Privacy Policy - Draper and Kramer, Incorporated

Last Updated: March 21, 2024

Draper and Kramer, Incorporated, an Illinois corporation, D&K Real Estate Service Corporation, a Delaware corporation, and DKRESC Texas LLC, a Texas limited liability company (collectively, with each of their agents, employees, officers, subsidiaries, parents, partners, and affiliates) (“Draper and Kramer”, “we”, “us”, or “our”) is committed to protecting the privacy of our consumers (“consumers”, “users”, “you”, or “your”). Draper and Kramer has created this Privacy Policy in order to demonstrate in writing our firm commitment to privacy. In particular, this Privacy Policy describes our privacy practices with regard to information about you that could reasonably be used to identify you personally or that is associated with information that identifies you (“Personal Information”).

Please take a moment to review the terms of this Privacy Policy. Please also review the Terms and Conditions, which govern your use of this web site if you are currently accessing this Privacy Policy on the Internet, and any other web sites under Draper and Kramer’s control, whether partial or otherwise (including, without limitation, any web site from which this Privacy Policy was accessed from) (individually a “Site” and collectively, the “Sites”). Please note that certain features or services discussed in this Privacy Policy may not be offered on the Sites at any particular time.

SECTION 1. Scope of This Policy

In this Privacy Policy, we describe the types of Personal Information we collect, how we use it, how it is shared and how you can access, delete, correct, change and limit our use of it.

Draper and Kramer’s policy is to comply with data protection legislation. Depending on your state or country of residence, there may be differences in our processing of your Personal Information and you may have different rights in respect of your Personal Information. For additional location-specific information, please see Section 15.

SECTION 2. Categories of Information We Collect

To provide you services, we collect the following general categories of information about you: Personal Information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of all these categories of information.

Personal Information is information that can be used to identify you, or any other individual to whom the information may relate, personally. We do not collect Personal Information unless you provide or have provided it to us. Some examples of Personal Information that we may collect, depending on the services you use and local law, are: your name; contact information, such as address, e-mail address, and telephone number; social security number; credit card number; bank account information and routing numbers; driver’s license number or state identification number; information about your vehicles including license plate numbers; and information about third parties, such as references or contacts, that you provide to us if you have their consent to do so.

Demographic information is information that is not unique to you in the sense that it refers to selected population characteristics, such as your ZIP code or postal code, birth date, age, preferences, gender, marital status, race or ethnicity, occupation, interests and favorites.

Draper and Kramer also collects, or logs, certain other behavioral information that cannot identify you personally when you visit our Sites. This information includes your Internet Protocol (“IP”) address and your domain name. An IP address is a number that is automatically assigned to your computer by the Internet Service Provider (“ISP”) through which you access the web and a domain name is the name of the ISP computer itself through which you access the web. Draper and Kramer logs these IP addresses and domain names and aggregates them for system administration and to monitor the use of our Sites. We use the aggregated information to measure the number of visits to a Site, the average time spent on a Site, the number of pages viewed, and various other Site use statistics. This monitoring helps us evaluate how our Sites are used and continuously improve the content we provide. For more information, please review Section 9.

In addition, Draper and Kramer may collect indirect information about you when you use certain third-party services on our Sites. For example, if you register on our Sites by using your User ID and password associated with a third-party provider (e.g., Microsoft, Facebook or Google), you authorize us to have access to and store the information from your account profile from the third-party provider; such information will be subject to, and treated in accordance with, the policies and practices described in this Privacy Policy.

SECTION 3. How and Where we Collect Your Personal Information

We may collect Personal Information through the following:

Online Services. We collect Personal Information when you interact with our Sites and any related Sites that post a link to this Privacy Policy. This may include, for example: when you fill out and submit forms (such as forms requesting information needed to consider you for apartment rentals or potential employment opportunities); when you initiate payments to us through the Sites; when you post to any interactive forum, bulletin board, or chat room that we may make available on a Site; when you register for e-mail communications; and when you submit a survey response, question or request to a Site using a form or the e-mail address links on the Sites. We may also use that information to make you aware of additional products and services of Draper and Kramer or trusted third parties with whom we have alliances which may be of interest to you, or to contact you regarding Site changes.

Offline Collection from You. Draper and Kramer may also collect Personal Information from you through means other than the Sites. This may include offline collection, such as when you submit a paper application to rent an apartment, make a payment by check, call or visit a Draper and Kramer property, or apply for a job with Draper and Kramer. It may also include e-mails that you send to us separate from the Sites and customer service calls. This Privacy Policy also applies to Personal Information that you provide to us through means other than the Sites. Without limitation, to the extent we combine the Personal Information we collect from you outside of the Sites with Personal Information that we collect through the Sites, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

Information Collected from Other Sources. We may receive Personal Information about you from other sources. For example, if you are applying for an apartment, condo, corporate housing, or employment, either via the Sites or offline, we may obtain information from third parties about your creditworthiness, among other information, as part of the application process. We may combine the information we receive from these other sources with Personal Information we collect through the Sites, online services, property visits and offline interactions. In those cases, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

SECTION 4. How Information is Used

We use the information we gather or have gathered for the purposes of delivering our products and services, responding to any queries and customer services requests you may have, operating and improving the Sites, fostering a positive user experience, analyzing trends, improving our marketing and promotional efforts, and improving the products and services that we offer. The information we gather or have gathered may be shared within the Draper and Kramer group of companies on a worldwide basis, including countries that might not have legislation that guarantees adequate protection with respect to your country or state of residence.

By providing your information to Draper and Kramer, or registering with our third-party providers, you have consented for us to use your information, subject to local law, in the following ways: to allow you to create an account; to create a profile for you based on information that you have provided to us; to contact you about Site updates, informational and service-related communications, including important security updates; to provide you additional communications, information, and promotions such as newsletters; to inform you of other products or services available from Draper and Kramer or its affiliates; to enable you to provide feedback, to contact us and for us to respond to you; to conduct surveys, questionnaires, promotions and contests, and to provide the results thereof such as success stories and contest winners; to provide information about you and your potential interest in applying for an apartment, condo, corporate housing, or employment; to provide products and services that enable users to network, and post information on bulletin boards; to generate internal reports about the use of our Sites; and to provide ‘forward to a friend’ features.

If you post any of your Personal Information in public areas of the Sites, such as in online forums, bulletin boards or chat rooms, such information may be collected and used by others over whom Draper and Kramer has no control. Information you post in public areas of the Sites may be accessed, used, and stored by others around the world, including countries that might not have legislation that guarantees adequate protection with respect to your country or state of residence. By providing your Personal Information for inclusion in our database, you acknowledge that you consent to your information being used as described herein. While Draper and Kramer takes measures to safeguard your information from unauthorized access or inappropriate use by third parties, Draper and Kramer does not control these third parties and we are not responsible for their use of information you post or otherwise make available in public areas of the Sites. Accordingly, you should ensure that you do not post sensitive information, including personality profiles, to any Site.

SECTION 5. How Information is Shared

We disclose to third parties your Personal Information, combined personal, demographic, behavioral or indirect information, as set forth below.

We may share your information with third parties who help us in the delivery of our own products and services to you. Examples include third parties who assist in hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals may be located in countries whose data protection legislation is different from your country or state of residence, and they will have access to your Personal Information as necessary to perform their functions, but they may not share that information with any other third party or use that data for any other purpose. We also share aggregated anonymous information about visitors to the Sites with Draper and Kramer’s clients, partners, other Site visitors, and other third parties so that they can understand the kinds of visitors to the Sites and how those visitors use the Sites.
Draper and Kramer may also provide such information to subsidiaries, affiliates and other trusted third parties with whom we have alliances in connection with providing products or services on our behalf or on behalf of the owner(s) or management of one of our properties, subject to the terms of this Privacy Policy. This includes, without limitation: the owner of any community where you submit an application or where you lease; the management company for such community; and third parties that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. These third parties may have access to Personal Information in order to provide these services to us or on our behalf.
If you configure your profile to receive information about the opportunities, products or services of third parties, we may supply your contact information to select third parties such as data aggregators, marketers or others for the purpose of sending you e-mail or otherwise communicating with you. We use data we have about you (such as the interests and preferences you have expressed) to determine whether you might be interested in the opportunities, products or services of a particular third party.
We disclose information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Because Draper and Kramer is a U.S. company and information collected on our Sites is stored in whole or in part in the United States, your information will be transferred to the United States and become subject to U.S. law. By using the Sites, you consent to this transfer.
We may disclose and transfer such information to a third party who acquires all or a substantial portion of Draper and Kramer’s business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Draper and Kramer becomes the subject of an insolvency proceeding, whether voluntary or involuntary, Draper and Kramer or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. You will be notified of the sale of all or a substantial portion of our business to a third party by e-mail or through a prominent notice posted on the Sites. In addition, when a potential buyer is interested in purchasing one of our properties, we may provide the potential buyer with information about the property and the tenants who live there, which may include your Personal Information. Upon the sale of the property in which you live, all of your Personal Information may be transferred to the purchaser.
If you choose to enter a sweepstakes, contest or other promotion, your Personal Information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

Again, in each of these situations, the recipients of your data may potentially be located in any country in the world. If you are a resident in any EU member state, for example, you must be aware that the EU authorities do not generally consider that the regulations of non-EU countries ensure an adequate or equivalent level of protection as compared to the EU data protection regulations.

SECTION 6. How to Access and Control Your Information

You may have access to, review, correct, update, change or delete your account profile information at any time. Simply log into your account, go to your profile, and make the necessary changes. Making a request to exercise your consumer rights with respect to your Personal Information does not require you to create an account with us. See the methods for contacting us described in Section 14 below. Before providing you with a copy of your Personal Information or correcting, updating or deleting such information, we reserve the right to verify and authenticate your identity and the Personal Information to which you have requested access. Access to or correction, updating or deletion of your Personal Information may be denied or limited by Draper and Kramer if it would violate another person’s rights and/or as otherwise permitted by applicable law. We endeavor to respond to consumer requests within 45 days of receipt. If we require additional time to respond, we will inform you of the reason and extension period in writing and promptly supplement our response within the time period required by applicable law.

Please note that in accordance with our routine corporate record-keeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

If you wish to delete or close your account or account profile information altogether, please contact us using the methods described in Section 14 below. An email will be sent to you to confirm that your Personal Information has been deleted (save for an archival copy which is not accessible by you or third parties on the Internet). The archival copy is retained only for as long as Draper and Kramer reasonably considers necessary for audit and record purposes. We will retain logs, demographic, indirect, and statistical information about you and keep an archival copy of this information in an anonymous form. If your Personal Information was previously accessed by others using our Sites, we are not able to delete the information or copies thereof from their systems.

SECTION 7. Security

Your data is submitted to Draper and Kramer and is hosted and stored in a database on servers situated in the United States owned and maintained by Draper and Kramer, Incorporated.

You are responsible for ensuring that your log-in credentials (your User ID and password) are kept confidential. Draper and Kramer has implemented technical and organizational measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure. Notwithstanding such measures, no data storage or transmission can be guaranteed to be completely secure and without risk and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your Personal Information for improper purposes. Please consider this prior to submitting your Personal Information to us.

SECTION 8. Children

In keeping with the Children’s Online Privacy Protection Act, children under 13 years of age must have permission from a Parent or Legal Guardian before providing Personal Information as described above. Draper and Kramer will not knowingly receive Personal Information from children under 13 years of age who have not received prior parental consent. Any Personal Information from a child stored by Draper and Kramer will be deleted upon written request from the child’s parent or legal guardian. Deletion requests should be sent to us using the methods described in Section 14 below.

SECTION 9. Use of Cookies and Other Tracking Technologies

Draper and Kramer uses “cookies” to help personalize and maximize your online experience and time online. A cookie is a text file that is either stored in your computer’s memory temporarily or placed on your hard drive by a web page server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you.

When you return to the Site, cookies enable us to retrieve the information you previously provided, so you can easily use the features that you customized. Because of our use of cookies, we can deliver faster and more accurate results and a more personalized site experience. For example, if you personalize Draper and Kramer pages, or register for services, a cookie helps us to recall your specific information (such as User ID, password and preferences).

Draper and Kramer uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) (and in the future may use other similar sites or services). Google Analytics uses cookies to analyze your use of the Sites, including your IP address. That information will be transmitted to and stored by Google on its servers . Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity, and providing other services relating to Site activity. We may also enable additional Google Analytics advertising features, including Remarketing. Remarketing uses the Google Analytics and/or third party cookies to serve advertisements to you across the internet based on your visit to our Sites. For more information about how Google collects and uses information, visit https://www.google.com/policies/privacy/. To opt out of being tracked by Google Analytics across all Sites visit: https://tools.google.com/dlpage/gaoptout.

We may also allow other companies to display advertisements to you while you are visiting our Sites. Because your web browser must request these advertisements from the other companies’ servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site. Draper and Kramer has no control over, and is not responsible for, the practices of those third-party advertisers. Draper and Kramer encourages you to review the policies of such advertisers.

We may allow third party cookies as part of online advertising campaigns to determine and track site traffic landing from Draper and Kramer’s advertising banners that have been placed on the web sites of third parties. The data collected via these cookies is anonymous and the information is not linked to your Personal Information without your permission.

Most cookies expire after a defined period of time or you can delete cookie files stored on your computer at any time. While most web browsers are initially set up to accept cookies, you can reset your web browser preferences regarding targeted advertising to delete, block or allow cookies or to indicate when a cookie is being set. However, if you choose to block cookies, that may hinder performance and negatively impact your experience on the Sites. For example, without cookies, you will not be able to set personal preferences and may have difficulty completing financial transactions. You must exercise your preferences on each of the Sites you visit, from each web browser you use, and on each device that you use. Since your web browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to reset them again.

SECTION 10. Opting Out of Communications

Draper and Kramer provides consumers the opportunity to opt-out of or discontinue receiving communications from Draper and Kramer. If you do not desire to continue receiving communications from Draper and Kramer, please send your request to opt out to us using the methods described in Section 14 below. It may be necessary to contact affiliates, business partners or other third parties directly in order to cease receiving communications from those third parties.

SECTION 11. Links to Other Web Sites

The Sites contain links to other web sites over which we have no control. Draper and Kramer is not responsible for the privacy policies, content, or practices of other web sites to which you choose to access using a link from the Sites. We encourage you to review the privacy policies of those other web sites so you can understand how they collect, use and share your information.

SECTION 12. Third Party Interaction

You may interact with, purchase goods and/or services, or participate in promotions of advertisers, members, partners, or sponsors showing their goods and/or services on the Sites. Unless otherwise stated, any such interaction, purchase or promotion, including the delivery of and the payment for goods and/or services, and any other term, condition, warranty or representation associated with such correspondence, purchase or promotion, is solely between you and the applicable third party. You agree that Draper and Kramer has no liability, obligation or responsibility for any such interaction, purchase or promotion between you and any such third party.

SECTION 13. Changes to The Privacy Policy

Draper and Kramer reserves the right to modify or amend this Privacy Policy at any time and for any reason. Draper and Kramer will notify you about any significant changes by providing a prominent notice on the Sites. The changes will be effective as of posting on the Sites. Your continued use of the Sites, our online services, or participation in property visits or offline interactions with us following the posting of changes indicates your acceptance of these changes.

SECTION 14. Legal and Contact Information

If, at any time, you have questions or concerns about this Privacy Policy, believe that we have not adhered to this Privacy Policy, or wish to exercise your rights under any applicable laws, please feel free to email us at [email protected], or contact us through our Contact Us Form (if accessing this Privacy Policy through one of our Sites), or contact us at:

Draper and Kramer, Incorporated
55 East Monroe St, Suite 3900
Chicago, IL 60603

Attn: DK Marketing

SECTION 15. Texas Privacy Notice

Pursuant to the Texas Data Privacy and Security Act (referred to herein as the “TDPSA”), if you are a Texas resident, this notice provides you with information regarding how we use, process and disclose your Personal Information, and your rights under the TDPSA.

As described in this Privacy Policy, we collect Personal Information that is linked or reasonably linkable to an identified individual—otherwise known under the TDPSA as “personal data.” Under the TDPSA, personal data does not include certain types of publicly available information legally obtained from government records, deidentified data that cannot be linked to an identified or identifiable individual, or certain information excluded from the TDPSA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act.

To the extent permitted by applicable law, we may collect, process and disclose personal data, some of which may be “sensitive data” under the TDPSA, from residents of Texas, including the categories of personal data that are described in Section 2 above, such as your name and contact information. See Section 2 and Section 3 above for additional detail.

We process such data for the purposes described in Section 4 of this Privacy Policy.

We may disclose each of the foregoing categories of personal data described in Section 2 of this Privacy Policy to the extent permitted by applicable law to the categories of third parties described in Section 5 of this Privacy Policy.

If you are a resident of Texas, you may exercise your consumer rights under the TDPSA at any time by making the following requests using the methods of contacting us described in Section 14 of this Privacy Policy:

Confirm and Access. You have the right to confirm if we are processing your personal data and to access such personal data.
You have the right to correct inaccuracies in your personal data.
You have the right to delete the personal data provided by or obtained about you.
Data Portability. If the data is available in a digital format, you have the right to get a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format so that you can transmit the data to a third party.
Opt-Out of Targeted Advertising. We may process personal data in a manner that constitutes “targeted advertising.” We may use personal data obtained from or in connection with your browsing history to send more relevant advertising to you. You, or an authorized agent acting on your behalf, have the right to opt out of us processing your personal data for such targeted advertising. See Section 9 for additional information.
Opt-Out of Sale. We do not sell the personal data of our consumers.
Opt-Out of Profiling. We do not process personal data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning our consumers.

Draper and Kramer will not discriminate against you for exercising your consumer rights under the TDPSA.

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

Draper and Kramer will respond to your requests in accordance with Section 6 of this Privacy Policy. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. If we deny your request, we will inform you within 45 days and provide our justification for declining to take action, as well as instructions for how you may appeal the denial by sending us an email with “Data Privacy Appeal” in the subject line to [email protected].