Last updated: December 31, 2022
At PayLease, LLC, d/b/a Zego, a Global Payments Company, we respect your concerns about privacy. This Website Privacy Notice (“Notice”) describes how we collect, use and share personal information from and about users of the web and mobile applications (“Apps”) and the websites, forums, emails and blogs (“Sites”) that link to this Notice, subject to the additional information on the scope of this Notice provided below. For the purposes of this Notice, “Zego”, “we” and “us” refer to PayLease, LLC, d/b/a Zego, and to its subsidiaries and affiliates, each as the context requires.
In order to understand how Zego processes personal information, you must first understand how Zego serves its customers and their residents. Zego provides software solutions (the “Zego Solutions”) that help residential and commercial real estate property owners and property managers (the “Clients”) manage their real estate and other assets by, among other things, facilitating transactions between the Clients and their residents and service providers.
Zego provides the Zego Solutions according to two different models:
- In some cases, the Zego Solutions are integrated into comprehensive property management software solutions offered to the Clients by Zego partners (the “Integrated Solutions”). When the Zego Solutions are offered to a Client as a part of an Integrated Solution, Zego’s role is typically limited to the processing of resident payments on behalf of that Client. When Zego processes resident personal information exclusively for the purpose of providing payment processing services to a Client through an Integrated Solution, Zego does so pursuant to the terms of its contractual agreement(s) with that Client and the partner who worked with Zego to develop the Integrated Solution, and that processing of resident personal information is subject to the terms of the privacy notice that the Client provides to its residents. It is not subject to the terms of this Notice.
- In other cases, Zego provides the Zego Solutions to Clients directly, and, in addition to payment processing services, the Zego Solutions include Apps for residents that incorporate features designed to improve the resident experience, or to add value for the resident, in a way that is not directly related to the resident’s relationship with the Client (“Resident Features”). Examples of Resident Features include features that enable residents to report their rent payment history to credit bureaus, or that make residents aware of discounts and opportunities related to products and services that may be of interest to them outside of their relationship with a Client. When Zego processes resident personal information for the purpose of providing the Resident Features, that processing of resident personal information is subject to the terms of this Notice.
Regardless of the model of services, Zego’s processing of personal information about prospects, Clients, partners, and their personnel through Sites or Apps that link to this Notice is always subject to the terms of this Notice, as is Zego’s processing of personal information relating to any other users of the Sites or Apps.
Please read this Notice carefully. If you have any questions about the content of this Notice, or about whether or how it applies to you, you may contact us at email@example.com, or by using the other methods provided in the “Contact Us” section below.
This Notice covers the following topics:
- Personal Information We Collect
- Sources of Personal Information
- How We Use the Personal Information We Collect
- Our Processing of Sensitive Personal Information
- How We Share the Personal Information We Collect
- Our Relationship with Affiliate Companies
- Data Anonymization and Aggregation
- Login Details and Your Responsibility
- Managing Your Preferences
- Your Legal Rights
- Information for California Residents
- Our Commitment to Data Security
- Cookies and Other Tracking Technologies
- External Links
- Changes & Updates
- Contact Us
Personal Information We Collect
Through our Sites and Apps, and subject to your consent if required by law, we may collect and/or process the following personal information:
- Identifiers, including full name, date of birth, age, resident or social media account ID, and basic contact details such as telephone number, email address and postal address;
- Sensitive Personal Information, including Zego account credentials (see “Login Details and Your Responsibility” below), government-issued IDs (such as a Social Security Number), information used to verify your identity (such as security questions and answers), and information used to process payment transactions (such as credit/debit card information or other financial account information);
- Commercial Information, including records of our transactions with you and information about your preferences regarding our and our partners’ products and related services which may be of interest to you (see “Managing Your Preferences” below);
- Internet/Electronic Activity, including information gathered from cookies, pixel tags and other tracking technologies, App usage data, and information that is automatically collected as you interact with our Sites or Apps through the normal operation of the internet (such as IP address, browser type, operating system and referring page);
- Geolocation Information, including your physical address and IP address;
- Professional or Employment-Related Information, such as your employment status, job title, and business contact information;
- Information That You Provide, such as the contents of your communications with us and any associated metadata; and
- Inferences drawn from any of the foregoing, such as inferences about your product preferences, your characteristics, or your predispositions.
Sources of Personal Information
Information that you provide to us: We collect personal information that you provide to us when you set up an account with us, use our Sites or Apps, or communicate with us. For example, if you attempt to register for an account with us, we may request your name, contact information, and other information necessary to direct your payments to the appropriate Client (for residents) or to evaluate your suitability for the services (for prospects and Clients). Providing us with personal information in these contexts is voluntary, and you can always choose not to provide it, but if you do not provide us with the information necessary to perform the product of service you request, you may not be able to participate in that product or service.
Information collected from third parties: We may collect information about you from third parties in the course of marketing our services to you or providing our services to you. For example, we may collect personal information like your name and contact information from a referral partner or other third party in order to contact you about the services we provide. We may also receive business-related information about you from third party companies that supplement our business customer records with firmographic and professional information.
Information collected through technology: When you use our Sites or Apps or interact with an email we send to you, we may collect certain information automatically, including your account or device identifier and usage information, such as the pages that you visit, links you click, types of content you interact with, frequency and duration of your activities, and other information about how you use our services. You have the ability to express your preference regarding some of the ways we collect information through technology in some of our services (see “Cookies and Other Tracking Technologies” for more information).
How We Use the Personal Information We Collect
Subject to your consent if required by law, we may use your personal information for the following business purposes:
- To contact you regarding any inquiry you make or to fulfill a request, such as, for example, a request for information about our products and services;
- To improve and personalize your experience when you use our Sites or Apps;
- To provide and improve our products and services and for the development of future products and services;
- For internal record keeping and administration of records;
- For auditing related to a current interaction with a consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
- For detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- For internal research for technological development and demonstration;
- To verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our services;
- To contact you by email and, if you have signed up for our services, to share e-newsletter or any other updates, communications or publications;
- For direct marketing purposes, subject to your consent if required by applicable law (see “Managing Your Preferences” below);
- As necessary to set up and administer your sign up to, and use of, the log-in facility available on the Sites and Apps; and
- For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations.
We retain the personal information we collect for different periods of time depending on what it is and how we use it, but only for as long as is necessary to complete the legitimate business or legal purposes for which we collected it. In many cases, the retention period will correspond to the time period for which you have an account or other relationship with us plus an established period after that relationship ends, which will be defined by our regulatory requirements.
Our Processing of Sensitive Personal Information
Sensitive Personal Information includes personal information defined as sensitive under applicable privacy and data protection laws. When we collect Sensitive Personal Information, we will limit our use and disclosure of that information to what is necessary to perform the services, unless we are required to do otherwise under applicable laws. In addition to processing Sensitive Personal Information as required to perform the services, we may process Sensitive Personal Information to detect and prevent security incidents or fraud, to ensure the physical safety of natural persons, for short-term transient uses (when consistent with the purpose for which the information was collected), and to verify or maintain the quality or safety of any services we perform. Under some privacy and data protection laws, you may have the right to limit the processing of your Sensitive Personal Information. You can find more information about your rights in other sections of this Notice, including any applicable section directed at residents of the state in which you reside.
Zego Does Not Process Biometric Information
Zego does not collect, process or store any biometric information about you. If you are a user of the Apps, you may have the option to enable authentication features like Face ID (for devices using Apple’s iOS) or Fingerprint (for devices using Google’s Android OS) to facilitate your sign-in process. When you enable these features, Zego does not gain access to any biometric information stored within your device. Zego simply receives a notification, through your device’s operating system, indicating whether your authentication attempt was or was not successful. To learn more about Apple’s Face ID feature and your privacy, please click here. To learn more about Google’s Fingerprint feature and your privacy, please click here. Zego is not responsible for any third party’s processing of your personal information.
How We Share the Personal Information We Collect
Except as otherwise specified, we may share any of the categories of your personal information in the manner and for the purposes described below:
- With Zego affiliates, where such disclosure is necessary to provide the services or to manage our business (see “Our Relationship with Affiliate Companies” below).
- With service providers whose systems, applications, products or services help us to provide the services. For example, we share personal information with IT service providers who help manage our back office systems or administer our Sites and Apps. We take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as necessary for their service delivery and for no other purpose.
- With third parties with whom you have a relationship. For example, if you were referred to Zego by a third party partner, we may share information with the referring partner in accordance with our business relationship with you and that partner.
- With the appropriate Client(s), if you are a resident affiliated with a specific Client or Clients.
- With logistics service providers to enable the delivery of packages to individuals.
- With other third parties, such as our partners or entities whose offers you have selected within the marketplace, with whom you direct us to share your personal information, subject to your specific consent for such data sharing.
We do not sell your personal information to third parties for monetary compensation. To the extent that we share your personal information with third parties for cross-context behavioral advertising, we will implement features within the services that enable you to see a list of the entities with which the personal information is shared and which enable you to express your preferences. You can find additional information about how those third parties use personal information in the applicable third-party privacy notice.
Our Relationship with Affiliate Companies
Subject to your consent if required by applicable law, we may appoint an affiliate company to process personal information in a service provider role. In most cases, we will remain responsible for that company’s processing of your personal information pursuant to applicable data privacy laws. Because our affiliate companies are located around the globe, your personal information may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence. We take appropriate steps to ensure that transfers of personal information are in accordance with applicable law.
Data Anonymization and Aggregation
Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct risk assessments and analysis of costs and charges in relation to our products and services. We may share anonymized or aggregated data with our global affiliates and with other third parties. This Notice does not restrict Zego’s use or sharing of any non-personal, summarized, derived, anonymized or aggregated information.
Login Details and Your Responsibility
Subject to your consent if required by law, we will collect and process your personal information as necessary to set up and administer your login credentials for our Sites and Apps. We will use “cookies” to “remember” the machine or other device you use to access our Sites (see “Cookies and Other Tracking Technologies” below). Please remember that if we contact you, we will never ask you for your password in an unsolicited email, message or phone call. If you choose to use the log-in facility available on our Sites and Apps, you are required to adhere to the security procedures we establish in the documentation we provide you as part of the services.
Managing Your Preferences
Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services, as well as those of our global affiliates and third parties. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, we may provide direct marketing information, and we may permit others to do that, as allowed by our terms.
We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Your Legal Rights
If you are an End User who interacts with our Sites or Apps for the purpose of engaging with our Customers and have questions about legal rights you may have with respect to your personal information collected by our Customer, please consult the Customer with which you have a relationship.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have the right to:
- Know whether we process your personal information;
- Know how your personal information is used;
- Access, request and receive the personal information we have collected in a portable manner;
- Object to having your personal information sold or shared; and
- Request that we delete your personal data.
For some users we have additional disclosures in the sections of this Notice directed at users based on where they reside. You may contact us using the information in the Contact Us section of this Notice for additional information about how to exercise your rights.
Information for California Residents
If you are a California resident, this section applies to you, in addition to the rest of the Notice.
California Shine the Light
If you are a resident of California, you may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the information provided in the “Contact Us” section of this Notice.
Categories of Personal Information We Collect and Our Purposes for Collection and Use
You can find a list of the categories of personal information that we collect in the “Personal Information We Collect” section above. For details regarding the sources from which we obtain personal information, please see the “Sources of Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “How We Use the Personal Information We Obtain” section above.
Categories of Personal Information Disclosed and Categories of Recipients
Our disclosures of personal information are described in the “How We Share the Personal Information We Collect” section above. To further clarify the content of that section, we disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
- We disclose Identifiers to service providers, affiliates and third-party partners.
- We disclose Sensitive Personal Information to service providers, affiliates and third-party partners.
- We disclose Commercial Information to service providers, affiliates and third-party partners.
- We disclose Internet/Electronic Activity to service providers, affiliates and third-party partners.
- We disclose Geolocation Information to service providers, affiliates and third-party partners.
- We disclose Professional or Employment-Related Information to service providers, affiliates and third-party partners.
- We disclose Information that You Provide to Us to service providers, affiliates and third-party partners.
- We disclose Inferences to service providers, affiliates and third-party partners.
As a California resident, you have rights with regard to your personal information. You can contact us using the information provide in the “Contact Us” section of this Notice with regard to the following rights:
Right to know about personal information collected, disclosed, and sold
You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
Right to opt-out of the sale of personal information
|You may request that we do not sell your personal information to third parties. You may also request that we do not share your personal information for cross-context behavioral advertising.|
Right to request deletion
|In some circumstances, you have the right to have your personal information erased or deleted.|
Right to equal service and
|You have the right to request that we correct any inaccuracies in your personal information.|
Right to request correction
|In some circumstances, you have the right to have your personal information erased or deleted.|
Right to limit the use and disclosure of sensitive personal information
|In some circumstances, you may request that we limit the use and disclosure of your sensitive personal information.|
Our Commitment to Data Security
We take seriously our responsibility to protect the security and privacy of the information we receive via our Sites and Apps. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide via the Sites and Apps against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.Please remember that communications over the internet such as emails are not secure. We seek to keep secure all confidential information and personal information submitted to us through our Sites and Apps in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through the internet.
Cookies and Other Tracking Technologies
How to Delete or Block Cookies and Other Tracking Technologies
On some Sites and Apps, when technically feasible, we will enable tools to help you make choices about cookies and other tracking technologies. You may also delete or block cookies at any time by changing your browser settings. You can click “Help” in the toolbar of your browser for instruction or review the cookie management guide produced by the Interactive Advertising Bureau available at www.allaboutcookies.org. If you delete or block cookies, some features of the Sites and Apps may not function properly.
Zego provides links, both on our Sites and within our Apps, particularly within Resident Features like the marketplace, to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our Sites and Apps and to read the privacy statements of each and every website that collects personal information. This Notice applies solely to information collected by us. You should read any other applicable privacy and cookies notices carefully before accessing and using such other websites.
Our Sites are not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18 and we do not sell or share personal information of consumers under age 18. Please do not use this website if you are under the age of 18.
Changes and Updates
We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Notice, in whole or in part, at any time. When we amend this Notice, we will revise the “Last Updated” date located at the top of the document. We will also take reasonable steps to ensure you are made aware of any material updates including providing you direct communication about such changes or providing a notification through the Sites and Apps, as appropriate. If you provide personal information to us or access or use our Sites or Apps after this Notice has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Notice will be available on the Sites and Apps and will supersede all previous versions of this Notice.
If you have questions about this Notice, or if you want to exercise your rights as described in this Notice, you may submit a request by completing this form or may contact us as follows:
PayLease, LLC, d/b/a Zego
9350 Waxie Way, Suite 550
San Diego, CA 91923
In order to honor any access or deletion request, we will require you to provide enough information for us to verify your identity. For example, we may ask you for information associated with your account, including your contact information or other identifying information. If you designate an authorized agent to make a rights request on your behalf, we may require proper proof of that authorization as well as direct verification of your identity from you.
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