Privacy policy

Last Updated: October 4, 2023

Mynd Management, Inc. and its affiliates (“Mynd,” “we,” “us,” and “our”) provide a platform offering real estate services to landlords, tenants, and applicants. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.

Notice at Collection

At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. California residents can find those details by clicking on the above links.

1. Scope

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called “Services.”

However, this Privacy Policy does not apply to the processing of “non-public information” that is subject to the Gramm Leach Bliley Act (“GLBA”). For details about how Mynd Mortgage, Inc. processes “non-public information” that is subject to the GLBA, please contact us as set forth below.

2. Personal information we collect

The categories of personal information we collect depend on how you interact with us, including whether you are a property owner (“landlord”), applicant or resident, our Services, and the requirements of applicable law.

We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

Please note, any information that is collected from applicants and/or residents of a property may be provided to landlord that owns or otherwise controls the property as permitted by applicable law. If you are an applicant or tenant submitting information to Mynd in connection with a property, you are using Mynd to intentionally disclose the information you provide to the landlord. Landlords may process applicant and tenant information for their business purposes. We do not control and are not responsible for the processing of applicant and tenant information by landlords.

A. Information you provide to us directly

We may collect the following personal information that you provide to us.

• Account creation. We may collect information about landlords or about prospective and current residents, when you create an account, such as your name, email address, postal address and phone number. Depending on which of our Services you may interact with, we may also collect your gender, date of birth, financial information, proof of ownership, photos and/or videos of a landlord’s property, insurance information, and other information.
• Property tours and application. When you register for a property tour, apply for a property, or apply for other Services offered by Mynd, we may collect your driver’s license or state identification information, email address, name, phone number, background information (including consumer or credit reports), financial information such as your annual income, Social Security Number, and other information necessary to verify your identity and qualification to rent the property or otherwise receive Services from Mynd.
• Purchases and rent payments. We may collect personal information and details associated with your purchases and rent payments, including payment information. Any payments made via our Services are processed by third-party payment processors, such as Paylease. We do not directly collect or store any payment card information entered through our Services, but it may receive information associated with your payment card information (e.g., your billing details).
• Your communications with us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information. Interactive features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., blogs and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Interactive features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., blogs and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Business development and strategic partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job applications. If you apply for a job with us, we will collect any personal information you provide with your application, such as your contact information and CV.

B. Information collected automatically

We may collect personal information automatically when you use our Services:

• Automatic data collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Location information. We may collect precise location information, such as GPS coordinates if you enable location services on your device in order to improve and personalize the Services.
• Cookies, pixel tags/web beacons, and other technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
• ‍Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your privacy choices and rights” below to understand your choices regarding these Technologies.

Analytics Our uses of these Technologies fall into the following general categories:

• Google analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
• FullStory. We may also use Fullstory’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how FullStory uses your personal information, please visit FullStory’s Privacy Policy. To learn more about how to opt out of FullStory’s use of your information, please click here.
• Social media platforms. Our Services may contain social media buttons such as Facebook and LinkedIn (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information collected from other sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. In addition, we may collect information from commercially available sources that provide us with leads about potential customers and from consumer reporting agencies.

3. How we use your information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide our services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Evaluating your application for tenancy, or other Services offered by Mynd;
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading or enhancing our Services;
• Developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our agreements and policies; and
• Complying with our legal obligations.

C. Marketing and advertising our products and services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact us” below.

D. Other purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• Automated decision making. We may engage in automated decision making, including profiling. Mynd’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
• De-identified and aggregated information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws.
• Share content with friends or colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).

4. How we disclose your information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to provide the Services

The categories of third parties with whom we may share your information are described below.

• Service providers. We may share your personal information with our third-party service providers that help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• Landlords or residents you transact or interact with. If you are a prospective, current or past resident, we may share your personal information with the landlord. Additionally, if you are an landlord, we may share your information as needed in lease documents, tenant notices, or otherwise as necessary to provide the Services.
• Business partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our company affiliates.
• Advertising partners. Phone numbers we collect will not be shared with third parties for their marketing purposes. However, we may share your personal information with third-party advertising partners via the use of Technologies as described in this section. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to protect us or others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the event of merger, sale, or other asset transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Your privacy choices and rights

Your privacy choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email and telephone communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
• Text messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
• Mobile devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and interest-based advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

To adjust your advertising preferences with Facebook, please visit Facebook’s website.

Please note you must separately opt out in each browser and on each device.

Your privacy rights. In accordance with applicable law, you may have the right to:

• Request access to personal information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
• Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request deletion of your personal information;
• Request restriction of or object to our processing of your personal information; and
• Withdraw your consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. International data transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

7. Retention of personal information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. Supplemental notice for California residents

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

The CCPA provides California residents with the right to know what categories of personal information Mynd has collected about them, whether Mynd disclosed that personal information for a business purpose (e.g., to a service provider), whether Mynd “sold” that personal information, and whether Mynd “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal information we collect”, “How we use your information”, and “How we disclose your information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of personal information.”

We “sell” and “share” your personal information to provide you with “cross-context behavioral advertising” about Mynd’s products and services.

‍Additional Privacy Rights for California Residents

Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by installing the Ghostery ad-blocker browser plug-in and blocking our use of advertising cookies via that tool or by otherwise configuring their Internet browser to prohibit advertising cookies from being set.

Disclosure Regarding Individuals Under the Age of 16. Mynd does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Mynd does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

‍Disclosure Regarding Sensitive Personal Information. Mynd only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Mynd and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Mynd, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Mynd.
• For purposes that do not infer characteristics about individuals.

‍Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

‍__Verification. __ To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include include asking you to answer questions regarding your account and use of our Services.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent using the information found in “Contact Us” above and ask us for additional instructions.

9. Children's information

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

10. Other provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

11. Contact us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

MYND Management, Inc.
1611 Telegraph Ave, 12th Floor
Oakland, CA 95612

MYND Mortgage, Inc.
1611 Telegraph Ave, 12th Floor
Oakland, CA 95612
privacy@mynd.co
+1 (833) FOR-MYND