Last Modified: October 2019
This policy applies to all Carson products including all Carson apps, as well as the Carson website (www.Carson.live) and software (collectively the Carson "Platform”).
Customers and Users
Our “Customer” is typically a legal entity representing a building or property. Customers purchase or license one or more products or services that are part of the Platform. You are a user of the Platform. Carson collects information from our Customers and users on behalf of our Customers. There are many types of users, and each one has a unique relationship to the information that we collect. Users can include our Customers’ employees (building staff, maintenance personnel, managers, etc.), residents (tenants, owners, subtenants, guests, etc.), service providers (outside contractors, local businesses, etc.) and others. Each of these (and generally anyone who has a Carson username and password) is considered a “Registered User”. Some users may not be Registered Users, such as a visitor to our public website. Most Registered Users will be affiliated with one or more Carson Customers (i.e., your buildings). Carson is the custodian of data on behalf of our Customers, with respect to much of the information we collect. Each Customer also determines its own policies regarding information collection, access, sharing and retention. Please contact the Customer if you have any questions regarding their privacy practices.
The Information we collect
Finally, we receive some information from other Registered Users. An example would be when a Registered User submits or modifies the information and settings for various non-member 3rd parties, such as family members, roommates, or other people who are relevant to the building’s management and who they wish to submit through Carson (e.g. housekeepers, cleaners, caretakers). There may also be personal information submitted by our Customers about our Registered Users that Registered Users cannot access directly.
The types of information we collect depend on your level of access and engagement with the Carson Platform and can include:
Contact information such as names, email addresses, mailing addresses, phone numbers
Unique identifiers such as usernames, passwords, Carson account numbers
Basic information submitted by you or on your behalf such as service request descriptions
Information uploaded by you such as documents attached to the Carson Platform
If you choose to use sign in services such as Facebook Connect, these services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address
If you choose to use Carson's single sign-on (SSO) with 3rd party vendors such as Clickpay or Aptexx, these services will authenticate your identify and provide you the option to access such 3rd party services such as Clickpay or Aptexx services. Carson does not store, transmit, nor process your payment or other personal information. Clickpay and Aptexx and similar 3rd party vendors process your payment information or other information in accordance with their respective privacy policies, here and here.
Your communications with us, such as your requests for customer support
Information about your usage such as IP addresses, browser type, date/time stamp and clickstream data
Employment information for Customer employees (including title, name, phone number)
Photographs (of residents, employees, pets, visitors, maintenance request attachments)
Scans (license, business card) in the context of building
Incident details and information
Resident instructions (including permission to enter, permission for authorized visitors, intercom call settings)
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.
Web Beacons / GIFs
Third party tracking technology companies employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' personally identifiable information.
Analytics / Log Files
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personally identifiable information.
3rd Party Tracking
Legal Bases for Collecting Information
We process personal data for, or based on, one or more of the following legal bases:
Performance of a Contract
We use personal data to enter into and to perform under, an agreement between Carson and the Customer.
We use personal data for our legitimate interests, including contact information, services offered, and website usage data.
Compliance with Legal Obligations and Protection of Individuals
We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
We process certain personal data because you have given us your consent to process it in that manner.
Why We Collect Your Information
Carson uses the information we collect from all our Services for the following purposes:
Customize Our Services
We use your information to deliver our services, and customize for each Registered User or Customer.
Maintain & Improve Our Services
We also use your information to ensure our Platform is working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use your information to make improvements to our services.
Provide Personalized Services
We use the information we collect to customize our services for you.
We use data for analytics and measurement to understand how our services are used. For example, we analyze data about how much time you spend accessing the Platform to do things like optimize Platform design.
Communicate with You
We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity, like an attempt to sign into your Carson account from an unusual location. Or we may let you know about upcoming changes or improvements to our services. And if you contact Carson, we’ll keep a record of your request in order to help solve any issues you might be facing.
Protect Carson, Our Users, and The Public
We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Carson, our Customers, Registered Users, or the public.
We use different technologies to process your information for these purposes. We use automated systems that analyze your content to provide you with things like customized services, or other features tailored to how you use our Services. And we analyze your content to help us detect abuse such as spam, malware, and illegal content.
We may combine the information we collect among our Platform and across your devices for the purposes described above. If other Registered Users already have your email address or other information that identifies you, we may show them your publicly visible Carson account information, such as your name and photo. This helps people identify an email coming from you, for example.
How we use the information
For users of the Platform, we use the information we receive to:
Provide the services our Customer requested
Notify you of activity related to your account, such as when a package is delivered to the property for you
Administer your account
Keep your account secure (including to verify your identity and prevent fraud)
Respond to customer service and support requests
Create and provide better and improved products and services based on your use of the site and your feedback
List you in our member directory made available only to other members of your building
Conduct research and analysis
Send you our newsletter, which you may opt out of at any time
For visitors requesting information about our products and services from one of our websites, we use the information we receive to:
Assess the needs of your business to determine suitable products
Send you requested product or service information
Send you marketing communications
Send you our newsletter, which you may opt out of at any time
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
European Union Users
Data protection law in Europe requires a “lawful basis” for collecting, processing and transferring personal information from citizens or residents of the European Economic Area (EEA). Our lawful bases, as detailed above, include performance of our contract with our
Customers, user consent (which is always easy to withdraw), and our legitimate interests (except where such interests are overridden by the interests or fundamental rights and freedoms of our EU users).
Your personal information is neither sold nor rented to third parties without your express permission. We do retain the right to share non-identifying aggregated demographic and/or statistical information with partners, advertisers and sponsors. We may use non-identifying and aggregated information to improve your experience on the website and to share with partners, advertisers and sponsors. For example, any personal information will remain with us, however, your visit may be counted to demonstrate the number of visitors to a particular page or area of the site.
Links to Third Party
We may disclose your personal information:
As required by law, such as to comply with a subpoena, or similar legal process
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
If Carson is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
Carson will only retain personal data we process on behalf of our Customers for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
User Access and Choice
Users residing in certain countries, including in Europe, are afforded certain rights regarding their personal information. These rights include the right to access, correct and request deletion of your personal information. While these rights are not applicable worldwide, all Carson Registered Users can manage their personal information as described below.
You may access, correct, update, amend or remove certain personal information by making the change on your user account settings page or by requesting that your property manager (or other program administrator) make such change on your behalf. Your account is protected by a password. We encourage you to choose your password carefully and keep it secure. If you have trouble accessing your account or your information, you can contact Carson by emailing our customer support team at email@example.com. If you no longer require our services, or wish to request your personal information be deleted/removed, please contact us using the aforementioned direct methods. Termination of service proceedings are conducted offline and are subject to approval by our Customer, if you are a resident or staff user. We will respond to your request within thirty (30) days.
Our commitment to children's privacy
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
The EU-U.S. Privacy Shield
Data Protection Addendum
To assist our customers in the EEA in complying with applicable data protection legislation, we offer a Data Processing Addendum (DPA) to our Subscription Agreement. To request a DPA, contact us at firstname.lastname@example.org.
Data Protection Officer
To contact our Data Protection Officer, please email email@example.com.
Changes to this policy
Postal 85 Fifth Avenue, Floor 4
Address New York, N.Y. 10003
Phone +1 (646) 661-2250