Privacy Policy
PRIVACY
Last Updated: January 1, 2025
FirstService Residential (“Company,” “we,” “us,” or “our”) provides this Privacy Policy (this “Policy”) to describe our privacy practices regarding personal information we collect from individuals (“you” or “your”), including when you visit our offices, or when you visit our websites or our mobile applications (collectively, the “Sites”).
If you do not agree with all of the terms of this Policy, you should not use, browse, or otherwise access any of the Sites. By browsing or using any of the Sites, you agree to our collection and use of your personal information as described in this Policy and in our Terms of Use.
This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.
Definition of Personal Information
For the purposes of this Policy, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably linked , directly or indirectly, with a particular individual or household. It does not include personal information that is publicly available
Notice at Collection: Personal Information We May Collect About You
This section describes the categories of personal information we collect about you and may have collected about you in the past 12 months:
- Personal identifiers: Name, physical address, email address. phone numbers and other contact information, whether you live in a community managed by us, and IP addresses.
- Professional information: Job title, name and contact information of employer or entity you represent; status as a board member of your homeowner’s association or residential community; name and location of the homeowner’s association or residential community you represent.
- Audio and Visual information: CCTV recordings of you in the public areas on those properties on which our clients operate security cameras; voice recordings of calls made to our customer service line.
- Internet or other electronic network activity: Information regarding your browsing history, visits to and interaction with our Sites and advertisements, information about visits to our social media accounts, device IDs.
Note: whether we collect these categories of personal information is dependent on how you interact with our company. For example, if you neither called our offices on the phone nor were physically present in a facility with video cameras, we would not have collected audio or visual information.
Notice at Collection: Purpose for the Collection of Personal Information
With respect to each of the categories of personal information above, this section describes the reasons we may have collected and used such information in the past 12 months and why we may continue to collect and use it.Provide You with Services on Behalf of Our Clients: We use your personal information to provide a full range of property management services to our clients, including: management of facilities, public grounds and common areas in communities; contacting you and responding to your requests and inquiries; facilitating sales and leasing/rentals; processing payments; responding to requests for documentation associated with the association or ownership/leasing/rental of real property within each community; providing marketing; facilitating the operation of association boards of directors; providing customer service; operating a call-in center; distributing newsletters and similar materials; compliance with applicable laws, regulations or codes of practice.
Provide You With Additional Services: In addition, we collect personal information in order to market and provide information about our services and company; improve the Sites by, among other things, understanding who and how they are used; compliance with applicable laws, regulations, or codes of practice.
Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection. We may use personal information, for fraud prevention, or to protect our company, affiliates, our clients, or our Sites, or a third-party website or platform.
Compliance with Laws and for Protection: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property, or safety of others.
Marketing and Recruiting: We use personal information to inform you about the Company and the services we offer. We may also use your personal information to send you information about career opportunities.
Communications: We use personal information to communicate with you about your account or our relationship. We may contact you about your use of our Sites. We may contact you about your account or feedback. We might also contact you about this Policy or the Sites’ Terms of Use.
Debug and Identify Errors: We use your personal information to debug and identify and repair errors that impair existing intended functionality.
Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.
For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.
Notice at Collection: Categories of Personal Information We Sell or Share or Use for Targeted Advertising
When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of “sell” under select state privacy laws), share them for purposes of cross-context behavioral advertising, or use them for targeted advertising: personal identifiers (IP address); and internet or other electronic activity information.
These categories of personal information are sold to or shared for cross-context behavioral advertising or targeted advertising with, advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the services we provide. We do so by allowing third parties to place cookies or other tracking technologies on our Sites that may collect information about your online activities over time and across different websites or applications. For more information about the use of cookies and other tracking technologies, see the section “Cookies and Other Tracking Technologies” below.
To opt out of such sales/sharing/targeted advertising, click here.
We do not sell or share for cross-context behavioral advertising or targeted advertising any of the other categories of personal information we collect.
Information collected through our SMS Program(s) won’t be shared with third parties for their marketing purposes.
Notice at Collection: Retention Periods
Sources of Collection
Use or Disclosure of Sensitive Personal Information
We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our services.
No Profiling to Facilitate Decisions with Legal or Other Significant Effects
We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
In the last 12 months, we may have disclosed the personal information described above with the following categories of entities for business purposes, as described in the chart below.
Categories of Consumers’ Personal Information | Categories of Entities to Which We Disclosed Personal Information for a Business Purpose |
Personal identifiers: Name, physical address, email address, phone numbers and other contact information, whether you live in a community managed by us, device IDs and IP addresses. | Service providers that provide: customer relationship management (CRM) services; internet, IT, and telecommunications services; analytics information; advertising and marketing services; printing, mailing or other communications services; legal and accounting services. |
Professional information: Job title and name of employer; status as a board member of your homeowner’s association or residential community; name and location of the homeowner’s association or residential community you represent. | Service providers that provide: customer relationship management (CRM) services; printing, mailing or other communications services; advertising and marketing services; legal and accounting services. |
Internet or other electronic network activity information: Device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements. | Service providers that provide: customer relationship management (CRM) services; internet, IT, and telecommunications services; analytics information; advertising and marketing services. |
Audio or Visual information: CCTV recordings of you in the public areas on those properties on which our clients operate security cameras; voice recordings of calls made to our customer service line. | Service providers that provide: customer management (CRM) services; legal services |
Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; process payments; fulfill orders and transactions; engage in advertising and marketing; operate our IT systems and secure our systems; prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.
Additional Information About How We May Disclose Personal Information
With respect to each of the categories of personal information we collect as noted above, we may also collect and share personal information with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to the Sites, or the public. We may also share personal information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with an actual or contemplated sale, merger, or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
Cookies and Other Tracking Technologies
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.When you visit our Sites, we may place a “cookie” or other online tracking devices (e.g., web beacons) that recognizes you. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with the Sites. We may use cookies or similar tracking technologies to capture information about the use of our Sites, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies.
We use Google Analytics to evaluate the use of our Sites. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy
Additionally, we also allow third parties to set cookies and other trackers when you visit our Sites which may collect information about your online activities over time and across different websites, applications, or other online platforms. These third parties may use such information to, for example, provide analytics information or to offer products or services in which you may be interested, and they may combine information about your activities across different websites, applications, or other online platforms to do so.
Personal Information of Minors
Our Sites are not directed to minors under the age of 13. Additionally, we do not knowingly collect or sell personal information of minors under 16.Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not comply with automated browser signals regarding tracking mechanisms, which may include "do not track" instructions.Security
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring, and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.Third Party Sites / Social Media Buttons
From time to time, we may advertise certain third party services through the Company’s Sites which we feel will be helpful or relevant to you (collectively, “Third Party Services”). Third Party Services may include, but are not limited to, banking and financial services, insurance-related services, payment processing services and property management-related services.When you click on a link for a Third Party Service, your Web browser will be re-directed to the third party provider of the Third Party Service that you selected. Third party providers may have privacy policies that are different than this Policy, and you should carefully read the privacy policies of those vendors prior to releasing any of your information to them, financial or otherwise.
We do not endorse, warrant, or guaranty the nature, scope, quantity, availability, or quality of any Third Party Services. We make you aware of such services for your convenience. If you have any questions, comments, or concerns about any Third Party Service, you are instructed to contact directly the vendor offering the service.
Additionally, our Site may direct a user to other third parties that assist us in providing services to our clients, such as by operating a website to process payments. It also includes social media buttons. When you navigate to third-party websites or social media platforms through our Sites, the privacy policies and terms of use for those websites and platforms exclusively govern the personal information you may disclose to those third parties.
Changes to this Privacy Policy
We reserve the right to amend, alter, or otherwise change this Privacy Policy in our sole and absolute discretion. If we make material changes to the Privacy Policy, we will post notice on the Sites. Further use of the Sites following any such notification constitutes your agreement to follow and to be bound by the amended Privacy Policy.Accessibility Policy
The Company is committed to ensuring that our communications, including our Sites, are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us [email protected]US State Data Privacy Rights
Consumer Rights Under Comprehensive US State Data Privacy Laws
We may be subject to state privacy laws in California, New Jersey, New Hampshire, Nebraska, and Virginia. These laws give state residents various rights with respect to many types of personal information we collect about them, with some exceptions. The rights provided under these laws are similar in many respects, with some differences from state to state. We list below the rights that may be applicable to our business under these laws:
Right to Know: The right to confirm whether or not we are processing a resident’s personal information and to access such data. Laws in some states provide the right to know more detailed information.
- California’s privacy law gives residents the right to request the following additional information collected since January 1, 2022: Categories of personal information we have collected about them; categories of sources from which such personal information was collected; categories of personal information that the business sold or disclosed for a business purpose about the consumer; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information.
Right to Access / Copy: The right to access or request a copy of the personal information we have collected from the resident, subject to certain exceptions.
Right to Delete: The right to request deletion of their personal information that we have collected from or about the resident and to have such information deleted, subject to certain exceptions.
Right to Correct: The right to request that we correct inaccuracies in the resident’s personal information, taking into account the nature of personal data and purposes of processing such information. This is not a right under the Utah data privacy law.
Rights to Opt Out: Various rights to request that we stop using the resident’s personal information for one or more of the following purposes:
- Sale of Personal Information: The right to request that we stop selling f their personal information, consistent with the definition of “sale” in each law. This is not a right available under the Utah data privacy law.
- Targeted Advertising: The right to request that we stop processing their personal information for targeted advertising, subject to exceptions in some state laws. This is not a right that is specified under the California data privacy law.
- Sharing for Cross-Context Behavioral Advertising: California’s law provides the right to request that we stop sharing personal information for cross-context behavioral advertising.
Please note, California’s law is the only law that applies to all state residents, irrespective of the context in which they interact with us (e.g., a customer, a business contact, a vendor). Laws in other states apply only to people when acting in an individual or household context.
California Shine the Light
With reference to California Civil Code Section 1798.83, also known as the “Shine the Light” law, we allow California residents to opt out of the disclosure of personal information to third parties for those third parties’ direct marketing purposes. To exercise that opt-out option, click here.
We Are Service Providers to Our Clients
When we collect and process personal information on our clients, we act as their “service provider,” as that term is defined in the CCPA. We do not disclose, use, or retain any of the personal information we collect when collecting or processing Personal information on behalf of our clients for any purpose other than the specific purpose of performing the services specified in our contracts with our clients.
This means that the Company does not own the personal information we collect on behalf of our clients (i.e., your homeowners’ or condominium association). Please be advised that homeowners/condominium associations are not subject to CCPA (and therefore are not required to provide these rights), as they are not-for-profit entities. Nevertheless, you may always review the information in your Resident Portal.
Exercising Your Rights
We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided under the requestor’s state law as of the effective date of that law. The laws in some states listed above may not be in effect as of the date of this Privacy Policy.
To exercise rights to know, access/copy, delete, correct, submit a request here or contact us at [email protected] or 888-247-2381. We will provide a substantive response to these requests within 45 days of the date on which we receive your request. If we require additional information or time to process your requests, we will contact you.
To exercise opt-out rights, submit your request here
Opt-out Preference Signals
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.
We recognize the Global Privacy Control signal for California residents based on IP address and do so at the browser level and, therefore, it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information.
Exercising Your Rights Using Authorized Agents
Agents may submit opt-out requests on behalf of individuals under some state data privacy laws. California residents can designate an agent to submit all other types of requests. If the agent submits an opt-out request on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. Agents can submit opt-out requests here
If you are a California resident and you use an agent to submit other types of requests, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. You will also be required to verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Agents can submit requests on behalf of California residents (other than opt-out requests) here
Verification of Requests
When you exercise rights other than opt-out rights, we will take steps to verify your identity. We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
When We Do Not Act on a Request – Appeal Process
In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.
Additionally, under some state laws, you have the right to appeal our decision by contacting us within 30 days after your receipt of our decision. We will provide additional details about how to appeal in our response to you.
Our Commitment to Honoring Your Rights
If you exercise any of your rights described in this Privacy Policy, we will continue to treat you fairly and you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.Contact Us
If you have any questions about our Privacy Policy, or to request a copy of this Privacy Policy in another format, you may email us at [email protected] or at the following address:ATTN: Privacy Officer
c/o FirstService Residential
1855 Griffin Rd.
Suite A-330
Dania Beach, FL 33004
888-247-2381
When contacting the Privacy Officer please be sure to provide your name, your physical address, your email address, your phone number (if you wish to be contacted by telephone) and a description of the question or issue that you wish to have resolved.