DISTRIX LLC PRIVACY POLICY

Last Updated: January 27, 2020

Distrix LLC (“Distrix” or “we”) understands that you care about how we collect, use, and share information when you interact with us, and we value the trust you place in us. Please read this Privacy Policy (the “Policy”) carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to download, register with, or use our Services (as defined herein). By clicking the “I Agree” button below, you agree to this Policy.

This Policy may change from time to time. We will post any changes, and changes will become effective when they are posted. The date this Policy was last revised is identified at the top of the page. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

This Privacy Policy explains:

This Policy applies to Distrix’s Services and any information we collect when you interact with us directly or through other services. Please note that Distrix does not control the privacy practices of landlords or other third parties with whom you may choose to share your information.

For questions about our privacy practices, contact us at:

Distrix LLC

28 Liberty Street

6th Floor

New York, NY 10005

Phone: 877-DISTRIX

E-mail: privacy@distrixnyc.com

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Overview of Our Practices

The type of information we collect from and about you will depend on the nature of your interactions with Distrix.

Who You Are

What We Collect

What We Do With It

Visitors to our website

If you’ve come here to learn more about our services, certain information about your use of our Services is automatically collected. See Additional Information About Our Use of Tracking Technologies, below.

If you contact us via e-mail or chat, we may keep a record of that correspondence and any contact information provided.

We use this information to ensure that our website functions properly, to improve our products and Services, and to develop our promotional outreach.

Prospective Tenants

When you create an account, we ask for certain contact and demographic information. We also continue to collect information about your use of our Services, including the website and mobile app, whenever you log in.

When you decide to create an application to rent an apartment, we ask you to provide additional information in order to allow landlords to evaluate your application. This includes information about your professional experience, income, and rental history. We then, with your consent, go through a process of collecting information about you either from you directly or from third parties, such as credit bureaus and your bank (through an aggregation service) in order to verify the information in your application. We walk you through this process in detail when you create an application and seek your consent at every step of the way.

When you make a payment on the Services, we use a third-party service provider to process your payment. Distrix does not have access to your credit card number, nor is your payment information stored by either us or the processor.

We use this information to enable you to create applications for rental properties and to provide you service-related communications.

We also use the information to enable us to interact with you, including to send you direct marketing communications if you consent to us doing so.

We compile your application information and provide it back to you for review. At which point, you can choose to proceed with the application and send the completed application to the landlord. If you think the data that we have collected is incorrect, you can let us know and we will review the issue pursuant to our Dispute Policy.

If you want us to delete any or all your information, see Your Options and Rights, below.

We may combine this information with other information we collect from your interaction with the Services or from other companies, as discussed further in the Combination of Information section below.

Distrix will not sell, lend or otherwise share your information with third parties.

Landlords/Property Managers

When you create an account to list a property, we collect from you your business contact details. We also collect from you information about any properties you list.

We may collect additional detailed information about you, your business, and your properties in order to verify your identity. This may include information we request from you directly or collect from public records.

When deciding whether to submit an application, prospective tenants can view the information about a rental property that you provide to us. Prospective tenants can also view your business contact details that you provide to us.

Any additional information we collect about you or your business, including to verify your identity, will not be shared on the Services.

We also use the information to enable us to interact with you, including to send you direct marketing communications.

How We Use and Protect Your Information

We may use the information we collect from you for the following purposes:

  • To provide you with our Services, including to allow you to create applications for rental properties send related communications.
  • To enable additional features on our Services and to provide you with a personalized service.
  • To enable us to interact with you, including to send you direct marketing communications if you consented to us doing so.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To provide you with the best service and to continuously improve our Services and how we interact with you, including understanding our customer base and purchasing trends, and understanding the effectiveness of our marketing.
  • To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.

We may also disclose your information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts between you and us, including the Services’ Terms of Use, and for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Distrix, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to law enforcement per the terms of the User Agreement or if we, in our reasonable and sole discretion, deem it necessary.

There may be other instances not included within this Policy where we may use or collect your information and data. Such instances will only be at your direction or with your consent.

How We Secure the Information We Collect From or About You

We have implemented reasonable measures and practices designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure . Any information we collect will be encrypted using industry standard technology.

We take reasonable steps to protect the information from unwanted use and disclosure. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal information from unauthorized access, use, or disclosure . All supplied information is transmitted via Secure Socket Layer (SSL) technology. However, no company can fully prevent security risks and as such you understand and agree that mistakes may happen and that bad actors may defeat even the best safeguards. If a breach in security of your information occurs, we will notify you using the e-mail you provided.

The safety and security of your information also depends on you. Where you have chosen a password for access and use our Services, you are responsible for keeping this password confidential We ask you not to share your password with anyone. If you use biometric technology (such as your fingerprint) to access and use our Services, or if this feature is available to unlock your mobile device, you should be aware that any biometric information you register, including those of others, may be able to access your personal information in the Services.

Unfortunately, the transmission of information over the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information stored in, or transmitted by, the Services or the servers we use to provide you with our Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

Our Sharing of Your Information

The purpose of our Services is to facilitate the information gathering process of a residential rental application, and to enable the necessary sharing of information between individuals seeking to rent properties and the landlords/property managers who oversee those properties. As described above, the prospective tenant has full control over whether to participate in this process and can decide not to proceed at any time. Application requirements are set by the landlords, not Distrix. This means that an individual may not be able to proceed with using the Services to create and submit their rental application, if they provide only some, but not all, of the information requested by a particular landlord.

Distrix also shares the information collected with service providers as necessary to perform functions on our behalf such as: website, software, data storage, content management, database management, technical integration, analytics, site optimization, conducting customer surveys, and payment processing. In some cases, such as payment processing, the service provider may collect the data directly from you on behalf of Distrix. Distrix requires that third-party service providers use any personally identifiable information provided to them for the limited purposes of providing Distrix with contracted services.

Distrix will not share data about you from a third party with anyone other than service providers and the landlords you select. However, Distrix may share information collected directly from you with additional parties:

  • Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the third party to collect some information about you through digital cookies they place on your device and other tracking mechanisms. In some cases, the third party may recognize you through its digital cookies even when you do not interact with their application. Please visit the third parties’ respective privacy policies to better understand their data collection practices and controls they make available to you.
  • Third Parties Involved in Advertising: We partner with third parties who assist us in serving advertising regarding our Services to others who may be interested in the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. Distrix will not share information that identifies you by name with unaffiliated third parties for their own uses; however, such third parties may, with sufficient data from other sources, be able to personally identify you.

Additional Information About our Data Collection and Sharing Practices

  • Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies, and analytics providers. These third parties will not be able to relate this data to identifiable individuals and we may disclose aggregated information and data about users of our Services, and information that does not identify any individual, without restriction.
  • Combination of Information: We may combine information from the Services together and with other information we obtain from our business records.
  • Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same way as described in this Policy.
  • Cross-border Transfer of Data: Distrix is based in the United States and you acknowledge that the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us from outside of the United States, you understand that we may collect, process, and store your personal information in the United States. The laws in the U.S. regarding personal information may be different from the laws of your state or country.

YOUR OPTIONS AND RIGHTS

Please visit the Account Login page to provide or update your contact information.

When you create an application, that application will be accessible within your account for only a limited time. To protect you, we delete application data when it is no longer necessary or when 6 months passes without you using the Services. Your account, including your contact information, will remain active, but you can request deletion by contacting privacy@distrixnyc.com.

You may also send us an e-mail at privacy@distrixnyc.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information if it is necessary for us to maintain the personal information for the purposes of completing a transaction, providing a service you requested, or reasonably anticipated within the context of our ongoing business relationship. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If at any time you would like to unsubscribe from receiving future e-mails, you can click the unsubscribe link at the bottom of any e-mail bulletin or e-mail us at privacy@distrix.com and we will promptly remove you from all correspondence.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.ADDITIONAL INFORMATION ABOUT OUR USE OF TRACKING TECHNOLOGIES

When you interact with the Services, certain information about your use of our Services is automatically collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. Distrix relies on third-party partners to provide many features of our sites and services using data about your use of the sites. We, including through these third-party partners, use cookies for the following purposes:

  • Site Operations: Enabling features that are necessary for providing you the services on our site, such as identifying you as being signed in, tracking content views, remembering your preferences
  • Analytics: Allowing us to understand how our services are being used, track site performance and make improvements
  • Personalized Advertising: Delivering tailored advertising to you across services and devices and measuring the effectiveness of ads
  • Social Media: Enabling the sharing of content from our services through social networking and other sites

The type of data we collect using cookies includes:

  • Details of your visits to our site and information generated in the course of the use our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
  • Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type.
  • Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.

We may also use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Device Information: We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, version of our Services, and the device's telephone number.
  • Location Information:Our mobile application collects real-time information about the location of your device, including geolocation information provided by your wi-fi connection or GPS services on your mobile device.

We may also collect automatically your browsing history, and any other records regarding your use of the Services. If you do not want us to collect this information, do not use the Services and delete our mobile application if you have already downloaded it. To clarify, we will track your online or mobile-application activities by using the third-party services or other online services.

Below is a list of some of our third-party partners, with links to more information their use of your data and how to exercise your options regarding tracking. We do not control these third parties' tracking technologies or how they may be used.

Category

Partner

Further Information

Analytics

Google

How Google users information from sites or apps that use our services

Site Operations

AWS Cognito

Privacy Notice

In addition to our third-party partners, some hyperlinks and images on our website or mobile application may link to other third-party websites. You should be aware that these third-party websites are not controlled by Distrix and are not subject to this Policy. You should check the privacy policies of these individual sites to see how your information will be collected and used.

Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the third-parties who conduct tracking through our Services.

You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for theNetwork Advertising Initiative, theDigital Advertising Alliance, and theEuropean Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.

Your browser or device may include “Do Not Track” functionality. At this time, Distrix does not respond to browser “Do Not Track” signals.


CHILDREN UNDER THE AGE OF 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to Distrix. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to Distrix on or through any of our Services, including but not limited to our website and mobile application or on or through any of their features, register for our Services, make any purchases from Distrix, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 13, please contact us at privacy@distrixnyc.com.

CHANGES TO THIS POLICY

As noted above, we may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. We will provide notice of material changes to the policy, either by posting a notice on our websites, by sending an e-mail, or another reasonable method as determined in our sole discretion. Your continued use of our Services following the posting of any changes will mean you accept those changes.