Effective Date: December 7, 2023

Total Association is dedicated to offering transparent and concise information regarding the collection and processing of personal information. By accessing our website or utilizing Total Association software services (collectively, “Total Association Services”), you express your consent to the information collection and handling practices outlined in this policy.

 

I. Collection of Personal Information

 

Total Association acts as a service provider to property owners, property residents, and management companies (collectively, “Clients”) and collects personal information related to Clients’ residents, prospects, and employee end users of Total Association Services. This information includes various data elements falling into the following categories within the last twelve (12) months:

 

• Identifiers:

As an example: Name, mailing address, email address, phone number, Social Security number, driver’s license number/image, state identification card, passport number, or similar personal identifiers associated with residential and commercial real estate leasing activities.

 

• Sensitive Personal Information:

As an example: Social Security number, driver’s license number/image, state identification card, passport number, account log-in, financial account, debit card, or credit card number, racial or ethnic origin, etc.

 

• Commercial Information:

As an example: Rental ledger data, payment history, record of applications, services utilized, customer support records, and similar identifiers associated with residential real estate leasing activities.

 

• Biometric Information:

As an example: Voice call recordings from product support operations.

 

• Internet or Other Network Activity:

As an example: Information on individual interaction with Total Association website, application, or service.

 

• Geolocation Data:

As an example: Physical location for localized search/application functionality.

 

• Professional or Employment-Related Information:

As an example: Current or past job history, income, and similar identifiers associated with residential real estate leasing activities.

 

• Inferences Drawn from Other Personal Information:

As an example: Profile reflecting preferences, characteristics, predispositions, behaviors, and identifiers associated with residential real estate leasing activities.

 

II. Exceptions to Personal Information

 

Personal information excludes publicly available information from government records, de-identified or aggregated consumer information, and information excluded from state privacy law scope such as health information covered by HIPAA and information covered by sector-specific privacy laws.

 

III. Sources of Personal Information

 

Total Association collects personal information from Clients, their owners, residents, and prospective renters or buyers directly, as well as from credit reporting agencies, payment processors, banks, and website analytics services integrated with Total Association Services.

 

IV. Use and Processing of Personal Information

 

In delivering the suite of Total Association Services, Total Association primarily functions as a service provider contracted by our CLIENTS. As a service provider, Total Association does not exercise control over the personal information processed on behalf of our CLIENTS. Our CLIENTS are responsible for the collection and control of all such personal information, and Total Association is obligated to provide products and services in accordance with Clients’ contractual provisions and instructions concerning data collection, privacy, processing, and security. Total Association does not assume responsibility for the data collected and entered by our CLIENTS into the Total Association products.

 

Consequently, we may use or disclose the personal information we collect for one or more of the following purposes:

 

• To fulfill the intended purpose for which the personal information was collected and to provide the requested Total Association Services.
• To integrate with services offered by Total Association or third-party service providers contracted by Clients.
• To distribute communications and legally required notices regarding the status of Total Association Services via phone, email, and SMS text.
• To maintain the upkeep, enhancement, research, development, security, support, and optimization of Total Association Services.
• To ensure compliance with federal and state laws related to software-as-a-service, background screening, financial institutions, and money services businesses.
• To create, maintain, customize, and secure Total Association Services user accounts.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To assess or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Total Association’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Total Association is among the assets transferred.

 

Total Association commits not to collect additional categories of personal information or use the collected personal information for materially different, unrelated, or incompatible purposes without providing notice. Additionally, the processing of sensitive personal information by Total Association is restricted to activities necessary for the delivery and performance of Total Association Services on behalf of our CLIENTS and end users.

 

V. Personal Information Disclosure

 

Total Association does not sell personal information and may disclose it to third parties, including service providers and vendors, only to the extent necessary to support Total Association Services requirements. Total Association does not have direct control over the privacy policies and practices of Clients or other third-party entities.

 

VI. Personal Information Rights and Choices – State Privacy Rights

 

Residents of certain states (California, Virginia, Colorado, Connecticut, and Utah) have specific rights regarding their personal information. This section outlines rights related to accessing, updating, obtaining specific information, portability, and deletion of personal information.

 

Accessing and Updating Personal Information

 

If your personal information is determined to be outdated, incomplete, or inaccurate, you can access and update it by logging into your Total Association Services account or contacting your property manager. Should you require verification that your requested changes have been completed and such verification is not readily displayed in your Total Association Services account, you may request confirmation at the email address listed below (See “Contact Us”).

 

Access to Specific Information Regarding Personal Information Use/Disclosure and Portability

 

You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. In most circumstances, this disclosure request should be submitted to the property manager overseeing your apartment community or rental property. As mentioned earlier, Total Association acts solely as a service provider for our Clients, and we do not control the collection, use, and disclosure of your personal information.

 

However, if you maintain a direct relationship with Total Association, consumer requests should be submitted directly to Total Association via the approved channels listed in Section VII below. In response to a verifiable consumer request for these services, we will disclose the following information for the relevant Total Association Services:

 

• The categories, specific types, and sources of personal information we collected about you.
• Our business purpose for collecting the personal information.
• The categories of third parties with whom we share that personal information and the purpose for the disclosure.

You also have the right to request a copy of this personal information in a readily usable format that is transferable to other entities, commonly known as “data portability.” If you make a data portability request, Total Association may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.

 

Deletion of Personal Information

 

You have the right to request the deletion of any of your personal information that we have collected and retained, subject to certain exceptions. Under most circumstances, this deletion request should be submitted to the property manager overseeing your apartment community or rental property. As previously mentioned, Total Association operates solely as a service provider for our CLIENTS, and we do not control the collection, use, and disclosure of your personal information.

 

However, if you maintain a direct relationship with Total Association, consumer requests should be submitted directly to Total Association via the approved channels listed in Section VII below. Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:

 

We may deny your deletion request if retaining the information is necessary for Total Association or our service providers to:

1. Complete the transaction for which we collected the personal information, provide the Total Association Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug Total Association Services to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. 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.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or our CLIENTS.
7. Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

VII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights

 

Consumer requests are generally directed to property managers. However, individuals with a direct relationship with Total Association may submit requests directly to Total Association via provided channels below.

 

Only you (or someone legally authorized to act on your behalf) may submit a verifiable consumer request related to your personal information. Additionally, you have the right to make a verifiable consumer request on behalf of your minor child.

 

You are limited to making a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

 

• Provide sufficient information enabling us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
• Describe your request with enough detail to allow us to properly understand, evaluate, and respond to it.

 

Please be aware that we cannot respond to your request or provide personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm that the personal information pertains to you. Making a verifiable consumer request does not necessitate creating an account with us. However, requests made through your password-protected account are considered sufficiently verified when they pertain to personal information associated with that specific account.

 

The personal information provided in a verifiable consumer request will only be used to verify the requestor’s identity or authority to make the request.

 

VIII. Consumer Request Responses and Timelines

 

Total Association confirms receipt of requests within ten (10) business days and aims to respond within forty-five (45) days. A possible extension of up to an additional 45 days may occur, with notice provided.

 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

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.

 

IX. Personal Information Sales and Sharing – Opt Out Rights

 

Total Association does not sell personal information. If practices change, affected individuals will receive advance notification and the option to opt in/opt out in accordance with regulatory requirements.

 

X. Non-Discrimination

 

Total Association does not discriminate against individuals for exercising privacy rights and refrains from engaging in discriminatory practices.

 

XI. Other California Privacy Rights

 

California residents are entitled to specific privacy rights under laws separate from the CCPA/CPRA. These rights include those outlined in California’s “Shine the Light” law (Civil Code Section § 1798.83), permitting residents to request certain information about the disclosure of their personal information to third parties for direct marketing purposes. To make such a request, please send an email to info@Total-Association.com.

 

XII. Cookies, Web Beacons, and Other Technologies – Do Not Track

 

Total Association utilizes cookies and tracking technologies. Our product relies on those to function properly. If you do not agree with that, please refrain from using the Total Association products.

 

XIII. Third Party Links to Other Sites

 

Total Association Services may contain links to third-party service providers contracted by Clients. These linked services are operated by unaffiliated third parties with distinct and independent privacy statements, terms of use, and associated notices or disclosures regarding their practices in handling information. We cannot assume responsibility for the information handling practices of these independent parties and strongly encourage you to review their practices before disclosing any information.

 

XIV. Data Security

 

Total Association implements security measures to protect processed information. While no security program is 100% secure, Total Association strives to safeguard personal information.

 

XV. Children’s Online Privacy

 

Total Association Services do not target or attract children under the age of 13 for the online collection of personal information.

 

XVI. Changes to Our Privacy Statement

 

Total Association reserves the right to amend this privacy statement at its sole discretion. Changes will be posted on relevant platforms with the effective date. Continued use of Total Association Services implies acceptance of changes.

 

XIV. Contact Us

 

For questions or concerns about this Privacy Statement, contact Total Association via the provided methods.

 

Via US Postal Service at:

Total Association

Attn: Privacy (Legal)

1787 NW 38th av.

Fort Lauderdale, FL 33319

 

OR Via email at: info@Total-Association.com