CRS Temporary Housing Privacy Notice
Last updated and effective: January 1, 2025
Summary of Key Points
- Who we are: CRS Temporary Housing, Inc. provides temporary housing services to insurance companies and their policyholders.
- What information we collect: We primarily collect and process personal information such as policyholder contact details, housing preferences, and related data necessary to provide our services. We also collect information about you and your devices when you use our services.
- How we use it: Your personal information is primarily used to facilitate temporary housing services, communicate with you, to operate and improve our services, and meet contractual obligations with your insurer.
- Sharing your information: We primarily share your personal information with our clients, third-party service providers (like landlords and vendors), and as required by law.
- Your rights: You may request to access, correct, or delete your personal information. Residents of certain states, such as California, may have additional rights under applicable law.
- Security: CRS employs reasonable security measures to protect your personal information.
- Contact us: For any questions about this policy or your personal information, email us at [email protected] or call us toll-free at: 1-800-968-0848 x215.
Full Privacy Notice
1. Introduction
CRS Temporary Housing, Inc. (“CRS,” “we,” “our,” or “us“) is committed to protecting the privacy of individuals whose personal information we process while providing temporary housing and related services. This Privacy Notice describes the types of personal information we collect, how we use and share it, the legal bases for processing such information, and the rights you have with respect to your personal information.
2. Scope of this Privacy Notice
This Privacy Notice applies to personal information collected through our “Services”, which include:
- Our “Websites,” located at crsth.com, as well as any other website where we post or reference this Privacy Notice (including subdomains of those sites); and
- Our “Platform,” which includes our online portal, APIs, and other web-based services, in each case, to the extent we are a controller/business with respect to the operation of the Platform.
Please note: We provide certain services and process information (e.g., policyholder information, claims data, housing preferences and needs data, and other content) on behalf of our insurer and insurance adjuster clients who have entered into an agreement with us to provide our Services (our “Clients”). This Privacy Notice reflects only how we process personal information through our Services. This Privacy Notice does not apply to information processed by or on behalf of our Clients or any other third party. Please see the Client’s privacy policy for more information. Click here to view the privacy policies for certain Clients.
Please note: We provide certain services and process information (e.g., policyholder information, claims data, housing preferences and needs data, and other content) on behalf of our insurer and insurance adjuster clients who have entered into an agreement with us to provide our Services (our “Clients”). This Privacy Notice reflects only how we process personal information through our Services. This Privacy Notice does not apply to information processed by or on behalf of our Clients or any other third party. Please see the Client’s privacy policy for more information. Click here to view the privacy policies for certain Clients.
3. Information We Collect
We collect different types of personal information depending on your relationship with us and how you interact with our Services. When we refer to “personal information,” we refer to information that relates to an identified or identifiable individual or household. The categories of personal information we collect include:
- Personal Identifiers: Name, address, email, phone number, and other identification or contact details.
- Policyholder Information: Information provided by your insurance company, such as policy number, claim details, and covered services.
- Housing Preferences and Needs: Specific details related to your temporary housing requirements, including preferred locations, accessibility features, pet accommodations, and family needs.
- Device/Usage Information: Information collected using our website, including IP address, browser type, operating system, session or device identifiers, logs, and browsing behavior on our site.
- General Location Data: Non-precise location data, city, region, state, or similar locations.
- Transaction Data: Records of interactions with CRS, including communications, invoices, payments, and service requests.
- Audio/Visual Data: Audio or video recordings, e.g. when you contact us via phone or video call.
- Inference Data: Personal information derived from other personal information, e.g. relating to your preferences or interests.
- User Content: Unstructured/free-form data that may include any category of personal information, e.g., data that you give us in free text fields such as a contact box.
4. Sources of Personal Information
We may collect personal information directly from you, from your insurer or our Client, from our service providers, or automatically through interactions with our website, mobile applications, and online services. In some cases, we may create additional personal information, such as inference data or anonymized data.
5. Notices at Collection
At CRS Temporary Housing, we respect your privacy and want to ensure you understand how we collect and use your personal information. Please review the following notices at collection, which apply to the various contexts in which you may interact with our Services.
A. Claims Data – Notice at Collection
Note: Through our Portal, we collect personal information from you, or your insurer, adjusters, and others acting on behalf of our Clients. We provide the following notice as a convenience to you, but this Privacy Notice does not apply to the Clients on whose behalf we collect and process personal information. To review the notice at collection for your insurer, click here.
- Categories of Information Collected from you: We collect personal information such as your name, contact details (email, phone number), policyholder information (policy number, claim details), housing preferences, and transaction data (billing and invoicing). See below for information collected via by Portal and Websites.
- Purpose of Collection: The personal information we collect is used to facilitate the provide temporary housing services, to communicate with you and your insurer, fulfill our contractual obligations with insurers and Clients, process payments for services on behalf of the insurer/Client, and for our business purposes.
- Sharing of Information: We do not sell or “share” (as defined by CCPA) personal information collected in this context. See below for the third parties with whom we share personal information.
B. Our Portal & Corporate Website – Notice at Collection
- Categories of Information Collected from you: We collect personal information such as device/usage data, personal identifiers, general location data, and inference data when you access and use our Websites, including websites that facilitate access to our Portal.
- Purpose of Collection: The personal information we collect is used to provide you with the Websites and deliver the content and features you request; to ensure the security of our Websites, Services, and other technology systems; analyzing the use of our Websites, including navigation patterns, clicks, etc. to help understand and make improvements to the Services; to create aggregate information about users’ content viewing and usage patterns, which we use to help improve our Services and Website content; and for our business purposes.
- Sharing of Information: We do not sell or “share” (as defined by CCPA) personal information collected in this context. See below for the third parties with whom we share personal information.
- Our use of Cookies and Similar Technologies. We may collect data using cookies and similar technologies. We and authorized third parties may use cookies and similar technologies for the following purposes:
- for “essential” purposes necessary for our Websites to operate (such as maintaining user sessions, CDNs, and the like);
- for “functional” purposes, such as to enable certain features of our Websites (for example, to remember content input into a form); and
- for “analytics” purposes and to improve our Websites, such as to analyze the traffic to and on our Websites (for example, we can count how many people have looked at a specific page, or see how visitors move around our Websites when they use them, to distinguish unique visits/visitors to our Websites, and what website they visited prior to visiting our Websites, and use this information to understand user behaviors and improve the design and functionality of our Websites).
Third parties may access or set their own cookies or web beacons on our Website. We, or these third party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties have their own privacy policies, and their processing is not subject to this Privacy Notice.
C. Portal Accounts – Notice at Collection
- Categories of Information Collected from you: We collect personal information such as personal identifiers, contact data, device/network data, and user content when you sign up for an account on our Platform, e.g. to use our Platform or where you are an administrator acting on behalf of the Client.
- Purpose of Collection: The personal information we collect is used provide our Services, to authenticate users and secure our Portal, to perform our obligations to our Clients, and for our business purposes.
- Sharing of Information: We do not sell or “share” (as defined by CCPA) personal information collected in this context. See below for the third parties with whom we share personal information.
D. Marketing Communications – Notice at Collection
- Categories of Information Collected from you: We collect personal information such as your name and contact details (email, phone number) if you are enrolled in marketing communications.
- Purpose of Collection: With your consent or where otherwise permitted under applicable law, we may use your personal information to send you promotional content, including offers related to our Services or information about new products or services offered by CRS, as well as for our business purposes.
- Sharing of Information: We do not sell or “share” (as defined by CCPA) personal information collected in this context. See below for the third parties with whom we share personal information.
E. Contact/Support – Notice at Collection
- Categories of Information Collected from you: We collect personal information such as your name and contact details (email, phone number), transaction data, audio/visual data, and user content, if you contact us with inquiries, or for support relating to our Services.
- Purpose of Collection: The personal information we collect is used to fulfill your support or other request or to contact you about that request, as well as for our business purposes.
- Sharing of Information: We do not sell or “share” (as defined by CCPA) personal information collected in this context. See below for the third parties with whom we share personal information.
6. General Uses of Your personal information
CRS processes personal information for a variety of common purposes related to the provision of temporary housing services and the operation of our business (our “business purposes”). Specifically, we process personal information for the following business purposes:
- Service Provision: We process personal information as necessary to operate our Services or deliver the features you request. On behalf of our Clients, we also arrange and facilitate the provision of temporary housing to policyholders and insured individuals. This includes matching housing options to your preferences, coordinating move-in/move-out details, and providing ongoing support during your stay.
- Communication: We may contact you via email, SMS, or other channels, if allowed by law, with service-related updates, including the status of your housing arrangements, payment reminders, and customer support.
- Contractual Fulfillment: We process your personal information to fulfill contractual obligations with our Client or to you directly as a Client user.
- Billing and Payments: We process your transaction information to manage invoices, process payments, and maintain financial records in compliance with applicable accounting regulations.
- Legal Compliance and Security: We process personal information as necessary to comply with legal obligations, such as responding to court orders, legal processes, or requests from government authorities. Additionally, we may process your information to protect against fraud, unauthorized access, or security threats to our systems and data.
- Data anonymization/aggregation: We may aggregate or anonymize personal information so that it cannot be reasonably used to identify individuals (“anonymized data”). We process anonymized data in order to identify trends (e.g. feature and service utilization trends, service performance, user satisfaction, and other similar information) and for other purposes. Anonymized data is not personal information, and the processing of anonymized data is not subject to this Privacy Notice.
Improvement of Services: We process personal information to improve our services, website functionality, and customer experiences, to understand how our Services are used or function, for customer service purposes, for internal research, technical or feature development, to track service use, QA and debugging, audits, and similar purposes.
7. Sharing of Your Information
We share your personal information with third parties only as necessary to provide our services or comply with legal requirements. This includes:
- Service Providers: We share your information with landlords, property managers, contractors, and other vendors who assist in delivering housing services. These third parties are required to use your information only as necessary to provide the requested services and are bound by confidentiality obligations.
- Clients: We share relevant personal information with your insurer or other of our Clients to ensure that housing services are properly coordinated and covered under your policy.
- Payment Processors: For processing payments and managing financial transactions, we share information with secure third-party payment providers.
- Legal and Regulatory Authorities: We may share your personal information in response to legal processes, such as court orders, subpoenas, or government investigations, or where necessary to comply with legal obligations.
- Business Transfers: If CRS undergoes a business transaction, such as a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction.
8. Data Security
We take the security of your personal information seriously and implement a variety of industry-standard measures to protect it from unauthorized access, disclosure, or misuse. Despite these precautions, no system can guarantee absolute security. We encourage you to notify us immediately of any concerns regarding the security of your personal information.
9. Your Rights and Choices
You have certain rights regarding your personal information, which vary depending on your jurisdiction. These rights may include:
- Access: You have the right to request a copy of the personal information we hold about you and to receive details on how it is processed.
- Confirm: Right to confirm whether we process your personal information.
- Correction: You may request that we correct any inaccuracies in your personal information.
- Deletion: You may request the deletion of your personal information under certain circumstances, such as when the personal information is no longer needed for its original purpose or where you withdraw your consent (where applicable). Please note that certain personal information may need to be retained for legal or contractual purposes.
- Data Portability: Where applicable, you may request a portable copy of your personal information to be provided in a structured, commonly used, and machine-readable format.
- Right to Limit: You the right to opt-out/limit the use of sensitive personal information used for certain purposes. We do not currently process sensitive personal information for non-necessary purposes.
- Right to Withdraw Consent: If we process your personal information on the basis of your consent, you can withdraw that consent at any time.
- Opt-Out of Marketing Communications: You can opt-out of receiving marketing communications at any time by following the unsubscribe instructions in those communications or contacting us directly.
Cookies and Similar Technologies: you can manage/deny cookies (and certain technologies) using your browser’s settings menu or our cookie management tool. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.
10. Additional Rights for California Residents (CCPA)
Under the CCPA, California residents have specific rights regarding their personal information, including:
- Right to Know: You have the right to request that we disclose the categories or specific pieces of personal information we collect, the sources from which it is collected, the business purposes for which we use it, and the categories of third parties with whom we share it.
- Right to Delete: You have the right to request that we delete any personal information we have collected about you, subject to exceptions provided under CCPA.
- Right to Opt-Out of Sale/“Sharing”: CRS does not sell or “share” your personal information to third parties. However, you have the right to opt out of any future sale should this practice change.
- Right to Limit: You the right to opt-out/limit the use of sensitive personal information used for certain purposes. We do not currently process sensitive personal information for purposes other than those listed in CCPA section 7027(m).
- Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your rights under the CCPA.
- List of Direct Marketers: California residents may request a list of personal information we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year (if any).
11. Additional Rights for California Residents (CCPA)
For purposes of the CCPA, we have disclosed to Service Providers for “Business Purposes” in the preceding 12 months the following categories of personal information, to the following categories of recipients:
| Category of personal information | Category of Recipients |
|---|---|
| Device/Usage Data; Transaction Data; General Location Data; Personal Identifiers; Inference Data; User Content | Service Providers; Clients; Payment Processors; Legal and Regulatory Authorities; Business Transfers |
- For purposes of the CCPA, we have not sold, “shared,” or disclosed for “Commercial Purposes” any personal information in the preceding 12 months.
- For purposes of CCPA, we have not sold or “shared” sensitive personal information or used it for purposes other than those listed in CCPA section 7027(m).
12. Submitting Rights Requests; Verification
To exercise any of your rights, you can contact us at [email protected] or by calling 1-800- 968-0848 x215.
If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, ensure that it is not erroneous or fraudulent, and to ensure the security of others’ personal information. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
We may require that you verify personal information we have on file in order to adequately validate your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain personal information to you if prohibited by law or where we cannot adequately verify your identity.
13. Retention of Your Data
CRS retains personal information for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws, including:
- Service-Related Retention: Personal information related to the provision of services is retained for the duration of the service and for a reasonable period thereafter for audit, legal, and business continuity purposes.
- Legal Obligations: We may retain personal information for longer periods where required by law, such as for tax, regulatory, or legal compliance.
- Anonymized Data: In some cases, we may retain anonymized or aggregated data for research, statistical analysis, or to improve our services.
We generally consider the following factors when we determine how long to retain personal information (without limitation):
- Retention periods established under applicable law;
- Industry best practices;
- Whether the purpose of processing is reasonably likely to justify further processing;
- Risks to individual privacy in continued processing;
- Applicable data protection impact assessments;
- IT systems design considerations/limitations; and
- The costs associated continued processing, retention, and deletion.
We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.
14. International Transfers of Personal Information
While CRS primarily operates within the United States, we may transfer personal information to service providers or business partners in other countries. If we transfer your personal information outside of the U.S., we ensure that appropriate safeguards are in place to protect your privacy.
15. Children
Our Services are neither directed at nor intended for use by persons under the age of 18. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such personal information if required by law.
16. Changes to This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our business practices, legal requirements, or industry standards. When we make changes, we will update the “Last Updated” date at the top of this page and, where appropriate, notify you of significant changes.
17. Contact Information
If you have any questions about this Privacy Notice or wish to exercise your privacy rights, please contact our Data Privacy Officer at:
- Email: [email protected]
- Mail: CRS Temporary Housing, 20430 N. 19th Ave, Ste 275, Phoenix, AZ 85027, Attn: Data Privacy Officer
- Phone: 1-800-968-0848 x215
