Carillon Properties Online Privacy Notice
Carillon Properties Online Privacy Notice
Effective Date: February 9, 2021
Carillon Properties (“Carillon Properties,” “Carillon Point,” “CP,” “we” or “us”) is a property management organization that values privacy and is committed to implementing appropriate safeguards necessary to protect sensitive information and adhere to compliance obligations regarding the protection of personal information.
This Privacy Statement is required by law and informs the reader about the handling of Personal Information in connection with the services and web sites offered by Carillon Properties (CP) accessible by the Uniform Resource Locator (URL) www.carillon-point.com (the “Site”). Additional URLs covered by this privacy notice include: carilloncams.com, and carillonprop.com. This Privacy Statement will disclose what data is collected, how it is used, with whom it is shared and how it is processed and secured. Protecting the privacy of Personal Information is very important to us. Please read this notice carefully to understand how the Personal Information collected via electronic means is handled by Carillon Properties.
By accessing or using our website, you agree and consent to this Privacy Notice. This notice may change from time to time. Any changes or updates to the Privacy Notice are effective immediately upon posting to the website and your continued use of the website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. If you do not agree with our policies and practices, you may choose not to use our website.
If you wish to browse the website without providing Personal Information you may generally do so anonymously. There is no need to provide any Personal Information while browsing our website and functionality is unlikely to be affected by browser configuration settings disabling cookies. If you choose to contact us requesting assistance with services or general questions, we ask for your Personal Information on our Contact Us form. This information helps us process your inquiry and provide the best service possible.
Questions regarding this Privacy Notice may be directed to our Data Protection Office using the information below.
4100 Carillon Point
Kirkland, WA 98033
What, When and Why
When you engage with CP by requesting services, any Personal Information you provide is voluntary. We collect and use only the minimum information necessary to assist our customers with property services and respond to concerns. In most cases, the information you provide is limited to personal contact information, such as name, company name, address, telephone number, or email address.
We collect personal data in accordance with law in order to provide property services. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual and includes the following examples:
- Email address
- Postal address
- Telephone number
- Employer information
- Personal or commercial property and/or vehicle or marine vessel information
- Credit and debit card number or other payment data
- Travel itinerary, tour group, or activity data
In more limited circumstances, we may also collect:
- Data about family members and companions, such as names and ages of children
- Financial information
- Insurance information
- Images and video and audio data via: (a) security cameras located in public areas, such as parking lots and lobbies, in our properties; and (b) body-worn cameras carried by law enforcement officers and other security personnel
Other data, such as is common in the navigation of websites, is information that does not directly identify you as an individual but rather your browser type, IP address, the URL of the previous web site you visited, the type of operating system used, the time of day, etc. The server for the website www.carillon-point.com may automatically collect these types of non-personal information from your browser when visiting this site.
Cookies are text files containing small amounts of information that may be downloaded and stored in your browser’s memory when you visit the Site. Cookies are useful because they help arrange the content and layout displayed appropriate for your device and choice of browser and allow our web server to recognize those computers or devices that have visited our site before. Cookies perform various tasks, such as allowing our website to remember your preference settings and helping us to enhance the usability and performance of our sites and your experience using them.
This site uses session cookies to store information that you provide and to store technical information useful for your interactions with our site. For instance, they may remember your user ID and elements of your user profile upon login. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.
Google Analytics is a web analysis service supplied by Google, Inc. (“Google”), which utilizes “cookies” by means of which it collects non-identifying Personal Data on the visitor, which is forwarded to, and deposited on, Google servers in the United States. Google utilizes this information in order to track and examine your use of the website and to prepare reports on the activities of the website for the website operators. A visitor’s desire to avoid utilizing cookies, by selecting the appropriate configuration setting within your browser, will not have an affect on the functionality or user experience of this website.
Third Party Links
We have chosen to partner with additional responsible third parties to assist in providing our services. These third parties include Clearent (www.clearent.com) to process marine tenant payments and other purchase transactions and MailChimp (www.mailchimp.com) to assist with email communications. Their business policies may include different privacy statements and practices than those in use at Carillon Point. Please be aware that when you choose to utilize the services or web functionality provided by these third parties our privacy policies no longer apply to the data collection or functionality provided by their site and that we are not responsible for the privacy practices of these other sites. We encourage you to review the policies of each site you use.
Any personal information provided to us is stored within a secured computing environment accessible to a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We employ reasonable information security safeguards intended to protect Personal Information from unauthorized disclosure or alteration. It is not possible, however, to warrant or guarantee that any computing environment is impervious to compromise by malicious parties endeavoring to acquire sensitive information illicitly. Therefore, you acknowledge an element of inherent risk in providing your Personal Information. While we will utilize reasonable safeguards and industry best practices to protect your Personal Information, it is not possible to foresee every possible contingency or threat to the security of data.
California Online Privacy Protection Act
The California Online Privacy Protection Act (CalOPPA) is the first state law in the nation to require commercial websites and online services to post a Privacy Notice. The law applies to businesses beyond California and requires a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy notice on the websites they operate disclosing the information being collected and any third parties with whom it is being shared.
In accordance with CalOPPA, CP agrees to the following:
- Users can visit our site anonymously
- We will provide a link to this Privacy Notice on our home page
- Our Privacy Notice link includes the word ‘Privacy’ and can be easily identified on the page specified above
- Users are able to amend and correct their Personal Information by contacting us
How does www.carillon-point.com handle Do Not Track (DNT) signals in browsers?
- We honor Do Not Track (DNT) signals and our servers do not track, set persistent cookies or use behavioral tracking advertising when a Do Not Track (DNT) browser mechanism is in place.
Does www.carillon-point.com accommodate third party behavioral tracking?
- Beyond the performance monitoring involved with the non-personally identifiable information mentioned above, we do not support third party behavioral tracking.
Children’s Online Privacy Protection Act
When it comes to the collection of Personal Information from children under 13, the Children’s Online Privacy Protection Act (COPPA) provides parents the right to control the data identifying their child(ren). The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
The Site, www.carillon-point.com, does not specifically market to children under 16 years of age nor do we knowingly collect this type of information. If we learn we have collected or received personal information from a person under 16 years old without verification of parental consent, we will delete that information.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out penalties for violations.
CP may collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Perform services and to send information and updates pertaining to services
- Send additional information related to the services requested by you
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be in compliance with the CAN-SPAM Act we agree to the following:
- We will not use false, or misleading subjects or email addresses
- Identify marketing messages as an advertisement in some reasonable way
- Include the physical address of our business or site headquarters
- Monitor third party email marketing services for compliance, if one is used
- Honor opt-out/unsubscribe requests quickly
- Allow users to unsubscribe by using the link contained within each marketing email
If at any time you would like to unsubscribe from receiving future emails, you can do so by using the link provided within those emails for the purpose of unsubscribing or by sending an email requesting subscription changes to us at firstname.lastname@example.org
Fair Information Practices Principles
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is valuable in complying with the various privacy laws that protect Personal Information.
In order to be in compliance with Fair Information Practices, CP will take the following responsive action, in the unlikely event a data breach occurs:
- We will notify those affected via email within 7 business days of discovery of the event.
- We will notify website visitors via in-site notification within 7 business days of discovery of the event.
Purchase or Sale of Business
In the unlikely event that we are required by law to disclose the information that you have submitted we will comply with requests made by authorized law enforcement. Unless we are legally prohibited from doing so, we will attempt to provide you with notice that a request for your information has been made in an effort to give you an opportunity to object to the disclosure. If you do not challenge the disclosure request, we may be legally required to submit your information to law enforcement officials.
Visitors Outside the United States
Carillon Properties and the servers hosting the www.carillon-point.com website are located in the United States and are subject to the applicable state and federal laws of the United States. If you use the www.carillon-point.com website, you consent to the use and disclosure of information in accordance with this Privacy Notice and subject to such laws.