Minerva Capital LLC and our affiliates and subsidiaries (“Minerva Capital,” “we,” “us,” or “our”) provide property management companies and property owners (each, a “Property Manager”) with artificial intelligence leasing and resident assistant services, including AI voice agents (“Services”). The Services may include artificial intelligence and machine learning technologies (collectively, “AI Technologies”). Property Managers communicate with residents, prospective residents and other individuals through our Services, including by phone, text message, email, and webchat. We record these communications and use them for the purposes stated in this Privacy Policy, including to provide and improve the Services.
This Privacy Policy (“Privacy Policy”) explains how we collect, process, store and share information that identifies, relates to, describes, is reasonably capable of being associated directly or indirectly, with a particular individual or household (“Personal Information”). Personal Information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from Personal Information). This Privacy Policy also provides you with important information about your Personal Information rights and how to exercise them.
This Privacy Policy covers how we treat Personal Information that we acquire from you or other sources related to our Services or other interactions with us. This Privacy Policy does not apply to Property Managers’ use of Personal Information or any third-party websites, applications or services that you access or connect with through the Services. We do not have control over the privacy practices or the content of Property Managers or third parties. As such, we are not responsible for the privacy practices employed by or content provided by Property Managers or third parties. Please consult the applicable Property Manager or third-party privacy policy and terms of service for information on their privacy practices.
By using, interacting with, or accessing our Services, or by providing your Personal Information to us:
- You acknowledge that you accept our privacy practices and policies outlined in this Privacy Policy;
- You consent to us collecting, processing, storing and sharing your information as described in this Privacy Policy;
- You acknowledge that you may communicate with bots powered by generative artificial intelligence when you use the Services;
- You consent that you will not disclose the Personal Information of another individual to us, or make it available on the Services, unless you have the prior written consent of the person who is the subject of the information and such person is 18 years of age or older;
- You consent to us recording and using all of your communications made through the Services—including by phone, text message, email, and webchat.
Personal Information We Collect
We may collect your Personal Information in various ways, such as when you use the Services, submit a tenant application, interact with our AI voice agent, enter into a transaction or contractual arrangement with us, or make any other inquiries or communications with us. We may also collect your Personal Information from other sources, including Property Managers and third-party vendors or service partners.
Personal Information and Identifiers
Full name, alias, date of birth, signature, postal address, email address, phone number, government identification numbers (including social security number, driver’s license or state identification number, passport number, or tax identification number), credit or debit card numbers, bank account numbers, bank statements, and physical characteristics or descriptions.
Characteristics of Protected Classifications
Age, gender and/or sex, family size or marital status, disability, veteran or immigration status, or other characteristics of protected classifications under California or federal law that we may infer or collect based on information you provide to our Services.
Commercial Information
Records of personal property, residential rental or lease history, services purchased, obtained, or considered, prior and current rent payments, transactions, defaults, and/or evictions.
Internet or Other Electronic Network Activity Information
Account information (including username and password), browsing and search history, online identifiers, IP addresses, cookie data, webpage interactions, device information (including device type, operating system, device settings, unique device identifiers and crash data), and other Services usage or preferences data.
Geolocation Data
The city or region where your device is located, as determined by your IP address or device settings.
Audio, Visual or Electronic Information
Voice recordings of your interactions with our AI voice agent or customer support, transcripts generated from those recordings, and photographs of your face (including those on government-issued identification cards) submitted as part of tenant applications.
Professional or Employment-Related Information
Employer name and company affiliation, job title, professional contact information, and employment history, as provided in tenant applications.
Sensitive Personal Information
Sensitive Personal Information may include:
- Government-issued identifiers such as your social security, driver’s license, state identification card, or passport number;
- Financial information such as your account log-in, financial account, debit or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- Certain characteristics of a protected classification, such as your citizenship or immigration status;
- The content of your communications transmitted to a Property Manager through our Services, including your rental or lease preferences;
- Inferences drawn from Personal Information listed in this section to create a profile of an individual’s preferences and characteristics for communications or Services delivery purposes.
We use Sensitive Personal Information only as reasonably necessary, such as to provide, improve, and protect our Services, process payments, prevent and mitigate fraud or other illicit practices, and ensure the integrity, safety, and security of our systems.
Sources of Personal Information
We collect Personal Information about you from the following categories of sources:
- Directly from you, such as when you access or use our Services, submit a tenant application, interact with our AI voice agent by phone or browser, or communicate with us in any way;
- Indirectly from you, for example, through cookie data and other information from your device, browser, or activity on the internet or in our Services;
- From our third-party vendors, for example, from our analytics providers or third-party verification providers for our tenant application services;
- From Property Managers or other users of our Services.
How We Use Personal Information
This section details how we use your Personal Information and the business purposes for which we collect, process, store and/or share it.
- Provide and protect our Services, including to provide the Services to Property Managers and interact with residents and prospective residents through the Services on behalf of Property Managers; process and evaluate tenant applications including background and credit screening; manage leases and tenancy records; process rent payments and security deposits; create and track maintenance requests; schedule property showings; prevent or address service errors, security or technical issues; and respond to requests and inquiries.
- Improve our Services and AI Technologies, including to carry out internal research and development; troubleshoot, test and conduct data analysis; update, improve and train the algorithms, models and functionality of the Services and AI Technologies; and develop new products, services and features.
- Deidentify Personal Information, including aggregating and anonymizing Personal Information so that it is no longer Personal Information.
- Support our everyday operations, including using third-party vendors and service providers for business purposes such as hosting, technology and communications.
- Meet legal and compliance requirements, including to perform audits, monitoring and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of you, us or a third party; respond to legal process and governmental, court or law enforcement requests; and comply with applicable laws and regulations.
- Evaluate or conduct business changes, including a merger, acquisition, sale, financing, bankruptcy or other transaction in which a third party invests in or acquires control of our business or assets.
We do not sell your Personal Information. We do not share Personal Information with third parties for third parties’ direct marketing, cross-context behavioral advertising, or targeted advertising purposes.
Categories of Parties with Whom We Share Your Personal Information
We may share your Personal Information with the following categories of parties:
- Property Managers who control how we collect and process the Personal Information we collect from users of the Services on their behalf.
- Our Vendors who help us provide, improve, and enhance the Services or perform business functions on our behalf, including hosting, technology and communication providers, AI and machine learning service providers, telephony providers, speech processing providers, analytics providers, support and customer service vendors, third parties who facilitate tenant application processing (including background check and credit screening providers), and payment processors.
- Parties You Access, Authorize or Authenticate, including third parties you access through the Services such as identity and payment verification service providers.
- Parties for Legal Purposes, including governmental authorities, law enforcement or other third parties in connection with legal process, investigations, or compliance obligations.
- Parties for Business Changes, for example, your Personal Information may be shared with or transferred to a third party if we undergo a merger, acquisition, sale, financing, bankruptcy or other business transaction.
Processing of Sensitive Personal Information by AI Service Providers
In the course of providing our Services, Personal Information you submit—including government-issued identification numbers (such as Social Security numbers, driver’s license numbers, and passport numbers), financial documents (such as pay stubs and bank statements), and the content of your voice communications—may be transmitted to and processed by third-party AI service providers. This processing is necessary to operate core features of our Services, including AI-assisted tenant application review, voice agent conversations, and speech transcription.
We require all AI service providers to operate under strict data processing agreements that include the following protections:
- No training on your data — your Personal Information, including Sensitive Personal Information, is not used to train, improve, or fine-tune any AI service provider’s general-purpose models;
- Zero or minimal retention — AI service providers are contractually required to delete your data promptly after processing and may not retain it beyond the brief period necessary to deliver the specific service response;
- Purpose limitation — your data is processed solely to fulfill the specific request made by our Services (e.g., generating a transcription, processing an agent response) and for no other purpose;
- Encryption in transit — all data transmitted to AI service providers is encrypted using industry-standard TLS encryption.
If you do not wish for your Sensitive Personal Information to be processed by AI service providers, you may opt out of AI-assisted application review by contacting us at info@castellan.so. Please note that opting out may require manual processing of your application, which may result in longer processing times.
Use of Generative AI in Our Services; Consent to Recording
Our Services use bots powered by generative artificial intelligence to communicate with you by phone, text message, email, and webchat. You acknowledge that you may communicate with AI-powered bots when using the Services.
We monitor, record, and use communications made through the Services, including phone, text message, email, and webchat. You consent to us monitoring and recording all of your activities and communications made through the Services and to us using such recordings for all purposes described in this Privacy Policy.
Data Security
We maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of Personal Information from unauthorized access, use, disclosure or transfer, including encryption of data in transit (TLS) and at rest, role-based access controls, and regular security reviews. Despite our efforts to ensure security, we cannot guarantee or warrant that your Personal Information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure of your Personal Information. We urge you to take adequate precautions to protect your Personal Information as well, including choosing a strong password and never sharing your account credentials.
Retention of Personal Information
We retain Personal Information about you for as long as we deem necessary or advisable for the purposes described in this Privacy Policy or as directed by Property Managers. We may maintain your Personal Information after you have stopped using or interacting with our Services; for example, we may retain your Personal Information to improve our Services, comply with legal obligations, or resolve disputes. Specific retention periods include:
- Financial records are retained as required by applicable tax and accounting regulations;
- Voice recordings and transcripts are retained for 90 days unless a longer period is required for dispute resolution or legal compliance;
- Tenant application data for applicants who are not approved is deleted within 60 days of the decision, upon the applicant’s request.
Your Privacy Rights and Choices
Subject to exemptions and limitations provided by applicable law, you have the right to:
- Right to know — request that we disclose certain information about our collection and use of your Personal Information;
- Right to access — request the specific pieces of Personal Information we collected about you;
- Right to data portability — request a copy of your Personal Information in a portable, and, if feasible, readily usable format;
- Right to delete — request that we delete your Personal Information that we collected, subject to certain exceptions under applicable privacy law;
- Right to correct — correct inaccurate or complete incomplete Personal Information;
- Right to opt out of voice recording — request that your calls not be recorded; note that this may limit our ability to provide AI-assisted services;
- Right to limit use of sensitive information — limit the use or disclosure of your Sensitive Personal Information to just those actions necessary to perform specific purposes outlined by law;
- Be free from unlawful discrimination for exercising your rights under applicable privacy law.
How to Exercise Your Privacy Rights
To exercise the rights described above, you must send us a written request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. We will work to respond to your request within the timeframes required by applicable privacy law (usually between 15 to 45 days). We will not charge you a fee for making a request unless it is excessive, repetitive or manifestly unfounded.
You may submit a request by sending an email to: info@castellan.so
You have the right to appeal our decision to not honor your request by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.” Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). The rights described in the section above apply to you. In addition:
- We do not sell your Personal Information, nor do we share Personal Information with third parties for cross-context behavioral advertising or targeted advertising purposes;
- Categories of Personal Information we have collected in the prior 12 months include: identifiers, financial information, government-issued IDs, commercial information, internet/electronic network activity, geolocation data, audio and visual information, professional or employment-related information, sensitive personal information, and inferences drawn from the foregoing;
- We will not discriminate against you for exercising any of your CCPA rights.
Personal Information of Children
You must be 18 years of age to use the Services. By accessing or using the Services, you represent and warrant to us that you are at least 18 years of age.
We do not knowingly collect, process, store or share Personal Information about children under 18 years of age. If we learn we have collected Personal Information from a child under 16 years of age, we will delete that data as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Information to us, please contact us at info@castellan.so.
To our knowledge, we do not sell or share for cross-contextual behavioral advertising or targeted advertising purposes the Personal Information of children under the age of 16.
Privacy Policy Updates
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our website with a new “Last Updated” date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
Contact Us
You may contact us with questions or concerns related to this Privacy Policy and our privacy practices at:
Minerva Capital LLC
info@castellan.so