Privacy Policy

ClickPay Privacy Policy

Effective Date: January 1, 2023

RealPage, Inc. (“RealPage”) is committed to providing clear and concise information regarding our collection and processing of personal information. This Privacy Policy describes how RealPage and its subsidiary, NovelPay, LLC, (collectively, “ClickPay”, “we,” or “us”) collect, use, and disclose certain personal data for ClickPay payment services (collectively “CP Services“). By accessing our website or utilizing CP Services, you consent to the information collection and handling practices outlined in this statement.

I. CP Services & Scope

ClickPay collects and processes personal information as a service provider to property owners, HOAs, and other real estate management companies (collectively, “Clients”). ClickPay offers CP Services to Client residents and property owners for purposes of paying their rent, HOA fees, and other real estate fees (collectively “payments”) online. ClickPay users may make their payments via various payment methods, including ACH, debit card, and credit card. This Privacy Statement covers the information collection, use, and handling practices for the entire scope of ClickPay services, including any integration with property manager resident ledgers and related services. References to “CP Services” encompass both the ClickPay service and the corresponding supporting activities of RealPage in offering and operating the service. This Statement does not apply to the privacy or security practices of any third party.

II. Personal Information Collection

CP Services collect personal data necessary to establish user accounts, process the requested payment(s), and comply with applicable regulatory requirements. ClickPay has collected the following categories of personal information necessary to provide our CP Services in the preceding twelve (12) months:

II. Personal Information Exceptions

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from state privacy law scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

III. Personal Information Sources

CP Services personal information is collected from (i) the ClickPay account holder during service enrollment, (ii) HOA and property management companies’ accounting ledger and management systems, and (iii) third-party vendors supporting the processing of payment transactions within the banking and card brand networks.

IV. Personal Information Use & Processing

In providing CP Services, ClickPay acts as a service provider under contract to our Clients. As a service provider, ClickPay does not control any of the personal information we process on behalf of our Clients. Our Clients collect and control all such personal information, and ClickPay is required to provide our products and services in accordance with Clients’ contractual provisions and instructions regarding data collection, privacy, processing, and security.

The personal data collected by CP Services is used for a variety of purposes, including:

• Integration of your ClickPay user account with your apartment community leasing and rents software and resident accounting ledger or HOA accounting ledger
• Processing of payments and payment instructions submitted by users through their ClickPay account
• Distribution of communications and legally required notices regarding the status of your ClickPay account and any scheduled, processed, or declined payments.
• Integration with your apartment community online resident portal or HOA portal
• ClickPay service and website optimization
• Maintaining compliance with federal and state laws related to financial institutions and payment processing

ClickPay will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Additionally, ClickPay processing of sensitive personal information is limited to activities necessary for the delivery and performance of CP Services.

Personal Information Disclosure

ClickPay does not sell personal information collected through CP Services, and no such activity has occurred in the prior 12 months.

ClickPay may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors that support or integrate with the CP Services described in this statement (see chart below). ClickPay only discloses personal information to the extent reasonably necessary to support CP Services requirements, or for the third-party vendors or service providers to perform the services on our or your behalf. We do not permit third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request of them. However, please note that ClickPay does not maintain direct control over the privacy policies and practices of Clients or any other third-party companies, agents, or contractors.

VI. Personal Information Rights and Choices – State Privacy Rights

Certain state jurisdictions (California, Virginia, Colorado, Connecticut, and Utah) provide their legal residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with statutory guidelines. This section describes your rights and explains how to exercise those rights. Please be advised, the nature of CP Services and applicable regulations may exempt a significant portion of the personal information collected by CP Services from the scope of state privacy rights.

Accessing and Updating Personal Information

In the event your personal information is determined to be outdated, incomplete, or inaccurate, you may access and update your information by logging into your CP Services account or contacting our customer support team at (800)533-7901. If you require verification that your requested changes have been completed, and such verification is not readily displayed in your CP Services account, you may request confirmation at the email address listed below (See “Contact Us”).

Access to Specific Information Regarding Personal Information Use/Disclosure and Portability

You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months from the Client (your property manager, HOA manager, condo association, etc.) that has contracted with ClickPay for offering of CP Services. The Client will evaluate your request and instruct ClickPay accordingly.

In response to a verifiable consumer request submitted to ClickPay by our Client, we will disclose the following information to the Client for the applicable CP Services:

• The categories, specific types, and sources of personal information we collected about you.
• Our business purpose for collecting the personal information.
• The categories of third parties with whom we share that personal information and the purpose for the disclosure.

The Client will then respond directly to you to complete your verifiable consumer request in accordance with applicable privacy laws.

Following this same process, you also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, ClickPay may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk. If such limitation exists, ClickPay will communicate these factors to the Client, and the Client will notify you in accordance with applicable privacy laws.

Deletion of Personal Information

You have the right to request that the Client (your property manager, HOA manager, condo association, etc.) delete any of your personal information that we collected and retained, subject to certain exceptions. The Client will evaluate your request and instruct ClickPay accordingly.

Once we receive a verifiable consumer request submitted to ClickPay by our Client, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records as instructed by the Client, unless one of the following exceptions applies:

We may deny your deletion request if retaining the information is necessary for ClickPay or our service providers to:

1. Complete the transaction for which we collected the personal information, provide the CP Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug ClickPay Services to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or our Clients.

7. Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.

8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If any such limitation exists, ClickPay will communicate these factors to the Client, and the Client will notify you in accordance with applicable privacy laws. The Client will then respond directly to you to complete your verifiable consumer request in accordance with applicable privacy laws.

VII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights

Consumer requests should be submitted to the Client (your property manager, HOA manager, condo association, etc.).

Only you (or someone legally authorized to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use personal information provided in a verifiable consumer request submitted by a Client to verify the requestor’s identity or authority to make the request.

VIII. Consumer Request Responses and Timelines

We endeavor to respond to a verifiable consumer request submitted by a Client within forty-five (45) days of your original request submission to the Client. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform the Client of the reason and extension period in writing, and the Client will inform you in accordance with applicable privacy laws.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

IX. Personal Information Sales and Sharing – Opt Out Rights

ClickPay does not sell personal information collected through CP Services, and no such activity has occurred in the prior 12 months. In the event that ClickPay changes its practices and engages in the sale of personal information as regulated by law, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with regulatory requirements.

ClickPay utilizes cookies and tracking technologies as set forth in the Cookie Policy. Under some circumstances, these technologies may be deemed a “sharing” of personal information under applicable privacy laws. ClickPay provides a cookie preference center to allow you to opt out and customize the cookies presented on our websites and services.

X. Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law, we will not engage in any of the following practices in response to your exercise of privacy rights:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

XI. Other California Privacy Rights
The State of California also grants California residents privacy rights via laws unaffiliated with the CCPA/CPRA. Those rights include the following:

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@realpage.com.

XII. Cookies, Web Beacons, and Other Technologies – Do Not Track
When you access our CP Services or our website, our servers may place small text files (“cookies”) on your computer for recordkeeping purposes. Among other things, cookies enable us to gather information about your activity on our website for the purposes of improving your online experience, establishing secure user accounts, remembering your preferences and settings, and for other similar customization purposes.

In addition to cookies, our CP Services and our website may utilize web beacons, clear gifs, or other technologies to gather information on how users interact with and utilize various features. For example, these technologies can identify popular pages, viewing patterns, click-through, conversion rates, and other information that can be used to improve, monitor, and operate our websites, products, and services.

A detailed summary of our cookie and similar technology usage is set forth in our Cookie Policy.

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers, and our sites are not currently set up to respond to those signals. Most internet browsers provide controls that allow users to directly manage or disable the placement and usage of cookies on their computer. Please note that disabling cookies may deactivate or otherwise restrict certain features of our CP Services or our website.

XIII. Third Party Links to Other Sites

Our CP Services may include links to third party service providers contracted by Clients. These linked services are operated by unaffiliated third parties that have separate and independent privacy statements, terms of use, and related notices or disclosures regarding information handling practices. We cannot be responsible for the information handling practices of independent parties and encourage you to review their practices prior to information disclosure.

XIV. Data Security

ClickPay implements and maintains appropriate physical, administrative, technical and organizational measures to protect the information we process against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to personal information is restricted and authorized only for those who have a business need for such access. ClickPay strives to protect the personal information that we process; however, no security program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal information. We maintain security incident response policies and procedures to handle incidents involving unauthorized access to personal data we process.

XV. Children’s Online Privacy

Our CP Services do not target or attract the attention of children under the age of 13 for the online collection of personal information.

XVI. Changes to Our Privacy Statement

ClickPay reserves the right to amend this privacy statement at our sole discretion at any time. When we make changes to this privacy statement, we will post the updated content to our applicable websites and services along with the effective date of the change. Your continued use of our CP Services following the posting of changes constitutes your acceptance of such changes.

XIV. Contact Us

Via US Postal Service at:

RealPage, Inc.
Attn: Privacy (Legal)
2201 Lakeside Blvd.
Richardson, TX 75082

OR Via email at: privacy@realpage.com