Effective Date: December 20, 2019

Last Updated: October 27, 2022

1. Introduction

This privacy policy (the "Privacy Policy") is designed to inform users of the Zumper, Inc. website and any related smartphone or mobile application, including Zumper Pro (collectively, the "Website"), about how Zumper, Inc. ("Zumper", "we" or "us") gathers and uses Personal Information submitted to Zumper through the Website. Zumper will take reasonable steps to protect user privacy consistent with the guidelines set forth in this Privacy Policy and with applicable U.S. laws. In this Privacy Policy, "user" or "you" means any person viewing the Website or submitting any Personal Information to Zumper in connection with using the Website. The term “Landlord” means any user who is a landlord, landlord representative, broker, property manager, or and sub-lessor who lists a property for rent on the Website. The term “Tenant” means persons who search, apply, contact or otherwise review properties for rent on the Website.

By using the Website, you are indicating your consent to this Privacy Policy. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD NOT USE THE WEBSITE.

Defined terms not defined herein shall have meanings ascribed in the California Consumer Privacy Act (the “CCPA”), the regulations to the CCPA, and Zumper’s Terms and Conditions.

2. How We Collect, Use, and Share Information

Summary of Zumper’s Collection, Use, and Disclosure of Information

Zumper is an apartment search platform that maintains an online real estate marketplace designed to connect prospective Tenants and Landlords and to offer the services listed in Zumper’s Terms and Conditions (Zumper’s “Services”). To provide you with Zumper’s Services, we must collect and process your information, including your Personal Information. Your privacy is important and we are committed to protecting information that identifies you personally. The types of information we collect, use, and disclose depend on how you want to use Zumper.

If you are a Tenant, you may provide us or our Service Providers with Personal Information such as: identifiers; employment, criminal, financial, and rental histories; criminal histories (except where such collection is prohibited by law); financial information (including your credit score); and your rental preferences. You may also provide us with any information you choose to submit to landlords via our messaging service. We use this information to connect you to Landlords that you may be interested in renting from; to verify your background information for Landlords; to process your rental applications and payments; to improve and customize Website functionality; and more.

We share some of the information that you provide with Landlords, Service Providers, and other third parties when you express interest in their properties or services. We may also sell certain Personal Information to marketing partners and advertisers, as specified below.

If you are a Landlord, you may provide us or our Service Providers with Personal Information such as identifiers; bank account information; and information about your business and your properties. We use this information to connect you to Tenants who may be interested in renting from you; to verify information about your properties; to process rental applications and payments; to improve and customize Website functionality; to provide rental guarantee services; and more. We share some information that you provide with Tenants, Service Providers, and Third Party syndicators such as Facebook Marketplace. We may also sell certain Personal Information to marketing partners and advertisers, as specified below. You agree that you will not use any information provided to you regarding a Tenant except for the purpose of renting to the Tenant.

Table of Zumper’s Collection, Use, and Disclosure of Information

Below is a table that explains what Personal Information we have collected over the past twelve months (as of the effective date of this Privacy Policy), the sources of the information, why we collect the information, and what Third Parties and Service Providers we give the information to.

Additional Disclosures About Zumper's Use of Information

• Your Disclosures to Third Parties:

  You may use Zumper’s Website to share Personal Information with Third Parties directly. For example, you may provide Landlords with your Personal Information when you contact them regarding an apartment or apply to rent the apartment. You may also click links on Zumper’s Website that take you to a Third Party’s website. Zumper is not responsible for the privacy practices of Third Parties or the content of Third Party websites. Users should be aware of this when they share information with Third Parties on our Website or when they leave our Website to share information. Users should read the Third Parties’ privacy statements, as this Privacy Policy applies solely to personal information collected by Zumper.

• Aggregated or De-identified Data:

  We may sell or share aggregated or de-identified information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular user.

• Legal Requests:

  We may access, preserve and share your Personal Information with regulators, law enforcement or others in the following circumstances:
  • In response to a legal request (like a search warrant, court order, or subpoena) if we have a good faith belief that the law requires us to do so.
  • When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Services, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property, or Services), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Services.

3. What Are My Rights Regarding My Personal Information?

The CCPA gives California residents certain rights with respect to their Personal Information. Zumper believes that all users should have the rights provided by the CCPA, and is extending CCPA rights to all of its users.

Summary of User Rights

Users have the right to:

• Request information about our collection, use, and disclosure of their information (a “Request to Know”), including:
  1. the categories and specific pieces of Personal Information we have collected about the user;
  2. the categories of sources from which we have collected the user’s Personal Information;
  3. the business or commercial purpose for collecting or selling the user’s Personal Information;
  4. the categories of Personal Information we have sold about the user; and
  5. the categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.
• Opt-out of the sale of their Personal Information (a “Request to Opt-Out”).
• Opt-in of the sale of their Personal Information (a “Request to Opt-In”).
• Request that we delete their Personal Information (a “Request to Delete”).

We will not discriminate against users for exercising their rights under the CCPA.

In accordance with the CCPA, Landlords who provide Zumper with their Personal Information in their capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency do not have the right to submit a Request to Know or Request to Delete.

“Request to Know” Rights

Users may submit a Request to Know by completing the form provided at http://www.zumper.com/ccpa/request or by emailing Zumper at [email protected].

Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that Zumper has collected about you in the past twelve months; or (2) a request for the categories of Personal Information that Zumper has collected about you in the past twelve months, and how Zumper has used and disclosed your information.

When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If you submit a Request to Know for the specific pieces of information that Zumper has collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.

If Zumper is able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why the CCPA does not require us to provide the requested information. If Zumper is unable to verify your identity, Zumper will respond by explaining why it cannot verify your identity. We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.

If the CCPA requires us to provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.

“Request to Opt-Out” Rights

Users may opt-out of the sale of their Personal Information by completing the form provided at http://www.zumper.com/ccpa/request or by emailing Zumper at [email protected]. You may be required to provide certain information to verify your identity and so that we can process your request. We will only use that information for purposes of processing the Request to Opt-Out.

Within 15 days of receiving a Request to Opt-Out, we will:

• Not sell your Personal Information unless and until you subsequently provide express authorization for the sale of your Personal Information.
• Notify all Third Parties to whom we have sold your Personal Information within 90 days prior to our receipt of your Request to Opt-Out that you have exercised your Right to Opt-Out, and instruct them not to further sell your Personal Information.
• Not ask for permission to sell your Personal Information for 12 months after receiving the Request to Opt-Out.

“Request to Opt-In” Rights

Users who have opted out of the sale of their Personal Information may opt back into the sale of their Personal Information by completing the form provided at http://www.zumper.com/ccpa/request.

“Request to Delete” Rights

Users may submit a Request to Delete by completing the form provided at http://www.zumper.com/ccpa/request or by emailing Zumper at [email protected]. When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If Zumper is able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why the CCPA does not require us to delete your Personal Information. Zumper may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information. We will specify the manner in which we delete your Personal Information.

If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete.

Authorized Agents

Users may submit Requests to Know, Requests to Opt-Out, and Requests to Delete through an Authorized Agent. Unless the Authorized Agent provides Zumper with a power of attorney executed by the user, Zumper may require the user to verify their identity with Zumper and/or to provide Zumper with written confirmation of the Authorized Agent’s authority to make the request.

4. Minors

Zumper’s Services are not designed to be used by persons under 18 years of age. If you are under the age of 18, you are not permitted to use this Website. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

For purposes of the CCPA, other state laws governing the collection and use of minors’ personal information, and the Children’s Online Privacy Protection Act (“COPPA”), Zumper does not have actual knowledge that it collects, maintains, or sells the Personal Information of any users under 18.

5. Security

We use reasonable security precautions to protect the security and integrity of your Personal Information, both during transmission and once we receive it, in accordance with this Privacy Policy and applicable law. We encrypt transmissions of Personal Information through the Website using secure socket layer technology (SSL). However, no method of electronic storage or Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

6. Accessibility

Any person with a disability that prevents or restricts them from accessing this Privacy Policy through Zumper’s Website may request a copy of this Policy in an alternative format by contacting Zumper at [email protected].

7. Website Visitors from outside the United States

Zumper and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Website, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.

8. Statement Regarding the GDPR

Zumper is not currently subject to the General Data Protection Regulation (EU) (“GDPR”). Zumper does not act as either a controller or processor of personal data provided by EU data subjects, as those terms are understood under the GDPR. Zumper markets and provides its products and services to entities and individuals based in the United States. Zumper does not have a presence in the European Union, and does not offer or otherwise market any products or services to individuals based in the EU. Although Zumper is not subject to the GDPR, Zumper takes seriously its customers’ privacy, and is committed to protecting Personal Information in accordance with this Privacy Policy and applicable law. Should you have any questions, please do not hesitate to contact us at [email protected].

9. Terms and Conditions

This Privacy Policy forms part of, and is subject to, the provisions of Zumper's Terms and Conditions, available at https://www.zumper.com/terms-and-conditions.

10. Amendments

Zumper may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by Zumper, to this Privacy Policy, including in the way in which Personal Information is collected, used or transferred, we will notify you by e-mail to the address specified in your Zumper profile or by means of a notice on the Website prior to the change becoming effective.

11. Contact Information

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: [email protected].