Effective as of March 22, 2024‍

Privacy Statement

Inhabit IQ and its family of software brands take pride in conducting business responsibly and ethically. We place the highest regard on the data privacy and security of our customers and on our legal obligations to protect such personal data.

Tenant Verification Service, Inc. (“TVS,” “we,”“us”or “our”), as Inhabit IQ brands, developed a data privacy program that respects and protects the privacy rights of individuals whose personal information we process. We recognize that data privacy coincides with data protection, thus, we implement reasonable and appropriate data security and protection measures to preserve the confidentiality, integrity, and availability of the personal information we process.

Contents

  1. Who are we?
  2. What is the scope of this Privacy Notice?
  3. What do we collect?
  4. How we use the personal information we collect
  5. How we share and disclose your personal information
  6. How long we retain personal information
  7. How do we secure your personal information

  8. Your Choices and Rights

    1. Your Choices

    2. Your Rights

      1. Canadian Privacy Rights
      2. California Privacy Rights
      3. Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, Virginia
      4. GDPR Privacy Rights

    3. Exercising Your Rights

      1. How to Exercise Your Rights
      2. Use of an Authorized Agent
      3. Minors
      4. TVS as a Service Provider
  9. Changes to this Privacy Notice
  10. Contact us
  11. Your California Privacy Choices

  1. Who are we?

    Tenant Verification Service, Inc. (“TVS,” “we,”“us”or “our”) are a property management software provider operating under Inhabit IQ, a global PropTech software company serving the residential and vacation property management industries offering software-as-a-service (SaaS) solutions for core areas like accounting and operations, customer relations management, marketing, background screening, rent payment processing, and insurance.

    We are a consumer reporting agency providing a complete end-to-end screening solution that property management companies or individual landlords need to conduct tenant screening, criminal background checks, sex offender search, eviction record check and tenant credit check, among others, through predictive screening model, configurable criminal grid settings, subprime data, and identity verification tools. When we use the term “Service(s)” we mean collectively:

    1. The information and services provided through websites owned and controlled by us, including the website at https://tenantverification.com/, https://tenantverification.ca/ and any related external facing web pages, applications or platforms (the “Site(s)”);
    2. The provision of online tools for real estate and property management and related services to those who purchase such tools and services; and
    3. Our marketing and business development activities, including any social media properties we create, and emails that we send (“Marketing”).

    We offer these Services to property management companies, landlords or property owners  (“Client”). The Services are intended for a general audience and are not targeted to children under the age of 13.

    We are a “Data Controller” under Data Privacy Laws when we process personal information relating to our Clients, potential Clients, business partners, our suppliers or service providers.

  2. What is the scope of this Privacy Notice?

    We strive to be transparent and keep you informed on how we process your personal information through this notice. This notice sets out how we collect, use, store, share, dispose, and protect your personal information as a Data Controller and a Data Processor.

    This Privacy Notice covers the disclosures that are required by “Data Privacy Laws” governing our processing of personal and sensitive personal information, which include, but are not limited to the following:

    Law Scope Effectivity
    GDPR
    General Data Protection Regulation    		 Imposes obligations onto organizations anywhere, so long as they target or collect data related to people in the EU. May 25, 2018
    PIPEDA
    Personal Information Protection and Electronic Documents Act    		 Applies to private sector organizations engaged in commercial activity or operating in Canada. January 1, 2001
    CCPA
    The California Consumer Privacy Act    		 California state law that addresses the privacy rights of California consumers. It was updated, amended and expanded by California Privacy Rights Act (CPRA). CCPA: January 1, 2020
    CPRA: January 1, 2023
    CPA
    Colorado Privacy Act of 2021    		 Applies to legal entities conducting business in Colorado or delivering products or services targeted to Colorado residents. July 1, 2023
    CTDPA
    Connecticut Data Privacy Act of 2022    		 The act applies to those who conduct business in the state or who produce products or services targeted to Connecticut residents. July 1, 2023
    FDBR
    Florida Digital Bill of Rights    		 Applies to for-profit entities that conduct business in Florida and collect personal data about Florida consumers. July 1, 2024
    MCDPA
    Montana Consumer Data Privacy Act    		 Companies that conduct business in Montana or persons that produce products or services targeted to residents of Montana. October 1, 2024
    OCPA
    Oregon Consumer Privacy Act    		 Applies to any person that conducts business in Oregon or provides products/services to Oregon residents. July 1, 2024
    TDPSA
    Texas Data Privacy and Security Act    		 Applies to for-profit businesses or persons that do business in Texas or produce a product or service consumed by a Texas resident. July 1, 2024
    UCDPA
    Utah Consumer Privacy Act of 2022    		 The Act regulates companies that conduct business in Utah or produce a product or service that is targeted to consumers in Utah. December 31, 2023
    VCPDA
    The Virginia Consumer Data Protection Act of 2021    		 Provides Virginia consumers with specific rights regarding their personal information. January 1, 2023

    This notice applies as we process personal information as a Data Controller relating to:

    • visitors to one of TVS’s Site(s);
    • our Clients including their representatives, officers, employees, partners, independent contractors, agents and other authorized users; and
    • our prospective Clients, including their representatives, officers, employees

    If you are an individual resident of a property managed or owned by a Client who has been invited to use the client-facing features of the Services in a limited capacity (“Resident”), we process your personal information as a Data Processor for our Clients and the processing of your personal information will be governed by your relationship with them. Please note that our Clients have their own privacy notices, and this notice does not apply to their collection, use, storage, destruction, disclosure, and/or processing of any personal information they handle.

    This Privacy Notice does not cover the practices of companies we do not own or control or people we do not manage and this Privacy Notice does not apply to any third-party sites that may link to or be accessible from our Sites.

    We use some phrases in this Privacy Notice that are unique to our business or our Services:

    • “Personal Information or Personal Data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include certain de-identified or aggregated information, information publicly available in government records, or certain other information excluded from the scope of various Data Protection Laws.

    • "Sensitive Personal Information” is a type of personal information depending on what is considered as sensitive personal information as provided under the applicable Data Privacy Laws, sensitive personal information is that which reveals the following:

      • Personal identification numbers, including social security, social insurance, driver's license, passport, or state ID card numbers, or provincial ID card numbers
      • Account or debit or credit card numbers combined with passwords or codes that would enable access to the accounts
      • A consumer's precise geolocation
      • A consumer's racial or ethnic origin, religious beliefs, or union membership, individual’s medical history,  mental or physical health condition or medical treatment or diagnosis, sex life or sexual orientation, or citizenship or citizenship or immigration status
      • A consumer's mail, email, or text message content unless the information was intentionally sent to the business
      • A consumer's genetic data, biometric data that may be processed for the purpose of uniquely identifying an individual
      • Personal data from a known child under 13 years old (for those consumers in CO, CT, VA).
      • This also includes Special Categories of Data as defined under the GDPR: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
    • “Processing” means any operations performed on personal information, including: collecting, storing, retrieving, consulting, analyzing, disclosing or sharing with someone else, erasing, or destroying personal data.
    • “Client” refers to the property management companies, property owners, managers or individuals who we contract with and provide our Service for.
    • “User” refers to individuals who are given access to the platforms we offer our Clients. They may be Primary Users: client representative, staff, employee or personnel of our Clients or Secondary Users: the applicants, employee, tenants or residents (“Consumer”) of our Clients.

  3. What do we collect?

    We collect the following Personal Information from the following categories of individuals and sources.

    1. Data from our Clients, Primary Users, Potential Clients and Site Visitors

      1. 1. Directly from you when you interact with our customer support by email, regular mail or telephone; or when you use any of our application or solutions as an Authorized User/Subscriber or End User

        • ● Name, phone number, fax number, email address, or unique personal identifiers (wireless device ID, cookies, IP address), current and previous residential address, rental property address, date of birth, Social Security Number, Social Insurance Number (“Identifiers”).

        • Occupation, position or designation (“Demographic Data”)

        • ● Company name, company address, company phone number, business type, tax ID number, business number, commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
        • Usernames, passwords, log-in credentials (“Log-in Data”);

      2. Directly from you as a visitor to one of our Site:

        When you visit our Site, you may choose to provide information to us, such as when you contact us to request or provide information through our “Sign Up” page, “Contact Us” page and “Login” or newsletter registration in any of our Sites.

        In addition, when you interact with our Site, we use technology and Google tools (such as Google Analytics, Google AdSense, Google Display Network Impression Reporting) to gather information on how visitors are using the Site and Services.

        We collect IP address information so that we can properly manage our system and gather information about how our site is being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Information. We collect details of visits to our Site, including the volume of traffic received, logs and the resources that you have accessed. We may also collect certain location information such as your mobile device's GPS signal, or information about nearby WiFi access points and cell towers.

        We may collect the following categories of information from our Site:

        • Name, address, date of birth, social security number, social insurance number, company name, phone number, email address, company address, company phone number, years in business, number of rental properties, rental property type, business type, phone bill, property insurance or tax statement, business documents, real estate license, property management agreement, lease application or agreement, unique personal identifiers (cookies, IP address), (“Identifiers”).
        • Internet or other network or device activity (such as type of device, internet connection, browser type and version, time zone, operating system and platform, referring/exit pages, account access date/time stamp, UTMs (Urchin tracking modules) for lead source) (“Internet Data”).

      3. From our Clients as needed for us to perform our Services for them.

        • Name, address, date of birth, social security number, social insurance number, phone number, email address, company name, company phone number, business type, company address, company phone number, Rental property information and any other information required to provide service (“Identifiers”).

    2. Data from Consumers

      1. Directly from you as a Consumer of our Clients who has been invited to use the customer-facing features of the Services in a limited capacity:

        • Name, phone number, email address, postal address, state identification card numbers, social security number, driver’s license number or unique personal identifiers, passport number, insurance policy number, bank account number (wireless device ID, cookies, IP address), (“Identifiers”).

        • Birthdate (“Demographic Data”).

        • Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”).
        • Usernames, passwords, log-in credentials (“Log-in Data”);
        • Internet or other network or device activity (such as browser type and language, operating system or app usage) (“Internet Data”);

      2. 2. From our Clients as needed for us to perform our Services.

        • Name, phone number, social security number, social insurance number, email address, postal address, state or province identification card numbers, driver’s license number or unique personal identifiers, passport number, insurance policy number, bank account number (wireless device ID, cookies, IP address), (“Identifiers”).
        • Employment details, educational data, citizenship, homeownership, marital status, military or veteran status, monthly income and size, gender and birthdate (“Demographic Data”).

  4. How we use the personal information we collect

    We only collect the information reasonably necessary to provide our Services, to carry out our operations which may involve automatic processing using machine learning and artificial intelligence applications, as required by law, and for the other legitimate business purposes, under applicable laws.

    Some of these uses may,under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to our Clients, or are necessary to serve our legitimate interests as provided below:

    1. For provision of our Services:

      • To facilitate the use of the software application, to maintain and administer our Clients account which includes sending transaction records, notice and other documents necessary for the continued use of the application and for other purposes that would be necessary or beneficial to administer our Client’s use of the same (“Servicing").
      • To continuously provide you or our Clients with our services through your use of the platform and access of its database (“Servicing").
      • To respond to your queries, comments, feedback, or requests and address your complaints and provide customer support (“Servicing").
      • To verify or ascertain your identity, uniquely identify you or your business and identify potentially fraudulent activity (“Fraud Prevention").
      • To carry out our obligations arising from of our contracts with our Clients (“Servicing").
      • To conduct research and gain an understanding of the users of our platform, their experiences and preferences to further improve the platform (“Quality Improvement").
      • To assist in business development, compile statistics regarding how the site or our Service is used in order to improve our them, for example, we may use your personal data to improve the layout of our Site based on the click path you utilized to access certain information within the Site (“Quality Improvement").
      • To run system diagnostics to ensure that platform is functioning properly and to improve the user experience (“Quality Improvement").
      • To detect or prevent security incidents or other illegal activity, debug, verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us (“Security").

    2. For marketing and advertising activities (“Marketing"):

      • To communicate with our Clients and Potential Clients regarding services, activities, programs, trainings, promotions, services, products or other offers in which they have indicated an interest or to which they’ve subscribed and to contact them with information that may be of interest to them.

      • To provide our Clients and Potential Clients newsletters, articles, alerts and announcements and other information we think they may find useful or which they have requested from us.

      • To personalize our Clients and Potential Clients’ experience and allow us to deliver individualized content and product offerings according to their specific interests.

      • To provide our Clients and Potential Clients with the marketing materials of third parties which we think may interest you.

      Please note that we do not conduct marketing activities to Residents or use any of the Residents personal data for marketing purposes.

    3. For compliance with our legal obligations, regulatory requirements and for other legal purposes (“Legal"):

      • To process any complaints, implement preventive measures and to investigate act, omission, or misconduct that would constitute a violation of our contracts and of the applicable laws.

      • To verify your identity or conduct internal audits or reviews.

      • To enforce our Terms and Conditions, Master Subscription Agreement, and other agreements.

      • To gather the necessary information required by law, record keeping and good business practices.

      • To comply with our legal obligations and other regulatory requirements.

      • To protect our lawful rights and interests in court proceedings and to establish, exercise or as defense from legal claims.

    We do not monitor or profile visitors to our Site or collect, in any automated manner, any special categories or sensitive Personal information about you. No automated decision-making, including profiling, is used when processing your Personal Information

    What Information Do Our Websites Collect for Interest-Based Advertising?

    We and our third-party advertising partners may use cookies or web beacons to collect information for the purposes of interest-based advertising based on your visits to our Site. These cookies identify the pages you view, the links and ads you click on, other actions you take on those websites, and the referring website. Similarly, online advertisers use cookies to deliver advertising to you for companies other than us based on your visits to our Site and other websites.

  5. How we share and disclose your personal information

    The below chart summarizes the categories of personal and sensitive personal information we collect, from where we collect it, how we use it, and with whom we share it.

    This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review in compliance with the CCPA.

    We generally do not directly sell your Personal Information in the conventional sense (for money). Like many companies, however, we do disclose Personal Information for internal business purposes or operational purposes of our business (servicing, quality improvement, fraud detection, security, legal), and we use services that help deliver interest-based ads to you or analyze our website traffic and may transfer Personal Information to business partners for their use. Making personal information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under certain Data Privacy Laws. If you would like to opt out of sales of your personal information that take place via cookies, immediately notify us in accordance with the “Your Choices and Rights” section below.

    1. Data from our Clients, Users, Site Visitors

      CATEGORIES OF DATA COLLECTED EXAMPLE DATA ELEMENTS SOURCES WE COLLECT FROM PURPOSES BEHIND COLLECTION, USE, AND SHARING CATEGORIES OF THIRD PARTIES WE DISCLOSE TO
      Identifiers Name, phone number, email address, date of birth, SSN, SIN, driver’s license, passport, professional license information, state or provincial ID card information, rental property information, phone bill, utility bill, property tax or insurance policy, rental application, business documents, real estate license (wireless device ID, cookies, IP address), From our Clients Servicing, Marketing, Legal Our Service Providers
      Demographic Data Employment history, marital status, occupation
      Identifier Name, phone number, email address From Consumers Quality Improvement, Fraud Prevention, Legal Corporate Subsidiaries and Affiliates

      We share Personal Information with the following categories of recipients for the following business purposes:

      1. Third-party Service Providers: Your Personal Information will only be shared with and processed by our affiliates and non-affiliated third-party service providers as permitted by law and for the purposes described in this Privacy Notice. We may disclose Personal Information to certain non-affiliated specialized service providers, including professional advisors, consultants, technical service providers, and other third parties, who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. We may disclose your Personal Information to third-party service providers to provide us with services such as Site hosting, including information technology and telephony services, and related infrastructure, customer service, e-mail delivery, auditing, and other similar services.
      2. Corporate Subsidiaries and Affiliates: We share the collected personal information as described in this notice with our subsidiaries and affiliated businesses within the Inhabit IQ, each of which use your personal information consistent with this Privacy Notice. Those businesses may also use your personal information for each of their own purposes, including marketing purposes. Please visit their Privacy Notice on their website to learn more.
      3. Business Transfers: When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy
      4. With Your Consent or at Your Direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction

      2. When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.

  6. How long we retain personal information

  7. How do we secure your personal information

    We use reasonable organizational, technical and physical measures to maintain the privacy and security of your Personal Information within our organization against any unauthorized access, use, disclosure, loss or alteration, or theft of personal information. We maintain policies and practices to ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

    • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
    • Technical safeguards such as encryption, firewalls, antivirus software and similar measures to protect information stored in electronic format;
    • A designated Privacy Officer to monitor our compliance with applicable privacy laws;
    • Employee privacy and data security training; and
    • Procedures for receiving, investigating and responding to security incidents involving personal information.

    Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

  8. Your Choices and Rights

    We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.

    1. Your Choices

    2. Your Rights

      Subject to applicable Data Privacy Law, you may have certain rights to know, access, update, port your personal data, correct inaccuracies, delete, restrict processing of your personal information in our custody and control.

      For security purposes, we will verify your identity when you request to exercise your data privacy rights. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate.

      Your right over your personal information depends on the Data Privacy Law applicable where you reside:

      1. Canadian Privacy Rights

        For additional information for residents of Canada click here.

      2. California Privacy Rights

        For additional information for residents of the State of California click here.

      3. Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, Virginia

        For additional information for residents of any of these states click here.

      4. GDPR Privacy Rights

    3. Exercising Your Rights

      This provides for instructions on how you can exercise your rights under applicable Data Privacy Laws.

      1. How to Exercise Your Rights

        To submit a request to access, rectify, delete, port your personal data you can submit a request to us either:

        Note in the body of the email the specific right you want to exercise. In the subject line, include “<Your State/Country> Consumer Request".

        To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request. Your request must include details sufficient for us to properly understand, evaluate, and respond to the request.

        Please also note that as part of the verification process, we're required to consider:

        1. the potential adverse effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another) because such improper disclosure would likely adversely affect the privacy rights and freedoms of the relevant data subject/consumer, we limit certain personal data we make available.

      2. Use of an Authorized Agent

      3. Minors

        We do not knowingly collect personal information of minors (minority age depends on the applicable Privacy Laws) under the age of 13, nor are our Sites or Services developed for, offered to, or directed at children under the age of 13. If you believe that we have collected information of a child under the age of 13, please contact us and we will take appropriate action.

  9. Changes to this Privacy Notice

    Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on our Site or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

  10. If you have any questions, or complaints, regarding the collection or use of your personal information or the content of this notice, please contact our Privacy Officer at the coordinates below.

    Privacy Officer
    Inhabit IQ
    2035 Lakeside Centre Way, Suite 250
    Knoxville, TN 37922
    [email protected]

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