The purpose of this policy is to outline our procedures regarding the collection and use of sensitive personal information, including social security numbers, disclosed to the Owner or the Agent (collectively “we” or “our” or “us”) by a prospective or existing Resident (collectively “you” or “your”). Except as otherwise defined herein or unless the context otherwise requires, capitalized terms used in this policy have the same meaning as those terms are used in any Apartment Lease Agreement which has been or may be executed between you and the Owner. For the purposes of this policy, the term “sensitive personal information” means an individual’s first name or first initial and last name in combination with any one or more of the following items, if the name and the items are not encrypted: (a) social security number; (b) driver’s license number or government-issued identification number; or (c) account number or credit or debit card number in combination with any required security code, access code, or password that would permit access to an individual’s financial account. Sensitive personal information does not include publicly available information that is lawfully made available to the general public from the federal, state, or local government.

1. Collection and use of sensitive personal information. When you apply to rent an Apartment in the Community, we will ask you to disclose certain sensitive personal information on your rental application and possibly on other Lease documentation. This sensitive personal information will be used by us for business purposes including confirmation of your identity, determination of your eligibility for rental, and collection of amounts you owe.

2. Protection and access to sensitive personal information. We will keep the sensitive personal information you provide to us in our files. If you become a resident in the Community, we will keep the sensitive personal information in a resident file. If you do not become a resident, we will keep the sensitive personal information in a general file. Personnel with the Owner and Agent, if applicable, will have access to the files. We also reserve the right to disclose sensitive personal information for business related reasons to others such as independent contractors, credit reporting agencies, collection agencies, or prospective purchasers or their agents in a manner allowed by law.

3. Disposal of records containing sensitive personal information. It is our policy to dispose of business or customer records that contain sensitive personal information by modifying the records, through shredding, erasing, burning, pulverizing, making the sensitive personal information unreadable, undecipherable, or unreconstructable, or destroying or erasing electronic media containing sensitive personal information, so that the sensitive personal information cannot practically be read or reconstructed, or by entering into and monitoring compliance with a contract with another party engaged in the business of record destruction to dispose of records that contain sensitive personal information in a manner consistent with this policy.

4. Taking corrective action. In the event that you experience identity theft or we discover that there has been unauthorized acquisition of data that compromises the security, confidentiality, or integrity of sensitive personal information, we will comply with all applicable law with regard to taking appropriate corrective action.

This policy has been designed to meet the requirements of applicable law with respect to the adoption of a privacy policy. Nothing contained in this policy shall constitute a representation or warranty of any type whatsoever that sensitive personal information will not be misplaced, duplicated, or stolen and no liability is assumed with respect to any such occurrence.