__________________Privacy Policy

PRIVACY POLICY

Effective Date: November _12_, 2024

Cooper Multifamily Services LLC, its subsidiaries, affiliates and related entities (“CMS,” “we,” “our” or “us”) respects your privacy and is committed to protecting your information. This Privacy Policy (this “Policy”) describes our privacy practices with regard to information about you that could reasonably be used to identify you personally, or that is associated with information that identifies you (“Personally Identifiable Information”) that we gather or collect via this website and any other CMS website(s) or online service(s) (including but not limited to e-mails and chats), as well as Personally Identifiable Information that we collect offline in connection with any services we provide to you (collectively, “Service”).

PLEASE REVIEW THE TERMS OF THIS POLICY. IF YOU DO NOT CONSENT TO OUR PRACTICES AS STATED HEREIN, DO NOT CONTINUE USE OUR SERVICE. YOUR USE OF THE SERVICE REPRESENTS ACCEPTANCE OF OUR POLICY AND AGREEMENT TO OUR TERMS OF USE.

For purposes of this Policy, Personally Identifiable Information may include, where applicable: your name; your home or other physical address; your email address; your telephone number or other contact information; Social Security number; driver’s license or state identification card number; financial information (i.e. bank account number and routing number); your account username and password; and/or any other identifier that identifies you.

Please note that this Policy does not govern the practices of third parties, such as our partners, third party service providers, or advertisers except to the extent we provide them with Personally Identifiable Information. Any information you provide directly to a third party while utilizing their website or service, even if you access their website or service through ours, will be governed by the third party’s privacy policy and terms of use, and not this Policy. Please review such third-party policies and terms of use carefully.

1. COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION. We may collect Personally Identifiable Information about you in a number of ways, including directly from you (e.g., when you use our Service), passively from you as you visit our website(s) (e.g., by collecting information from cookies as discussed below) or from third parties (e.g., as part of a credit report). “Personally Identifiable Information” generally means any information that is linked or reasonably linkable to an identified or identifiable person. It does not include information that has been de-identified or that is publicly available. We may collect Personally Identifiable Information about you depending on how you interact with us or our Service. We may combine the Personally Identifiable Information we collect from you with information from third parties such as advertising and marketing partners, public databases, and social media platforms, to supplement the information we receive from individuals. If we do so, this Policy governs how we can use that information.

In some cases, we may collect Personally Identifiable Information directly from you, for example, when you: (a) create or modify a profile; (b) make an appointment or interact with us in person, such as to visit one of our communities; (c) any content or contributions you post on our website(s); (d) Submit an application; (e) make a payment; (f) request accommodations or specialized services; (g) make a maintenance request or complaint; (h) consent to marketing communications; (i) submit comments, reviews, or other user-generated content; (j) connect or interact with us through social networks (e.g., Facebook/Meta, Google, Twitter/X; Instagram, etc.); and/or (k) request customer or technical support or Service.

Personally Identifiable Information may include:

(i) Personal identifiers and record information. For example:
a. Your account username and password;
b. Name, alias, physical address (current and former), email address (personal and work-related), telephone number, date of birth, medical condition, and any other personal profile or account information you affirmatively provide to us;
c. IP address, device ID, online identifiers, and other information collected via cookies, pixels or other software when you access our website(s);
d. Status as a victim of domestic violence, assault, or stalking (e.g., if we are provided with a copy of a restraining order limiting a third party’s access to a property);
e. Application and claims history, criminal history, and criminal records (e.g., as part of our standard background checks for applicants or if we are provided with a copy of a restraining order/related documentation limiting a third party’s access to a property);
f. Emergency contact information, children’s names, parent’s name(s) (e.g., if included on your application, if you volunteer this information, and/or if we are provided with a copy of a restraining order/related documentation limiting a third party’s access to a property);
g. Insurance policy information, including insurance policy number(s);
h. Identifying numbers such as Social Security, Driver’s License, passport or other state or national identification card numbers and details; and
i. Protected classifications such as AIDS/HIV status, citizenship status, disability or specific condition, gender identity and gender expression, marital status, military or veteran status, political affiliation and activities, racial or ethnic origin, religion and religious beliefs, reproductive health data, and sexual orientation (e.g., if your application or lease lists two individuals of the same gender as spouses, if included or necessary as part of an accommodation request, if provided or requested in determining eligibility for certain grants or funds, etc.);
(ii) Biometric identifiers such as health data and voice recordings;
(iii) Sensory information such as audio information (i.e., voicemails) and visual information (i.e., videos);
(iv) Geolocation information;
(v) Internet usage information such as interactions with advertisements and our website(s) Site, Site navigation and interaction history, and interactions with applications;
(vi) Financial information such as credit card, debit card or bank account number, credit report information, credit history, bank statements, and income;
(vii) Commercial information, including purchasing tendencies, personal property records, records of products or services considered or purchased;
(viii) Payment information, including information submitted in connection with online transactions;
(ix) Professional or employment information such as benefits and entitlements data, bonus payments, bullying and harassment details, business unit / division, company / entity, end date and reason for termination, hours of work, job title / role, office location, previous work history, start date, compensation data, grievances and complaints, health & safety related information and reporting, personnel number, record of absence / time tracking / annual leave, reference or background checks, salary, wage, salary / wage expectation, and workers compensation claims;
(x) Educational information, including education and training history;
(xi) Other information that you voluntarily provide such as any content or contributions you post on the Site (e.g., photos or comments on any forums); any information you provide in communications with us, such as via email or in residential service requests, including move-in date;
(xii) Any information you provide in communications with us, such as via email or in residential service requests, including move-in date;
(xiii) Inference information including abilities, preferences, behavior, and attitudes; or
(xiv) Sensitive personal information including sensitive identification numbers such as social security or driver’s license numbers, gender, disability or health information, racial information, sexual orientation, or information that can be surmised from information that you provide us (e.g., based on the genders of co-tenants).

In addition to collecting Personally Identifiable Information, we may collect information that does not identify you and is not associated with your Personally Identifiable Information. We also may de-identify information so it no longer identifies you. We aggregate and use such information to engage in marketing and other activities as well as for internal business reporting and reviews. Because this information is no longer Personally Identifiable Information, it is outside the scope of this Policy.

2. USE OF PERSONALLY IDENTIFIABLE INFORMATION. We retain and use your Personally Identifiable Information to: (a) provide you with services or process transactions that you have requested; (b) communicate with you regarding information, features or offers that we believe will be of interest to you; (c) respond to your questions or other requests (including use of transcripts or recordings collected from chats, customer service calls, emails, and/or activity sessions); (d) contact you with regard to the Service or otherwise; (e) process any applications, payments or changes to your account information; (f) process other information or Personally Identifiable Information that you submit through the Service; (g) conduct user surveys; (h) contact you regarding a sweepstakes, contest or promotion in which you have participated; (i) evaluate your application for employment; (j) fulfill other purposes disclosed at the time you provide your Personally Identifiable Information; and (k) as otherwise required or permitted by applicable law. This includes, without limitation using your Personally Identifiable Information and other information to improve the Service, to customize your experience on the Service, to serve you specific content, to prevent and address fraud and data security risks, or for other business purposes.

3. SHARING OF INFORMATION WITH THIRD PARTIES.

(a) Non-Personally Identifiable Information. We may share non-Personally Identifiable Information with third parties without restriction as permitted by applicable law. CMS and third parties may convert your Personally Identifiable Information to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information, and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices.

(b) Personally Identifiable Information. We may share your Personally Identifiable Information as set forth in this Policy, in any manner in which you expressly consent via the Service, or in the following circumstances:

a. Affiliated or Subsidiary Companies. We may share Personally Identifiable Information with our affiliated or subsidiary companies who require access to Personally Identifiable Information for legitimate business purposes related to your potential, current or former tenancy or to process any application, request, or inquiry. This includes the owner of any community where you make application or where you lease. We may also share your Personally Identifiable Information during the subscription to our text message program(s) (e.g., your phone number and opt-in) with our affiliated or subsidiary companies for only legitimate business purposes related to operating the text message program(s).
b. Direct Marketing. Subject to your communications choices explained in “Exercising Control Over Your Personally Identifiable Information” below, and, we may share or sell Personally Identifiable Information and other information with third parties for their own direct marketing purposes.
c. Third parties providing services on our behalf. We may share your Personally Identifiable Information with third parties who perform services on our behalf or on behalf of the owner of one of our properties (“Service Providers”). This includes, without limitation, Service Providers that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. It also includes call center, chat, and session replay vendors. These Service Providers may have access to Personally Identifiable Information in order to provide these services to us or on our behalf. Notwithstanding anything to the contrary herein, when you subscribe to a text message program, the Personally Identifiable Information obtained during the subscription process (e.g., your phone number and opt-in) is shared with our Service Providers and with telecommunications companies, to provide these text message program(s) and related purposes.
d. Legal Requirements and Law Enforcement. We may disclose you Personally Identifiable Information and other information when we believe in good faith that the law requires it; when we receive an enforceable request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Service and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Service, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
e. Sweepstakes and Promotions. If you choose to enter a sweepstakes, contest or other promotion, your Personally Identifiable Information may be disclosed to Service Providers, co-sponsors, and other third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may include consent to additional or differing data practices from those contained in this Policy, and which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.
f. Corporate Change. We reserve the right to disclose and transfer your Personally Identifiable Information and other information in connection with negotiations of any proposed or actual corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change. For example, when a potential buyer is interested in purchasing one of our properties, we may provide the potential buyer with information about the property and the tenants who live there, which may include your Personally Identifiable Information. Upon the sale of the property in which you live, all of your Personally Identifiable Information may be transferred to the purchaser.

4. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS. The Service may permit you to post or submit User Generated Content (“UGC”) including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to CMS’s usage or sharing limitations, or other obligations, regarding Personally Identifiable Information under this Policy or otherwise, and may be used and shared by us and third parties to the fullest extent not prohibited by applicable law. CMS encourages you to exercise caution when making decisions about what you disclose in such public areas. Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, CMS relies on you to only send to people that have given you permission to do so.

5. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, AND SOCIAL FEATURES. The Service may include or link to third-party websites, apps, ads, locations, platforms, code (e.g., plug-ins, application programming interfaces, software development kits, or other services (“Third-Party Services”). These Third-Party Services may use their own cookies, web beacons, and other technologies (collectively, “Tracking Technology”) to independently collect information about you and may solicit Personally Identifiable Information from you.

6. SECURITY. While we take reasonable steps to secure your Personally Identifiable Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personally Identifiable Information on the Service or on other servers or databases to which the information may be transferred can be guaranteed to be completely secure. Please consider this prior to submitting your Personally Identifiable Information to us via the Service. We use current security measures to safeguard your Personally Identifiable Information. These security measures may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

7. CHILDREN. The Service is intended only for adults over the age of eighteen (18) and is not directed to children younger than age eighteen (18). CMS also does not knowingly collect Personally Identifiable Information from children under the age of thirteen (13) on the Service and will delete any information if later determined to be from a person younger than age thirteen (13) as required by applicable law.

8. PRIVACY POLICY CHANGES. This Policy may change prospectively from time to time effective upon posting of the updated notice on our Service. Your continued use of the Service after we make changes is deemed to be acceptance of those changes, so please review this Policy periodically for updates. To the extent any provision of this Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

9. EXERCISING CONTROL OVER YOUR PERSONALLY IDENTIFIABLE INFORMATION. In general, you may browse the Service without providing Personally Identifiable Information. However, if you choose not to provide certain information through the Service or a Portal Site, we may not be able to provide certain services or process certain of your requests. You may not be able to submit an application for employment or residency, may not be able to access resident services online, or otherwise use all of the features and products that we make available online.

Updating your information. Depending on the functionality associated with the Service feature you are using, you may be able to update certain of your Personally Identifiable Information on the Service by following the instructions provided there.

Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from us at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from CMS to text the word, “STOP.” Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or CMS’s ongoing business relations.

Consent to transfer. The Service is operated in the United States. Your Personally Identifiable Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Policy.

10. QUESTIONS AND CONCERNS. If you have any questions or concerns about this Policy, you may contact us by email at general at cmsmultifamiiy.com.