PRIVACY POLICY

This website (this “Site”) is provided to you by Massachusetts Institute of Technology, subsidiaries and related entities (“MIT,” “we,” “our” or “us”). We recognize the importance of protecting the privacy of individual-specific information (“Personal Information”) and are committed to supporting the privacy of our current and prospective tenants who use this Site. This Privacy Policy describes what information we gather and how we use it. Unless specifically stated otherwise, this Privacy Policy applies only to Personal Information that we gather or collect via the Site. It does not apply to any Personal Information collected offline or otherwise outside of the Site.

We do not sell or market to unaffiliated third parties any information you may provide to us through the Site. Any personal information you may provide including name, address, phone and e-mail is used by us to verify your residency at one of our properties, and to provide you with information and/or services that may be of interest to you.

Collection of Information about You:

We may collect Personal Information from you at various places and through various mechanisms on the Site. This may include, for example, when you fill out and submit forms (such as forms requesting information needed to consider you for apartment rentals), when you initiate payments to us through the Site, when you post to any interactive forum, bulletin board, chat room that we may make available on the Site, when you register for e-mail communications, and when you submit a survey response, question or request to the Site using a form or the e-mail address links on the Site.

When you visit the Site, we automatically collect certain information about your activities (“Site Usage Information”). Site Usage Information is information about how our visitors use and navigate the Site. This includes, for example, the number and frequency of visitors to each web page, the length of their stays, the type of browser each visitor is using to view the Site (for example, Internet Explorer, Firefox), the type of operating system each visitor is using (for example, Windows XP, Mac OS), the domain name of each visitor’s Internet service provider (for example, America Online, EarthLink), the visitor’s IP address, the address (or “URL”) of the web site that the visitor came from before visiting the Site, which pages were visited on the Site, what was clicked on, and certain other available information. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which our web servers use to identify where to send the information your computer requests. When you request pages from the Site, our servers log your IP address as well as information about your activities on those pages. To collect this Site Usage Information, the Site and any e-mails sent to you by the Site may utilize cookies, web beacons, embedded scripts or similar technologies.

A cookie is a small data file sent to your browser when you visit the Site, and stored on your computer. Cookies automatically identify your web browser to the Site whenever you visit the Site, and may make navigating and using the Site easier for you. Also, by tracking how and when you use the Site, cookies help us determine which areas are popular and which are not. Additionally, accepting cookies may allow you to, among other things, personalize and enhance your experience on the Site. If you do not wish to allow for use of cookies, you can generally opt-out of providing this information by setting your browser to reject cookies. However, please be aware that some areas of the Site may not provide you with an acceptable use experience if you have disabled the use of cookies.

A web beacon is a small, often invisible, graphic element included in a web page or e-mail. It allows the party that set the web beacon to monitor and collect certain limited information about the view of the web page or e-mail message (such as the type of browser downloading the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed, as well as the URL of the page the web beacon comes from). We may use web beacons for many purposes, such as to count visitors to the Site, or to monitor how visitors navigate the Site, and we may include web beacons or similar technologies in e-mails in order to count how many e-mails (or particular articles, links, etc.) we sent were actually opened.

An embedded script is programming code that is designed to collect information about your interactions with the Site. It is temporarily downloaded onto your computer from our Web server or a third party we work with, is active only while you are connected to the Site, and is deleted thereafter.

Site Usage Information is frequently anonymous information, since it is not normally associated with you or your identity. It may be used for a number of purposes, such as system administration, to help us understand the demographics of the visitors to the Site, to enhance the performance and usefulness of the Site, to report aggregate information to our business partners, or to audit use of the Site. If Site Usage Information is combined with your Personal Information in a manner that is directly associated with your identity, then it will be treated as Personal Information under this Privacy Policy.

When you make payments through the Site, we collect bank routing information necessary to process such payments. Such information may include billing address. If you use automated clearing house (ACH) deduction from your bank account to purchase services or products, we collect that information needed to set up the billing and payment for the services that your purchase. This account information includes the account number, account type, account name and the ABA routing number of the financial institution where your account resides.

MIT may also collect Personal Information from you through means other than the Site. This may include offline collection, such as when you submit a paper application to rent an apartment, make a rent payment by check, or call or visit the management office. It may also include e-mails that you send to us separate from the Site. This Privacy Policy does not apply to Personal Information that you provide to us through means other than the Site. However, if we combine the Personal Information we collect from you outside of the Site with Personal Information that we collect through the Site, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

We may receive Personal Information about you from other sources. For example, if you are applying for an apartment, either via the Site or offline, we may obtain information from third parties about your creditworthiness, among other information, as part of the application process. This Privacy Policy does not apply to Personal Information about you that we receive from other sources. However, we may combine the information we receive from the other sources with Personal Information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

The Site is not directed to minors. We do not knowingly collect Personal Information from children under the age of eighteen (18) on the Site and we will delete any information later determined to be from a person younger than age eighteen (18).

Use of Personal Information:

We retain and use Personal Information to: (1) provide you with services or process transactions that you have requested; (2) communicate with you regarding information, features or offers that we believe will be of interest to you; (3) respond to your questions or other requests; (4) contact you with regard to the Site; (5) process any applications, payments or changes to your account information; (6) process other information or Personal Information that you submit through the Site; (7) conduct use surveys; and (8) fulfill other purposes disclosed at the time you provide your Personal Information. We may also use the information you provide to improve the Site or our services, to customize your experience on the Site, to serve you specific content, or for other business purposes.

Sharing of Personal Information with Third Parties:

We do not share your Personal Information with third parties for those third parties’ marketing purposes. We may share non-personally identifiable information, such as Site Usage Information or other aggregated user statistics, with third parties. In addition, we may share your Personal Information as set forth in this Privacy Policy, in any manner in which you expressly consent via the Site, or in the following circumstances:

We may share Personal Information with our affiliated or subsidiary companies who require access to Personal Information for business purposes related to your tenancy or to process any application, request, inquiry, or other information or Personal Information you submit via the Site. This includes the management company for the property where you make application or where you lease.

We may share your Personal Information with third parties who perform services on our behalf. This includes, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. These third parties may have access to Personal Information in order to provide these services to us or on our behalf.

We may disclose Personal Information when we believe, in good faith, that the law requires it; at the request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms and Conditions of Use or other agreements or policies governing the Site and applicable law, rules and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect of enforce the rights, interests, or safety of the Site, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

Updating your Information:

Depending on the functionality associated with the Site feature you are using, you may be able to update certain of your Personal Information on the Site.

Please note that in accordance with our routine corporate recordkeeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

Security of Personal Information:

While we take reasonable steps to secure your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information on the Site or on other servers or databases to which the information may be transferred can be guaranteed to be completely secure. Please consider this prior to submitting your Personal Information to us via the Site.

Third Party Content:

When you are on the Site, certain content may be served by a third party. These third parties may also drop their own cookies and/or use web beacons or embedded scripts, which may be used to identify some of your preferences or to recognize you if you have previously had contact with those third parties. We do not control the use of such technology by third parties, the information they collect, or how they use such information.

Privacy Policy Changes:

We reserve the right to alter, modify, update, add to, subtract from, or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless we receive your consent to the new or revised policy.

Consent to Transfer:

The Site is operated in the United States. Your Personal Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Site or providing us with your information, you consent to this transfer.

Questions:

If you have any questions about this Privacy Policy, you may contact us by e-mail at [email protected].