This policy applies to all prospective, current and former TPH customers. Note that, in order to use our services, you must be a U.S. resident 18 years of age or older.
Information We Collect About You
Information Provided by You
We collect personal information about you that you provide while you use zerodown.com or any associated websites, desktop or mobile applications. We collect most of this information during the registration and/or application process for tenant screening. Additional information may be gathered during your subsequent use of the site, or when we communicate with you via telephone, email or other means.
Certain personal information must be supplied during the tenant screening processes in order to meet our legal obligations, verify your identity, determine eligibility for a lease, protect against fraud, and complete your transaction. The following categories of information may be collected:
- Your basic identifying information (for example, your name, address, email, telephone number, and date of birth);
- Your Social Security number;
- Your employment and income information;
- Your bank account and security account information;
- Login credentials used to access our site;
- Any personal information you provide us
In addition, we gather names and email addresses of people who contact us with questions. We collect this information only for the purpose of responding to inquiries. If you use our “refer-a-friend” feature, we will collect information from you in order to process your referral request.
Information Collected From Third Parties
When you check your status for a lease arrangement through TPH, we will collect information from credit bureaus and other partners to determine your eligibility and assess risks related to your lease application. We collect information from credit bureaus in order to assess risks associated with your lease application or to provide you with marketing offers. If another company refers you to TPH or assists you in any way in the lease application process, we may collect your information from that company in order to process your application.
The following categories of information are generally collected:
- Your identifying and application information (for example, your name, address, email, telephone number, date of birth, social security number, and employment information);
- Your credit score & history;
- Your bank account and security account information and up to 24 months of transactions and balances;
- Your mortgage information;
- Your public LinkedIn profile for your employment and education history;
- Public records, including bankruptcy, judgments, liens and payment statuses;
- Information from any of your secured creditors about outstanding debts and related collateral.
Information Gathered Based on Your Activity on the TPH Platform
In order to provide services to you, improve our business and maintain records required by law, TPH collects information about your transactions and activity. For tenants, this includes your payment history. For all members, TPH collects information about your computer and your visits to www.zerodown.com and any other TPH websites, such as your IP address, geographical location, browser type, referral source, length of visit, button clicks and page views.
Cookies and Web Beacons. TPH and our marketing partners and service providers use technologies such as cookies, beacons, tags, embedded links and scripts, to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis.
Usage Data & Site Activity. TPH also uses local storage to store content information and preferences. Various browsers may offer their own management tools for removing content persisted in the browser’s local storage.
TPH does not process or respond to “do not track” signals or other similar signals whereby a visitor to a website requests that it disable collection of information about the visitor’s online activities over time and across different websites.
Additional Limits on Use of Your Google User Data
TPH use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
How We Use Your Information
Processing Your Transaction
If you register as a user/tenant applicant, TPH will use your information to facilitate your lease application request. This may include:
- Generating your tenant profile and processing your lease application;
- Enabling automatic payments and fund transfers with other financial institutions;
- Implementing collection activities as needed;
- Implementing eviction activities as needed;
- Reviewing your payment history;
- Communicating with you concerning your account and transactions;
- Addressing any disputes or inquiries you may raise concerning your account
We will use your information to run our everyday business and in accordance with applicable law. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, such as recordkeeping, tax reporting requirements, fraud prevention, audit and data integrity.
Maintenance of Your Transaction
When you register on our site you will receive emails that confirm specific actions you requested. These notifications are typically sent to notify you of a change in status, or for legal or security purposes. For example, you will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and the successful submission of tenant lease requests; you will receive notifications regarding certain changes to legal agreements and required tenant and privacy disclosures; and you will receive progress updates on the status of lease requests. These transactional notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. We may also send you responses to emails you send us, if appropriate or applicable. Generally you may not opt out of these service-related emails.
Data Analysis & Optimization
TPH also uses your information to conduct analyses related to our services and our website. We use this information to improve our services and tenant screening model. We also use this information to improve our websites’ usability and to evaluate the success of particular marketing campaigns and other activities.
During the course of processing your application, we accumulate non-public personal financial information from you and from other sources about your income, your assets, and your credit history in order to allow a lender to make an informed decision about granting you credit. We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your non-public personal information.
We collect non-public information about you from the following sources: (i) information we receive from you on applications or other forms; (ii) information about your transactions with us, our affiliates, or others; and (iii) information we receive from a consumer reporting agency. We do not disclose any non-public information about our customers or former customers to any third party, except as permitted by law.
Optional Communications: Marketing & Surveys
TPH may also use your personal information to select you for certain marketing offers, newsletters, surveys and/or requests for feedback regarding your experience. TPH may use your personal information both to select you for an offer and to communicate that offer to you.
Receipt of these communications via email is voluntary. If you do not wish to receive these communications, please reply to sender asking to unsubscribe.
How We Share Your Information
TPH shares your information with third parties as permitted by law, including in the following specific ways:
- Third Party Service Providers. TPH relies on third party service providers to help us conduct our business and marketing activities, such as maintaining our files and records, offering customer service, sending marketing communications, or facilitating fund transfers. TPH may share your information with such companies, which are authorized to use your personal information only as necessary to provide these services to TPH. Information may also be shared among affiliates for this purpose where one affiliated company provides services to or on behalf of another affiliated company in connection with your account.
- Referral Partners. If you were referred to TPH by another company (a “Referral Partner”), TPH will share your information as necessary to honor the terms of its agreement with that Referral Partner and to process your transaction. In some cases, TPH may share with a Referral Partner for that Referral Partner’s own business purposes, such as to analyze and improve its business and provide targeted marketing offers to you. Your rights with respect to this sharing are discussed in the following section.
- Affiliates. TPH affiliates, including entities covered by this policy and other companies related by common ownership or control may share your information with each other, including information related to your tenant screening application, for purposes of general business analysis or to present targeted marketing offers to you or others. Your rights with respect to this sharing are discussed in the following section.
- Legal Requests & Regulatory Requirements. TPH may also share information with law enforcement or other governmental agencies or officials to comply with any applicable law, regulation, court order, judicial proceeding, legal process or governmental request; or to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability; or in connection with an audit. We may also share or transfer your information to a successor in interest to TPH, which may include, but may not be limited to, a third party in the event of an acquisition, sale, merger or bankruptcy involving TPH.
- Sharing of Anonymized Data. TPH may share aggregated and anonymized data sets including your information with third parties, including but not limited to business partners, service providers, and among TPH affiliates. No personally identifiable information will be included in these data sets.
Important Privacy Choices
Right to restrict information sharing with companies we own or control (affiliates): TPH may share your information among affiliated companies whether or not those companies are covered by this policy. Federal law gives you the right to limit this sharing in certain circumstances, including where it includes information about your tenant eligibility or is used for the purpose of marketing to you. If you would like to opt-out of this type of sharing, please follow the instructions below. We may begin sharing your information related to your tenant eligibility or any information to be used for marketing purposes 30 days from the date that we first provided this notice if you have not opted-out.
In order to revoke your consent for information sharing with Referral Partners and/or opt-out of TPH affiliate information sharing, please email us.
Additional Facts About Your Personal Information
How you can change your personal information
You can access the personal information you have provided to us by logging in to the [“Settings”] page of your account. As a registered user, you can update your password, email, secret question(s), screen name, phone number or bank account information at any time. If you are registered as a tenant, you may update your mailing address at any time after your tenant profile has originated. To change other information, contact us. We will respond to your request within a reasonable time.
We will retain your information as needed to provide you services, comply with our legal obligations, resolve disputes, conduct analysis, audits, or to enforce our agreements or as otherwise required by law.
How We Secure Your Information
TPH uses significant safeguards, including physical, technical, and operational controls to protect your personal information, both during transmission and once received. Despite these efforts, no security measures, however thorough, are perfect. Accordingly, we do not guarantee the security of the information you provide to us. If you have any questions about the security of your information, you can contact us.
TPH equips all servers with an Extended Validation (EV) Secure Socket Layer (SSL) certificate to ensure that when you connect to our websites you can tell that you are actually on our site and that all data entered into the websites are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected. Data security is achieved through technical safeguards that include a combination of a firewall, intrusion detection system, malware detection system, and data loss prevention system. TPH also conducts vulnerability scans of applications and systems regularly.
Access to the system is controlled and limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and internal information use policy ensure that only trained and trusted staff are permitted to access personal information.
We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.
Protection of Account Numbers
When we contact you about your account to confirm a funds transfer, we only reference an access token via plaid integration. This gives us access to a truncated set of digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own.
At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. You should always choose a password that is difficult for others to guess and change your password frequently.
Additional Steps You Should Take to Ensure the Security of Your Information
TPH sends important communications regarding your account via email. You should therefore take steps to secure and restrict access to your email account, change your email account password frequently and use strong passwords. You should also be aware of fraudulent emails known as “phishing,” from companies claiming to be TPH and requesting your login information or other account information. TPH will never ask for your login information in an email.
When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files. This step is particularly important if you use a computer that is accessed by other people, such as in a public library or Internet cafe. You should install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users.
You may not include any identifying information in your TPH screen name. We are not responsible for any personal information that you may choose to reveal in your screenname.
Changes to this policy
Questions, Comments and Contact Information
For additional information, or if you have any questions regarding this policy or the privacy practices at TPH, please submit your questions or comments directly to firstname.lastname@example.org.
You can also send questions or comments to:
T. P. Hamilton inc.
149 New Montgomery St., Floor 4
Telephone: +1 628-400-8162
NOTICE TO CALIFORNIA RESIDENTS
Subject to certain restrictions, California residents have the right to request that we disclose what personal information we collect about you, to delete any personal information that we collected from or maintain about you, and to opt-out of the sale of personal information about you. As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us
Accessing and Deleting Your Personal Information
Right to request access to your personal information
California residents have the right to request that we disclose what categories of personal information that we collect, use, or sell about you. You may also request the specific pieces of personal information that we have collected about you. However, we may withhold some information where the risk to you, your personal information, or our business is too great to disclose the information.
Right to request deletion of your personal information
You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.
How to exercise your access and deletion rights
California residents may exercise their California privacy rights by submitting your request
Sales of Personal Information
California residents may opt out of the “sale” of their personal information. We believe that we currently do not “sell” your personal information as we understand that term to be defined by the California Consumer Privacy Act ("CCPA") and its implementing regulations.
California residents have the right to not be discriminated against for exercising their rights as described in this section. We will not discriminate against you for exercising your CCPA rights.