage cookies and interest-based advertising. You can manage the use of certain types of cookies, including targeting cookies used for personalized advertising, also known as interest-based advertising (IBA), by amending your cookies settings in your browser’s privacy preferences menu. You also may be able to block or delete cookies by selecting the appropriate settings on your browser’s privacy preferences menu.

You can also opt out of IBA by turning off targeting cookies used for IBA via the consumer choice tools created under self-regulation programs in many countries, such as the US-based YourAdChoices, the Canada-based AdChoices or the EU-based Your Online Choices. We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Interest-Based Advertising.

Certain content and features in our services depend on cookies to function. For example, authentication cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. Please note, if you choose to block all cookies, you will not be able to use the full functionality of the site, as you cannot sign in or use certain content or features. If you choose to delete cookies, any settings and preferences dependent on those cookies will be lost.

5. Why We Use Your Personal Information. We collect, use, and share consumer personal information for the following business purposes:

• Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
• Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

6. EMAIL MANAGEMENT. You may receive emails from Company for a variety of reasons. We respect your desire to manage email correspondence. If you have an account with Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.
7. Who We Share Your Personal Information With. In the preceding 12 months, we have shared consumers’ personal information with:

• Our affiliates and corporate partners, including companies within the MG Properties group;
• Service providers we use to help deliver our products and/or services to you, including situations where sharing or disclosing your information is required in order to offer you products or services you desire;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts.  These companies include:  (1) Apartments.com (advertising); (2) Zillow (advertising); (3) ApartmentList (advertising); (4) Yardi (client relationship management and PMS (property management software); (5) Elise AI (leasing, tour appointments, etc.); (6) Google Analytics; (7) ApartmentSEO for Google Advertising; (8) Rentable Google My Business Advertising (prospect data); (9) Rentgrata (resident referrals); (10) CORT (furniture rental); (11) Flex (rent data); (12) Zark Parking (parking data); and (13) RentCafe (property management).
• A person who in the reasonable judgment of Company is seeking the information as an agent of the individual;
• A third party or parties, where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Credit reporting agencies;
• Our insurers and brokers;
• Our banks; and
• External auditors.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. Specifically, we may be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order, a subpoena/summons, or a law enforcement agency’s request.

We may also disclose information if, in the reasonable judgment of Company, it is necessary to enforce compliance with our internal policies or the Terms of Use, to prevent illegal activity or suspected fraud, or to protect our Site, customers, or others.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

8. Categories of Personal Information We Shared. In the preceding 12 months, we have shared the following categories of personal information:

• Identifiers (e.g., 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);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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;
• Characteristics of protected classifications under California or federal law;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Geolocation data;
• Professional or employment-related information;
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive personal information.

9. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers (e.g., 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);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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;
• Characteristics of protected classifications under California or federal law;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Geolocation data;
• Professional or employment-related information;
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive personal information.

10. How We Store Your Information. Company is committed to protecting the security of any personal information you provide to us. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. In spite of these protections, Company cannot guarantee the security of any data submitted over the Internet. After your information reaches Company, however, it is protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process your personal information in the United States or Canada or any other country in which we or our agents maintain facilities. By using the Site, you consent to the transfer of your information among these facilities, including those located outside your home country.
11. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.  We retain your personal information for one year after your tenancy ends, after which time it is deleted. 

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

12. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

13. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by e-mailing us at [email protected], or write to us at Attention:  Director of Marketing – MG Properties, 10505 Sorrento Valley Road Suite 300, San Diego, CA 92121.  You may also call 1-800-424-2273.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. 

“Your rights under the California Consumer Privacy Act”

The California Consumer Privacy Act (CCPA) provides you with rights regarding how your data or personal information is treated. Under this law, California residents may choose to opt out of the “sale” of their personal information to third parties. Based upon the CCPA definition, “sale” refers to data collection for the purpose of creating advertising and other communications. Learn more about CCPA and your privacy rights.

“Limit Use of My Sensitive Personal Information”

You have the right to request us to limit the use or disclosure of certain Sensitive Personal Information we collected about you to uses necessary to provide you the services, and for certain business purposes (which are listed in the Privacy Policy). Please note that you may only object to the use and disclosure of a Sensitive Personal Information we collected or processed for the purpose of inferring characteristics about you.

You can send us a request to [email protected].  Once we receive and confirm your verifiable consumer request, we will limit the use or disclosure of your information (and direct our service providers to do so), unless any lawful exception applies.