Effective Date: January 1, 2024
Mia MGMT Group LLC is committed to providing clear and concise information regarding our collection and
processing of personal information. By accessing our website or utilizing Mia MGMT Group LLC software
services (collectively, “Mia MGMT Group LLC Services”), you consent to the information collection and
handling practices outlined in this policy.
I. Personal Information Collection
Mia MGMT Group LLC collects and processes personal information as a service provider to property owners
and management companies (collectively, “Clients”). This personal information includes a broad range of
data elements and may pertain to Clients’ residents, prospective renters, current and prospective
Clients, and Client employee end users of Mia MGMT Group LLC Services.
In particular, Mia MGMT Group LLC Services have collected the following categories of personal
information from our Clients regarding their residents, prospects, and/or employee end users within the
last twelve (12) months:
Category Examples
Identifiers Name, mailing address, email address, phone number (305-322-8767), Social Security number,
driver’s license number/image, state identification card, passport number, or other similar personal
identifiers associated with the residential and commercial real estate leasing activities.
Note: Some personal information included in this category may overlap with other categories.
Sensitive Personal Information Social Security number, driver’s license number/image, state
identification card, or passport number;
Account log-in, financial account, debit card, or credit card number in combination with any required
security or access code, password, or credentials allowing access to an account;
Racial or ethnic origin; and
Personal information categories listed in the Florida Customer Records statute (Fla. Stat. § 501.171)
Name, electronic signature, Social Security number, physical characteristics or description, address,
telephone number, passport number, driver’s license or state identification card number, insurance
policy number, employment status, employment history, bank account number, credit card number, debit
card number, or any other financial information, and similar personal identifiers associated with
residential real estate leasing activities.
Note: Some personal information included in this category may overlap with other categories.
Protected classification characteristics under Florida or federal law Age (40 years or older), race,
color, national origin, citizenship, marital status, medical condition, physical or mental disability,
gender identity, veteran/military status, and similar personal identifiers associated with residential
real estate leasing activities.
Commercial information Rental ledger data and payment history, record of applications and services
utilized, customer support records and communications, and similar personal identifiers associated with
residential real estate leasing activities.
Biometric information Voice call recordings from product support operations.
Internet or other similar network activity Information pertaining to an individual’s interaction with a
Mia MGMT Group LLC website, application, or service.
Geolocation data Physical location for localized search/application functionality
Sensory data Voice call recordings from product support operations
Professional or employment-related information Current or past job history and income, and similar
personal identifiers associated with residential real estate leasing activities.
Inferences drawn from other personal information Profile reflecting a person’s preferences,
characteristics, predispositions, behaviors, and personal identifiers associated with residential real
estate leasing activities.
II. Personal Information Exceptions
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from state privacy law scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996
(HIPAA); and
personal information covered by certain sector-specific privacy laws, including the Fair Credit
Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or Florida Financial Information Privacy Act
(FIPA), and the Driver’s Privacy Protection Act of 1994.
III. Personal Information Sources
Mia MGMT Group LLC collects the categories of personal information listed above from the following
sources:
Resident and prospective renter personal information is collected (i) from Clients’ residents during
enrollment in or utilization of Mia MGMT Group LLC Services offered on behalf of Clients, (ii) from
Clients via direct input into Mia MGMT Group LLC Services or integration with Client software systems
and third-party service providers, and (iii) indirectly from credit reporting agencies/bureaus, payment
processors/gateways/banks, and website analytics services integrated with Mia MGMT Group LLC Services.
Client and Client employee end user personal information is collected (i) from Client’s employees during
setup of Mia MGMT Group LLC Services user accounts, and (ii) from Client during activation and
implementation of Mia MGMT Group LLC Services.
IV. Personal Information Use & Processing
In providing the suite of Mia MGMT Group LLC Services, Mia MGMT Group LLC primarily acts as a service
provider under contract to our Clients1. As a service provider, Mia MGMT Group LLC does not control any
of the personal information we process on behalf of our Clients. Our Clients collect and control all
such personal information, and Mia MGMT Group LLC is required to provide our products and services in
accordance with Clients’ contractual provisions and instructions regarding data collection, privacy,
processing, and security. Where Mia MGMT Group LLC is providing services as a data controller, a
separate privacy policy is provided exclusively for such services at the point of data collection.
Accordingly, we may use or disclose the personal information we collect for one or more of the following
purposes:
To fulfill the purpose for which the personal information was collected and provide the requested Mia
MGMT Group LLC Services.
To integrate with services offered by Mia MGMT Group LLC or third-party service providers contracted by
Clients.
To distribute communications and legally required notices regarding the status of Mia MGMT Group LLC
Services via phone, email, and SMS text.
To provide Mia MGMT Group LLC Services maintenance, enhancement, research, development, security,
support, and website optimization.
To maintain compliance with federal and state laws related to software-as-a-service, background
screening, financial institutions, and money services businesses.
To create, maintain, customize, and secure Mia MGMT Group LLC Services user accounts.
To respond to law enforcement requests and as required by applicable law, court order, or governmental
regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale
or transfer of some or all of Mia MGMT Group LLC’s assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information held by Mia MGMT Group LLC
is among the assets transferred.
Mia MGMT Group LLC will not collect additional categories of personal information or use the personal
information we collected for materially different, unrelated, or incompatible purposes without providing
you notice. Additionally, Mia MGMT Group LLC processing of sensitive personal information is limited to
activities necessary for the delivery and performance of Mia MGMT Group LLC Services on behalf of our
Clients and end users.
V. Personal Information Disclosure
Mia MGMT Group LLC does not sell personal information collected through Mia MGMT Group LLC Services, and
no such disclosure has occurred in the prior 12 months.
Mia MGMT Group LLC may provide personal information to third parties for business purposes under limited
circumstances, including service providers and vendors that support or integrate with the Mia MGMT Group
LLC Services described in this statement (see chart below). Mia MGMT Group LLC only discloses personal
information to the extent reasonably necessary to support Mia MGMT Group LLC Services requirements or
for the third-party vendors or service providers to perform the services on our or our Clients’ behalf.
We do not permit third-party vendors or service providers to use or disclose your personal information
except for the purpose of providing the services we request of them. However, please note that Mia MGMT
Group LLC does not maintain direct control over the privacy policies and practices of Clients or any
other third-party companies, agents, or contractors.
Category | Third Party Disclosure
Business Purposes | Sales
Identifiers | Service providers/vendors/subsidiaries N/A
Sensitive Personal Information | Service providers/vendors/subsidiaries N/A
Personal information categories listed in the Florida Customer Records statute (Fla. Stat. § 501.171) |
Service providers/vendors/subsidiaries N/A
Protected classification characteristics under Florida or federal law | Service
providers/vendors/subsidiaries N/A
Commercial information | Service providers/vendors/subsidiaries N/A
Biometric information | Service providers/vendors/subsidiaries N/A
Internet or other similar network activity | Service providers/vendors/subsidiaries N/A
Geolocation data | Service providers/vendors/subsidiaries N/A
Sensory data | Service providers/vendors/subsidiaries N/A
Professional or employment-related information | Service providers/vendors/subsidiaries N/A
Inferences drawn from other personal information | Service providers/vendors/subsidiaries N/A
VI. Personal Information Rights and Choices – State Privacy Rights
Certain state jurisdictions (Florida, Virginia, Colorado, Connecticut, and Utah) provide their legal
residents with specific rights regarding their personal information. Each right includes the ability to
make a specific consumer request and corresponding obligation of the receiving party to (i) verify the
identity of the requestor and (ii) respond in accordance with statutory guidelines. This section
describes your rights and explains how to exercise those rights.
Accessing and Updating Personal Information
In the event your personal information is determined to be outdated, incomplete, or inaccurate, you may
access and update your information by logging into your Mia MGMT Group LLC Services account or
contacting your property manager. If you require verification that your requested changes have been
completed, and such verification is not readily displayed in your Mia MGMT Group LLC Services account,
you may request confirmation at the email address listed below (See “Contact Us”).
Access to Specific Information Regarding Personal Information Use/Disclosure and Portability.
You have the right to request a summary of the collection, use, and disclosure of your personal
information over the past 12 months. Under most circumstances, this request for disclosure should be
submitted to the property manager that operates your apartment community or rental property. As stated
above, Mia MGMT Group LLC is merely a service provider for our Clients, and we do not control the
collection, use, and disclosure of your personal information.
However, if you have a direct relationship with Mia MGMT Group LLC, consumer requests should be
submitted directly to Mia MGMT Group LLC via the approved channels listed in Section VII below.
In response to a verifiable consumer request for these services, we will disclose the following
information for the applicable Mia MGMT Group LLC Services:
The categories, specific types, and sources of personal information we collected about you.
Our business purpose for collecting the personal information.
The categories of third parties with whom we share that personal information and the purpose for the
disclosure.
You also have the right to request a copy of this personal information in a readily useable format that
is transferable to other entities (frequently referred to as “data portability”). If you make a data
portability request, Mia MGMT Group LLC may be (i) restricted from providing certain sensitive personal
information in response to the request or (ii) prohibited from granting the request entirely if it
presents an unreasonable security risk.
Deletion of Personal Information
You have the right to request that Mia MGMT Group LLC delete any of your personal information that we
collected and retained, subject to certain exceptions. Under most circumstances, this request for
deletion should be submitted to the property manager that operates your apartment community or rental
property. As stated above, Mia MGMT Group LLC is merely a service provider for our Clients, and we do
not control the collection, use, and disclosure of your personal information.
However, if you have a direct relationship with Mia MGMT Group LLC, consumer requests should be
submitted directly to Mia MGMT Group LLC via the approved channels listed in Section VII below.
Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct
our service providers to delete or de-identify) your personal information from our records, unless one
of the following exceptions applies:
We may deny your deletion request if retaining the information is necessary for Mia MGMT Group LLC or
our service providers to:
Complete the transaction for which we collected the personal information, provide the Mia MGMT Group LLC
Services that you requested, take actions reasonably anticipated within the context of our ongoing
business relationship with you or your property manager, or otherwise perform our contract with you or
your property manager.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
Debug Mia MGMT Group LLC Services to identify and repair errors that impair existing intended
functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or
exercise another right provided for by law.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest
that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely
render impossible or seriously impair the research’s achievement, if you previously provided informed
consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your
relationship with us or our Clients.
Comply with laws, regulations, statutes, codes, ordinances, or other legal obligations.
Make other internal and lawful uses of that information that are compatible with the context in which
you provided it.
VII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights
Under most circumstances, consumer requests should be submitted to the property manager that operates
your apartment community or rental property. As stated above, Mia MGMT Group LLC is merely a service
provider for our Clients, and we do not control the collection, use, and disclosure of your personal
information.
However, if you have a direct relationship with Mia MGMT Group LLC, consumer requests should be
submitted directly to Mia MGMT Group LLC. To exercise the access, data portability, and deletion rights
described above, please submit a verifiable consumer request to us by either:
Calling us toll-free at: 305-322-8767
OR
Via the secure webform linked here
Only you (or someone legally authorized to act on your behalf) may make a verifiable consumer request
related to your personal information. You may also make a verifiable consumer request on behalf of your
minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month
period. The verifiable consumer request must:
Provide sufficient information that allows us to confirm your identity as the person about whom we
collected personal information (and, if applicable, the authority and identity of an authorized
representative).
Describe your request with sufficient detail that allows us to properly understand, evaluate, and
respond to it.
Please note, we cannot respond to your request or provide you with personal information if we cannot (i)
verify your identity or authority to make the request and (ii) confirm the personal information relates
to you. Making a verifiable consumer request does not require you to create an account with us. However,
we do consider requests made through your password-protected account sufficiently verified when the
request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request.
VIII. Consumer Request Responses and Timelines
We will confirm receipt of your request within ten (10) business days. If you do not receive
confirmation within the 10-day timeframe, please contact us at privacy@MiaMGMTGroup.com. We endeavor to
respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require
additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a
total response timeline capped at 90 days). In the event that an extension is necessary, we will inform
you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account where possible. If
you do not have an account with us, or your existing account lacks a communication feature, we will
deliver our written response to your designated email address.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer
request’s receipt. The response we provide will also explain the reasons we cannot comply with a
request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you
why we made that decision and provide you with a cost estimate before completing your request.
IX. Personal Information Sales and Sharing – Opt-Out Rights
Mia MGMT Group LLC does not sell personal information collected through Mia MGMT Group LLC Services, and
no such activity has occurred in the prior 12 months. In the event that Mia MGMT Group LLC changes its
practices and engages in the sale of personal information as regulated by law, we will provide advance
notification to impacted individuals and offer the ability to opt in/opt out in accordance with
regulatory requirements.
Mia MGMT Group LLC utilizes cookies and tracking technologies as set forth in the Cookie Policy. Under
some circumstances, these technologies may be deemed a “sharing” of personal information under
applicable privacy laws. Mia MGMT Group LLC provides a cookie settings preference center to allow you to
opt out and customize the cookies presented on our websites and services.
X. Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law,
we will not engage in any of the following practices in response to your exercise of privacy rights:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or
other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or
quality of goods or services.
XI. Other Florida Privacy Rights
The State of Florida also grants Florida residents privacy rights via laws unaffiliated with the
CCPA/CPRA. Those rights include the following:
Florida’s privacy laws (Fla. Stat. § 501.171) permit Florida residents to request certain information
regarding our disclosure of personal information to third parties for their direct marketing purposes.
To make such a request, please send an email to info@MiaMGMTGroup.com.
XII. Cookies, Web Beacons, and Other Technologies – Do Not Track
When you access Mia MGMT Group LLC Services or our website, our servers may place small text files
(“cookies”) on your computer for recordkeeping purposes. Among other things, cookies enable us to gather
information about your activity on our website for the purposes of improving your online experience,
establishing secure user accounts, remembering your preferences and settings, and for other similar
customization purposes.
In addition to cookies, the Mia MGMT Group LLC Services and our website may utilize web beacons, clear
gifs, or other technologies to gather information on how users interact with and utilize various
features. For example, these technologies can identify popular pages, viewing patterns, click-through,
conversion rates, and other information that can be used to improve, monitor, and operate our websites,
products, and services.
A detailed summary of our cookie and similar technology usage is set forth in the Cookie Policy.
XIII. Third-Party Links to Other Sites
Mia MGMT Group LLC Services may include links to third-party service providers contracted by Clients.
These linked services are operated by unaffiliated third parties that have separate and independent
privacy statements, terms of use, and related notices or disclosures regarding information handling
practices. We cannot be responsible for the information handling practices of independent parties and
encourage you to review their practices prior to information disclosure.
Mia MGMT Group LLC Services that offer mobile applications do not include third-party ad partners,
campaigns, or personalized ad delivery.
XIV. Data Security
Mia MGMT Group LLC implements and maintains appropriate physical, administrative, technical, and
organizational measures to protect the information we process against unauthorized or unlawful access,
use or disclosure, and against accidental loss, damage, alteration, or destruction. Under our security
policies and practices, access to personal information is restricted and authorized only for those who
have a business need for such access. Mia MGMT Group LLC strives to protect the personal information
that we process; however, no security program is 100% secure, and we cannot guarantee that our
safeguards will prevent every unauthorized attempt to access, use, or disclose personal information. We
maintain security incident response policies and procedures to handle incidents involving unauthorized
access to personal data we process.
XV. Children’s Online Privacy
Mia MGMT Group LLC Services do not target or attract the attention of children under the age of 13 for
the online collection of personal information.
XVI. Changes to Our Privacy Statement
Mia MGMT Group LLC reserves the right to amend this privacy statement at our sole discretion at any
time. When we make changes to this privacy statement, we will post the updated content to our applicable
websites and services along with the effective date of the change. Your continued use of Mia MGMT Group
LLC Services following the posting of changes constitutes your acceptance of such changes.
XVII. Contact Us
If you have any questions or concerns about this Privacy Statement or its implementation, you may
contact us via the following methods:
Via US Postal Service at:
Mia MGMT Group LLC
Attn: Privacy (Legal)
300 S Biscayne Blvd
Miami, FL 33131
OR Via email at: info@MiaMGMTGroup.com
Thank you for your attention to this updated Privacy Statement.
Sincerely,
Mia MGMT Group LLC