American Campus Communities

Last Revised and Effective Date: December 3, 2024

American Campus Communities LLC (“American Campus Communities,” “ACC,” “we,” “us,” or “our,”) respects the privacy of our users (“you” or “your”). This privacy policy (“Privacy Policy”) applies to personal information we collect online and offline, such as when you visitor our campus properties, visit the websites we and our affiliates, subsidiaries and related entities operate on which this Privacy Policy is displayed, or when you otherwise interact with us, such as through our customer support channels.

This policy does not apply to ACC employees or job applicants. Please see our ACC Employee Privacy Notice and Job Applicant Privacy Notice for further detail.
 
Our goal is to provide you with an excellent customer experience. We will take reasonable measures to protect the privacy of our residential applicants, residents, residents’ guarantors, prospective residents, prospective residents’ guarantors, and website visitors.
 
We collect personal information only for purposes that a reasonable person would consider appropriate in the circumstances. Personal information is data that can be used to directly or indirectly identify an individual. This Privacy Policy is intended to inform you of the personal information that we collect, use, and share (collectively, “process”), why we process this information, and the ways in which we will protect this information.  

We also describe in this Privacy Policy our handling of “sensitive” personal information or data, which are subject to additional protections under applicable data privacy laws.
 
Please take a moment to become familiar with our privacy practices as described below. Our websites may contain links to other sites for organizations that are not directly affiliated with American Campus Communities.  Also, American Campus Communities may have a presence on one or more social-networking sites to which you may have access. We are not responsible for the content or privacy practices of these sites and recommend that you review their privacy statements as they may differ from those of American Campus Communities.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with an additional notice (such as by sending you an email notification about the new Privacy Policy) in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS
1. Notice at Collection
2. Advertising and Analytics
3. Your Choices
4. Children
5. Disclosures for Individuals in the United States
6. Disclosures for Individuals in Canada
7. Transfer of Information to the United States and Other Countries
8. Contact Us

1. Notice at Collection

A. Sources of Your Personal Information
We may collect personal information from the following sources:

• Personal Information You Provide to Us: We receive and store any information you provide in relation to our services, such as when you submit an application, communicate with us via phone or email, participate in surveys, or provide information to your online account. The types of personal information that we may collect directly from you include contact, financial, and other identifying information and demographic information.

• Personal Information We Collect from Other Parties: We may collect contact and identifying information from other parties, such as our affiliates and subsidiaries, credit reporting agencies, background check agencies, and/or collections agencies.

• Personal Information We Collect Passively: We may collect Internet or other electronic activity passively using tools like browser cookies, web beacons, and tracking pixels, SDKs, and other similar technologies. This activity is further described in the “Advertising & Analytics” section below.

B. Personal Information We Collect
The categories of Personal Information that we may collect about you include the following:

• Contact Information and Other Identifiers: We may collect certain identifiers and contact information, such as name, current and previous mailing addresses, phone number, email address, geolocation, Social Security number, Insurance Number, government-issued identification number, passport number, IP address, and other similar identifiers.

• Employment or Other Professional Information: We may collect employment-related information, such as current and past job history, job title, and place of work.

• Education Information: We may collect information about your education such as your academic major and educational institution.

• Demographic Information: We may collect certain demographic information, such as date of birth, race and ethnicity, marital status, veteran or military status, and background check information.

• Internet or Other Electronic Activity: We may collect information about your activity on our website, such as your browsing and click history when you are using our website.

• Other Information:  We may collect other personal information, such as during roommate matching searches (such as name, email address, or gender).

C. Purpose and Use of Your Personal Information
We may use the categories of personal information identified in personal information we Collect in Section 1.B. above for the following purposes:

• Transactional Purposes: We may use your personal information to:

  • create, maintain, customize, and secure your account with us;

  • process transactions and send you related information, including confirmations, receipts, invoices, and resident/tenant experience surveys;

  • provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; and

  • provide you with email alerts, event registrations and other notices concerning our services, or events or news, that may be of interest to you.

• Analytical Purposes: We may use your personal information to analyze preferences, trends, and statistics in connection with our business.

• Business Purposes: We may use your personal information to conduct business dealings with our partners, affiliates, service providers, or contractors.

• Maintenance and Improvement of Services and Websites: We may use your personal information to:

  • provide and maintain functionality on our websites;

  • improve our websites and services;

  • optimize amenities at our properties; and

  • help us diagnose technical and service problems and administer our websites.

• Security and Fraud Prevention: We may use your personal information to protect our websites, our properties, and you and other residents and for fraud detection, theft prevention, and emergency response purposes.

• Legal and Financial: We may use your personal information to comply with our legal and financial obligations, as otherwise permitted or required by law, or as we may notify you.

• Other: We may use your personal information to carry out any other purpose described to you at the time the information was collected.

D. Disclosure of Your Personal Information
American Campus Communities discloses personal information in the following circumstances or as otherwise outlined in this Privacy Policy:

• Our Service Providers, Contractors, and Processors: We may disclose personal information to other parties that provide certain services to our business, such as:

  • Building maintenance staff who may process names and contact information to facilitate maintenance requests and repairs;

• • Property managers who process names, current and previous mailing addresses, phone number, email address, Social Security number, Social Insurance number, government-issued identification number, passport number, demographic information, and other provided information to process leasing applications and aid property management;

• • IT providers, who process IP addresses, and activity on our website, such as your browsing and click history when you are using our website to provide us IT services;

  • Payment processors who process names and financial account information to process rental payments;

  • Communications providers who process names, email address, and other contact information to provide us customer support services;

  • Screening and insurance providers for background checks who process names, current and previous mailing addresses, phone number, email address, Social Security number, Social Insurance Number, government-issued identification number, passport number, demographic information and employment information to process background checks and insurance policies and claims;

and

• • Credit reporting agencies who process names, government identifiers, and financial information to run credit reports.

• Our Business and Marketing Partners: We may disclose personal information to business and marketing partners whose products, offers, or services you may be interested in, and they may use the information for their own marketing purposes or the marketing purposes of others.

• Our Affiliates and Subsidiaries: We may disclose personal information (including Internet or other electronic activity) with our affiliates and subsidiaries so that they may assist us in providing our services to you. We may also disclose personal information to our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

• Corporate restructuring: If we enter into a business transaction with another party that involves the sale, transfer, or merger of all or a part of our business or involves granting security over all or part of our business, we may disclose your personal information to the other party for the purposes of the business transaction.

• Law Enforcement and Courts: We will disclose your personal information without your consent in response to a subpoena, warrant or order of a judicial or governmental authority with jurisdiction. We may also disclose your personal information in response to a lawful request from law enforcement officials or other governmental authorities or if we have reasonable grounds to believe that the information is relevant to a breach of contract or laws or in other cases where we are permitted to by law in connection with protecting our legal rights or those of others. In matters involving a danger to personal or public safety, we may voluntarily provide information to appropriate government authorities.

• Advisors and Lawyers: We may disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or to otherwise protect and manage our business interests.

• With Your Consent: We may disclose personal information with your consent or at your direction.

• Sold or Shared: We may sell your or share your personal information for cross-context behavioral advertising, as described in the Selling or Sharing of Personal Information in Section 6.C below.

• Disclosure of Non-Personal Information: We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you. When doing so, we publicly commit to maintain and use the information in an aggregated or de-identified form and not attempt to re-identify the information, unless permitted or required by law.

E. Retention of Your Personal Information
We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.  When your personal information is no longer required, we will delete, destroy, de-identify or anonymize your personal information, in accordance with legal requirements.

2. Advertising and Analytics

To enable our systems to recognize your browser or device, to provide our services to you, and to serve advertisements on our behalf, we use cookies, web beacons and similar tracking technologies. A “cookie” is a small text file that a website can place on your computer’s hard drive to, for example, collect information about your activities on the site, to keep your account secure, to help us enhance your experience when using our website, and to gain insight on how to better serve our website users. The use of cookies is an industry standard, and, as such, you will find them on most major websites. We use both first and third-party cookies on our website. First-party cookies are those set by us, whereas third-party cookies are set from a domain different from the domain of the website you are visiting for our advertising and marketing efforts. We use cookies to:

• Assist with your navigation of our website;

• Track interactions on our websites or particular features on our websites;

• Remember your site preferences (e.g., language preferences); and

• Tailor advertisements to you and provide you with a personalized marketing experience.

We also classify cookies into the following categories:

• Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be disabled.

• Analytical/Performance Cookies: These cookies are used to allow us to recognize and maintain a log of the number of visitors that reach our website. These cookies assist us in improving our website function in the most efficient manner possible.

• Functionality Cookies: These cookies are used to recognize users when they return to our website, so we can personalize content for you and remember your preferences. If you choose to disable these cookies, we will not be able to automatically set your preferences when you visit our site (e.g., your preferred language and region).

• Targeting Cookies: These cookies are set through our website by our advertising partners, such as Meta and TikTok. These partners may use information obtained through their cookies about your visits to our and other websites, in combination with information about your purchases and interests in order to provide advertisements about goods and services relevant to you.

3. Your Choices

A. Account Information

You may update certain account information at any time by logging into your account or emailing us at privacy@americancampus.com. If you wish to delete your account, please email us at privacy@americancampus.com, but note that we may retain certain information as required by law or for our legitimate business purposes.

B. Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our website.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their websites or tailor their online ads for you.”

Certain companies we work with to serve Interest-based Ads participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display within the ads an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting.  You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.

In addition, certain advertising networks and exchanges we work with to serve Interest-based Ads may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members' ad networks.  To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. 

In Canada, please visit: http://youradchoices.ca/choices/.

C. Communications Preferences

You may opt out of receiving text messages or promotional emails from ACC by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

4. Children
Because of the nature of our business, our services are not provided to minors. To that effect, our website is not directed at minors. We will not ask minors, specifically children under the age of 13, to provide personal information. We do not knowingly sell or share personal information of consumers under the age of 16.

5. Disclosures for Individuals in the United States
This section contains additional information for residents in the United States regarding our personal information handling practices and your data privacy rights.

A. Summary of Categories of Personal Information Collected and Disclosed

In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For details about the precise data points, we collect and the categories of sources of such collection, please see Sources of Your Personal Information in Section 1.A and Personal Information We Collect in Section 1.B above. We collect personal information for the business and commercial purposes described in Purposes and Uses of Your Personal Information in Section 1.C above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients, which we also describe in greater detail in Disclosure of Your Personal Information in Section I.D above:

Category of Personal Information We Collect	Business Purpose for Disclosure and Processing	Recipients of Personal Information
Identifiers, such as name, phone number, current or previous mailing address, email address, Social Security number, government-issued identification number, passport number, IP address, or similar information.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such marketing, IT, payment processing, package solutions, utility management providers, screening providers for background checks, credit/collections reporting, property managers, or roommate matching services.
Any personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, physical characteristics or description, Social Security number, address, telephone number, passport number, driver’s license number, insurance information, employment history, or financial information.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, payment processing, package solutions, utility management providers,  property managers, credit/collections reporting, or roommate matching services.
Characteristics of protected classifications under California or federal law, such as race, color, age, marital status, and military or veteran status.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, credit/collections reporting, or property managers.
Commercial information, such as information regarding the products or services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, and rent amount.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, payment processing, property managers, or credit/collections reporting.
Internet or other electronic network activity, such as IP addresses, electronic key usage, and browsing and click history when using our websites.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, comply with  legal processes and requests from law enforcement, including subpoenas and warrants, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, or property managers.
Geolocation data	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing or IT.
Audio, electronic, visual or similar information, such as video or photo footage that we may capture, dates and times that you arrive to and leave our premises, and information when you enter a particular unit and a defined area of common space.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, comply with  legal processes and requests from law enforcement, including subpoenas and warrants and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, or property managers.
Professional or employment-related information, such as current and past job history, job title, and, in the case of prospective and current residents or tenants, pay history and income.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as IT, screening providers for background checks, property managers, or credit/collections reporting.
Education information, such as academic major, educational institution, or degree.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as marketing, IT, or property managers.
Inferences drawn from any of the information identified herein, during roommate matching searches that may reflect a person’s preferences, predispositions, behavior, and attitudes.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as IT, property managers, or roommate matching.
Sensitive personal information or data, such as race and ethnicity, sex life or sexual orientation (if revealed from marital status), Social Security number (including Taxpayer Identification number), driver’s license number, passport number, financial information, and user names/account names and passwords.	We use and disclose for a business purpose this category of personal information to provide our services, learn more about our website users, and for other reasons, as described in greater detail in the Purpose and Use of Your Personal Information and Disclosure of Your Personal Information in Sections 1.C and 1.D.	We may have disclosed this category of personal information with our service providers, contractors, and processors that provide business purpose services to us, such as IT, property managers, credit/collections reporting, or screening providers for background checks.

Our prior 12-month practices are consistent with our current personal information handling practices described in Notice at Collection in Section I.

B. Selling or Sharing of Personal Information

Below, we describe the categories of personal information we may sell or share for targeted advertising currently and in the preceding 12 months. We also describe the third parties who received or may receive the personal information and the business or commercial purpose for the sale or sharing. We do not knowingly sell or share the personal information of children under the age of 16 and have not done so in the prior 12 months.

Category of Personal Information	Sold or Shared	Category of Third Party	Business or Commercial Purpose for Sale or Sharing
Identifiers, such as IP address, unique personal identifier, or other similar information.	Sold or Shared	Advertising, marketing, data analytics providers, and social networks.	We may have sold or shared this category of personal information with third parties to receive advertising, marketing, and analytics services.
Internet or other electronic network activity information, such as browsing and click history when using our website.	Sold or Shared	Advertising, marketing, data analytics providers, and social networks.	We may have sold or shared this category of personal information with third parties to receive advertising, marketing, and analytics services.
Geolocation	Sold or Shared	Advertising, marketing, data analytics providers, and social networks.	We may have sold or shared this category of personal information with third parties to receive advertising, marketing, and analytics services.
Inferences drawn from any of the information identified herein	Sold or Shared	Advertising, marketing, data analytics providers, and social networks.	We may have sold or shared this category of personal information with third parties to receive advertising, marketing, and analytics services.

C. Opt-Out Preference Signals and "Do Not Track" Requests

1. We Honor Opt-Out Preference Signals

We honor opt-out preference signals. An opt-out preference signal is a signal that is sent by a platform, technology or mechanism on your behalf that communicates your choice to opt-out of the sharing for targeted advertisements or sale of your personal information. For instance, you can learn more about implementing opt-out preference signals by clicking “Do Not Sell or Share My Personal Information” at the bottom of the website or by exploring other developing technologies and services that offer this tool.  

We treat opt-out preference signals as valid requests to opt-out of the sale or sharing of your personal information under privacy laws. Ordinarily, your opt-out preference signal is sufficient for us to honor your request, but in some instances, we may request additional information to help facilitate your request for offline sales or sharing.  We will not use, disclose or retain this additional information for any purpose other than to facilitate the request.

2. Do Not Track Requests

Some web browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals. However, as noted above, we do honor opt-out preference signals.

D. Sensitive Personal Information
ACC collects certain information that is considered “sensitive” under United States privacy laws, as described in the table above. Where required by law, we will obtain your consent before processing your sensitive personal information. We will also only use your sensitive personal information for limited purposes, such as to process an application or manage a lease.  If you have any questions about our handling of sensitive personal information or to withdraw your consent, please contact us at the email or mailing address in Section 9 below.

E. Your Privacy Rights

Data privacy laws afford consumers residing in the United States certain rights with respect to their personal information, subject to certain exceptions. If you reside in the United States, this section applies to you. Subject to certain limitations if you are a resident of the United States, you have the following rights:

Right to Confirm Processing, Know and Access
You have the right to confirm whether we are processing your personal information and know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

Right to Deletion
You have the right to request that ACC delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete and direct our service providers to delete your personal information from our records, unless an exception applies.

Right to Correction
You have the right to request that ACC correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing.

Rights Related to Sharing for Targeted Advertising or Sale
You have the right to opt out of sharing for your personal information for targeted advertising or the sale of your personal information. You may opt-out of the sale of your personal information or sharing of your personal information for targeted advertising by clicking Do Not Sell or Share My Personal Information. You may also exercise this right using the methods below.

List of Specific Third Parties
If you are an Oregon resident, you have the right, at our option, to receive a list of the specific third parties, other than natural persons, to which we have disclosed either: (1) your personal information or (2) any personal information.

Right to Opt-Out of Profiling
You have the right to opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. ACC does not currently engage in this practice.

Right to Data Portability
You have the right to receive the information about you that we process in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment or hindrance.

Rights Related to Sensitive Personal Information or Data
Data privacy laws may provide additional protection for sensitive personal information or data. Please see Sensitive Personal Information in Section 6.D above for more information.

Right to No Discrimination
You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

Right to Appeal
If we decline to take action in response to your exercise of a privacy right, we will inform you of the reason for denying your request and provide you instructions on how to appeal the decision.

F. Exercising Your Privacy Rights

You may exercise your privacy rights and withdraw consent (to the extent we are processing your personal information based on consent) by submitting a verifiable consumer request to ACC by one of the following four methods:

• Phone: Call us at 1-833-665-0160;

• Email:  Email us at privacy@americancampus.com;

• Mail: Send a written request to:

American Campus Communities
ATTN: Privacy Office
12700 Hill Country Blvd, Suite T-200
Austin, TX 78738 

You may also opt-out of the sharing of your personal information for targeted advertising by clicking on the ”Do Not Sell or Share my Personal Information” on the footer of the website.

Before we can process your request, we will ask you a series of questions in order to attempt to verify your identity. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension as permitted by data privacy laws.  However, we will honor opt-out of sale and sharing and limit use and disclosure of sensitive personal information requests within 15 business days.
 
G. Appealing a Denial of a Privacy Right Request

If you are a resident of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia, you may appeal a denial of your privacy right requests by calling us at our toll-free phone number 1-833-665-0160, or by emailing us at privacy@americancampus.com. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may submit a complaint to the Attorney General of your state. 

H. Authorized Agents

If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent (which may include a guardian or conservator). If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at the email or mailing address listed below in Section 9. 

I. Shine the Light Disclosure for California Residents

California law permits California residents to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us as described in “Contact Us” in Section 9 below.

6. Disclosures for Individuals in Canada
This notice applies to collection of personal information from Canadian residents by ACC and its subsidiary, Canadian Campus Communities, Inc. For the purposes of this section, references to ACC include reference to Canadian Campus Communities Inc.

A. Data Collection, Use & Disclosure

ACC collects, uses, or discloses your personal information consistent with this Privacy Policy.  Please refer to the sections of this privacy policy describing personal information collected directly and indirectly from ACC applicants, residents, residents’ guarantors, prospective residents, prospective residents’ guarantors, and website visitors above.  We hope this information helps you better understand the types of personal information we collect, and the choices or opt out rights you have for this collection.

ACC collects personal information only for purposes that a reasonable person would consider appropriate in the circumstances. We retain personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, as may be required by law (e.g., for tax and accounting purposes), or as otherwise communicated to you. 

B. Security

We are committed to online privacy and security. We have taken certain physical, administrative, and technical steps to safeguard your personal information both during transmission and once it is in our possession. While our security measures are intended to protect your personal information, the complete security of any transmission over the public internet cannot be guaranteed. As a result, we do not warrant the security of any electronically stored information or information you transmit to us over the Internet.

C. Video Surveillance

ACC uses closed circuit television and digital recorders for monitoring purposes at our Canadian properties.

E. Your Personal Information Rights
Canadian residents can access or update the personal information ACC holds on them, as further described in the “My Choices” section of the Privacy Policy above. You may also withdraw consent to the continued use or disclosure of your personal information, subject to limitations provided by applicable data privacy laws. You may also request to receive or transmit a portable copy of your personal information in a structured, commonly used technological format, subject to limitations provided under applicable data privacy laws.

You may exercise your rights by contacting our Privacy Office at the information set out at the “Contact Us” section below. We may need to verify your identity before we can process your request.
 
F. Accountability
ACC is accountable for the personal information collected from Canadian residents and maintains a PIPEDA compliance program. 

Your personal information may be handled by the following categories of personnel within our organization:

• Operations team, including property managers, property support staff,  maintenance staff, administrative staff, and leasing agents;

• People & Culture;

• Information technology (IT);

• Residence services;

• Marketing;

• Finance; and

• Legal

Our personnel have the following roles and responsibilities when handling personal data from its collection to its deletion:

• The Chief Legal Officer has ultimate responsibility for ensuring compliance with applicable privacy and data protection legislation, including Quebec’s “Act respecting the protection of personal information in the private sector.”

• The Privacy team handles everyday tasks relating to ACC’s privacy and data protection. This includes managing and promoting day-to-day privacy and data protection compliance within the organization, responding to rights requests, developing policies and standards, creating rules and policies, and developing and/or facilitating privacy training.

• The security team is responsible for developing, implementing and managing the data security measures deployed in our organization.

• All other personnel must perform their duties in compliance with ACC policies about privacy and data security.

To learn more, please contact us using the contact information provided in the “Contact Us” section below.

H: Complaints Process
If you have any complaints or concerns about our processing of your personal information, please contact us at the information provided below.

Our process for dealing with complaints related to the protection of personal information generally includes:

1. 1. Acknowledgement of receipt without reasonable undue delay;

   2. Appropriate steps to confirm the identity of the complainant, and to obtain the details of the complaint as well as any relevant documentation;

   3. Consideration of applicable laws;

   4. An appropriate, fair and impartial investigation; and

   5. Communicating the outcome of the investigation to the complainant, including any remediation measures we take (where justified).

7. Transfer of Information to the United States and Other Countries
ACC is headquartered in the United States, and we have operations and service providers in the United States and Canada. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. If you are located in Quebec, please be advised that your personal information may be communicated outside of Quebec. Personal information transferred or communicated outside of Canada may be accessible to foreign courts, law enforcement and national security entities. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.  If you have any questions or wish to receive further written information about the collection, use, disclosure or storage of personal information by our service providers or affiliates outside of Canada, please contact our Privacy Office at the information provided below.
8. Contact Us
If you have questions or concerns about your privacy or this Privacy Policy, please contact us at:
American Campus Communities
Attn: Privacy Office
12700 Hill Country Blvd, Suite T-200
Austin, TX 78738 
Call us at 1-833-665-0160 

You may also contact our Privacy Office at privacy@americancampus.com.