HireAction, Inc., and its subsidiaries and affiliates referred to herein as “HireAction” “we,” “us,” or “our” herein) recognizes the importance of protecting the privacy of individual-specific information (“Information”) collected about our residents and prospective residents (referred to as “Residents,” “you” or “your”). This privacy statement discloses what information we gather, how we use it, and how you can correct or change it. It is our intention to give you as much control over your personal data as possible to preserve your privacy, while still allowing us to utilize that Information in the course of our business to provide you a valuable service and hopefully to have you as a new resident of our facility.
This Privacy Policy constitutes an integral part of our website’s User Agreement and is subject to the provisions thereof, including with respect to Limitation of Liability and governing law. We encourage you to read this Privacy Policy before you send or share information with us or use our website and to read it again when we notify you of changes to the Privacy Policy that are made from time to time.

Usage Tracking: Use of IP Addresses

An IP address is a number that is automatically assigned to your computer whenever you’re surfing the Internet. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. HireAction collects IP addresses for the purposes of system administration, reporting aggregated information, and to audit the use of our site. When Residents request pages from the HireAction site, our servers log the Residents’ IP addresses.
We do not normally link IP addresses to anything personally identifiable, which means that a Resident’s session will be logged, but the Resident remains anonymous to us. We can and will use IP addresses to identify a Resident when we feel it is necessary to enforce compliance with our house rules or terms of service or to protect our service, site, residents or others from potential harm.


Use of “Cookies”

Cookies are pieces of information that a website transfers to an individual for record-keeping purposes. Cookies make web surfing easier for you by saving your preferences while you are at our site. The use of cookies is an industry standard, and as such, you’ll find them at most major websites. By showing how and when Residents use a site, cookies help us see which areas are popular and which are not. Many improvements and updates to the site are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies only to provide services better tailored to our Residents’ needs. We never save passwords or credit card information in cookies.


What Information Do We Share or Disclose?

As a general rule, HireAction will not disclose personal Information except when we have your permission or under special circumstances, such as when we believe, in good faith, that the law requires it or under the circumstances described below.
We do not commercialize or share any personally identifying information with third parties, unless:
·    Such information is shared and/or commercialized following receipt of a specific request and/or permission from users

·    Such information is shared with affiliated companies and/or potential investors (in any form of business transaction, including purchase or merger) pursuant to an agreement which contains reasonable confidentiality arrangements
·    Such information is shared with contractors who work with us (in order to facilitate our business) pursuant to an agreement which contains reasonably confidentiality arrangements

·    Such information is shared in order to comply with or in accordance with any applicable law and/or court orders and/or in order to prevent suspected illegal acts, frauds, situations involving potential threats to the safety of any person, or as otherwise required by law

·    Such information is shared in order to help HireAction defend against claims and/or establish or exercise any legal right that HireAction may have

·    Such information is shared in order to help HireAction prevent violations of HireAction’s User Agreement and this Privacy Policy or to otherwise protect the rights, property, or safety of HireAction employees or resident, or others, including exchanging information with third parties for fraud protection and credit risk reduction


HireAction Business Transitions

In the event that HireAction goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, users’ personally identifying information will, in most instances, be part of the assets transferred.


Third-Party Site Links

You should be aware that when you are on HireAction’s website you could be directed to other sites that are beyond our control. There are links to other sites from HireAction, which take you outside our service. For example, if you “click” on a banner advertisement or a search result, the “click” may take you off the HireAction site. These other sites may include sites of other advertisers, sponsors and partners that may use their logo as part of a co-branding agreement. These other sites may send their own cookies to Residents collect data or solicit information. HireAction does not control such sites, and, therefore, is not responsible for their content. HireAction’s inclusion of hyperlinks to any other sites does not imply any endorsement of the material on such sites, nor any association with their operators. HireAction’s policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control.
Remember that whenever you give out Information online, that information may be collected and used by people you don’t know. While HireAction strives to protect your Resident Information and therein your privacy, we cannot guarantee the security of any Information you disclose online and you therefore disclose such Information at your own risk.


Securing Information

HireAction takes reasonable measures in order to safeguard users’ personally identifying information.
Payment information (such as credit card number and/or Social Security number) and information about the security vulnerability of users’ website is protected, by using Secure Sockets Layer (SSL) software, which encrypts the aforementioned information when viewed online.
While on a secured page, the lock icon on the bottom of Web browsers such as Firefox and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just surfing.
In addition, we limit access to personally identifying information to employees who we believe reasonably need to receive such information to provide our Services or in order to do their jobs and take other precautions we deem reasonable to protect the security of users’ personally identifying information.
However, users should be aware that we cannot fully guarantee the security of their personally identifying information. As in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injuriousness to the confidentiality of users’ personally identifying information. If users have any questions about security, please contact us.


Encryption

We have put in place encryption software, which fully encrypts or distorts all data you submit to us through the use of the Online Rental Application (“Items”). This encryption will be processed at 256 bits, making it a difficult code to hack into without the appropriate decoding software. Your personal data is immediately encrypted as you send it to us, and we then decode the encrypted data and use the converted data to process the aforementioned Items. We also work very hard to ensure that our employees are aware of the sensitivity of the data submitted to us and that they handle it with care, being careful not to allow any improper access by third parties.
Because the security of all Information associated with our residents is of utmost concern to us, we periodically review and improve our security and privacy policies as necessary when new technology becomes available. We exercise great care in providing secure transmission of your Information from your PC to our servers. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100 percent secure. As a result, while we strive to protect your Information, HireAction Software can’t ensure or warrant the security of any information you transmit to us online, and you, therefore, do so at your own risk. Once we receive your transmission, we use industry standard efforts to safeguard the confidentiality of your Information, such as firewalls and Secure Socket Layers, and our encryption techniques, as well. It is important, however, to remember that, despite these state of the art precautions, “perfect security” does not exist on the Internet.


Email Consent and Opt-Out

Your provision of Personal Information through any of our resident portal Sites constitutes Your affirmative consent that we may contact you by email to provide you with information and notices relating to the property where you reside, and various services available to you at or through that property.
You may choose to opt out of receiving future commercial email messages from us. Each mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. Please note that if you are a resident of a HireAction community and you opt out of receiving commercial email from us, you will continue to receive email from us regarding operational issues surrounding your apartment, your lease, and/or your community.


Children’s Privacy

We do not collect or maintain information at our Site from those we know are under 13, and we do not permit children under 13 years of age to become registered users of our Site. No part of our Site is structured to attract anyone under 13. By using our Site You represent that you are not under 13 years of age.


Non-U.S. Residents

If you do not reside in the U.S. and are visiting our Site, if you provide Personal Information to us it may be transferred to and processed on computers in the U.S. and other countries. Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. Your provision of Personal Information to us will be handled in accordance with this Privacy Policy. From time to time, your Personal Information may be transferred to a country different from where you are located, and processed there in accordance with this Privacy Policy. You hereby consent to such transfers and processing as described in this Privacy Policy. Your provision of Personal Information to us through this Site means that you agree to the terms of this Privacy Policy.


Correcting/Updating/Deleting/Deactivating Personal Information

If a user’s personally identifying information changes (such as zip code, phone, email or postal address), or if a user no longer desires our Service, we provide a way to correct, update or delete/deactivate users’ personally identifying information. This can usually be done at the Registered User account settings page or by emailing our Customer Support.
When a request for user deletion is received, we will make all reasonable efforts to purge said data from our systems. However, due to the nature of our service, some information may not be fully removed due to backups or archived copies.


Notification of Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.


Contact Information

If users have any questions or suggestions regarding our privacy policy including privacy, information use, collection, or security please contact us.


Acceptance of These Terms

By using this site, or providing information to us, you signify your agreement to our Privacy Policy. If you do not agree with this policy, please do not use this site. In addition, your continued use of our site following the posting of changes to these terms will also signify your acceptance of those changes.
Version: July, 2015