BRIGHTSTAR COMMUNITIES Privacy Notice

Effective Date: [3.2.26]

Last Updated: [3.2.26]

This Privacy Notice (“Notice”) explains how brightSTAR Communities LLC (“brightSTAR,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal data when you interact with us on our website at https://www.brightSTARcommunities.com/ (“Website”), as well as through social media or offline interactions. As used herein, “personal data” means any information that identifies, relates to, or could reasonably be linked to you or your household.

We are committed to protecting your privacy. By using our Website, you are consenting to the collection, transfer, handling, storage, disclosure, and other uses of your information as described in this Notice. Accordingly, any personal data provided by you to us shall be used in accordance with this Notice. However, this Notice applies only to information collected by our Website and does not protect information you post to public areas or third-party websites, except as set forth herein. This Notice imposes no duties on brightSTAR not imposed by state, federal, or other applicable law. This Notice does not apply to workforce information, such as data collected by applicants, employees, or contractors.

We reserve the right to modify or amend this Notice at any time to reflect changes in our personal data practices or applicable law. Should it be necessary to do so, will notify you and/or request your express consent, if required, of any material changes to this Notice by posting such changes at the Website or by other acceptable means. Each version of the Notice is identified at the top of the page by its Lasted Updated date. Your continued use of the Website after changes have been posted constitutes your acceptance of the Notice as amended for personal data collected going forward, unless additional consent is required under applicable law. If you do not agree to the terms of our Notice, please do not use the Website or provide us your personal data.

If you have any questions after reviewing this Notice, please contact us via email privacy@brightstarcommunities.com. The Terms of Service and other supplemental documents that may be posted on the Website from time to time are incorporated herein by reference.

1.     The Personal Data We Collect & the Sources

We collect personal data directly from you, which may include through the use of tracking technologies, as described in more detail below.

• Personal Data We Collect

The personal data we collect directly from you depends on the context of your interactions with Website, our social media, or your offline interactions with us. Depending on the foregoing, the personal data we collect from you may include the following:

• Contact Information:  name; phone number; email address; postal address; and organization/company, if applicable.
• Financial Information:  financial account or credit card information; payment and transaction history.
• Residency Application Information:  tax ID number or Social Security number; driver’s license or state identification number; characteristics of protected classifications under applicable state or federal law, such as race, color, sex, gender identity, age, national origin, disability, citizenship status, veteran status; current and past employment history; residence history and purchase information; financial information; signature (on any signed documents).
• Other User Content:  any other personal data contained in the documents you upload to the Website or otherwise provide to us.
• Account Information:  account log-ins and credentials.
• Communications:  contents of communications sent to us through our Website or social media, or other methods, such as email.

We may supplement the information we collect about you with information from third parties in order to enhance our ability to serve you, to tailor our content to you, and/or to offer you services that we believe may be of interest to you.

Any personal data you provide is voluntary or is necessary for the identified purposes for which it is to be used. Sensitive personal data is only collected if you affirmatively choose to provide it. You have no obligation to provide the information requested on any brightSTAR form, but the failure to do so can impact our ability to respond to your inquiry, problem, request, or other communication, and may result, in the case of a service or other request, in the denial of such request.

• Information Automatically Collected

Cookies. As indicated above, we may use cookies to automatically collect information when individuals use our Website. Cookies are small text files that can be placed on your device by websites, apps, or even certain online ads. They are bits of code that help the websites and apps function, remember user preferences (e.g., to remember settings related to language and font size), and understand how visitors use the website and app. Cookies can also be used for advertising purposes, such as to provide advertisements to individuals based on their interests.

Some cookies only last while the user is using the website or app and then expire when the website or app is closed. Other cookies can stay on an individual’s device for days, months, or even longer, until they expire or the individual deletes them. Cookies can be set either by the website or app owner (these are sometimes called “first-party” cookies) or by the owner’s service providers, such as analytics or advertising partners (these are often called “third-party” cookies).

We may use first- and third-party cookies on our Website to make the Website more responsive to your needs, by delivering a better and more personalized experience to you. We may use these cookies to identify you as a valid user, store your preferences, and help us understand how users use our Website so we can improve them.

We may automatically receive or collect the following information through cookies: IP address, IP location, browser type, browser language, device characteristics, internet connection, resource requested, date and time of resource requested, HTTP referring resource (if provided by the browser), usage data, persistent electronic identifiers, operating system, and/or clickstream data. We may aggregate this data, and may combine this data with other information we collect about users to better understand how visitors use our Website, improve user experience, and to help manage, maintain, and report on use of our Website. We may also store IP addresses for fraud detection and prevention purposes.

You can control cookies through your Cookie Preferences settings or through your browser or device settings. However, some features of our Website, or the entirety of our Website, may not work if cookies are blocked, limited, or deleted. You may learn more about cookies and how to opt out of them by visiting the following third-party website: https://allaboutcookies.org/.

Pixels. We may use pixels, such as the Meta pixel, on our Website (also known as web beacons), which are code embedded within a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often associated with cookies and are used for similar purposes. When you access a service that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser, or collect other information about your browser or device. Pixels may collect and send IP addresses, URLs, and other information from an advertisement that you click associated with your visit to our Website to other third-parties.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Site (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Site. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links: 

• https://policies.google.com/technologies/partner-sites
• https://support.google.com/analytics/topic/2919631

2.     How We Use Personal Data

We use the personal data we collect for a variety of reasons, depending on how you interact with our Website, social media, or through offline mechanisms. More specifically, we may use your personal data for one or more of the following purposes:

• To effectuate an account registration made by you;
• To respond to your inquiries or requests;
• To process resident applications and requests for services;
• To provide you with requested information and services;
• To provide you with support, including to investigate and address any concerns you may have and monitor and improve our responses;
• To administer and/or enhance marketing, promotions, and our newsletter;
• To customize the advertising and content you see;
• To conduct research and perform analyses to measure, maintain, protect, develop, and improve our Website and services;
• To analyze trends, administer the Website, track user movement, and compile broad aggregate demographic information for reporting and sponsorship purposes;
• To make communications to notify you regarding services, requests, security, privacy, and administrative issues;
• To provide functionality of the Website;
• To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities and manage risk exposure;
• To otherwise help ensure the security and integrity of our Website;
• To comply with our legal and regulatory obligations;
• For auditing, reporting, corporate governance, and internal operations;
• To defend or exercise our legal rights, protect us from liability, or protect the rights, property, or safety of us, our customers, or others; and
• For any other purpose for which you provide your personal data or as described to you prior to collecting your personal data, or otherwise as permitted by law.

3.     How We Disclose Personal Data

We may disclose the personal data we collect for the purposes outlined above in Section 2 (How We Use Personal Data) to the following third parties:

• Our suppliers, contractors, service providers, and other third parties who perform services for us and are contractually obligated to keep personal data confidential, use it only for the purposes for which we disclose it to them, and refrain from selling or sharing the personal data. This may include service providers that host our data services, process payments, deliver communications and advertisements, fulfill service requests, operate apps or plug-ins, or perform analytics on our behalf;
• Government entities and other third parties in response to a validly issued subpoena, court order, or other legal process, when necessary to establish or exercise our legal rights or defend against legal claims made by you or on your behalf, or when necessary or appropriate to protect the rights, property, or safety of us, our customers, or others;
• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal data is among the assets transferred;
• Our affiliates and other members of our corporate group; and
• We may share personal data for other reasons that we may disclose to you from time to time, with your consent, or as permitted or required by law.

We may share aggregated, non-personally identifiable information with third parties to the extent permitted by applicable law.

4.              Marketing Communications

We may offer marketing communications to you. If you sign up to receive our newsletter or we otherwise have your consent, we may send you communications about new services, offers, and other information related to our products and services through email. If you no longer wish to receive these communications, you can unsubscribe from receiving emails by clicking the “unsubscribe” link included in any brightSTAR marketing email. Note that you cannot unsubscribe from transactional or required email communications. Alternatively, you can opt out of receiving these marketing communications by contacting us via email at privacy@brightstarcommunities.com. Please note, you will continue to receive certain transactional and account-related communications from us.

SMS Messaging. If you sign up to receive text (SMS) messages from us or otherwise provide your express consent, we may collect and use your mobile telephone number to send you SMS or text messages. These messages may include marketing and customer care, such as special offers and promotional information for the communities, as well as informational and customer care communication messages.

Message and data rates may apply depending on your mobile carrier and plan. Message frequency may vary. You may opt out of receiving text messages at any time by replying “STOP” to any message you receive from us or by contacting us using the information provided in this Privacy Notice. You may also reply “HELP” for more information. Please note that opting out of text messages may affect your ability to receive certain time-sensitive notifications regarding your account or our services.

SMS consent and phone numbers are not shared with any third parties or affiliates for marketing purposes. No mobile opt-in data is shared. For questions regarding our SMS messaging practices, you may contact us at the address or email provided in this Notice.

5.              Personal Data Retention

We retain your personal data for as long as needed to fulfill the purpose for which it was collected, comply with legal obligations, resolve disputes, and enforce our policies. When information is no longer required, we securely delete or de-identify it in accordance with applicable law. We reserve the right to use de-identified data for any legitimate purpose without further notice or consent.

6.              Security Safeguards

To protect your personal data in our possession or control from theft, unauthorized access, use, modification, and disclosure, and to maintain its accuracy and integrity, we have implemented reasonable technical, physical, and administrative security measures. Although we have implemented reasonable safeguards, please note that no electronic transmission of information can be guaranteed to be entirely secure. You acknowledge and agree that we are not responsible for the theft, destruction, or inadvertent disclosure of your personal data except to the extent required by applicable law.

7.              Children’s Privacy

The Website is intended for use by individuals 18 years of age and older. We do not knowingly collect data from children under 18 years of age. If you are a parent or guardian and believe we have unnecessarily collected your child’s personal data, please contact us via email at privacy@brightstarcommunities.com.

8.              International Users

The Website is hosted in, and intended for use solely in, the United States, but may function in countries other than the United States. If you provide us with your personal data or otherwise engage with our Website from outside of the United States, you explicitly consent to the transfer, storage, and processing of your personal data in and to the United States, where laws regarding personal data may differ from the laws of other countries. If you reside in a jurisdiction other than the United States and have questions regarding our use of your personal data, please contact us via email at privacy@brightstarcommunities.com.

9.              Social Media & Third-Party Links

Our Website may include social media features, plug-ins, and links, and may use social media application programming interfaces (“APIs”) for log-in. The applicable social networking site may collect certain personal data about you, such as your name, username, email address, and/or profile picture, and you may allow us to have access to certain personal data associated with your social media account (e.g., name, username, email address, and/or profile picture) for the purpose of providing the social media feature through our Website. Please see the privacy policies for the applicable social networking sites to learn more about how these social networking sites share your personal data, which practices may differ from ours.

The Website may also contain links to other websites of interest. Once you have used these links to leave our Website, we will not have any control over the other websites and the Notice will not apply to personal data collected on such websites. We have no responsibility or liability for the practices, policies, and security measures implemented by such websites. Please see the privacy policy or privacy notice for the applicable website to learn more about how the website processes your personal data, as their practices may differ from ours.

10.           Changes to this Notice

We reserve the right to modify or amend this Notice at any time to reflect changes in our personal data practices or applicable law. Should it be necessary to do so, we will notify you and/or request your express consent, if required, of material changes to this Notice by emailing you (using the email address we have on file), posting such changes on our Website, or by other acceptable means. Each version of the Notice is identified at the top of the Notice by its Last Updated date. Your continued use of the Website after changes have been posted constitutes your acceptance of the Notice as amended for personal data collected going forward, unless additional consent is required under applicable law. If you do not agree to the terms of our Notice, do not use the Website or otherwise provide us your personal data.

11.           Contact Us

If you have questions regarding this Notice or our personal data practices, please contact us via email at privacy@brightstarcommunities.com or (513) 202-3737.