At The Management Trust, protecting your privacy is important to us. If you are a California resident, you may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) as described in the Privacy Notice for California Residents subsection.
Privacy Policy
Revision Date: 06/2024
| Facts | WHAT DOES THE MANAGEMENT TRUST DO WITH YOUR PERSONAL INFORMATION? |
|---|---|
| Why? | The Management Trust will choose how to share your personal information on behalf of homeowner associations, homeowners, or other similar entities. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on your relationship with the entity managed, such as your homeowner association, property owner, metropolitan district, etc. This information can include:
When you are no longer affiliated with the managed entity, we continue to share your information as described in this notice. |
| How? | All associations, and, by extension, their contracted management companies, need to share residents’ personal information to run their everyday business. In the section below, we list the reasons associations can share their residents’ personal information, the reasons The Management Trust chooses to share, and whether you can limit this sharing. |
| Reasons we can share your personal information |
|---|
| For our everyday business purposes— such as to process your transactions, maintain your account(s), providing communication about your property or association, respond to court orders and legal investigations, engaging collection agencies, or reporting to credit bureaus. |
| We may share your information with service providers who receive, use, and process your information on our behalf, including for operations, technology, payment, communication, and other purposes. Please note that such service providers include our web and SMS chat service provider(s). By using web and SMS chat functionality to communicate with us, you consent to our use of these web service providers and their underlying technology systems. |
| For purposes of payment processing— to allow for payment by check, e-check, credit/debit card |
| For purposes of association, metropolitan district, or property owner business activity— to provide business information to the board of directors or business owner for everyday business |
| For our targeted advertising— to provide information on services or goods available to you as clients of The Management Trust. This communication comes directly from The Management Trust, and we do not share your information with the providers of these services or goods. You may opt out of this communication by selecting the Opt-Out link in the email communication or following the instruction in the SMS messaging. |
| What we do | |
|---|---|
| How does The Management Trust protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with industry best practices. These measures include computer safeguards and secured files and buildings. We restrict access to only those employees who need to know information to provide products or services to you. No information, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, The Management Trust cannot and does not ensure or warrant the security of your information. |
| How does The Management Trust collect my personal information? | We collect your personal information, for example, when you
We also collect your personal information from third-parties, such as your Home Owner Association, Title Companies, Real Estate Agents, Credit Bureaus or other service providers. We may also obtain your information from other family members, roommates, and/or neighbors. |
| How long does The Management Trust retain my personal information? | We retain your information for as long as reasonably necessary for our business purposes. In determining the criteria by which to retain or dispose of your information, we consider the type, sensitivity, context, and purpose of collecting the information. We may additionally delete your information in response to a valid data subject request, as provided by law. |
| Automated Data Collection | |
|---|---|
| Cookies, Web Beacons, and Similar Technologies | Our Sites use a technology called “cookies,” which are pieces of information that may be placed on your computer’s browser or your device by a website or service to store your preferences. We also use similar technologies such as “Web Beacons” or clear GIFs, which use pieces of information placed on a service or email to track and collect information about the receipt and viewing of this information. |
| Google Analytics | We use automated technologies and applications, such as Google Analytics, to evaluate usage of our Sites. We also may use other analytic means to evaluate our Sites and Services. We use these tools to help us improve the Sites, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: http://www.google.com/analytics/learn/privacy.html |
| Geolocation and Tagged Information | Provided digital files may include information shared about the location of that file’s creation. These digital files may include pictures, posts, check-in information, or emails. We do not remove this information from files and communication provided to us. |
| Other important information |
|---|
| For California residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”), and the California Privacy Rights Act of 2020 (“CPRA”), as described in the Privacy Notice for California Residents. |
THE MANAGEMENT TRUST PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This Privacy Notice for California Residents supplements the information contained in The Management Trust’s Privacy Policy and applies solely to visitors, users, 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 the California Privacy Rights Act of 2020 (“CPRA”) and any terms defined in the CCPA and CPRA that have the same meaning when used in this notice.
Information Collected
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, household, or device (“personal information”), and sensitive personal information, all as further explained within this policy.
Personal and sensitive personal information does not include:
- publicly available information from government records;
- deidentified or aggregated consumer information;
- information excluded from the CCPA/CPRA’s scope, such as:
- 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; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (CalFIPA), and Driver’s Privacy Protection Act of 1994.
Categories of Personal Information Collected
We may have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Description |
|---|---|
| A. Identifiers | A real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
| B. Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) | A name, signature, Social Security number, 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. (Some personal information included in this category may overlap with other categories.) |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression), pregnancy or childbirth (including related medical conditions), sexual orientation, veteran or military status |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
| E. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
| F. Geolocation data | Physical location or movements. |
| G. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. |
| H. Professional or employment-related information | Current or past job history or performance evaluations. |
| I. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
| J. Sensitive Personal Information | This may include your Social Security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; your biometric information for the purpose of uniquely identifying you; your health information; and/or information related to your sex life or sexual orientation. |
| K. Personal Information | Under CCPA, personal information does not include: • Publicly available information from government records • Deidentified or aggregated consumer information • Information excluded from the CCPA’s scope, such as: • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) 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-Billey Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 |
Sources of Information Collected
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you or your agents. For example, from forms you complete or documents you provide us with related to the services for which we are engaged.
- Indirectly from you or your agents. For example, through information we collect from our clients in the course of providing services to them.
- Indirectly from our service providers and contractors. For example, web analytics data, such as type of browser software, during use of our digital services, or credit and related information from an independent authorized consumer credit/background check agency.
Collection of Information for Business or Commercial Purposes
We may collect personal information for one or more of the following business or commercial purposes.
They include:
- fulfillment of the reason(s) you provided the information, such as the:
- provision of information, products, or services you request from us; and
- processing of your requests, transactions, and payments;
- provision of support and responses to your inquiries, such as investigating and addressing your concerns and monitoring and improving our responses;
- prevention, detection, and investigation of security incidents that potentially compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted data;
- resistance to malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
- the carrying out of our obligations and enforcement of our rights arising from any contracts entered into between you and us;
- support of our ongoing operations and to maintain all our services and products, including audits and analytics collection, processing, debugging, and research;
- responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- evaluation or conducting of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; and
- any other purpose described to you during collection of your personal information or as otherwise set forth in the CCPA/CPRA.
Please note that the examples provided are illustrative and not intended to be exhaustive. If we decide to collect additional categories of personal information or use the information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
No Selling or Sharing of Personal Information to Third Parties
In the preceding twelve (12) months, we did not sell or share personal information to or with third parties.
No Selling or Sharing of Personal Information of Consumers Under the Age of Sixteen
We do not have actual knowledge that we sell or share information of consumers under the age of sixteen (16).
Automated Decision-Making Technology
We do not use Automated Decision-Making Technology to analyze consumer preferences or for any other purpose.
Limited Disclosures of Sensitive Personal Information to Third Parties
We limit the disclosure of personal information and sensitive personal information to business purpose uses which are:
- reasonably expected by an average consumer/user of our goods or services; and
- reasonably necessary and proportionate for such purposes.
We employ the same standard in our agreement requirements for service providers and others of our contractors who necessarily become privy to your personal information.
Retention of Your Information
Our retention periods are based on timeframes necessary to:
- fulfill the completion of transaction(s) for which we collected the personal information;
- take actions reasonably anticipated within the context of our ongoing business relationship with you and the HOA, or otherwise perform our contract with you and the HOA;
- detect and mitigate security incidents, including malicious, deceptive, fraudulent, and illegal activity, or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- engage in research in the public interest that adheres to applicable laws, if you provided informed consent;
- enable our operations and solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation or exercise a right provided for by law; and/or
- make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Your Rights and Choices
The CCPA/CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your rights as a consumer under California law and explains how to exercise those rights.
A. Right to Know – You have the right to be notified which categories of personal information we have collected about you from any source and the purposes for which the personal information is being sought. This request pertains to:
- specific pieces of personal information we collected about you;
- categories of personal information we collected about you;
- categories of sources from which the personal information was collected;
- categories of personal information we disclosed or sold (if any) for a business purpose about you;
- categories of third parties with whom the personal information was shared or sold (if any) or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
Requested information will be provided in portable format (readable on most devices) which may be transmitted to another entity at the consumer’s request without hindrance.
B. Right to Delete – You have the right to request deletion of your personal information that we have collected from you, provided, however, that any such request may be denied if retaining the information is necessary for us or our contractors/designated service providers 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 Election Communications Privacy Act (Cal. Penal Code Section 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.
C. Right to Correct – You have the right to have corrected inaccurate or incomplete personal information that we maintain about you. Such a request requires verification of your identity (see “Verification” below) before it can be processed. When accepting any such corrections, we also instruct all service providers and contractors that maintain the personal information at issue to make the necessary corrections in their respective systems.
D. Right to Freedom from Discrimination – You have the right not to receive discriminatory treatment by us for the exercise of privacy rights described here and in the CCPA/CPRA, as directed by those laws. This includes the right not to be retaliated against for the exercise of your CCPA/CPRA rights and the right to be free from:
- The denial of goods or services to you;
- Being charged different prices or rates for goods or services;
- Our providing a different level of quality;
- Suggesting that you will receive a different price or rate or a different level of quality in goods or
services.
How to Exercise Your Rights and What to Expect from the Process
To exercise any of the above rights, you or your legally authorized agent may communicate your inquiry or request with us by:
- emailing us at privacy@managementtrust.com
- calling us toll-free at 1-888-622-9904
Verification of your Identity
If you or your authorized agent submit a request to know, request to delete, and/or request to correct your personal information, the first step in our response will be to verify your identity in order to protect your confidentiality. You or your agent will be asked to provide information to validate against our records associated with your account. Once we verify this information, we will proceed with reviewing your request/instructions and take reasonable steps to assess the accuracy of any records containing personal information. This verification can also be initiated by submitting your request directly from your account using the my.managementtrust.com portal or by calling us toll-free at 1-888-622-9904.
Response Timing and Format
We will confirm receiving your request to know, correct, or delete within ten (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. In the event we are unable to respond within 45 days, we may request this deadline be extended for an additional 45 days. We will inform you of the reason and extension period in writing via email and/or posting on your account in the my.managementtrust.com portal. The scope of personal information we are required to disclose is limited to the data collected over the 12-month period directly preceding the date we received a verifiable request. The response we provide will also explain the reasons we cannot comply with a request, where applicable. For data portability requests, we will select a format to provide your personal information to you that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Fees
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.
Changes to Our Privacy Notice
We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on our website and update the notice’s effective date.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: privacy@managementtrust.com
Phone:1-888-622-9904
