Privacy Policy Privacy Policy Effective Date: December 31, 2019 Windsor Property Management Company (“Company” or “we”) respects your privacy. This privacy policy (“Policy”) describes how we collect, use, and share your Personal Information, as defined below, when you visit websites that are owned and operated by Company or download or use our mobile applications (collectively, the “Site”), contact us, or visit one of our properties. Please read this Policy carefully. By using the Site or visiting one of our properties, you agree to our collection, use, and sharing of your Personal Information as described in this Policy. This Site is controlled, operated, and administered by Company from its offices within the United States and is intended to serve individuals interested in properties or employment with the Company in the United States. If you are accessing this Site from a location outside the United States, you acknowledge and consent to the collection, storage, processing, and transfer of your Personal Information to our facilities in the United States and to any other parties with whom we share it as described in this Policy. Please note that privacy laws in the United States may not offer the same protections as the laws of other countries. COLLECTION OF PERSONAL INFORMATION Through your use of the Site or when you contact us or visit one of our properties (collectively, “Interactions”), we may collect “Personal Information,” which is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We may collect the following categories of Personal Information: Personal or government identifiers, such as your first and last name, alias or previous name, postal address, telephone number, facsimile number, unique personal identifier, signature, Social Security number, national identification number or other government-issued identification number, driver’s or operator’s license number, passport number, alien registration number; Device and online identifiers and related information, such as Internet Protocol address; email address; account user name; cellular, mobile, or wireless number; social media profile; unique device identifier and serial number; device information; Demographic information, such as your date of birth, gender, physical characteristics or description, language skills, number of children, household income data; Financial information, such as your credit or debit card information, bank account number, other financial information; Protected characteristics, such as your gender, race, sexual orientation, age, or any other protected classifications under applicable law; Internet, application, or network activity information, such as search history; clickstream/online website tracking information; data related to user activity, e.g., browser visits; cookies or other similar technologies; Commercial information, such as records of your personal property, vehicle information, current or past addresses, purchase and browsing histories, credit information or other purchasing or consumption histories or tendencies; Biometric information, such as your likeness; imagery of your fingerprint, face, or hand; voice prints; biological characteristics; behavioral tendencies; or sleep, health, or exercise data; Sensory information, such as photographs or videos, heat maps, or voice recordings; Professional or employment-related information, such as employment history, association membership, professional licenses, or previous salaries; Education information, such as schools attended, scholastic performance, and academic record; Geolocation data, such as current location, address, and location history; Medical or health information, such as insurance policy numbers, health insurance information, fitness information, health journals, or information regarding medical records; Communications, such as call logs, the content of text messages or emails that you send to us, message board or forum posts, poll or survey answers, reviews, or information you may share when you contact us with questions or feedback; Household information, such as information about your dependents, cosigners, or guests; and Inferences drawn from Personal Information, such as a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Information Provided by You We collect the Personal Information that you provide to us. If you choose to contact us to learn more about our properties, we may collect information such as your full name, telephone number, and email address. We will also collect any other information that you provide to us, such as your questions, comments, or feedback as well as any responses you provide in surveys that we may send to you from time to time. If you are a current or prospective tenant, we may collect additional information as part of your application or in the course of your tenancy, such as your current or prior address(es); contact information, such as your telephone number or email address; date of birth; education, occupation, or employment information; Social Security number or other national identification number; income and other financial information; familial status and information about your dependents; vehicle information; credit information; criminal history; and emergency contact information. We may also collect information about other occupants or prospective occupants of the property you are applying for, such as roommates, spouses, or minor children, or information about any guarantor(s). Additionally, if you are a tenant and choose to use the Resident Portal, we collect information when you choose to pay your rent online, such as bank account information and transaction history, and about any other communications with us, such as service requests or messages that you send to management. If you apply for employment with us through the Site, we collect information associated with your application, such as your contact information and resume. Information Automatically Collected We may automatically collect the following types of information when you use the Site: Usage Information: We collect certain information automatically through your use of the Site, such as which pages of the Site that you access, the frequency of access, and what you click on while on the Site. Location Information: We may collect information about your location which may be determined from your IP address. Device Information: We may collect information about the device you are using to access the Site, such as hardware model, operating system, application version number, browser, and other device attributes. Mobile Device Information: In addition to the Device Information listed above, when you access the Site via a browser on your mobile device, we may also collect mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes. Information from Other Parties We also collect information from other parties, such as identity verification services or credit reporting agencies. Aggregate Information We may collect statistical or aggregated information that does not directly identify a specific person, but is derived from your Personal Information. For example, we may aggregate Personal Information to calculate the percentage of Site visitors in a particular ZIP code. SOURCES OF PERSONAL INFORMATION We collect the Personal Information described above from the following categories of sources: Other parts of our business, including our parent company, subsidiaries, and affiliates, some of which do not share our name or branding; Our service providers, such as property management companies, payment processors, or website hosting providers; Consumer reporting agencies; Financial institutions; USE AND DISCLOSURE OF PERSONAL INFORMATION We use the Personal Information that we collect for the following purposes: In connection with the rental or employment application process, such as determining your eligibility to rent an apartment or suitability for employment, confirming your identity, completing the leasing process or requesting credit and background check reports in connection with lease or job applications; In connection with your lease, such as determining that you continue to meet eligibility/suitability requirements during your lease or employment term with us; To provide services that you request or fulfill our contractual obligations to you, such as completing transactions on the Site; To communicate with you, such as notifying you about updates to the Site or your rental or employment application; For marketing or promotional purposes, such as informing you of special promotions or offering you additional products or services that may be of interest to you; For specific purposes for which you provide consent, such as if you consent to fill out surveys regarding products and services provided by us, our affiliates, or partners; To provide customer service or technical support, such as contacting you in response to your inquiries, comments and suggestions or when otherwise necessary; To debug, maintain, and improve our services, such as tracking use of the Site for internal market research or Site improvement; and To protect the Company, its employees, or others, such as to detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activities. We disclose the following categories of information for our or our service providers’ operational purposes, or other notified purposes: Personal or government identifiers Device and online identifiers and related information Demographic information Financial information Protected characteristics Internet, application, or network activity information Commercial information Biometric information Sensory information Professional or employment-related information Education information Geolocation data Medical or health information Communications Household information Inferences drawn from Personal Information We may also disclose the following categories of information for commercial purposes (which may be “sales” in certain jurisdictions): Personal or government identifiers Device and online identifiers and related information Demographic information Financial information Protected characteristics Internet, application, or network activity information Commercial information Sensory information Professional or employment-related information Education information Geolocation data Medical or health information Communications Household information Inferences drawn from Personal Information We may disclose this information, for the following purposes: With our service providers or independent contractors: We may share information with other parties that help us perform functions and process your transactions. Within our corporate family: We may share information with our affiliates, joint ventures, or other companies under common control with us, to the extent permitted by law. If there is a change in corporate structure: We may share information in connection with a proposed or actual merger, acquisition, consolidation, change of control, or sale of all or a portion of our business or property or if we undergo bankruptcy or liquidation. To prevent harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person. For legal purposes: We will share information where we are legally required to do so, such as in response to court orders or legal process; to establish, protect or exercise our legal rights; to defend against legal claims or demands; or to comply with applicable legal requirements. For legitimate business purposes: We reserve the right to share information with other parties for our legitimate business purposes, to the extent permitted by law. With your consent: We may request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose. Without identifying you: We may share information in a manner that does not identify you. For example, we may share anonymous, aggregate information about your use of our Site and products with our service providers. We may share Personal Information with the following categories of third parties for valuable consideration (which may be “sales” in some jurisdictions): Members of our corporate family, including our affiliates Service providers, such as advertising and marketing providers, payment processors, and analytics companies Management companies Data brokers Consumer reporting agencies We do not engage in these disclosures for Personal Information of minors under age 16 without affirmative authorization. PROTECTION OF PERSONAL INFORMATION The security of your Personal Information is important to us. We maintain reasonable physical, technical and administrative security measures to protect and limit access to your Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially-acceptable means to protect your Personal Information, we cannot guarantee its absolute security. USE OF COOKIES We may directly or through our third-party service providers collect information through “cookies.” Cookies are small strings of text sent by our Site to your browser and then stored by your browser on your device’s hard drive. Cookies help us understand how you use our Site and other linked sites so that we can personalize and improve your experience on our Site. Most Web browsers automatically accept cookies, but you may change your browser settings so it won’t accept cookies. In order to create a profile on our Site, you must have your cookies turned on. The Site does not respond to “Do Not Track” signals sent by Internet browsers. THIRD-PARTY INFORMATION COLLECTION Some content or applications on the Site may be provided by third parties, including advertisers, ad networks and servers, analytics companies, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different sites and other online services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions, you should contact the responsible provider directly. 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 Site. One of the third-party services the Site uses is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze how individuals use the Site. The information generated by the cookie about your use of the Site (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 Site, compiling reports on Site activity, and providing other services relating to Site activity. We have also enabled additional Google Analytics Advertising Features, including Remarketing with Google Analytics. Remarketing with Google Analytics uses the Google Analytics and/or a third party cookie to serve advertisements to you across the Internet based on your visit to our Site. For more information about how Google collects and uses information, visit www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. To opt out of being tracked by Google Analytics across all sites visit: http://tools.google.com/dlpage/gaoptout. We may also use Facebook remarketing, a service offered by Facebook Inc. (“Facebook”) to service advertisements on third-party websites after you visit our Site. For more information about interest-based advertising from Facebook, visit https://www.facebook.com/help/164968693837950. To opt out from Facebook’s interest-based ads, visit: https://www.facebook.com/help/568137493302217. LINKS TO THIRD-PARTY WEBSITES Our Site may offer links to other sites operated by third parties for your convenience. Such third-party websites may have information, policies, and practices different from our Site. We do not control and are not responsible for the privacy policies, practices and/or content of such third-party sites. Please contact such third-party sites directly for information regarding such websites. CHILDREN The Site is not directed to, nor do we knowingly collect information from, children under 13 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using the contact information listed below. YOUR CHOICES If you are a California resident, you may have the following rights with respect to your Personal Information, subject to applicable exceptions: Right to access Personal Information. You may be entitled to request that we disclose to you the specific pieces of your Personal Information that we have collected in the 12 months preceding your request. Right to data portability. You may be entitled to request a copy of your electronic Personal Information in a readily-usable format. Right to disclosure. You may be entitled to receive the following information with respect to the 12 months preceding your request: the categories of Personal Information we have collected, the sources from which we collected that Personal Information, the purposes for which we collected and shared that Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom we sold Personal Information, and the categories of Personal Information that we disclosed for a business purpose. Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law. Right to opt–out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your Personal Information to third parties in exchange for monetary or other valuable consideration. You can exercise such right to opt-out here https://www.windsorcommunities.com/do-not-sell/. Please note that these rights may be limited under applicable laws. For example, we may need to retain certain Personal Information for business purposes, to complete transactions you have requested, to comply with our legal obligations, or for other purposes as required or permitted by applicable law. If you wish to exercise your rights under applicable law, please contact us at yourinfo@windsorcommunities.com or 1-844-671-0040 or go to https://www.windsorcommunities.com/privacy-policy/my-info/. If you would prefer, you may designate an authorized agent to make a request on your behalf. Please note that we may require additional information in order to verify your identity and process your request. We will not discriminate against you because you exercise any of the consumer rights described in this section. In addition to the rights described above, California residents who provide Personal Information to us in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information that we disclosed, if any, to other businesses for their own marketing purposes in the immediately prior calendar year. This request may be sent electronically by email to yourinfo@windsorcommunities.com or by phone at 1-844-671-0040. We will respond to these requests within 30 days. Requests for this information that come to us through other channels may result in a delayed response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. CONSENT AND CHANGES TO THE POLICY By using this Site and providing us with Personal Information, you have consented to our contacting you by email to provide you with information relating to your inquiry. You may opt out of any future commercial email messages from us by choosing the link with instructions on how to remove yourself from our email list. Please note that if you are a resident of one of our apartment communities and you opt out of receiving commercial email from us, you will continue to receive email from us regarding operational issues surrounding your apartment, your lease, and/or your community. We reserve the right, at any time, to make changes to this Policy. Please check this page periodically for the most recent version of this Policy. Unless otherwise stated, any changes will be effective immediately upon posting to the Site. Your continued use of this Site after any changes have been made will constitute acceptance of the revised Policy. you have other questions or concerns about this Policy, please send us an email at webmaster@windsorcommunities.com. Please note: Only inquires regarding this Policy can be answered at this email address. Home Privacy Policy Terms Accessibility Statement Equal housing opportunity .cls-1{fill-rule:evenodd;} © 2021 Windsor Property Management Co.. All Rights Reserved. | Powered by RENTCafé (© 2021 Yardi Systems, Inc. All Rights Reserved.)