Effective Date: January 1, 2020
Last Reviewed: January 1, 2020
This Privacy Notice for California Residents supplements the information contained in Vi's Privacy Policy and applies solely to all visitors, users, residents, prospective residents, consumers, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
1. Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Vi has collected the following categories of personal information from its consumers within the last twelve (12) months:
Personal information does not include:
We may use, or disclose the personal information we collect for one or more of the following purposes:
3. Sharing Personal Information
Vi may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
In the preceding twelve (12) months, Company has not sold personal information.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Vi 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 (see Exercising Access, Data Portability, and Deletion), we will disclose to you:
You have the right to request that Vi 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 (see Exercising Access, Data Portability, and Deletion, 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 provider(s) to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Making a verifiable consumer request does not require you to create an account with us. You may make a verified request by providing the following information: (a) presenting yourself for identification with proper government identification; (b) making a request through a known e-mail address.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. 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 the verifiable consumer request's receipt. 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.
10. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to editorial@viliving.com or write us at: Attn: Webmaster, 233 South Wacker Drive, Suite 8400, Chicago, Illinois 60606.
Changes to Our Privacy Notice
Vi reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website, products, and services following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Vi collects and uses your information described below and in Vi's Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Last Reviewed: January 1, 2020
This Privacy Notice for California Residents supplements the information contained in Vi's Privacy Policy and applies solely to all visitors, users, residents, prospective residents, consumers, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
1. Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Vi has collected the following categories of personal information from its consumers within the last twelve (12) months:
| Category | Examples1 | Collected | Sources | Purpose | Third Parties Shared | |
|---|---|---|---|---|---|---|
| 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 | (a) Directly or indirectly from you (b) From third parties |
(a) Performance of a contract (b) For our legitimate interests (c) Necessary to comply with a legal obligation |
(a) Third party payment processing providers; (b) Parking vendors; (c) Insurance providers; (d) Security vendors, including onsite at properties and cyber (e) Government agencies; (f) Financial institutions (g) Professional service |
|
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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. | YES | (a) Directly or indirectly from you (b) From third parties |
(a) Performance of a contract (b) For our legitimate interests (c) Necessary to comply with a legal obligation |
(a) Third party payment processing providers; (b) Parking vendors; (c) Insurance providers; (d) Security vendors, including onsite at properties and cyber (e) Government agencies; (f) Financial institutions (g) Professional service providers, including attorneys and accountants (h) Family members or caregivers |
|
| C. Protected classification characteristics under California or federal law. | Race (which includes historically associated traits, such as hair styles and protective hair styles, e.g., braids, locks, and twists), religious creed (which includes religious dress and grooming practices), color, national origin (which includes, but is not limited to, national origin groups and aspects of national origin, such as height, weight, accent, or language proficiency), ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex (which includes pregnancy, childbirth, breastfeeding, and related medical conditions), gender, gender identity, gender expression, age, sexual orientation, military or veteran status (including state and federal active and reserve members as well as those ordered to duty or training), immigration/citizenship status or related protected activities (which includes undocumented individuals and human trafficking), protected medical leaves, domestic violence victim status, political affiliation, or any other category or activity protected by federal, state, or local laws, ordinances, or regulations. | YES | (a) Directly or indirectly from you | (a) Performance of a contract (b) For our legitimate interests (c) Necessary to comply with a legal obligation |
(a) Third party payment processing providers; (b) Parking vendors; (c) Insurance providers; (d) Security vendors, including onsite at properties and cyber (e) Government agencies; (f) Financial institutions (g) Professional service providers, including attorneys and accountants (h) Family members or caregivers |
|
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | (a) Directly or indirectly from you | (a) Performance of a contract (b) For our legitimate interests |
(b) Parking vendors; (d) Security vendors, including onsite at properties and cyber |
|
| 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 | N/A | N/A | N/A | |
| F. Internet or other similar network activity. | Browsing history, search history, personal social media activity, personal email, online transactions, information on a consumer’s interaction with a website, application, or advertisement. | YES | (a) Directly or indirectly from you (b) From third parties |
(a) For our legitimate interests (b) Necessary to comply with a legal obligation |
(a) IT service providers (b) Security vendors, including cyber |
|
| G. Geolocation data. | Physical location or movements. | YES | (a) Directly or indirectly from you (b) From third parties |
(a) Necessary for our legitimate interests | (b) Security vendors, including cyber | |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | N/A | N/A | N/A | |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES | (a) Directly or indirectly from you | (a) Performance of a contract (b) For our legitimate interests (c) Necessary to comply with a legal obligation |
a) Third party payment processing providers; (b) Parking vendors; (c) Insurance providers; (d) Security vendors, including onsite at properties and cyber (e) Government agencies; (f) Financial institutions (g) Professional service providers, including attorneys and accountants (h) Family members or caregivers |
|
| 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 | N/A | N/A | N/A | |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | N/A | N/A | N/A |
1 Examples listed herein are illustrative of the types of personal information included in each category and may or may not be the specific types of personal information collected on an individual person. Additionally, some personal information included in the categories may overlap with other categories.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
- Directly from you. For example, from forms you complete or services you request that we provide to you.
- Indirectly from you. For example, from observing your actions with our company systems, the resident app, Vi’s website, or services or activities offered by us.
- From third parties. For example, from vendors who help us reach out to prospective residents and from our security vendors.
We may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request tour of a property, we will use that personal information order to process an application to lease or for payment of rent or other sums due to us.
- To provide, support, personalize, and develop our website, products, and services, including services and activities for which you may have registered through TouchTown, Inc.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries about our communities, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your experience with us and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via mail, e-mail, or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our communities, website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our communities, website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vi's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Vi about our Website users is among the assets transferred.
3. Sharing Personal Information
Vi may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers, such as payment processors, parking vendors, insurance providers, IT service providers, security vendors, including onsite at properties and cyber; government agencies, financial institutions, and professional service providers, including attorneys and accountants
- Data aggregators.
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category E: Biometric information.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category H: Sensory data.
- Category I: Professional or employment-related information.
- Service providers;
- Insurance providers;
- Payment processing providers;
- Parking vendors;
- Security vendors; and
- Financial institutions.
In the preceding twelve (12) months, Company has not sold personal information.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Vi 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 (see Exercising Access, Data Portability, and Deletion), 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 Vi disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
You have the right to request that Vi 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 (see Exercising Access, Data Portability, and Deletion, 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 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, 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.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (888) 216-3184
- Emailing us at editorial@viliving.com
- Visiting https://www.viliving.com/contact
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.
Making a verifiable consumer request does not require you to create an account with us. You may make a verified request by providing the following information: (a) presenting yourself for identification with proper government identification; (b) making a request through a known e-mail address.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. 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 the verifiable consumer request's receipt. 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.
10. Non-Discrimination
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.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to editorial@viliving.com or write us at: Attn: Webmaster, 233 South Wacker Drive, Suite 8400, Chicago, Illinois 60606.
Changes to Our Privacy Notice
Vi reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website, products, and services following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Vi collects and uses your information described below and in Vi's Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (888) 216-3184
Website: https://www.viliving.com/contact
Email: editorial@viliving.com
Postal Address:
Classic Residence Management Limited Partnership
Attn: Erin Swafford
233 South Wacker Drive
Suite 8400
Chicago, Illinois 60606