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Carson Privacy Policy

Last Modified: July 2024

Any references to "Carson," "we,” “our” or “us” refer to Carson Living, Inc. Carson respects your privacy as a user of this site. This Privacy Policy explains what personal information we collect from you, how we use that information and our legal basis for doing so. This policy also details the choices available to you regarding our use of your personal information as well as how you can access and update this information. This Privacy Policy will be easy to find on the Carson public homepage and on any page where we require information for use of the site.

What services does the Privacy Policy cover?

This policy applies to all Carson products including all Carson apps, as well as the Carson website ( www.Carson.live ) and software (collectively the Carson "Platform”).

Customers and Users

Our “Customer” is typically a legal entity representing a building or property. Customers purchase or license one or more products or services that are part of the Platform. You are a user of the Platform. Carson collects information from our Customers and users on behalf of our Customers. There are many types of users, and each one has a unique relationship to the information that we collect. Users can include our Customers’ employees (building staff, maintenance personnel, managers, etc.), residents (tenants, owners, subtenants, guests, etc.), service providers (outside contractors, local businesses, etc.) and others. Each of these (and generally anyone who has a Carson username and password) is considered a “Registered User”. Some users may not be Registered Users, such as a visitor to our public website. Most Registered Users will be affiliated with one or more Carson Customers (i.e., your buildings). Carson is the custodian of data on behalf of our Customers, with respect to much of the information we collect. Each Customer also determines its own policies regarding information collection, access, sharing and retention. Please contact the Customer if you have any questions regarding their privacy practices.

The Information we collect

In order for you to use the Carson platform, we need to collect and process certain information (such as your name or address) and anonymous information (such as your IP address). Most of this information is provided by our Customers or by you, when you use our Platform. Some information is obtained through your use of our Platform, for example, when we receive error reports or use cookies (see below).

Finally, we receive some information from other Registered Users. An example would be when a Registered User submits or modifies the information and settings for various non-member 3rd parties, such as family members, roommates, or other people who are relevant to the building’s management and who they wish to submit through Carson (e.g. housekeepers, cleaners, caretakers). There may also be personal information submitted by our Customers about our Registered Users that Registered Users cannot access directly.

The types of information we collect depend on your level of access and engagement with the Carson Platform and can include:

• Contact information such as names, email addresses, mailing addresses, phone numbers
• Unique identifiers such as usernames, passwords, Carson account numbers
• Basic information submitted by you or on your behalf such as service request descriptions
• Information uploaded by you such as documents attached to the Carson Platform
• If you choose to use sign in services such as Facebook Connect, these services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address
• If you choose to use Carson's single sign-on (SSO) with 3rd party vendors such as Clickpay or Aptexx, these services will authenticate your identify and provide you the option to access such 3rd party services such as Clickpay or Aptexx services. Carson does not store, transmit, nor process your payment or other personal information. Clickpay and Aptexx and similar 3rd party vendors process your payment information or other information in accordance with their respective privacy policies, here and here .
• Your communications with us, such as your requests for customer support
• Information about your usage such as IP addresses, browser type, date/time stamp and clickstream data
• Employment information for Customer employees (including title, name, phone number)
• Photographs (of residents, employees, pets, visitors, maintenance request attachments)
• Scans (license, business card) in the context of building
• Incident details and information
• Resident instructions (including permission to enter, permission for authorized visitors, intercom call settings)

Cookies

We use cookies on this site to provide users with customized and personalized services. Cookies are small amounts of data that are sent to a user’s browser from a website and stored on a user’s hard drive for record-keeping purposes. This information does not necessarily identify the user, but identifies the user’s computer. The cookies used will not collect any personal information like name, address or telephone number.

Our use of cookies and other tracking technologies

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.

Web Beacons / GIFs

Third party tracking technology companies employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' personally identifiable information.

Analytics / Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personally identifiable information.

3rd Party Tracking

The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media widgets and plug-ins) on the site is not covered by our privacy policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers' or Users' personally identifiable information.

Legal Bases for Collecting Information

We process personal data for, or based on, one or more of the following legal bases:

Performance of a Contract

We use personal data to enter into and to perform under, an agreement between Carson and the Customer.

Legitimate Interests

We use personal data for our legitimate interests, including contact information, services offered, and website usage data.

Compliance with Legal Obligations and Protection of Individuals

We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.

Your Consent

We process certain personal data because you have given us your consent to process it in that manner.

Why We Collect Your Information

Carson uses the information we collect from all our Services for the following purposes:

Customize Our Services

We use your information to deliver our services, and customize for each Registered User or Customer.

Maintain & Improve Our Services

We also use your information to ensure our Platform is working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use your information to make improvements to our services.

Provide Personalized Services

We use the information we collect to customize our services for you.

Measure Performance

We use data for analytics and measurement to understand how our services are used. For example, we analyze data about how much time you spend accessing the Platform to do things like optimize Platform design.

Communicate with You

We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity, like an attempt to sign into your Carson account from an unusual location. Or we may let you know about upcoming changes or improvements to our services. And if you contact Carson, we’ll keep a record of your request in order to help solve any issues you might be facing.

Protect Carson, Our Users, and The Public

We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Carson, our Customers, Registered Users, or the public.

We use different technologies to process your information for these purposes. We use automated systems that analyze your content to provide you with things like customized services, or other features tailored to how you use our Services. And we analyze your content to help us detect abuse such as spam, malware, and illegal content.

We may combine the information we collect among our Platform and across your devices for the purposes described above. If other Registered Users already have your email address or other information that identifies you, we may show them your publicly visible Carson account information, such as your name and photo. This helps people identify an email coming from you, for example.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

How we use the information

For users of the Platform, we use the information we receive to:

• Provide the services our Customer requested
• Notify you of activity related to your account, such as when a package is delivered to the property for you
• Administer your account
• Keep your account secure (including to verify your identity and prevent fraud)
• Respond to customer service and support requests
• Create and provide better and improved products and services based on your use of the site and your feedback
• List you in our member directory made available only to other members of your building
• Conduct research and analysis
• Send you our newsletter, which you may opt out of at any time

For visitors requesting information about our products and services from one of our websites, we use the information we receive to:

• Assess the needs of your business to determine suitable products
• Send you requested product or service information
• Send you marketing communications
• Send you our newsletter, which you may opt out of at any time

If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

California Residents' Privacy Notice

The following user access and choice rights are obligations of Carson where we are the "business" under the CCPA (i.e., with respect to the personal information described above under the caption "Personal information we process as a controller or business"). With respect to all other personal information described herein, the access and choice rights are properly addressed between you and our relevant Customer subject to such Customer's privacy policy.

Residents of the State of California may request information regarding the categories of personal information we gather about you, the categories of sources from which we obtain the personal information, the business purposes for which the personal information is gathered, and the categories of third parties with which we share or, in the event we ever sell personal information, by category of personal information sold to such parties, respectively.

Upon verifiable request or when required or otherwise appropriate, and within periods (if any) set by applicable law, we will grant you reasonable access to or copies or other compilations of the specific items of personal information that we hold about you provided that you establish to our reasonable satisfaction that you are the person whose personal information is requested. We may deny such access where the denial is permitted by applicable law and every request from an individual will be assessed on a case by case basis. In the event a request is denied, we will notify you regarding the reasons for the denial in writing. Consistent with how your personal information is maintained in the ordinary course of our business, we will provide the information in an understandable form, and to the extent feasible in a format that permits you to use the information on other systems. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage) to the extent permitted under applicable law.

We will take reasonable steps to permit you to correct or amend personal information that is demonstrated to be inaccurate or incomplete. We also will delete personal information we have gathered about you when you make a verifiable request that we do so, except to the extent applicable law permits or requires us to maintain that information.

To guard against fraudulent requests for access, we will require sufficient information to allow us to confirm the identity of the individual making the request before granting access or deleting the information. We will not discriminate against consumers who exercise their rights under California law. However, we may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided by your personal information.

California's Do Not Track Notice: At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other websites and online services, our Platform is currently unable to respond to Do Not Track signals. To find out more about "Do Not Track", you may wish to visit  http://www.allaboutdnt.com .

European Union Users

Carson complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Carson has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF, Carson commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable)].  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

Federal Trade Commission (FTC) Compliance

Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). This means that the FTC has the authority to investigateg and take action against our organization for any violations of privacy and data protection regulations.

Service Providers

We share your personal information only with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We may provide your personal information to companies that provide services to help us deliver our services such as processing payments (Stripe), hosting applications or fulfilling other functions of the website. These third-party service providers are limited to accessing or using this information solely for the purpose of providing services to us and to you and must provide reasonable assurances that they will appropriately safeguard all information. For example, we transfer anonymous phone numbers to our communications provider Twilio, which completes calls and text messages for our Virtual Doorman service and building notifications

Liability in Onward Transfers

Our organization takes responsibility for the personal data we transfer to third parties. In cases of onward transfers, our organization remains liable for the protection and handling of the personal data, ensuring that third parties adhere to the same level of data protection as outlined in our privacy policy and the DPF Principles.

Aggregated Information

Your personal information is neither sold nor rented to third parties without your express permission. We do retain the right to share non-identifying aggregated demographic and/or statistical information with partners, advertisers and sponsors. We may use non-identifying and aggregated information to improve your experience on the website and to share with partners, advertisers and sponsors. For example, any personal information will remain with us, however, your visit may be counted to demonstrate the number of visitors to a particular page or area of the site.

Links to Third Party

Sites Our Platform includes links to other Web sites whose privacy practices may differ from those of Carson. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Legal Disclaimer

We may disclose your personal information:

• As required by law, such as to comply with a subpoena, or similar legal process
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
• If Carson is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

Carson will only retain personal data we process on behalf of our Customers for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

User Access and Choice

Users residing in certain countries, including in Europe, are afforded certain rights regarding their personal information. These rights include the right to access, correct and request deletion of your personal information. While these rights are not applicable worldwide, all Carson Registered Users can manage their personal information as described below.

You may access, correct, update, amend or remove certain personal information by making the change on your user account settings page or by requesting that your property manager (or other program administrator) make such change on your behalf. Your account is protected by a password. We encourage you to choose your password carefully and keep it secure. If you have trouble accessing your account or your information, you can contact Carson by emailing our customer support team at  support@carson.live .

Opt-out Choices

Carson offers you choices regarding the collection, use and sharing of your personal information. If you no longer require our services, or wish to request your personal information be deleted/removed, please contact us.. Termination of service proceedings are conducted offline and are subject to approval by our Customer, if you are a resident or staff user. We will respond to your request within thirty (30) days.

Our commitment to children's privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

Binding Arbitration

Under certain conditions, individuals have the right to invoke binding arbitration. Our organization is obligated to arbitrate claims and adhere to the terms as set forth in Annex I of the Data Privacy Framework (DPF) Principles. If an individual wishes to invoke binding arbitration, they must deliver notice to our organization and follow the procedures and conditions outlined in Annex I of the DPF Principles.

Data Protection Addendum

To assist our customers in the EEA in complying with applicable data protection legislation, we offer a Data Processing Addendum (DPA) to our Subscription Agreement. To request a DPA, contact us at privacy@carson.live.

Data Protection Officer

To contact our Data Protection Officer, please email privacy@carson.live .

Changes to this policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account or by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy

Contact Us

Postal         88 University Pl., 10th Floor

Address     New York, N.Y. 10003  

Phone         +1 (646) 661-2250
Email           support@carson.live

                      privacy@carson.live