Last Updated: September 12, 2022
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 personal information 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.
The Site is owned and operated by NAP. Any inquiries about this Policy should be directed to us at [email protected], (513) 721-2744, or toll free at 1.866.973.6642, or by mail to:
North American Properties
212 E. 3rd Street, Suite 300
Cincinnati, Ohio 45202
The Information We Collect
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.
While using the Site(s), you may have the opportunity to register, order products, make requests, and post content. Accordingly, depending on the process, you may be asked to provide certain types of PI, such as:
- Postal address
- Email address
- Phone number
- Credit or debit card information
- Month and day of birth
- Location information, including geolocation
Any PI you provide is voluntary or is necessary for the identified purposes for which it is to be used. Sensitive PI (such as Social Security numbers, customer records, or protected classifications) 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.
In particular, we have collected the following categories of PI from its individuals within the past 12 months:
|A. Identifiers.||Yes, name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers, and, in limited circumstances for tenant applications and workforce purposes and related inquiries, Social Security number and other government identifiers.|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Yes, name, signature, address, telephone number, and financial information for online transactions.
Some PI included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.
|Yes, characteristics of protected classifications under applicable state or federal law, such as race, color, sex, age, religion, national origin, disability, citizenship status, veteran status, and genetic information.|
|D. Commercial information.||Yes, 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.|
|E. Biometric information.||No.|
|F. Internet or other similar network activity.||Yes, browsing history, search history, or information on a visitor’s interaction with our Sites or advertisement.
|G. Geolocation data.||Yes.|
|H. Sensory data.||No.|
|I. Professional or employment-related information.||Yes, for client, tenant, and workforce purposes, paper and electronic records containing personal information, including without limitation; name, signature, photo, contact information, and, in limited circumstances for tenant or employment applications and related inquiries, resume/CV information, education records, disciplinary records, employment history, Social Security number and other government identifiers, insurance policy number, financial or payment information, or credit card information.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Yes, for workforce purposes.|
|K. Inferences drawn from other personal information.||Yes, profile information reflecting a person’s preferences, characteristics, or purchasing behavior.|
We obtain the categories of PI set forth above from the following sources:
- Directly from you. For example, from forms or surveys you complete.
- Indirectly from you. For example, from observing your actions on our Site.
- From our Service Providers acting on our behalf.
- From our third-party affiliates.
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 will only use the PI you provide for 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, surveys, and targeted advertising, unless you have opted out;
- 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 site, 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 our legal rights;
- 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 Share PI
We do not sell PI and do not share, sell, rent, or otherwise distribute your PI with outside parties, except to provide products or services you’ve requested through us or to our affiliates, suppliers, and third parties (collectively, “Service Providers”) performing services for us, including for example, companies that host our data services, process payments, deliver communications on our behalf, fulfill service requests, operate apps, or plug-ins on our behalf, or have Data Analytic Providers perform analytics on the information you have provided (as described below in Webs Statistics and Shared Data) or for any other business purpose.
We may also provide your PI in response to a validly issued subpoena, court order, or other legal process, or when necessary to establish or exercise our legal rights or defend against legal claims made by you or on your behalf, or if disclosure is 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. Also be aware that we may disclose PI to 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 similar proceeding, in which PI held by us about users of our Sites and our services is among the assets transferred.
From time to time, we may employ the use of return email addresses to answer the email we receive from you. Such addresses are not used for any other purpose and are not shared with outside parties.
You may choose to restrict the collection or use of your information in the following ways:
- Do not submit information when presented with a form on our Sites. Your submission of such forms is considered free and voluntary.
- If you have previously agreed to us using your information for marketing purposes, you may change your mind at any time by using the unsubscribe links in your emails or by emailing us at [email protected].
In the preceding twelve months, we have disclosed PI for a business purpose the following categories of PI to the categories of Service Providers indicated in the chart below:
|PI Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|A: Identifiers.||Service Providers.||None.|
|B: California Customer Records personal information categories.||Service Providers.||None.|
|C: Protected classification characteristics under California or federal law.||Service Providers.||None.|
|D: Commercial information.||Service Providers;
Data Analytics Providers.
|E: Biometric information.||None.||None.|
|F: Internet or other similar network activity.||Service Providers;
Data Analytics Providers.
|G: Geolocation data.||Service Providers||None.|
|H: Sensory data.||None.||None.|
|I: Professional or employment-related information.||None.||None.|
|J: Non-public education information.||None.||None.|
|K: Inferences drawn from other personal information.||Service Providers;
Data Analytics Providers.
We may disclose generic aggregated demographic information not directly linked to any person without restriction.
Your Rights and Choices – CCPA
For certain jurisdictions: The CCPA provides California resident consumers with specific rights regarding their PI. Other jurisdictions may also provide similar rights. This section describes CCPA rights and explains how to exercise those rights.
- Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your PI over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:
- The categories of PI we collected about you.
- The categories of sources for the PI we collected about you.
- Our business or commercial purpose for collecting or selling that PI.
- The categories of third parties with whom we share that PI.
- If we sold or disclosed your PI for a business purpose:
- sales, identifying the PI categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the PI categories that each category of recipient obtained.
- The specific pieces of PI we collected about you (also called a data portability request).
- Right to Delete: You have the right to request that we delete any of your PI that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the PI applies. We may deny your deletion request if retaining the PI is necessary for us or our Service Provider(s) to, among other things:
- Complete the transaction for which we collected the PI, provide a service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- 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.
We will delete or deidentify PI not subject to one of these exceptions from our records and will direct our Service Providers to take similar action. We commit that we will not reidentify deidentified PI.
- Exercising Your Rights and Our Response: To exercise your rights described above, please submit a request by either:
- Calling us at 1.866.973.6642.
- Emailing us at [email protected]
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your PI.
You may only submit a request to know twice within a 12-month period. 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 only use PI provided in the request to verify the requestor’s identity or authority to make it.
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. 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.
For Designated Agents or Parents/Guardians
To designate an authorized agent or to submit a request to know or delete on behalf of your child, submit the form found here and, if applicable, include the required documents described below. Your request must:
- 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:
- Either a signed and notarized Power of Attorney, or submission of the form found here.
- For children under 13, submission of the form found here, along with:
- 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:
- a copy of your government issued ID, which we will delete from our records immediately upon confirmation of your parent/guardian status.
- Describe 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 CCPA rights. Unless permitted by the CCPA, 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 the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’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 currently provide the following financial incentives:
- Discounts for email sign ups
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.
To the extent that we are required under the CCPA to assign a monetary value to your personal information, the value of your information is equal to the value of the financial incentive that we have provided to you. We have calculated the value of your personal information 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. Please contact us [email protected] to request information as permitted by California law. When contacting us, please indicate your name, address, email address, and details regarding your specific request, such as the PI you do not want us to share with suppliers, affiliates, or third parties. The 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 allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your PI or requesting this notice.
Web Statistics and Shared Data
We collect and use IP addresses to analyze trends, administer the site, track user movement, and gather broad aggregate demographic information for reporting and sponsorship purposes. IP addresses are not linked to PI. NAP may provide third parties with aggregate statistics about our customers, traffic patterns, and related information. This data reflects site usage patterns gathered during thousands of customer visits to our Sites each month but does not contain behavioral or identifying information about any individual member, unless that individual has given us permission to share that information. We may also provide log files and other databases of user information to third parties for analysis, so we can get a better understanding of traffic through our Sites and thus improve our content offerings.
Information Collected Using Web Browser Cookies
- 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).
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “How We Use and Share PI” Section above.
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].
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. 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.
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.
NAP may change this Policy periodically by updating this Sites. It is your responsibility to check this page from time to time to ensure that you continue to agree with the terms of this Policy.