Privacy Policy  

Last Modified:  11/15/2024

1. Introduction

This Privacy Policy outlines Step Above Property Management (“we,” “our,” or “the Company”) practices with respect to information collected from users who access our website at www.oberon.com (“Site”) or otherwise share personal information with us (collectively: “Users”).

2. Grounds for Data Collection

The processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you, providing you with our services, protecting our legitimate interests, and complying with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

3. What Information We May Collect

We collect two types of data and information from Users:

a. Non-Personal Information

The first type is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-Personal Information”). We are not aware of the identity of a User from which the Non-Personal Information was collected. Non-Personal Information may include:

• Device type, operating system, browser type, and version
• Language preference, access time, geographical location
• Aggregated usage data (e.g., browsing history, search history, clicks, etc.)
• Tracking information (e.g., campaign IDs, click IDs, distinct tracking IDs)
• Information gathered from cookies, web beacons, pixel tags, and other tracking technologies
  

b. Personal Information

The second type is individually identifiable information that identifies or may, with reasonable effort, identify an individual (“Personal Information”). Such information includes:

• Identifiers:  Name, email address, phone number, IP address, login credentials, job title, company information, and social security number
• Commercial Information:  Transaction details, purchase history, billing information, and payment data (e.g., credit/debit card identifiers)
• Device Information:  Media Access Control (MAC) address, screen resolution, and Internet Protocol (IP) address
• Location Data:  Geolocation from your device
• Sensitive Data:  Social security number, government-issued identification, passport number, driver’s license, and precise geolocation
• External Profiles:  Social media and email provider logins, images, and contact details
• Professional Information:  Job title, work history, and professional qualifications
• User-Generated Content:  Information you provide when using our services or filling out forms (e.g., rental applications)

4. How Do We Receive Information About You?

We receive your Personal Information from various sources:

• When you voluntarily provide it to us:  such as when you register on our Site or fill out forms.
• When you use or access our Site:  through your interactions and activities.
• From third-party providers, services, and public registers:  for example, from analytics vendors.

5. What Are the Purposes of Processing?

We may use the information we collect for the following purposes:

• Account Management:  To process orders, manage accounts, and facilitate transactions
• Communication:  To respond to your inquiries, send service-related updates, and provide technical support
• Marketing and Personalization:  To provide personalized experiences, recommendations, and targeted advertisements
• Legal Compliance:  To comply with legal obligations, enforce our terms, and address security concerns
• Analytics and Research:  To analyze usage data, conduct research, and improve our Offerings
• Events and Promotions:  To manage and promote contests, referral programs, and other marketing activities
• Third-Party Services:  To allow integrated services (e.g., payment processing, renter’s insurance, background checks)

Consent for Communication:

By providing your contact information, you consent to receiving texts, calls, and emails from us. You can reply “STOP” to opt out of texts at any time.

4. Legal Basis for Processing Personal Data

We process Personal Data on various legal bases, including:

• Performance of Contract:  To fulfill contractual obligations and provide our services
• Legitimate Interests:  For security, fraud prevention, and business operations
• Consent:  When you opt into marketing communications or specific data uses
• Legal Compliance:  To meet regulatory and legal obligations
  

What are your rights with respect to your Personal Data? 

Under certain circumstances, depending on your jurisdiction, you may have rights under data protection laws in relation to the Personal Data we process about you:

• Request  access  to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we process about you.
• Request  correction  of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request  erasure  of your Personal Data. This enables you to ask us to delete or remove your Personal Data. 
• Object to processing  of your Personal Data. In certain circumstances you can object to our processing of your Personal Data. 
• Request  restriction of processing  of your Personal Data. 
• Request the  transfer  of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine- readable format. 
• You have the right to  withdraw consent  at any time where we are relying on consent to process your Personal Data. Please note that if you withdraw your consent, we may not be able to provide certain products or services to you.
• You have the right to  object to automated individual decision-making  and profiling which has produced legal effects or otherwise significantly affected you, and the right to request human intervention where, in such cases, we have relied on automated decision making or profiling.

Depending on the state in which you live, you may have the following rights:

California Rights -  California law provides California residents with the rights listed below. 

• Right to Know.  You have the right to know what personal information we have collected and disclosed about you in the last 12 months, including:
• The categories of personal information we have collected;
• The categories of sources of the personal information;
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold or shared and the categories of third parties to whom the information was sold or shared; and
• The business or commercial purposes for collecting, selling, or sharing the personal information; and
• The specific pieces of personal information we have collected about you.
• Right to Correct.  You have the right to request that we correct inaccurate personal information.
• Right to Delete.  You have the right to request that we delete the personal information we have collected from you (subject to certain statutory exemptions).
• Right to Access/Portability.  You have the right to request a copy of the personal information we have collected about you.
• Right to Opt Out.  You have the right to opt out of the sharing of your personal information to a third party for cross-context behavioral advertising (as defined under California law).

You also have the  right not to be discriminated against  for exercising any of the rights listed above.

Sensitive Personal Information.  Certain categories of personal information we collect and use to provide the Services may be deemed "sensitive personal information" under California law (such as: social security number, driver’s license, financial account or card numbers, precise geolocation, racial and ethnic characteristics, and content of mail, email, and text messages sent through our systems). We do not use or disclose sensitive personal information other than to provide our Services and as otherwise permitted by California law.

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• 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.

Colorado, Connecticut, Texas, Utah, and Virginia Rights 

• Right to Access.  You have the right to know and see what personal information we have collected about you.
• Right to Correct.  You have the right to request that we correct inaccurate personal information (Colorado, Connecticut, Texas, and Virginia only).
• Right to Delete.  You have the right to request that we delete the personal information we have collected about you.
• Right to Data Portability.  You have the right to request a copy of the personal information we have collected about you.
• Right to Opt Out.  You have the right to opt out of targeted advertising (as defined by each states' respective law).

Oregon Rights

• Right to Access.  You have the right to know what personal information we have collected and disclosed about you, including:
• The categories of personal information we have collected about you;
• A list of third parties to whom we disclosed your personal information for a business purpose; and 
• A copy of the personal information we have collected about you.
• Right to Correct.  You have the right to request that we correct inaccurate personal information.
• Right to Delete.  You have the right to request that we delete the personal information we have collected from you (subject to certain statutory exemptions).
• Right to Opt Out of Targeted Advertising.  You have the right to opt out of targeted advertising (as defined under Oregon law).

If you wish to exercise any of the above-mentioned rights or raise any concern, please contact us in accordance with the information mentioned at the bottom of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Appeal Process. 
In the event you disagree with the outcome of a request, you may initiate an appeal by contacting us. Please note that an appeal should only be submitted after you have received a response to your original request.

If you are located in the EEA or the United Kingdom, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

5. Sharing Personal Information

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy. We may disclose information:

• With our affiliates, subsidiaries, and subcontractors:  to assist in providing services or products.
• With trusted third-party providers:  for purposes such as hosting, analytics, advertising, and marketing.
• For legal reasons:  when necessary to comply with laws, regulations, legal processes, or governmental requests.

6. Your Rights Regarding Your Personal Data

Depending on your jurisdiction, you may have rights such as:

• Right to Access:  Request copies of your Personal Data
• Right to Correct:  Update or correct inaccurate data
• Right to Delete:  Request deletion of your Personal Data
• Right to Object:  Opt-out of processing for specific uses, like marketing
• Right to Data Portability:  Receive a copy of data in a structured format
• Right to Withdraw Consent:  Revoke consent at any time without affecting the legality of prior processing

7. How Long Do We Retain Your Personal Data?

We retain Personal Data as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are based on:

• Sensitivity and nature of data
• Legal and regulatory requirements
• Risk assessment and business needs

Outdated or unused data will be deleted at the earliest reasonable time.

9. Cookies and Tracking Technologies

We and our trusted partners may use cookies and other technologies in our related services, including when you visit our Site or access our services.

Types of Cookies We May Use:

• Session Cookies:  Stored temporarily and deleted when the browser is closed.
• Persistent Cookies:  Saved for a fixed period and not deleted when the browser is closed, used for repeat visits.
• Third-Party Cookies:  Set by other online services, such as analytics and advertising platforms.

Cookies help improve your experience by remembering preferences, ensuring smoother navigation, and serving relevant ads. You can disable cookies through browser settings, but some features of our Site may not function correctly.

10. Third-Party Collection of Information

This Privacy Policy does not apply to the practices of third-party services or websites that may be linked to our Site. We encourage Users to read their respective privacy policies.

11. Security of Your Information

We implement industry-standard measures to protect the information we collect. While we take reasonable steps to secure your data, we cannot guarantee absolute security.

12. Transfer of Data Outside the EEA

For Users in the European Economic Area (EEA), please note that data may be transferred to and processed in countries outside the EEA. Such transfers will be made to countries that provide adequate data protection or under agreements that provide a legal framework for data security.

13. Advertisements

We may use third-party advertising technology to serve ads based on your usage of the Site. You can opt out of personalized ads through networks like the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA).

14. Marketing

We may use your Personal Information for promotional purposes. Users have the option to unsubscribe from marketing communications at any time.

15. Corporate Transactions

In the event of a merger, acquisition, or sale, your information may be transferred as part of the transaction.

16. Minors

Our Site is not directed at children under the age of 13. We do not knowingly collect information from minors. Parents or guardians who believe a child has provided us with Personal Information should contact us.

17. Updates to This Privacy Policy

We reserve the right to amend this Privacy Policy periodically. Changes will be effective immediately upon display. Continued use of the Site constitutes acknowledgment and consent to these changes.

18. How to Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact:

Step Above Property Management

101 State Drive, Suite M, Hollister, MO 65672

(417) 559-5319

office@stepabovepropertymanagement.com