Picerne Military Housing

Privacy Policy

This privacy policy and agreement (the “Privacy Policy” or “Policy”) explains how, with your permission (as set out below) Picerne Military Housing (“we” or “us”) collects, uses and treats information that we receive about you (“User Information”).

The terms “you” and “your” refer to (1) any individual about whom we have User Information (“Data Subjects”) and (2) any individuals who provide to us User Information about Data Subjects (“Third-Party Data Providers”).

1. Your Consent

Please read this Privacy Policy carefully – when you consent to this Policy’s terms, it creates legal obligations for you and us. We ask you to show your consent to the terms of this Privacy Policy in different ways, depending on your relationship to us.

1.1. Consent via the Website. Any individual who visits our website is a “Site Visitor”. By accessing and using our website as a Site Visitor, you are acknowledging that you agree to be legally bound by this Privacy Policy. An individual who visits our website and creates an account or profile with us is a “Site Registrant”. If you register as a Site Registrant, such as by clicking an “I Accept” button linked to this Policy during the registration process, you further agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from using our website.

1.2. Consent Independent of the website. If you provide User Information to us about yourself or someone else (i.e., as a Third-Party Data Provider), you agree to be bound by this Privacy Policy. If you provide User Information to us about a Data Subject, you warrant and represent that you have first obtained consent from the Data Subject that is sufficient for this Privacy Policy. The term “User” means (i) Site Visitors, (ii) Site Registrants, and (iii) non-website Users.

2. The Types of Information You May Provide

User Information falls into five categories: (i) Contact Information; (ii) Government-Issued Identification Information; (iii) Personal Information; (iv) Anonymous Information; and (v) Other Information. These categories are defined further, below:

2.1. Contact Information. The term “Contact Information” means information about a Data Subject that would allow us (or others) to identify and contact the Data Subject, consisting of the Data Subject’s name, mailing address, telephone number, email address, and other contact information.

2.2. Government-Issued Identification Information. The term “Government-Issued Identification Information” means the Data Subject’s (a) Social Security Number; or (b) government-issued identification number included on a valid federal or state government-issued photo ID (such as a passport number, US military ID number, or US work authorization number). Government-Issued Identification Information does not include information that constitutes Contact Information.

2.3. Personal Information. The term “Personal Information” means information that could reasonably be used to identify the Data Subject, including the Data Subject’s Contact Information and Government-Issued Identification Information. Personal Information may also include the Data Subject’s resume, provided the resume includes the Data Subject’s Contact Information, Government-Issued Identification Information, or other information that could reasonably be used to identify the Data Subject.

2.4. Anonymous Information. The term “Anonymous Information” means information that does not identify a Data Subject, and may include statistical information concerning, for example, the pages on our website that Users visit most frequently, or the on-post military communities that receive the most housing applications. 2.5. Other Information. The term “Other Information” means all other information, except for Personal Information, we receive about a Data Subject. This information may include, but is not limited to, Employment Information, requests for products or services, and comments. “Employment Information” means information submitted by a User to enable us to determine whether the User is qualified for an employment opportunity with us. This information includes, but is not limited to, educational background, professional skills, prior work experience, salary requirements, relocation preferences, and work authorization status. Employment Information does not include Contact Information or Government-Issued Identification Information. Employment Information also excludes resumes that include Contact Information or other information that could reasonably be used to identify the Data Subject; where this information is included in a resume, the resume will be treated as Personal Information under this Privacy Policy.

3. Your Responsibility for Providing Information.

You should take care when providing information to us. If we ask for Contact Information or Government Issued-Identification Information (such as a social security number or passport number) over the website, for example, we will do so by labeling the appropriate portion of the online form or submission area with the specific information we seek. (For example, if we ask you for a Social Security Number, the online form will have a specific area labeled as “Social Security Number”.)

3.1. Resumes. We may invite you to submit resumes in specific areas of the website. We assume that the resume will include, at minimum, Contact Information. If the resume includes Contact Information about you or another Data Subject, or other information that could reasonably be used to identify you or another Data Subject, we will treat the resume as Personal Information under this Privacy Policy.

3.2. Disclosing Personal Information Where It Is Not Specifically Requested. If we have not specifically asked for a Data Subject’s Contact Information or Government-Issued Identification Information in a particular portion of an online form or submission area, you should not provide it in that portion of the form or submission area. If you choose to disclose Contact Information or Government-Issued Identification Information to us where it is not specifically requested, that information will be treated and protected as Other Information, not Personal Information.

4. Our Uses of Information About Data Subjects

We use Personal Information about Data Subjects only as provided in this Policy. We may collect information about Data Subjects at different points (for example, when you request information, submit housing applications to us or apply for jobs through our website), and use this information as follows:

4.1. Account Registration; User Names. In order to access information, products, and services on our Site that are limited to Site Registrants, we require that you complete a registration form. This form asks for Contact Information, which includes such items as (i) name; (ii) mailing address; and (iii) email address. The registration process for certain portions of the Site may require a Site Registrant to provide additional Personal Information, such as a social security number. We use the information a Site Registrant provides during the registration process to provide a Site Registrant with a user name and a password, and to allow the Site Registrant to gain access to password protected areas of the Site. We use Contact Information the Site Registrant provides during the registration process as further detailed below.

4.2. Providing Information, Goods or Services. We use Personal Information and Other User-Submitted Information to provide Data Subjects with the information, goods, services (such as housing services and maintenance services), or employment opportunities that they have requested. For example, as the occupant of a home in one of our communities, you can submit a maintenance request through our website. We use the information you submit to us to provide the maintenance services you have requested.

4.3. Employment Applications; E-Verify. In the employment section of our website and through other public job postings, we may invite you to apply for employment opportunities with us by submitting your Contact Information, Employment Information, resume, and other similar kinds of data. We may use this information to evaluate your application for particular jobs or to determine whether you may be qualified for positions with our company. Because we receive a large volume of applications, we do not guarantee that we will contact you after you submit your information or apply for a position. Additionally, it may be necessary or advisable for us to use Personal Information about a Data Subject to verify employment eligibility through the E-Verify system.

4.4. Third-Party Information. We may ask you to provide Personal Information for third parties through the Site or through other channels; when we do so, we will use this information to help provide the information, goods or services you have requested. In the Employment section of our website, for example, we ask you to provide the name and email address of the person who referred you to us. We may use the information you provide in this section to contact that person in connection with your job application. When we ask for this information, it will be protected under this Privacy Policy in the same way we protect your Personal Information. Before you submit Personal Information about third parties to us, please be sure you have permission from the third party to share this information with us.

4.5. Verifying Identity. When you request a product, service or information from us, we may collect additional Personal Information to verify your identity and process your request, beyond the data we originally received about you. This is designed to further protect you and to reduce the threat of identity theft and fraudulent transactions. v4.6. Promotions. We believe that our Users’ own experiences with us can often act as the strongest promotion for our homes and services. To promote and illustrate our homes and services, we may wish to post on our website home page, or elsewhere, endorsements from, or other descriptions of experiences by, our Users. You agree that your Contact Information and experiences with us may be used and adapted for these purposes (without the need for compensation).

4.7. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins or other information to Data Subjects and will receiving these communications as provided in Section 8, provided, however, that there are certain communications for which Data Subjects cannot opt out. Please refer to Section 8 for more details.

4.8. Surveys. Periodically we may initiate surveys on our Site, through the mail or by other means, and we may request Contact Information or other Personal Information from you in connection with such surveys. You are free to choose whether you participate in this type of survey. Survey information will be used for purposes of monitoring or improving the use and appeal of our Site, improving our homes and services, or for other business purposes. The information we receive through the survey will be used in accordance with this Privacy Policy, provided, however, that if we want to use your information in a manner different from what is set forth in this Policy, we will notify you of relevant details in connection with asking for your participation in such surveys.

5. Anonymous, Aggregate Information.

We use Anonymous Information to analyze the effectiveness of our Site, to improve our products and services and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of Users participating in our services and the characteristics of visitors at our Site, and may share Anonymous Information with third parties, including advertisers. Anonymous Information provided to third parties will not allow anyone to identify a Data Subject, or determine any Personal Information about the Data Subject. We may collect Anonymous Information through features of the software that supports our services, such as cookies or other means described below.

5.1. IP Addresses; Logs. Either directly, or through our hosting service provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other Users in order to understand how our website is being used and for security and monitoring purposes.

5.2. Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website on a future visit. We may include cookies on our website and use them to recognize you when you return to our website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our services.

5.3. Tags. We may use so-called “pixel tags” – small graphic images (also know as “web beacons,” “single-pixel GIFS,” or “Web bugs”) – for purposes such as: (i) to tell us what parts of our website have been visited, (ii) in connection with advertisements we may include on the Site, (iii) to measure the effectiveness of searches you perform on our Site, and (iv) for other purposes. Pixel tags also enable us to send email messages in a format you can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our Users and others. None of this data includes Personal Information, and you can “opt-out” of receiving these types of emails from us by following the directions provided in Section 8. If any Personal Information is collected using such tools, it will be subject to the terms of this Privacy Policy.

5.4. Click-Throughs. We may send email messages which use a “click-through URL” linked to content on our website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 8.

5.5. Banner Ads; Advertising Profiles. Our Site may include the use of ad banner partners for the serving and/or targeting of ads, promotions and other marketing messages. These ads may be provided, in some cases, by a third party ad service provider or advertiser (“Advertisers”). These Advertisers may use traditional banner ads, or other advertising methods, such as advertising using profiles and related content. An Advertiser may place or utilize its own cookie on your browser, and may use Anonymous Information about your visit to our Site, such as the number of times you have viewed the ad. If the Advertiser requests that you provide to it Personal Information, please be aware that this Advertiser’s use and collection of this information will be governed by its own privacy policy, and not this Privacy Policy. We recommend that you review the Advertiser’s privacy policy before providing Personal Information.

6. Any Information Linked With Personal Information Is Protected As “Personal Information”

To enable us to understand your characteristics better and/or to provide services tailored to your needs, we may link Personal Information with any combination of: (i) Anonymous Information; and/or (ii) Other Information. If we combine or link any Anonymous Information or Other Information with a Data Subject’s Personal Information, the resulting combination will be treated and protected as Personal Information under this Privacy Policy.

7. Disclosures to Third Parties

We will not disclose Personal Information about a Data Subject to any third parties without the Data Subject’s express consent, except in the circumstances specified below.

7.1. Vendors. We employ other companies to perform functions on our behalf or on your behalf, such as providing services related to our products, maintaining the website, collecting information, responding to and sending electronic mail, or other functions necessary to our business. We may need to share Personal Information with companies that assist in the running of our business (collectively, “Vendors”). We will provide Vendors with only that Personal Information necessary to perform their functions, and we will not allow them to use Personal Information for any purpose inconsistent with this Policy. We require that our Vendors agree contractually to comply with privacy laws, and agree to maintain protections for Personal Information that are consistent with this Policy.

7.2. Government Regulators. We are periodically required to disclose certain Personal Information to third parties, such as credit reporting agencies, and federal and state regulators, in order to do business with you.

7.3. Military Personnel. We disclose Personal Information and other User Information to the United States Military as the military requires, by law or regulation in accordance with our reasonable interpretation of that law or regulation, or as necessary to provide the goods and services we have agreed to supply as part of our contracts with the military. In doing so, we will not disclose more information than is necessary to comply with these obligations.

7.4. Affiliates. In order to provide Data Subjects with valuable product and service offerings, we share Personal Information with our Affiliates. Our Affiliates have agreed contractually to comply with privacy laws, and have agreed to maintain protections for Personal Information that are consistent with this Policy. Data Subjects have the ability to “opt-out” of this information-sharing, by following the directions provided in Section 8 (Opting Out).

7.5. E-Verify System. We will comply with the E-Verify program where applicable. Accordingly, it may be necessary or advisable for us to disclose Personal Information about Data Subjects – such as Government-Issued Identification Information – to the federal government.

7.6. Questions of Harm. We may reveal Personal Information about Data Subjects on a case-by-case basis to attorneys, private investigator organizations or law enforcement agencies if we believe that: (a) the Data Subject is at risk of harm from another, or (b) the Data Subject is harming or interfering (or will harm or interfere) with others, or is violating (either intentionally or unintentionally) our website terms of use, or are otherwise violating legal obligations.

7.7. Legal. We will reveal Personal Information about Data Subjects to the extent we reasonably believe we are required to do so by law. If we receive legal process requiring the disclosure of Personal Information about a Data Subject, we will attempt to notify the Data Subject via the email address we received for the Data Subject within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

7.8. Transfer of Ownership. We shall be entitled to transfer Personal Information to a third party in connection with a sale of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard Personal Information with protections that in all material respects are the same as, or more protective than, those set out in this Privacy Policy.

8. Opting Out

Because we respect privacy rights, we give Data Subjects the following choices of how their Personal Information may be used:

8.1. Opting-Out of Updates. If we choose to send bulletins, updates, product offerings, or other communications to Data Subjects, we will provide them with the ability to decline – or “opt-out of” – receiving such communications. Instructions for opting-out will be provided if and when we determine to send such a communication. Data Subjects will not be allowed to “opt-out” of formal notices concerning operation of our websites or legal and other related notices concerning their relationship to us or the website.

8.2. Opting-Out of Information-Sharing. Data Subjects may choose to opt out of our information-sharing with our Affiliates. Making this decision will prevent us from sharing Contact Information with our Affiliates, and this choice may limit our ability to offer certain information, services and products provided by our Affiliates. To opt-out of our information-sharing with Affiliates, please contact us as provided in Section 14.

8.3. Opting-Out and Multiple Data Subjects. For products and services that were ordered by a single Data Subject, but that apply to multiple Data Subjects or other individuals, we will treat an opt out by any Data Subject as applying to all Data Subjects (or others) covered by the products or service (for example, if you are head of household and opt-out under this section, we will apply that opt-out decision to your family as well).

8.4. Opting Out and Military or Government Personnel. Under certain circumstances, such as those specified in Section 7.3 or Section 7.5 , it may be necessary for us to disclose Personal Information about a Data Subject to the Military or U.S. Government. In these situations, Data Subjects do not have the option to opt-out of these disclosures of their Personal Information.

9. Access; Removing Information

We provide Data Subjects with access rights to their User Information and provide them with the right, upon their request, to remove their information in accordance with our contracts with the military and the law, as we reasonably interpret them. However, it may be impossible to remove this information completely, due to backups and records of deletions. Data Subjects may not remove de-identified, anonymous or aggregate data from our databases.

10. Security

We have put in place security systems, physical safeguards, technical safeguards, and quality controls designed to prevent unauthorized access to, or disclosure of, Personal Information. Our security systems are structured to deter and prevent unauthorized users and others from accessing Information we receive about Data Subjects. However, these safeguards are not fail-proof and, due to the nature of internet communications and evolving technologies, we cannot provide, and disclaim (to the extent permitted by law), any assurance that the information we receive about Data Subjects will remain free from loss, misuse or alteration by third parties who, despite our efforts, obtain unauthorized access. Moreover, you play a key role in protecting the security of information about you. For example, you should guard your password to our website and decline to allow others to use this password. In addition, you should close your browser when have finished viewing your information on our website to prevent others from viewing your Personal Information.

11. Website Participation by Children and Teens; Advisory

Due to federal law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 13 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 13 YEARS OLD TO USE OUR WEBSITE AND SERVICES. IF YOU ARE BETWEEN 13 AND THE APPLICABLE AGE OF MAJORITY, PLEASE REVIEW THIS AGREEMENT WITH YOUR PARENT OR GUARDIAN. Please understand that we cannot necessarily tell if a user is providing us with his or her true age.

12. Notification of Changes

From time to time, we may change our Privacy Policy. If we make any changes regarding the Policy, we will post the new Policy via the privacy link on our website and make the new Policy available in paper-form upon request. Changes to the Privacy Policy will become effective to Data Subjects and Third-Party Data Providers upon consent, pursuant to Section 1, and will be retroactive to the first time we received User Information from or about you.

13. Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this website, please contact us at:

Name: Bill Culton
Address: 1405 South County Trail
East Greenwich, RI 02818
Phone: 401-228-2800