ASPEN SQUARE RESIDENT PORTAL CAREERS COMPANY ASPEN SQUARE MANAGEMENT (413) 781-0712 info@aspensquare.com PRIVACY POLICY YOUR PRIVACY RIGHTS General. This Privacy Policy describes how Aspen Square Management, Inc. and its affiliates (collectively, “Aspen” or “we,” “our” or “us”) treat data and information about you that Aspen collects and receives through this website and other Aspen websites that link to this Privacy Policy (collectively, the “Websites”), as well as information Aspen collects and receives from you offline, such as when you visit the management or leasing office at an Aspen property. The Websites include without limitation: https://www.aspensquare.com and https://portal.aspensquare.com. Aspen’s affiliates include without limitation the entities operating the Websites listed above and other entities that may be affiliated with Aspen, including without limitation: Nepsa Property Investors, Inc., Nepsa Manager LLC, Nepsa Admin Services LLC, Nepsa Operating Group, Inc., and Johnson Real Estate Investors LLC. If you have a question whether a site is a Website of Aspen, or if an entity is an affiliate of Aspen Square Management, Inc., please check the information posted on the site or other material, or contact Aspen at info@aspensquare.com or 413-781-0712. ACCEPTANCE OF PRIVACY POLICY. Each time you access, use, submit an application, forms or other information on, or browse the Websites, you signify your acceptance of the then-current Privacy Policy. If you do not accept this Privacy Policy, you are not authorized to use the Websites and must discontinue use of the Websites immediately. If you provide personal information to Aspen offline, such as when you visit the management or leasing office at an Aspen property, or if you click on Aspen’s digital advertisements on third-party websites or applications, Aspen asks that you review this Privacy Policy which also governs information collected offline and through digital advertising. This Privacy Policy does not apply to the practices of companies that Aspen does not own or control. Please see Section 3 (Linking to Other Sites) below. LINKING TO OTHER SITES. Our Websites may contain third-party links, include third-party integrations, or offer a co-branded or third-party-branded service (collectively, “Other Links and Sites”). For example, Aspen may use Other Links and Sites for the processing of rental and employment applications. Through these Other Links and Sites, you may be providing information (including personal information) directly to the third party (which may include certain Service Providers), us, or both. Because these Other Links and Sites may not be hosted or controlled by Aspen, however, we are not responsible for the privacy practices of those Other Links and Sites or the content provided thereon. Collection Technology also may be used by some of those Other Links and Sites. Therefore, the privacy policies with respect to these areas may differ from those applicable to the Websites and we encourage you to review the privacy policies of each of those Other Links and Sites. COLLECTION OF INFORMATION. PERSONAL INFORMATION. Aspen collects personal information from you at various places and through various mechanisms on the Websites and in certain circumstances offline. This may include, for example, when you conduct business with Aspen, rent or lease property from Aspen, apply to be a lease guarantor, apply for employment, request information or materials, enter promotions, sweepstakes or contests offered by Aspen, register on the Resident Portal, employment application portal, employee onboarding portal or elsewhere on the Websites, make rent and/or other payments, or communicate with us about questions or other matters. Personal information is only collected if you voluntarily provide such information to Aspen. Such information may include, without limitation, your first, middle and last name, maiden name, marital status, date and place of birth, current and former home addresses, email addresses, telephone numbers, employment history, current and former employer names and addresses, job-specific qualification questions, income and asset information, driver’s license information and state/governmental identification number (where permitted by law), tax and withholding information, Social Security number, credit or debit card number or other payment method, billing information, emergency contact information, applicable licenses and certifications, and other information that is not otherwise publicly available. INFORMATION COLLECTED FROM OTHER SOURCES. Aspen also may acquire personal information about you from other sources, such as Service Providers (as defined below in Section 5.1), vendors and other third parties, that may share information as permitted in their privacy policies. This Privacy Policy does not apply to personal information about you that we receive from other sources. However, if we combine information that we collect through other sources with personal information covered under Section 4.1 in a manner that associates it with your name and contact information, we will use such information in accordance with the stricter of applicable law or the terms of this Privacy Policy. NON-PERSONAL INFORMATION. Non-personal information refers to data and information that does not personally identify you as the individual to whom the data or information relates, which may include data and information that (i) is aggregated (that is, relates to a group of individuals) by Aspen or a third party (“aggregated non-personal information”), or (ii) is not linked to personal information (“de-identified non-personal information”). In either case, non-personal information does not personally identify the individual to whom the information or data collected relates. Non-personal information may include, without limitation, your Internet Protocol (“IP”) address, your media access control (MAC) address, Collection Technology (as defined below) information, type of computer or device you use, the operating system you use (e.g., Microsoft Windows, Mac OS or Google Chrome), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer or Safari), the domain name of the Internet service provider, your activities while visiting or using the Websites and the content you access or view, the time of your visit to or use of the Websites, the pages you visit and the time spent on the pages, your general geographic location such as the city from which your computer or device is connecting to the Internet, information regarding the websites you visit prior to and after visiting the Websites, and information regarding your Internet location when you see Aspen’s ads and whether you click on such ads. Cookies and other “Collection Technology”. Non-personal information may be collected in a variety of ways, but Collection Technology is often used. “Collection Technology” refers to cookies, web beacons, pixels, gifs, tags and other technologies that collect information in similar ways. Collection Technology such as a cookie may store a piece of data on your browser or device, while other forms of Collection Technology may identify your browser or device and/or collect information through other means. To learn more about how we use cookies and your choices, please review our Cookie Statement. When you visit the Websites, or visit another website or application, your browser or device may be exposed to Collection Technology and Collection Technology may be stored on your browser or device. Aspen may come to acquire non-personal information about you upon collection of the non-personal information or some time thereafter. You may delete and/or refuse the use of certain Collection Technologies by selecting the appropriate settings on your browser. You may use the Websites even if you choose to refuse or delete such Collection Technologies; however please note that this may affect your ability to use the full functionality of the Websites, and may impact our ability to customize the Websites for you. Analytics Services. The Websites may use analytics services provided by third parties, such as Google Analytics and Moz, among others. These analytics services use Collection Technology to collect and store information about you and your use of the Websites, which may include the personal and non-personal information described above. You can read Googles’ privacy policy, which applies to Google Analytics, at http://www.google.com/intl/en/policies/privacy/. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current browser https://tools.google.com/dlpage/gaoptout. You can read Moz’s privacy policy, which applies to Moz analytics, at http://moz.com/privacy-policy. USE, SHARING AND DISCLOSURE OF PERSONAL INFORMATION. Aspen may use your personal information to: (i) provide you with services or process transactions that you have requested, (ii) carry out the purposes for which you provided the information, (iii) improve our services, (iv) process any applications, forms, requests, inquiries, or other information you submit through the Websites, (v) administer and process payments, (vi) attend to tasks relating to your transactions with Aspen, (vii) provide customer service, (viii) update account information, (ix) inform you of products or services that may be of interest to you, (x) customize the content or functionality of Websites to your preferences, (xi) respond to your communications, and (xii) communicate with you about the Websites and other activities related to the Websites. You authorize Aspen to transmit email and direct mail to you, call you, including with an automated telephone dialing system, send push notifications to your device, send you text messages, and otherwise contact you concerning these matters. Any Aspen affiliate that receives your personal information may share it with other Aspen affiliates for any purpose permitted under this Privacy Policy, including for our affiliates’ own marketing purposes. Affiliates and subsidiary companies include, without limitation, the owner of any property for which you apply or where you lease, as well as the management and/or administrative services company for such property. Your personal information will be intentionally disclosed to third parties only as follows: Disclosures to Third-Party Service Providers. Aspen may provide your personal information to third parties who work on behalf of or with Aspen including, without limitation, third-party service providers, agents, vendors, payment processors, insurance companies and brokers, benefit advisors and administrators, retirement plan record keeping companies, consultants, attorneys and other affiliates (“Service Providers”). These Service Providers may use your personal information as provided in the first paragraph under Section 5 above to help Aspen administer its business or the Websites, including, but not limited to, assistance in administering and processing payments, mailing information, providing services related to the deliveries and retrievals of packages and other mailings (e.g. include, but not limited to, Hub by Amazon services), maintaining databases, assisting with utility billing or insurance, providing credit, criminal and/or motor vehicle background checks, resident screening, employment screening, complying with governmental or quasi-governmental reporting, collection services, providing customer service, assisting in the recruitment and onboarding process for prospective employees and employees, setting up and administering insurance and other employment benefits, providing assistance to employees, or communicating with you about offers or other information relevant to Aspen. We may also share your personal information with Service Providers to provide general functions on our behalf relating to the Websites and our properties. Promotions, Sweepstakes and Contests. Aspen may operate promotions, sweepstakes or contests through the Websites that may require you to register online and/or submit personal information. We typically ask you for certain personal information when you enter and, if applicable, win a promotion, sweepstake or contest. We may share this personal information with third-party sponsors of such promotion, sweepstake or contest (irrespective of whether it is hosted by us), or otherwise in accordance with the rules applicable to such promotion, sweepstake or contest. You should carefully review the rules of each promotion, sweepstake or contest in which you participate through the Websites, as they may contain additional important information about Aspen’s or a third-party sponsor’s use of your personal information. Insofar as the terms and conditions of such rules concerning the treatment of your personal information conflict with this Privacy Policy, the terms and conditions of the promotion, sweepstake or contest shall control. Disclosures Under Special Circumstances. Aspen may provide information about you in response to or to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirements, subpoenas, court orders or legal process; to respond to your requests for customer service or other information; to establish or exercise our legal rights or defend against legal claims; or to protect the safety or property of Aspen or others. Aspen also may provide information about you if Aspen believes it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required or permitted by law. Major Transactions. Aspen reserves the right to transfer any and all information, including, without limitation, personal information, to any Aspen affiliate or a third party or successor in the event of any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations (including, without limitation, in connection with bankruptcy or any similar proceedings). Other Purposes. We may use your information for other purposes specifically disclosed to you at the time we request your information. By providing your information, you consent to all disclosed uses. USE, SHARING AND DISCLOSURE OF NON-PERSONAL INFORMATION. Aspen and its Service Providers may use your non-personal information in a variety of ways, such as to administer the Websites, improve the Websites, improve navigation of the Websites upon your return visit, in relation to or to improve the services we offer, analyze and develop advertisements and advertising campaigns, provide you with special offers and promotions and determine their effectiveness, customize the content or functionality of Websites to your preferences, and analyze trends and site usage. Aspen also may use non-personal information to present you with targeted content and advertisements (including on third-party websites) (collectively, “Interest-based Ads”) based on your past visits to the Websites and non-personal information collected over time by us and third parties, and to determine the effectiveness of and optimize the content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how those interactions relate to your visits to the Websites. Certain companies we work with to serve Interest-based Ads participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads on the ads that link to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/. If you prefer not to receive targeted advertisements from us, as described above, please click on the following link: http://www.aboutads.info/choices. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you may continue to receive standard advertisements from us and targeted advertisements from third parties after clicking the link. You may need to re-click the link if you delete Collection Technology or use a different computer or browser. Aspen may share or disclose your non-personal information with or to employees and Service Providers to perform the tasks described in this Section 6. Aspen also may use, disclose or share your non-personal information for our business purposes and other purposes consistent with applicable laws. If any aggregated non-personal information or de-identified non-personal information becomes identifiable to a person, Aspen will treat such information as Personal Information. PROTECTION OF PERSONAL INFORMATION. Aspen stores personal information using industry standard, reasonable and technically feasible physical, technical and administrative safeguards. Please be aware that the Websites and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond Aspen’s control. Aspen is not responsible for the acts and omissions of any third parties. Aspen cannot guarantee the security of the information on and sent from the Websites. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Aspen to intercept or access transmissions or private communications unlawfully. Neither Aspen nor any of our Service Providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk. DISPOSAL OF PERSONAL INFORMATION. Aspen has implemented certain information disposal practices to help prevent unauthorized access to – or use of – your personal information. Such measures may include shredding, erasing, or making the personal information unreadable or undecipherable, or by contracting with a person engaged in the business of disposing of records containing sensitive personal information. NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS. California “Shine the Light” Disclosure. Under California S.B. 27 (“Shine the Light” Law), California residents have the right under certain circumstances to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to info@aspensquare.com and please include the phrase “California Privacy Request” in the subject line, along with your name, address and email address. We will respond to you within thirty days of receiving such a request. California “Do Not Track” Disclosure. At this time, Aspen does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt out” setting or feature that may be offered by your browser. Children. The Websites are not designed to solicit individuals under the age of 13. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect or store any personal information from children under the age of 13. If we become aware that a Website user is under age 13 and has provided personal information, we will remove his or her personal information from our files. If you are a parent or guardian and believe Aspen may have inadvertently collected personal information from your child, please notify Aspen immediately by sending an email, including the Website or line of business to which your request pertains, to info@aspensquare.com. UPDATING YOUR PERSONAL INFORMATION. In certain circumstances, you may be able to review and request changes to your personal information on the Website or by contacting us at: info@aspensquare.com. CHANGES TO THIS PRIVACY POLICY. The Privacy Policy may be revised from time to time. We display an effective date at the end of this Privacy Policy (“Last Revised Date”) for you to know when there has been a change. Accordingly, you should check the Privacy Policy on a regular basis for the most current privacy practices. Each time you access, use or browse the Websites, you signify your acceptance of the then current changes to the Privacy Policy. Any changes in the Privacy Policy will take effect upon posting. If Aspen makes any material changes to this Privacy Policy, Aspen will provide you notice of such changes through the website or through other communications with you in the manner and to the extent required by law. CONSENT TO TRANSFER. Personal information collected through the Websites are stored and processed in the United States. By using the Websites, you expressly consent to any such transfer of information outside of your country. CONTACT US. If you have any questions about this Privacy Policy or our Websites, please contact us at info@aspensquare.com or 413-781-0712. Please note that email communications may not be secure. Accordingly, you should not include personal or other sensitive information in your email correspondence to the Website or Aspen. 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