Liberty Military Housing Privacy Policy

This Privacy Policy describes how Liberty Military Housing a Multifamily Holdco LLC and LMH Holdings (together, "Liberty") and all of our respective affiliates, subsidiary and parent companies ("Affiliates", and collectively with Liberty, "we," "us," "our") collects, uses, shares and protects personal information of users ("you," or "your") of our service centers, websites, software applications (including mobile applications) operated by us or on our behalf ("Services"). This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.  You can jump to particular topics by going to the headings below:

 

How We Collect Information

Use And Processing Of Information.

Sharing Of Information.

Your Choices.

How We Protect Personal Information

Additional Information For California Residents

Other Important Information

Contact Information

 

How We Collect Information

 

We collect information about you in a variety of ways depending on how you interact with us and use our Services, including:

 

  • Directly from you when you provide it to us, such as when you to fill out a job application, rental application, sign a lease, request maintenance or repair services,  attend our events where we collect information about you, or contact us by phone, e-mail, or otherwise interact with our Services.
  • Automatically when you interact with our Services or emails through the use of cookies, server logs, and other similar technologies.
  • From other sources, including, for example, third parties, business partners, Affiliates, or publicly available sources.  For example, in order to manage our military housing programs, we may collect information from the Government Family Housing Office or from our privatized military housing partners. If you apply for a job with us we may receive information from third-parties that we use to conduct background checks.

 

For a list of the categories of personal information that we collect see the chart below in the Sharing of Information Section.

 

Use And Processing Of Information.

 

The following provides examples of how we use the information that we collect. 

 

Context

Types of Data

Primary Purpose for Collection
and Use of Data

Account Registration

We collect your name and contact information when you create an account.  We also collect information relating to the actions that you perform while logged into your account.

We collect this information to communicate with you about your home, to manage our properties and our customer relationship with you.

Business Contact Information

We collect the name, and contact information, of our business contacts and their employees with whom we may interact. 

We collect this information to communicate with our business contacts concerning normal business administration such as projects, services, and billing.

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.

We collect this information to analyze how our Services are being accessed and used.

Cookies and Third Party Tracking

We may place tracking technology on our website that collects analytics or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests on our website, or on other websites. 

We collect this information to customize the advertising and content you see on our services.  You may opt-out of our use of information for these purposes by completing the form available at here: https://info.livelmh.com/ccpa

Financial Information

During the leasing application process we collect financial information such as credit or debit card information, bank information including bank account number and routing number.

We collect this information to obtain payment for services that we provide to you, including your rental payments.

Distance Information in Mobile Apps

When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products. 

We collect this information to provide our services to you specific to your location.  In some contexts our use of distance information is also based upon your consent to provide us with geo location information.

Email Interactions

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We collect this information to understand how you interact with our communications to you and for  our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you.

Job Application and Employment

If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information is required for employment.

We use information about current employees to perform our obligations to employees.  In some contexts, we are also required by law to collect information about employees or applicants. 

Providing Feedback/ Requesting Support

If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.

We collect this information to review and improve the Services to ensure that we are meeting your needs and requirements.

Rental Applications

When you submit a rental application we collect credit-related information such as your credit history, your job and occupational history, financial information, Social Security Number, Address history.

We collect this information to process and run credit checks in connection with your rental application.

Mailing List

When you sign up for one of our mailing lists we collect your email address or postal address.   

We share information about our products and services with individuals that consent to receive such information. 

Maintenance Requests

We collect your name, billing address, shipping address, e-mail address, and phone number when you place a maintenance request.

We use your information to respond to and fulfill your requests for maintenance and services. 

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores.

We collect this information to provide the mobile application services and analyze how you interact with the mobile apps.

Unit, Rank and Pay Grade  Information

When you submit a leasing application or register for our Services we collect information about the organization that you are assigned to, your rank, and pay grade.

We collect this information to process your leasing application and place you in living quarters and determine your eligibility for our military house programs.

Marital and Dependent Information

When you submit a rental application or sign a lease with us, we may collect information about your marital status, information about your dependents and spouse.

We collect this information to place you in military housing that appropriately accommodates your family and for our internal business and compliance purposes.

Public Health and Safety

In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, family member, or other individuals under the employee’s care.

We collect this information to protect the health and safety of our employees and guests. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. We also collect this information to comply with the laws in the jurisdictions in which we operate.

Surveys

When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We collect this information to understand your opinions, and collect information relevant to our organization.

Website interactions

We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms.  This may also include information about your device or browser.

We collect this information to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.

Web logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We collect this information to monitor our networks and the visitors to our websites.  Among other things, it helps us understand which of our services is the most popular.

 

Sharing Of Information.

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations:

 

  • Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. 
  • Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  • Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws including Uniform Code of Military Justice.  We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
  • Public.  Some of our websites may provide the opportunity to post comments, or reviews, in a public forum.  If you decide to submit information on these pages, that information may be publicly available. 
  • Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners.  If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them.  Their use of your information is not governed by this privacy policy.
  • Service Providers. We share your information with service providers.  Among other things service providers help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

 

Some states require that organizations disclose whether the following categories of personal information are collected, disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration.” The table below indicates the categories of personal information we collect and transfer in a variety of contexts.  Note that we do not “sell” your personal information.  To opt out of “sharing” as that term is defined under California law, please complete the form available at Do Not Share my Personal Information.

 

 

Categories of Personal Information We Collect

To Whom We Disclose Personal Information for a Business Purpose

To Whom We Share for Targeted Advertising

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Internet service providers
  • Other service providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks
  • Advertising networks

 

Government Issued Identification – this may include social security number, driver’s license number, military or other government ID or state issued identification number, passport number.

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

 

 

Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Payment processors and financial institutions
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

 

Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

 

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.

  • Affiliates or subsidiaries
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

Commercial information – this may include information about your personal property (e.g., vehicle or pet information) products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other service providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Advertising networks

 

Geolocation data

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other service providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms

 

Audio, electronic, visual, thermal, olfactory, or similar information

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other service providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Advertising networks

 

Professional or employment-related information such as your rank, branch of service, duty postal code, paygrade, unit code, and duty status.

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

 

Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, , insurance policy number

 

 

  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to provide you with our Services, comply with law or prevent illegal or fraudulent activity
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms

 

 

Some jurisdictions give you a right to know what categories of sensitive information we collect about you, the purpose of that collection and how we disclose that information:

 

Categories of Sensitive Personal Information We Collect

Purposes for which it is collected

Is information sold or shared for the purpose of cross-context behavioral advertising

Social security, driver’s license, state identification card, or passport number.

 

  • To process your application and leasing details
  • Required by law from employees
  • Eligibility for employment

No

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

  • To process your leasing applications.
  • To allow you to access your profile.

No

Precise geolocation.

  • To process your maintenance requests and provide tailored services to you.

No

Racial or ethnic origin, religious or philosophical beliefs, or union membership.

  • To comply with our legal obligations in providing you housing.

No

Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication

  • We monitor the work-related email accounts of our employees.

No

Health information such as mental or physical disability.

  • To place you in appropriate and accessible housing.

No

Sex life or sexual orientation

  • We do not collect this data directly but this information may be implied from your rental application or information provided by the Government Family Housing Office.

No.

 

 

Your Choices.

Some jurisdictions give you a right to make the following choices regarding your personal information:

 

  • Access To Your Personal Information. You may request access to your personal information (or confirmation that we have information about you) by contacting us at via the instructions provided below. If required by law, upon request, we will grant you access to the personal information that we have about you. You may also have the right to request that we provide your information in a portable, machine-readable format. Note that in some jurisdictions you may also be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. 
  • Changes To Your Personal Information. We rely on you to update and correct your personal information.  Most of our websites allow you to modify or delete your account profile.  If our website does not permit you to update or correct certain information, you can contact us at the phone number described below or form provided below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law. 
  • Deletion Of Your Personal Information.  Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.  You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below.  If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes. 
  • Objection to Certain Processing.  You may object to our use or disclosure of your personal information by contacting us at the phone number or form provided below. 
  • Online Tracking.  We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties.  You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.
  • Promotional Mailings.  If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by contacting us at Info@LiveLMH.com with "NO SNAIL MAIL" in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  • Promotional Text Messages.  If you opt-in to receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
  • Revocation Of Consent.  If you revoke your consent for the processing of personal information then we may no longer be able to provide you with the Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the phone number or form provided below.
  • Opt-Out of Sharing Your Personal Information. As we stated above, we do not “sell” your information as defined under California law. However, we do engage in behavior advertising which may be considered “sharing” under applicable law. If such laws apply to you, you may opt-out of the sharing of personal information, you may do so by accessing the form available at our       Do Not Share My Personal Information page.  

You may exercise the rights described above through our online request form or by contacting us as indicated in the “Contact Information” section below.  We do not discriminate against individuals that exercise rights conferred by law.  If you disagree with how we handled a request, you may appeal our decision by contacting us via email with the subject line “Appeal.”

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will contact you via phone to ask for information such as your name, address or other information necessary to verify that you are the person about whom we collected Personal Information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of a completed online request form indicating that you have authorization to act on the consumer’s behalf.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

 

Some of our websites permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

 

Additional Information For California Residents

California law requires us to disclose the following information related to our privacy practices:

 

  • California Shine the Light.  If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. 

 

Other Important Information

The following additional information relates to our privacy practices:

  • Third Party Applications/Websites.  We have no control over the privacy practices of websites or applications that we do not own.
  • Changes To This Privacy Policy.  We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.  Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
  • Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

 

Contact Information

 

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

Email: Info@LiveLMH.com

Toll-free number: 844-754-2272

 

Effective Date: January 1, 2020

Last Update: December 31, 2022