North American Properties Privacy Policy
Last Updated: September 12, 2024
North American Properties and our affiliates (collectively “NAP,” “we,” “our,” or “us”) are committed to your privacy and to providing you with transparency in our information practices. This Privacy Policy (“Policy”) sets forth how NAP collects, uses, protects, and otherwise processes personal information (“PI”, as further defined below) you provide or submit or we otherwise collect through our website, www.NAProperties.com, or any of our affiliated websites on which this Policy appears (the “Sites”).
We are committed to protecting your privacy. By using our Sites and services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Policy. Accordingly, any PI provided by you to us shall be used in accordance with this Policy. However, this Policy applies only to information collected by our Sites and does not protect information you post to public areas or third-party websites, except as set forth herein. This Policy imposes no duties on NAP not imposed by state, federal, or other applicable law.
We may change this Policy periodically by updating this Site. Should it be necessary to do so, we will notify you and/or request your express consent of material changes to this Policy. You should check this page from time to time to ensure that you continue to agree with the terms of this Policy. This Policy is incorporated by reference into the Terms of Use Agreement, to which you agreed upon entering the Site.
The Sites are owned and operated by NAP. Any inquiries about this Policy or our privacy practices should be directed to us at [email protected], (513) 721-2744, or toll free at (866) 973-6642, or by mail to:
North American Properties
Attn: Privacy
212 E. 3rd Street, Suite 300
Cincinnati, Ohio 45202
If you wish to download and print a copy of this Policy, please visit the following link: Privacy Policy PDF.
The Information We Collect & Disclosures
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 (and for California residents, household or device) (“PI”). PI does not include:
- Publicly available information from government records;
- De-identified or aggregated consumer information;
- Health or medical information covered by the Health Insurance Portability and Accountability Act and the California Confidentiality of Medical Information Act; or
- PI covered by various privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected, disclosed, and/or shared the following categories of PI within the past 12 months:
Category | Examples of PI Collected | Categories of Recipients and Disclosure Purposes |
Identifiers. | Name, alias, postal address, date of birth, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers, and, in limited circumstances for tenant applications, workforce purposes, and related inquiries, Social Security number and other government identifiers. | Disclosures for Business Purposes:
Sell/Share: Shared with Third-Party Digital Businesses (defined in How We Disclose PI) (only certain online identifiers like IP address). |
PI categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, signature, postal address, telephone number, financial information for online transactions (including debit and credit card numbers), and, in limited circumstances for tenant applications, workforce purposes, and related inquiries, information related to education and employment, insurance policy number, Social Security number, passport number, driver’s license or state identification card number.
Some PI included in this category may overlap with other categories. |
Disclosures for Business Purposes:
Sell/Share: N/A |
Protected classification characteristics under California or federal law. | Characteristics of protected classifications under applicable state or federal law, such as race, color, sex, gender identity, age, religion, national origin, disability, citizenship status, veteran status, and genetic information. | Disclosures for Business Purposes:
Sell/Share: N/A |
Commercial information. | Records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. We may also retain the details of communications, requests, transactions, or payments made or exchanged with us through the Sites in order to provide you with more personalized content. However, we will only keep your payment account number securely with our payment processor vendor. | Disclosures for Business Purposes:
Sell/Share: N/A |
Internet or other similar network activity. | Browsing history, search history, or information on a visitor’s interaction with our Sites or advertisements. | Disclosures for Business Purposes:
Sell/Share: Shared with Third-Party Digital Businesses. |
Geolocation data. | Physical location or movements. | Disclosures for Business Purposes:
Sell/Share: Shared with Third-Party Digital Businesses. |
Professional or employment- related information. | Paper and electronic records containing PI, including, without limitation, resume/CV information, current and past employment history, and performance evaluations. | Disclosures for Business Purposes:
Sell/Share: N/A |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | For workforce purposes, education records, such as grades, transcripts, and student disciplinary records. | Disclosures for Business Purposes:
Sell/Share: N/A |
Inferences drawn from other PI. | Profile information reflecting a person’s preferences, characteristics, or purchasing behavior. | Disclosures for Business Purposes:
Sell/Share: Shared with Third-Party Digital Businesses. |
Sensitive PI. | Debit or credit card numbers in combination with a security or access code, password, or other credentials, account log-ins, gender identity (particularly when different from gender assigned at birth) and, in limited circumstances for tenant applications, workforce purposes, and related inquiries, information related to education and employment, Social Security number, passport number, and driver’s license or state identification card number. | Disclosures for Business Purposes:
Sell/Share: N/A |
We obtain the categories of PI set forth above from the following sources:
- Directly from you. For example, from forms or surveys you complete on the Sites.
- Indirectly from you. For example, we use cookies and other technologies to collect PI automatically through your use of the Sites as described in the Information Collected Using Cookies & Other Technologies / Interest-Based Advertising section below.
- From our service providers acting on our behalf. For example, from our payment processors or marketing and advertising partners.
- From our third-party affiliates.
Any PI you provide is voluntary or is necessary for the identified purposes for which it is to be used. Sensitive PI is only collected if you affirmatively choose to provide it by opting in where applicable. You have no obligation to provide the information requested on any NAP form, but the failure to do so can impact NAP’s ability to respond to your inquiry, problem, request, or other communication, and may result, in the case of a service or other request, in the denial of such request.
Protecting the privacy of children is especially important to us. For that reason, we never collect or maintain PI from those we actually know are under 13, nor do we allow registration of users under the age of 13. If you are under 13, DO NOT give us any PI.
How We Use PI
We use the PI we collect to administer and manage our business operations. More specifically, we may use your PI for one or more of the following purposes:
- to effectuate an account registration made by you;
- to customize the advertising and content you see;
- to fulfill purchases or orders if applicable;
- to improve the content and overall look and feel of our Sites and services;
- to respond to your inquiries or requests;
- to process tenant and employment applications and requests for services;
- to provide you promotional messages and targeted advertising, unless you have opted out;
- to provide and administer surveys and contests;
- to provide you with support, including to investigate and address any concerns you may have and monitor and improve our responses;
- for testing, research, analysis, and product development, including to develop and improve our Sites, products, and services;
- to analyze trends, administer the Sites, track user movement, and compile broad aggregate demographic information for reporting and sponsorship purposes;
- to help maintain the safety, security, and integrity of our Sites, products and services, databases, and other technology assets and business;
- to defend or exercise our legal rights, protect us from liability, or protect the rights, property, or safety of us, our customers, or others;
- for auditing, reporting, corporate governance, and internal operations;
- to comply with legal obligations; and
- as described to you when collecting your PI or as otherwise permitted under applicable law.
How We Disclose PI
We may disclose your PI for the purposes outlined above in the How We Use PI section to the following third parties:
- Our suppliers, contractors, service providers, and other third parties who perform services for us and are contractually obligated to keep PI confidential, use it only for the purposes for which we disclose it to them, and refrain from selling or sharing the PI. This may include service providers that host our data services, process payments, deliver communications and advertisements, fulfill service requests, operate apps or plug-ins, or perform analytics on our behalf;
- Our affiliates and other members of our corporate group;
- Government entities and other third parties in response to a validly issued subpoena, court order, or other legal process, when necessary to establish or exercise our legal rights or defend against legal claims made by you or on your behalf, or when necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk protection;
- A buyer or other successor in the event 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 a similar proceeding, in which PI is among the assets transferred.
In addition to the foregoing, we may disclose generic aggregated demographic information not directly linked to any person without restriction.
We do not sell PI for monetary value. Under the various state laws that may be applicable to you, there are broad and differing concepts on “selling” PI for which an opt-out is required. California also has established a right to opt out of the “sharing” of PI with third party businesses for cross-contextual behavioral advertising (use of PI from different businesses or services to target advertisements) (“Third-Party Digital Businesses”). You may also opt out of “targeted advertising” (defined differently by also addressing tracking, profiling, and targeting of advertisements), as described in the chart above. As a result, we may “sell” or “share” your Personal Information, as these terms apply under the CCPA.
We also do not have actual knowledge that we sell or share the PI of consumers under the age of 16 for cross-contextual behavioral advertising.
Please see The Information We Collect & Disclosures section for more information on the categories of PI we have disclosed for a business purpose and/or shared for cross-contextual behavioral advertising in the preceding 12 months and the categories of recipients to whom we have disclosed and/or shared such PI.
Your Rights & Choices
Your State Data Privacy Rights
Depending upon your state of residence, you may have certain rights under applicable state data privacy laws. These rights may include:
Right | Description |
Right to Know and Request Disclosure (California) | The right to request that we disclose certain information to you about our collection and use of your PI, including:
In connection with any PI we may sell, share, or otherwise disclose to a third party for a business purpose, you have the right to know:
|
Right to Confirm | The right to confirm whether or not we are processing your PI. |
Right to Access | The right to access your PI, subject to exceptions set out in the applicable state law. |
Right to Delete | The right to request that we delete any of your PI that we collected from or about you and retained, subject to certain exceptions set out in the applicable state law. |
Right to Correct | The right to request that we correct any of your PI that is inaccurate. |
Right to Obtain a Copy | The right to obtain a copy of or otherwise receive the PI that you have provided to us in a portable, readily usable format that can be easily transferred to third parties. |
Right to Opt Out | The right to opt out of the following uses of your PI:
[To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting Your Privacy Choices. |
Right to Limit the Use of Sensitive PI | The right to (a) direct us to limit the use of sensitive PI, as defined under applicable state law, that we may collect about you and (b) know if your sensitive PI is used or disclosed to a third party, for additional, specified purposes.
To exercise the right to limit the use of sensitive PI, you (or your authorized representative) may submit a request to us by visiting Your Privacy Choices. |
Right to Non-Discrimination | The right to not be retaliated or discriminated against because you have exercised your data privacy rights. For more information, see the Non-Discrimination & Notice of Financial Incentive section below. |
Exercising Your State Data Privacy Rights
To exercise your rights described above, please submit a request by either:
- Calling us at (866) 973-6642;
- Emailing us at [email protected];
- Visiting the following link: Your Privacy Choices
Only you, or someone legally authorized to act on your behalf (if permitted by applicable state law), may make a request related to your PI. You may only submit a request to know twice within a 12-month period.
We may request additional PI from you to help us confirm your identity and execute your request. Any PI we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to PI associated with that specific account.
We will respond to your request within 45 days of receiving it. If we require more time we will inform you of the reason and extension period. We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Additionally, applicable law may allow or require us to refuse to provide you with access to some or all of the PI that we hold about you, or we may have destroyed, erased, or made your PI anonymous in accordance with our record retention obligations and practices. If we cannot fulfill your request, we will provide you an explanation for it.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. For data portability requests, we will select a format to provide your PI that is readily useable and should allow you to transmit the information from one entity to another without hindrance.
Depending upon your state of residence, you may also have the right to appeal our decision if we deny your request. If you wish to appeal our decision regarding your request, please contact us via email at [email protected], via telephone at (866) 973-6642, or by visiting Your Privacy Choices. If you wish to file a complaint, you may be able to contact your Attorney General or relevant enforcement agency.
If you have previously agreed to join our mailing list, you may change your mind at any time and unsubscribe by clicking the unsubscribe link included at the bottom of our email communications or by emailing us at [email protected]. Please note, you may continue to receive certain transactional or account-related communications from us.
For Designated Agents or Parents/Guardians
To designate an authorized agent or to submit a request on behalf of your child, submit the following information and documents via email to [email protected]:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative, which may include:
- To designate an authorized agent, either a signed and notarized Power of Attorney, or submission of the form found here.
- To submit a request on behalf of your child under the age of 16, submission of the form found here, along with a copy of your government issued ID, which we will delete from our records immediately upon confirmation of your parent/guardian status.
- A description of your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Non-Discrimination & Notice of Financial Incentive
We will not discriminate against you for exercising any of your data privacy rights. Unless permitted by applicable state data privacy laws, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you, from time to time, certain financial incentives permitted by applicable state data privacy laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your PI’s value and contain written terms that describe the material aspects of the financial incentive. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We may provide the following financial incentives:
- Discounts for email sign ups;
- Prizes for entering into contests;
- Loyalty programs; and/or
- Rewards for completing surveys.
To receive these financial incentives (or opt in), you will be asked to provide PI such as a name, email address, and/or cell phone number at the time you sign up.
You have the right to withdraw or opt-out of financial incentives at any time. To withdraw or opt out of financial incentives, please contact us via email at [email protected] or via telephone at (866) 973-6642. By withdrawing your consent, you will no longer be eligible for certain financial incentives, nor will you receive notifications about potential financial incentives.
To the extent that we are required under applicable state data privacy laws to assign a monetary value to your PI, the value of your PI is equal to the value of the financial incentive that we have provided to you. We have calculated the value of your PI in a reasonable manner, dependent on the purpose for which it is intended to be used.
California – Additional Privacy Rights
California’s “Shine the Light” law, Civil Code Section 1798.83, allows California residents who are NAP customers to request certain information regarding our disclosure of PI to third parties for direct marketing purposes. Such request should be sent to us at [email protected] or to our mailing address set forth herein, Attn: Privacy, and labeled “California Customer Choice Notice.” Please include the following information in your request: your name, postal address, email address, and details regarding your specific request. Please allow 30 days for a response. Also, please note there is no charge for controlling the sharing of your PI or requesting this notice.
Do-Not-Track Signals & Global Privacy Controls
The Site does not respond to Do-Not-Track (“DNT”) signals. You may learn more about DNT signals by visiting the following third-party website: www.allaboutdnt.com. However, we treat Global Privacy Control signals as requests to opt out of sale and opt out of interest-based advertising under applicable state laws.
For more information on opting out of interest-based advertising, please see the Information Collected Using Cookies & Other Technologies / Interest-Based Advertising section below.
Information Collected Using Cookies & Other Technologies / Interest-Based Advertising
Cookies & Other Technologies
We use cookies and similar tracking technologies to track the activity on our Sites and store certain information. These technologies may include:
- Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You may also set your preferences in our cookie consent manager at Your Privacy Choices. If you disable cookies, you may be required to re-enter your information more often and certain features of our Sites, or the entirety of our Sites, may be unavailable. You may learn more about cookies and how to opt out of them by visiting the following third-party website: www.allaboutcookies.org.
- Flash Cookies. Certain features of our Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences or your activity on our Sites. Flash cookies are not managed by the same browser settings as those used for Browser cookies. For more information on Flash cookies, please visit
https://www.adobe.com/products/flashplayer/end-of-life.html.
- Web Beacons. Certain sections of our Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
The Sites use cookies and other tracking technologies that are sent by us or our third-party service providers. The use of cookies and other tracking technologies allows us to make our Sites more responsive to your needs by delivering a better and more personalized experience to you.
The following information may automatically be received and/or collected through the Sites via cookies and other tracking technologies: IP address, browser type, browser language, internet service provider, resource requested, date and time of resource request, HTTP referring resource, operating system, and/or clickstream data. We aggregate this data, and may combine this data with other information we collect about you to better understand how visitors use our Sites, improve user experience, and help manage, maintain, and report on use of our Sites. We may also store IP addresses for fraud detection and prevention purposes.
Third-Party Service Providers
We may use third parties to help us gather and analyze information about the areas visited on the Sites (such as the pages most read, time spent, search terms, and other engagement data) in order to evaluate and improve the user experience and the Sites. Such third parties may include the following:
- Google Analytics (https://policies.google.com/technologies/partner-sites);
- Google Adsense (https://business.safety.google/privacy/);
- Adobe Fonts (https://www.adobe.com/privacy/policies/adobe-fonts.html)
- YouTube (https://policies.google.com/technologies/partner-sites);
- CallRail (https://www.callrail.com/privacy);
- Meta (https://www.facebook.com/privacy/policy);
- Complianz (https://complianz.io/legal/privacy-statement/);
- Bing Ads (https://privacy.microsoft.com/en-US/privacystatement); and
- Microsoft Clarity (https://privacy.microsoft.com/en-US/privacystatement).
Our real-time cookie list can be found at Your Privacy Choices. For more information about Google Analytics or to prevent the storage and processing of this PI (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Interest-Based Advertising
We partner with third parties such as advertising networks and other advertising companies to display advertising on our Sites and manage our advertising on other sites. Our third-party partners, listed above, may use technologies such as cookies and pixel tags to gather information about your activities on our Sites and other sites (such as web pages you visit and your interaction with our advertising and other communications) in order to make predictions about your preferences and provide you with tailored advertising across the Internet based upon your browsing activities and interests. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
If you would like to opt out of having your PI used for the purpose of serving you interest-based advertisements, you may do so by visiting Your Privacy Choices or contacting us via email at [email protected] or via telephone at (866) 973-6642]. Please note this does not opt you out of being served advertisements. You may continue to receive generic advertisements from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioral advertising from third-party advertising companies participating in the Digital Advertising Alliance, please visit the Digital Advertising Alliance at http://www.aboutads.info/choices/ or the Network Advertising Initiative at http://www.networkadvertising.org/choices/.
To successfully opt out, you must have cookies enabled on your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser and device you use, so you must opt out on each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again.
Children’s Privacy
Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Sites. We do not knowingly collect information from children under 13. If you are under 13, do not use or provide any information, register an account, enter any subscriptions, make any purchases or submit any applications, or use any of the interactive or public comment features of the Sites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received PI from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
Retention
We will keep your PI for as long as necessary to fulfill the purposes for which we collected it and in accordance with our document retention policies and any applicable laws. Different retention periods may apply for different types of PI.
Under some circumstances, we may anonymize your PI so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Security
We have implemented appropriate data collection, storage, and processing practices designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Sites. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
Scope of this Agreement / Third-Party Websites
Although this Policy applies to the PI obtained when you visit our Sites, it does not apply to entities that are not owned by, controlled by, or associated or affiliated with us. Our Sites may contain links to other third-party websites and digital platforms. Please be aware that NAP does not claim any responsibility for the privacy practices of these third-party sites. We encourage you to be aware when you leave our Sites and to take reasonable precautions when sharing your PI on third-party websites.
Our Sites may also contain integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share information or you otherwise interact with social media features on our Sites, those social media companies may collect information, including PI, about you and may use such information in accordance with their own policies. Your interactions with third-party social media companies and your use of their features are governed by the privacy policies of those companies. We recommend that you review the relevant privacy policies.
Modifications
NAP reserves the right, at any time, to modify, alter, or update this Policy without prior notice. Modifications shall become effective immediately upon being posted on the Sites. Your continued use of the Sites made after amendments are posted constitutes an acknowledgement and acceptance of this Policy and its modifications. Except as expressly stated herein, this Policy may not be amended.
Questions?
Any inquiries about this Policy or our privacy practices should be directed to us at [email protected], (513) 721-2744, or toll free at (866) 973-6642, or by mail to:
North American Properties
Attn: Privacy
212 E. 3rd Street, Suite 300
Cincinnati, Ohio 45202