COMPANY COMMUNITIES CAREERS CONNECT CONTACT Privacy Policy HOME PRIVACY POLICY GMH Communities and its affiliated entities (collectively, "GMH", "we", "us", "our") are committed to protecting individual privacy and maintaining the trust of our business affiliates, personnel, and partners and our end users and residents (collectively, "End Users"), and visitors to our websites (collectively, "Visitors"). It is important to us that we provide transparency regarding our collection, use, and disclosure of Personal Information (for purposes of this Privacy Policy, we use the California Consumer Privacy Act’s (“CCPA”) definition of “Personal Information”. To help us meet this commitment to you, we have created this Privacy Policy ("Privacy Policy"). This Privacy Policy governs data protection matters across our suite of products and services including data provided by Visitors to the websites we control and which link to this Privacy Policy. This Privacy Policy, along with our Terms of Use, form an integral and binding part of our relationship with you. Please Note: This Privacy Policy does not govern our processing of Personal Information/Personal Data covered by the EU General Data Protection Regulation (GDPR). You can view our service partner’s EU Privacy Policy here. APPLICATION OF PRIVACY POLICY This Privacy Policy describes how we use, share, and protect the Personal Information of Clients, Visitors, and End Users who visit the GMH Sites. It also describes the rights and choices regarding use, access to, and correction of Personal Information available. IMPORTANT TO NOTE: GMH provides its websites for use by our Clients, which are typically residential and commercial renters. Our Clients use our Platforms for many purposes, such as to manage the leasing lifecycle, and to facilitate communication with their End Users. GMH uses Entrata as its service partner, whom typically has no direct relationship with our End Users; Entrata simply processes and stores our End Users’ Personal Information (“Client Data”) on our behalf, as our service provider, while the we are responsible for the processing. Any use of Client Data by us is carried out pursuant to an agreement (and/or our applicable Terms of Service) in place between GMH and Entrata. If you, as an End User, have any questions or concerns about this, please contact GMH. Finally, GMH Sites may contain links to other third-party and affiliate websites. The information practices and content of such third-party and affiliate websites are governed by their own privacy notices. We encourage you to review the privacy notices of such third-party and affiliate websites to understand their information practices. WHAT INFORMATION WE COLLECT AND WHY We may collect Personal Information in various ways, such as when you: enter into a transaction or contractual arrangement with us; participate in GMH’s programs or activities; provide data at industry events and trade shows; visit our facilities or we visit you at your offices; contact our customer services; or in connection with your inquiries and communications with us. We may also collect Personal Information from other sources, including the Client, data companies, publicly accessible databases, and joint marketing partners. We have created the following table to help you understand the categories of Personal Information that we are responsible for, and process: Categories of Personal Information: Specific Types of Personal Information: Source: Why We Collect It – Our Purposes Client Personnel Information Contact Information: First and last name, email address, employer, phone number (work), physical address (work), job title. Marketing Preferences and Customer Service Interactions: Marketing preferences; responses to voluntary surveys. Operational Data: Transactions, sales, purchases, uses, supplier information, credentials to online services and platforms, and electronic content produced by individuals using company systems, including online interactive and voice communications such as blog, chat, webcam use, and network solutions. Directly from our Clients and Client Personnel Communicate with Clients and Client Personnel for the purpose of supporting our contractual relationship. This includes: Informing Clients about our various Platforms and solutions, and providing access to our Platforms where the Client enters into an agreement with us. Providing back-end access to the Platforms for Clients and Client Personnel Tracking and responding to Clients’ inquiries, reports, reviews or correspondence regarding products and services. Administering Client account(s). Providing and improving our customer service. Facilitating communications generally in the context of our business activities. Sending administrative information to Clients, such as changes to our terms, conditions and policies. Enforcing our Terms of Use and any other contractual terms and conditions that govern the relationship between GMH and our Clients. Continuously improving, customizing and personalizing our Platforms. Analyzing and improving the safety and security of our Platforms. Supporting internal GMH operations, including CRM and Client technical support. Connecting with vendors via APIs to allow vendors to provide specific services directly to Clients. Providing Clients and Client Personnel with access to our App Store’ to allow Clients to directly enable external applications. Carrying out machine learning, data extracting and loading data in data warehouses, in order to support GMH enterprise software, data access, modifications, operations, and provide access to third parties via secure integrations. Prospective Client Personnel Data First and last name, email address, employer, phone number (work), physical address (work), job title. Directly from Prospective Client Personnel. Contact prospective Clients in order to set up demos of our Platforms. This includes: For marketing purposes, such as re-engaging with prospective Clients who have expressed an interest in our Platforms. Administering account access to our Platforms. Responding to inquiries, for example, when you send us questions, suggestions, compliments or complaints, or when you request further information about our services. End Users Contact Information: Name. Survey Responses Directly from End Users in response to voluntary surveys Platform improvement and marketing purposes (to Potential Clients). HOW WE USE PERSONAL INFORMATION We do not use Personal Information for purposes that are materially different to the purposes for which they were originally collected, as set out in Section 2. If these purposes change in the future, we will provide you with notice and a request to consent to (or an opportunity to opt-out of) this new use where so required by applicable law. “Do Not Track” Notice: “Do Not Track” is a preference that you can set in your browser to let websites you visit know that you do not want them collecting certain information about you. GMH does not currently respond to, or honor, Do Not Track signals or requests from your browser. HOW WE DISCLOSE PERSONAL DATA We will not disclose any personal information that we collect from you to any external parties except as indicated below (for CCPA purposes, all of the below categories of data recipients are classified as Service Providers or Third Parties, as those terms are defined): Our Affiliates. We may disclose personal information to any of our service partners, subsidiaries and affiliates within GMH corporate group). Specifically, if our clients utilize our applicant screening service, Entrata will share personal information with its subsidiary ResidentVerify, LLC. Additionally, if you utilize the offered renters insurance agent, Entrata will share personal information with its subsidiary Entrata Insurance Agency, LLC. Service Providers. We may disclose personal information to our service providers who perform certain services necessary to run our business (for example, data hosting and development, data analysis, customer service, auditing and other services), provided that these service providers have entered into legally binding agreements with us to protect the personal information shared, limit their use, retention, and disclosure of the personal information, and assist us with our compliance requirements. Legal Request. We may disclose personal information to comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons. Business Transfer. We may disclose personal information to a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of GMH’s assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which personal information held by GMH are among the assets to be transferred. Enforcement of Our or Others' Rights. We may disclose personal information to external parties the extent that this is necessary to enforce or protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others, including enforcing our Terms of Use and any other agreements (such as for billing and collection purposes and fraud prevention). CHILDREN We do not knowingly collect personal information from children under the age of seventeen (17) without authorization by a holder of parental responsibility. If you believe that we may have collected personal information from or about a child under the age of seventeen (17), please contact us. HOW WE PROTECT YOUR PERSONAL INFORMATION We seek to use commercially reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a username and password (either as a Client or an End User) to access our Platforms, you are responsible for keeping this information confidential and preventing unauthorized access to your account. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "How to Contact Us" section below. Where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS). RETAINING YOUR PERSONAL INFORMATION We retain personal information for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you or our Client, and provide the use of our Platforms to you or our Client (for example, for as long as you have an account with us or keep using the Platforms); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). KEEPING YOUR INFORMATION UPDATED Where you have set up an account on one of our service partner’s Platforms through GMH, it is up to you to keep your personal information up to date. If you are unable to update your personal information, please contact GMH. INFORMATION FOR CALIFORNIA CONSUMERS The information and rights in this section apply specifically to California residents. In compliance with the California Consumer Privacy Act (“CCPA”), GMH does not sell, trade, or rent any Personal Information, nor have we done so in the preceding twelve months. GMH has not sold the Personal Information of minors under 16 years of age without first attaining affirmative authorization. California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Currently GMH does not disclose Personal Information to third parties for their direct marketing purposes. Thus, upon receipt of such a request by a California consumer, and as required by California state law, we will respond with either (1) a confirmation that we have not disclosed any Personal Information to third parties for their direct marketing purposes in the previous calendar year, or (2) if our practices have changed, provide a list of all third parties to whom Personal Information was disclosed for their direct marketing purposes in the preceding calendar year, whichever is relevant. California consumers may request further information about our compliance with this law by emailing us at dataprivacy@GMH.com. Under the CCPA, California consumers have various rights regarding the Personal Information that GMH’s clients collect and process using GMH’s platforms. California consumers have the right to: Request disclosure of the categories and specific pieces of Personal Information that a Business has collected about you. Request disclosure of the categories of third-party sources, if any, from which a Business has collected Personal Information about you. Disclosure of the Business or Commercial Purpose(s) for which your Personal Information has been collected. Receive a list of the categories of third parties with whom a business has shared your Personal Information. Request that a business delete any Personal Information that it has collected from you (subject to exceptions). Not be discriminated against by a business (e.g. charged different rates, provided different levels of service, denied goods or services, or suggested any of the preceding) for exercising any of the individual rights granted above. Designate an authorized agent to exercise any of the individual rights granted above, on your behalf. Opt-out of the sale of Personal Information, if applicable. To exercise any of your rights as a California consumer, you should contact us (e.g. personnel of our Clients or our potential Clients) by sending an email to info@GMHcommunities.com. Before complying with your request, we may need to verify that it is you that is making the request. To accomplish this, you (or your authorized agent) may be requested to (1) confirm specific pieces of Personal Information that we already know about you, or (2) provide us with appropriate identification depending on the sensitivity of the information requested. California consumers are limited to two requests for Personal Information per twelve-month period. END USERS' PERSONAL INFORMATION If our Clients utilize Entrata’s payment processing functions, your payment information may be processed via third party payment processors in accordance with such payment processors’ terms and policies. Entrata transmits your complete payment information when you initiate a payment through the Entrata Platform. Entrata collects this information only so that we can pass it along to our payment processors, which you agree to use by submitting a payment through the Entrata Platform. Where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS). UPDATES TO THIS PRIVACY POLICY It is our policy to post any changes we make to our Privacy Policy on this page, with a notice that it has been updated on our main homepage. If we make material changes to how we treat your Personal Information, we will notify you through a notice on the homepage. The date that this Privacy Policy was last revised is listed at the top of the page. You are responsible for visiting our site and this Privacy Policy to check for any changes. GOOGLE ANALYTICS This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses Cookies. The information generated by the Cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Find Google's privacy policy here. CONTACT US If you have any questions or complaints related to our practices with respect to the collection, use, or disclosure of personal information, please feel free to contact us at: GMH Communities 610.355.8000 View Us On Facebook View Us On linkedIn View Us On Instagram View Us On Youtube Privacy Policy Accessibility Policy Terms & Conditions (610) 355-8000 10 Campus Boulevard Newtown Square, PA 19073 Copyright © 2021 All Rights Reserved. Website Design & Marketing By JUMPEM EMPLOYEE INTRANET