Privacy Policy

    PRIVACY POLICY

This Privacy Policy applies to the website located at www.irtliving.com (collectively, the “Website” or “Site”) as well as to each of our Community Websites (as indicated herein).  Capitalized terms not otherwise defined herein shall have the meanings attributed to them in our Terms of Use, available at http://www.irtliving.com/page.aspx/contentId/22/Terms-of-Use/ (“Terms”).

This policy is effective as of:  August 1, 2018

Independence Realty Trust (“IRT” or “we,” “us” or “our”) is committed to protecting your privacy through compliance with this policy.  This Privacy Policy discloses how we collect, share, and use information about you that IRT collects through the Website or in connection with the provision of the Services and our use of and your ability to correct the information so collected.  The Website provides users with information about IRT’s various managed properties and certain corresponding Services, as provided in more detail in our Terms.  In using and viewing the Website, you understand and agree that IRT may use your Personal Data (defined below) and other information collected about you subject to the terms of this Privacy Policy.

This Privacy Policy applies to information that we (i) collect via the Website, in email, text, and other electronic messages between you and us via the Website; (ii) obtain from our third party service provider, RentCAFÉ, in maintaining and operating the Community Websites and providing any associated services (RentCAFÉ’s collection, use, and handling of Personal Data and information is pursuant to its privacy policy available on the Community Websites)  ; and/or (iii) obtain from our third party service provider, S&P, in maintaining and operating the Investor-Related Portions and providing any associated services (S&P does not collect any private information from users of the Investor Relation Portions and only collects information concerning page “hits,” delivered anonymously, including page views, location, browsing device, and screen resolution)).  This Privacy Policy expressly DOES NOT apply to information that is collected by us offline or via any other website operated by us or any third party (including any affiliate), including via any websites that are linked to the Website that are not Community Websites.  Moreover, you understand and agree that this Privacy Policy DOES NOT govern or apply to (i) RENTCafé’s collection, processing, storage, handling, disclosure, or use of Personal Data or other information collected about you when you use or access a Community Website, which is instead governed by the RENTCafé Privacy Policy (which is available on such Community Website); and/or (ii) S&P’s collection, processing, storage, handling, disclosure, or use of Personal Data or other information collected about you when you use or access Investor-Related Portions. 

Please review this Privacy Policy carefully.  If you do not agree with this Privacy Policy, your choice is to not use our Website.  By accessing or using the Website, you hereby agree to this Privacy Policy.  We may change the terms and conditions set forth in this Privacy Policy from time to time in our sole discretion and will provide you with ten (10) days’ notice before the new Privacy Policy come into effect by posting notice of the revised Privacy Policy on the Website.  Changes will apply prospectively only.  Accordingly, we ask that you check back to see if there are any updates to this Privacy Policy from time to time.  Your continued use of or access to the Website or Community Websites after the changes go into effect constitutes your acceptance of such changes.

Children's Online Privacy Protection Act
IRT complies with the Children's Online Privacy Protection Act of 1998 (“COPPA”). COPPA requires that website operators never knowingly request personally identifiable information from anyone under the age of 13 without requesting verifiable parental consent.  In accordance with COPPA, we do not knowingly collect any Personal Data from children under the age of 13. We recommend that no one under the age of 18 submit Personal Data to our Site. In the event that we determine that a user of this Site is under the age of 13, we will not maintain or use his or her Personal Data and will delete same.   

Information Collected on the Website
Certain of the information provided by IRT on the Website is available without IRT collecting any Personal Data from you. In using and viewing the Website, you understand that IRT may use your Personal Data subject to the terms of this Privacy Policy. IRT collects the following information about users of the Website:

  • Information by which you may be personally identified, such as, without limitation, name, postal address, e-mail address, telephone number, birthdate, employment information, or social security number (“Personal Data”);
  • information concerning page “hits,” delivered anonymously, including page views, location, browsing device, and screen resolution and/or
  • information as set forth below in the “Cookies Google® Analytics and other Technologies” Section of this Privacy Policy.
We collect Personal Data when you:
  • Request information about IRT through the Website;
  • Schedule a tour of an apartment complex or community;
  • Create or log-in to your User Account;
  • Send IRT an email message;
  • Fill out certain forms available on the Website including, without limitation, the Contact Us form;
  • Submit a review of an apartment complex or community; or
  • Otherwise provide IRT with Personal Data.
We also collect and obtain from RentCAFÉ certain Personal Data that you provide to RentCAFÉ via the Community Websites, such as Personal Data you provide to RentCAFÉ when you complete or submit an application via a Community Website. 
We also collect certain information automatically when you use or access the Site as set forth below under the header “Cookies, Google® Analytics, and other Technologies” Section.

Please note that the Website includes links to certain Residential Services that allows users to pay their rent.  In connection with such services, you may be asked to provide certain Personal Data and credit card or other financial information.  IRT is not responsible for the collection or storage of this information.  Rather, IRT uses a third party payment service provider, namely, RentCAFÉ or its service provider, to process any of the payments that you make via the Website.  Accordingly, the collection, handling, storage, and security of this information is the responsibility of RentCAFÉ or its service provider, and is subject to such entity’s own Terms of Use and Privacy Policy, available at http://www.irtliving.com/page.aspx/contentId/22/Terms-of-Use/.  RentCAFÉ or its service provider may provide us with Personal Data and we will use such information only as set forth herein.

Likewise, the Website or the Community Websites contain the following features maintained or operated by third parties: (1) the ability to generate leases, which is a service provided by Blue Moon Software; and (2) the ability to submit a request for a background check if you are a resident, which is a service provided by First Advantage.  In connection with such services, you may be asked to provide certain Personal Data and credit card or other financial information.  IRT is not responsible for the collection or storage of this information.  These service providers may provide us with Personal Data and we will use such information only as set forth herein.

You have a choice as to whether to provide IRT with any Personal Data. Although you are not required to disclose any Personal Data to us, some portions of the Website may not be available to you without your providing this information.

Use and Disclosure of Your Information
IRT uses any Personal Data and any other information that you provide in a limited number of ways. We may use your Personal Data or other information:
  • To respond to your emails sent to IRT;
  • To make the site easier for you to use by not making you enter certain of your Personal Data more than once and otherwise presenting the Website to you;
  • To provide you with information about IRT and its products and services;
  • To conduct a transaction that you have requested;
  • To verify your identity and grant access to your account;
  • To alert you to updated information and other news and information from IRT;
  • To carry out our obligations and enforce our rights arising from any agreements between us and you (including, without limitation, the Terms);
  • To notify you about changes to the Website;
  • To assist in scheduling tours of apartment communities when you provide such information to schedule a tour;
  • To advertise our services or apartment complexes when you submit a review to us;
  • To assist in the lease application process when you submit an application for rental;
  • To provide you with deals concerning third party goods or services that are made available to certain residents of our various communities;
  • As set forth elsewhere in this Privacy Policy;
  • To fulfill any other purpose for which you provide information; and
  • For any other purpose IRT deems appropriate with your consent or as described when you provide the information.
In addition, IRT may hire other companies to perform services on our behalf such as operating certain aspects of the Site or sending you email.  As noted above, this includes RentCAFÉ, S&P, BlueMoon and First Advantage.  These other companies may be supplied with or have access to your Personal Data or other information for the sole purpose of providing these services to us or on our behalf or as otherwise set forth in such third parties’ respective privacy policies.  IRT may also use third-party ad servers or ad networks to deliver ads to you on IRT’s behalf.  These third-party ad servers may be supplied with or have access to your Personal Data or other information for the sole purpose of providing these services to us or on our behalf.  They also may collect and use non-Personal Data about your visits to the Site in order to send advertisements that may be of interest to you.
We may also on occasion combine information about you that we have with information we obtain from other parties to enhance our ability to market to you those products or services that may be of interest to you.
We may need to disclose Personal Data or other information collected from you when required by law or if we have a good-faith belief that the action is necessary to comply with a pending judicial proceeding, a court order or legal process served on IRT or to protect our rights or the rights of others, to fight fraud, identity theft, to ensure the integrity and operation of our business and systems, or to protect the rights, property or safety of IRT, its employees, members or others.
We may also disclose your information (including your Personal Data) to a buyer or other successor in the event of a merger, divestiture, restructuring, change of control, reorganization or other sale or transfer of all or some of IRT’s assets, whether as a going concern or as a part of bankruptcy or liquidation or similar proceeding, in which such information is among the assets transferred. 

Control of your Personal Data; Choices concerning Personal Data
When you give us Personal Data or other information, IRT will not share that information with third parties without your permission, other than for the limited exceptions provided herein.  Such Personal Data or other information will only be used for the purposes set forth herein.  IRT may send periodic emails informing you of changes and updates regarding the Website.  If you would like to opt-out of our sharing of Personal Data with non-agent third parties, please provide us with an email at privacy@irtliving.com and we will accommodate the request.

How We Share Your Information
We will not disclose your Personal Data or other information to others without your permission, except as explained in this Privacy Policy.

Aggregate Information
On an aggregate basis only, we collect comprehensive demographic, business information and data, and other non-identifying information about users of the Website.  IRT will never disclose any Personal Data as part of this aggregate information but we may lend, sell, share or otherwise disclose aggregate information with others so we can perform research and provide the results to third parties, enhance and market the Website, and conduct accounting and process record keeping functions.

Other websites and links
We may include links to other websites that we think will be of interest to you or operated by our business partners, affiliates, advertisers, and others. These third parties have separate data collection and privacy practices independent from ours, and IRT cannot be responsible for their policies or activities. Please contact those third parties directly if you have questions about their privacy policies.

Cookies, Google® Analytics and other Technologies
IRT may also use a feature of your browser called a “cookie.” Your cookie automatically identifies your computer - but not you - to our servers when you visit the Website and allows us to correlate your computer with certain usage patterns which are stored in our log files. We use cookies to gather general, aggregate statistics about the overall popularity and usage of the Website.  IRT also uses more temporary cookies, often referred to as session cookies, to keep a user logged into the system and aid in the exchange of information between pages without loss of data.  Such a cookie, however, is only stored for the current browsing session and is deleted once the browser is closed. IRT can also only read cookies from the Website. Search for Cookies under your Web browser's Help menu for more information on cookie management features available to you. If your browser is set to reject all cookies, the Website may not function properly.
IRT uses Google® Analytics, which uses cookies Google places in users’ browsers to collect data regarding search behavior such as affinity categories (e.g., pet lovers), in-market segments (e.g., real estate), age, and gender.  IRT is using the Google Global Site Tag to track certain user activity in Google® Analytics.  IRT also collects user search behavior data in the form of audience lists in Google Adwords to re-serve ads to users that have expressed an interested by viewing specific content of IRT’s, but who have not completed a predetermined action, such as completing a form.  IRT also uses Google® Analytics for remarketing, which enables data collection for display and search remarketing, including data from Google’s signed-in users who have chosen to enable Google to associate web and application browsing history with their Google account, and allows the use of such information for personalized ads.  With respect to remarketing, IRT uses the Google® Adwords Remarketing Tag, which relies on cookie activity to both serve and block the serving of ads to users in the United States who have either converted or not converted, determined by the following four conversion ‘Goals’ IRT has implemented in Google® Analytics:
  1. Submitted a Contact Form – The user has arrived at an IRT property website page containing the following: ‘/contactsuccess.aspx’; for example, such as when a user completes and submits the Contact Us form.
  2. Register - The user has arrived at an IRT property website page containing the following: ‘/register.aspx’; for example, such as when a user has navigated to the “Create an Account” page.
  3. Check Availability - The user has arrived at an IRT property website page containing the following: ‘/availableunits.aspx’; for example, such as when a user has navigated to the “Check Available Units” page where current Rent Prices are displayed.
  4. Start an Application - The user has arrived at an IRT property website page containing the following: ‘/oleapplication.aspx’; for example, such as when a user has submitted their information to create an IRT account and has navigated to the application form page.

IRT uses Google® Analytics to track session duration, geographic region origination and the behavioral activity of users in the United States. 

Currently, IRT’s advertisements are placed only on Google.com using keyword and geographic targeting.  Google uses cookie activity to determine the website pages a user has or has not visited.

IRT does not collect behavioral data such as age, gender, and interests from any users outside of the United States and any data concerning users from outside of the United States is not being mapped to any behavioral activity.  Moreover, IRT’s remarketing activity is not collecting or using any user data from outside of the United States.

Please note that users can opt out of the Google® Analytics Advertising features that IRT uses by consistently clearing their browser cookies or by selecting the “Do Not Track” option in the “Advanced” section of their browser setting.  To opt-out of Google® Analytics, please visit the following website and follow the pertinent information for your web browser:  https://tools.google.com/dlpage/gaoptout/.

Further, you can opt-out of Google’s use of cookies by visiting Google's Ad Settings at http://www.google.com/settings/ads.  Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page at http://optout.networkadvertising.org/?c=1#!/.  In addition, you can opt-out of DoubleClick’s use of cookies by visiting the DoubleClick opt-out page at https://adssettings.google.com/anonymous?sig=ACi0TChU9N5D8okhguljAXhxtZgcdjMReJbE5Tw9HLQWAsAUWRUHhV1_zlF0F7ckOVkO7nGIG_FMQdFDl7m7fVxQdQwN3HEfFg&hl=en#display_optout; or the Network Advertising Initiative opt-out page at http://optout.networkadvertising.org/?c=1#!/.

Responding to DO NOT TRACK Signals
Please note that IRT does not currently respond to DO NOT TRACK requests sent from a user’s web browser, such as Internet Explorer, Chrome, and Safari.

Accessing and Updating Information
IRT does not currently have an online method for users to delete their Personal Data contained in our database. However, you may change or update the Personal Data we have collected, request that we delete it, or request that we change how we use it by sending an email to privacy@irtliving.com with your instructions. Please note that this deletion may otherwise impact prior transactions performed on the Website.  We will not accommodate a change or deletion if we believe doing so will violate any law or legal requirement or cause the information to be incorrect.

Changes to this Privacy Policy
We encourage you to review our Privacy Policy not just the first time you visit the Website but periodically afterwards since we may modify our Privacy Policy from time to time. The date of the last update of the Privacy Policy will always be posted below:

THIS PRIVACY POLICY WAS LAST REVISED ON  August 1, 2018.
If we make any substantive changes to our Privacy Policy in the future with regard to how we use your Personal Data, we will incorporate those changes here and will notify you via posting notice of the revised Privacy Policy on the Website.  Changes will apply prospectively only.  Your continued use of the Website after the changes are posted constitutes your agreement to the changes, both with regard to information we have previously collected from you and with regard to information we collect from you in the future. If you do not agree to the changes, please discontinue use of the Website. Lastly, if IRT is sold or merged with another company, your Personal Data and other collected information will be included as part of the sale as noted above but unless you’re notified that the Privacy Policy is changed, your Personal Data and other collected information will be maintained in the same manner.

International Users
While our Website is meant for use in the United States by United States residents, like almost every website, our Website is accessible around the world.  By visiting the Website and providing your information, you acknowledge and agree that your Personal Data can be stored for the purposes identified in this Privacy Policy. We process and store your information in North America and your information may be stored on servers located outside your residential jurisdiction and which may have less stringent privacy practices than your own. If you access the Website from outside the United States, your usage of the Website constitutes consent to the transfer of your data outside of your country and to North America.  In no event should the Website be used by individuals in the EU or UK, and we do not intend to offer any Services to individuals in these jurisdictions.  If you are a resident of these jurisdictions, do not use the Website.

Security
This Website has industry-standard security measures in place to protect the loss, misuse, and alteration of the information under our control, and we make good faith efforts to store your Personal Data in a secure operating environment. Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.  

Contacting IRT
Please feel free to share any comments and concerns with us. If you have any questions about this Privacy Policy or the practices of the Website, please send us an email at privacy@irtliving.com.

YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers of IRT who are California residents to request certain information regarding IRT’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to: privacy@irtliving.com or write us:
 
IRT Living
Attention: General Counsel
Two Liberty Place
Suite 3575
50 S. 16th Street
Philadelphia, PA 19102