Privacy Policy - Windsor Communities

Date Last Updated: January 2025

GID Investment Advisers LLC, GID Credit Advisers LLC, GID Industrial Advisers LLC, Windsor Property Management Company, and their affiliates (collectively, “Company” or “we”) respect 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, visit any social media page we maintain that contains a link to this Policy, or download or use our mobile applications where this Policy is posted (collectively, the “Sites”), contact us by email, telephone, or other means, visit one of our properties, reside or intend to reside at one of our properties, or otherwise interact with us. Please read this Policy carefully. By using the Sites or visiting one of our properties, you agree to our collection, use, and sharing of your Personal Information as described in this Policy.

Our Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and delete information.

Residents in of specific states within the US such as California, Colorado, Connecticut, Iowa, Nevada or Virginia should refer to the body of this Policy as well as the “Jurisdiction-Specific Notices” section below for additional information that may be applicable to them.

COLLECTION OF PERSONAL INFORMATION

Through your use of the Sites 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. “Sensitive Personal Information” refers to a smaller subset of Personal Information which is considered more sensitive to the individual, such as a Social Security, driver’s license, or passport number, race and ethnic origin, or physical or mental health information. We also collect information from other parties, such as identity verification services or credit reporting agencies, including the results of identity verification and credit report searches.

We may collect the following categories of Personal Information, including Sensitive 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, passport 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, 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, 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 histories, or credit information;
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;
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 personal identifiers, 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 rental application, your lease, or in the course of your tenancy, including location information (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; Sensitive Personal Information (such as 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, including financial information (such as bank account information), commercial information (such as transaction history), and information relating to 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 Sites, we collect information associated with your application, such as your contact information and resume.

Information Automatically Collected

We may directly or through our third-party service providers collect information through “cookies.” Cookies are small strings of text sent by our Sites to your browser and then stored by your browser on your device’s hard drive. Cookies help us understand how you use our Sites and other linked sites so that we can personalize and improve your experience on our Sites. Most Web browsers automatically accept cookies, but you may change your browser settings to reject cookies. In order to create a profile on our Sites, you must have certain cookies turned on.

We may automatically collect the following types of information when you use the Sites:

Usage Information: We collect certain information automatically through your use of the Sites, such as which pages of the Sites that you access, the frequency of access, and what you click on while on the Sites.
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 Sites, such as hardware model, operating system, application version number, browser, and other device attributes (“Device Information”).
Mobile Device Information: In addition to the Device Information listed above, when you access the Sites 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.

Some content or applications on the Sites 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 Sites. 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. You may manage the use of cookies by selecting the appropriate settings in the cookie banner associated with each Site, however, please note that if you do this you may not be able to use the full functionality of the Sites.

Please see our Cookie Policy for more information.

One of the third-party services the Sites use is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze how individuals use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. 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 Sites. 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 Sites. For more information about interest-based advertising from Facebook, visit https://www.facebook.com/help/568137493302217. To adjust your ad settings through Facebook, visit: https://www.facebook.com/help/568137493302217.

Information from Other Parties

We also collect information from other parties, such as identity verification services or credit reporting agencies, including the results of identity verification and credit report searches.

We also collect information from service providers, such as property management companies, payment processors and website hosting providers.

We collect information from financial institutions, such as credit reports.

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 visitors in a particular ZIP code.

Business Contact Information

We may receive your contact information, such as your personal identifiers (including your name, telephone number, and email address) and/or professional or business-related information (including your business address), through our online or offline interactions with you, such as when we work together on a project or discuss opportunities to work together. We may send you emails or call you with information about our business dealings, news, or marketing information to communicate with you for business purposes.

Social Media Information

If you post information on a webpage we establish on a social media platform, we may use the information to respond, to promote our business and services, and in the normal course of our business operations. We may collect personal identifiers, such as your social media username, and other personal characteristics that you have made publicly available on the social media website. Note that the third-party operators of social media websites also receive such information, and their use of your Personal Information is governed by their own privacy policies.

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 OF PERSONAL INFORMATION

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including 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 processing transactions on the Sites;
To communicate with you, such as notifying you about updates to the Sites or your rental or employment application;
To verify information provided, such as when we run identity verification and credit report searches;
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 Sites for internal market research or improvement of the Sites;
To comply with all applicable legal requirements;
For commercial purposes, such as processing your data for advertising purposes or sharing data with our select marketing and advertising providers;
To protect the Company, its employees, or others, such as to detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activities; and
To otherwise fulfill the purpose for which the information was provided.

Online Advertising

When you use the Sites, third parties may use cookies and other tracking technologies to collect information, including Personal Information, to help us target content to you on the Services or elsewhere. This information may be associated with other information or combined with information from other

sources, including information these third parties might track about your online activities over time and across the Internet. Third parties use this information to provide interest-based advertising and retargeting on our behalf, which may include placing our advertisements on other websites you visit, including your social media accounts, or matching a cookie or device ID to your email address so we can send you promotional emails that may be of interest to you. You may Opt-Out of these tracking cookies using the Cookie Banner provided on the Sites.

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information for the purposes identified above, to the following parties:

With our service providers or independent contractors, including payment processors and consumer reporting agencies: We may disclose all of the categories of Personal Information listed above with our service providers, including to help us perform functions and process your transactions.
Advertising and marketing providers, analytics companies, management companies, and data brokers: We may disclose all of the types of Personal Information listed above for commercial purposes (which may be considered a “sale” in certain jurisdictions).
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.

We may also share Personal Information:

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 Sites and products with our service providers.

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.

LINKS TO THIRD-PARTY WEBSITES

Our Sites 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 Sites. This Policy does not apply to the practices of such other websites, and 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.

International Data Transfers

The Sites are 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 the Sites 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.

No Use by Children

The Sites are not directed to, nor do we collect information from, children under 16 years of age. If you become aware that your child or any child has provided us with information without your consent, please contact us using the contact information listed below.

Privacy Rights

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to: (1) obtain a copy of Personal Information we maintain about you in a portable format; (2) correct inaccuracies or incompletion in your Personal Information; (3) object to the continued processing or use of your Personal Information; (4) or request that Personal Information be deleted. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “Contact Us” section below. You may also have the right to not be discriminated against for exercising your privacy rights. If you are a California, Colorado, Connecticut, or Virginia resident, see our “Jurisdiction-Specific Notices” section below for additional information as to how to exercise rights under the laws of those jurisdictions. If you are located outside that jurisdiction and seek to exercise your rights under the law of another jurisdiction, please contact us by emailing privacy@gid.com.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. When you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

JURISDICTION-SPECIFIC NOTICES

California

During the last twelve (12) months, we have collected the following categories of Personal Information from consumers depending on how a consumer uses our Sites.

Please see our Cookie Policy for information about the collection and use of Personal Information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Sites. Except as indicated above in the “Collection of Personal Information” section and below in the “California Job Applicants” section, we do not seek to collect any additional “sensitive personal information” (as defined in the CCPA).

Category (* may constitute “sensitive personal information” under the CCPA)	Type of Identifiers We Collect	Criteria used to determine retention periods	Sold or Shared	Disclosed To
Identifiers*	First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, Social Security number, social media username email address	The duration of our relationship with you; the length of time necessary to complete a transaction; whether your Personal Information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data.	Sold and Shared	Service providers, affiliates, management companies, and select advertising and marketing providers
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80€)*	Name, Social Security number, address, telephone number, bank account number	Same as above.	Not sold or shared	Service providers, management companies, and affiliates
Financial information	Income amount, Bank account information	Same as above.	Not sold or shared	Service providers, management companies, and affiliates
Employment and education information	Business/Institution address or name,	Same as above.	Not sold or shared	Service providers and affiliates
Commercial information	Transaction history, Records of personal property, products or services purchased,	Same as above.	Not sold or shared	Service providers, affiliates, and management companies
Internet or another similar network activity	Information on a consumer’s interaction with a website, application, or advertisement	Same as above.	Sold and Shared	Service providers, affiliates, management companies, and advertising and marketing providers

California Residents that are Job Applicants

When you apply for a job with Company, information may be collected about you in multiple ways: you may provide it to us in connection with your application; we may make observations in the application process or collect information from public information sources; or you may authorize us to collect information from other sources, such as a former employer or reference.

The following table describes our practices with regard to information submitted in the job application process. If you use our Sites in the job application process, additional information may be automatically collected, as described above.

Category (* may constitute “sensitive personal information” under the CCPA)	Types of information we collect	Criteria used to determine retention periods	Sold or shared	Disclosed to
Identifiers*	name, email address, phone number, and contact address, username, social media handle	The duration of our relationship with you; the length of time necessary to complete a transaction; whether your Personal Information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data.	Not sold or shared	Service Providers
Protected Classifications*	gender, race and ethnicity, date of birth	Same as above.	Not sold or shared	Service Providers
Geolocation Information*	location information (e.g., ZIP code, IP address)	Same as above.	Not sold or shared	Service Providers
Professional or employment-related information.	Employer’s name, employer’s address	Same as above.	Not sold or shared	Service Providers
Education Information	institutions attended, degrees and certifications attained	Same as above.	Not sold or shared.	Service Providers

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Rights Specific to California Residents

Under the CCPA, a California resident has the following rights:

to request additional information about our data collection, use, disclosure, and sales practices in connection with your Personal Information;
to request the specific Personal Information collected about you during the previous 12 months;
to request the deletion of the Personal Information we have about you;
to request a restriction on certain processing of Personal Information;
to request correction of inaccurate information; and
to restrict the usage and disclosure of Sensitive Personal Information. Windsor Communities does not use Sensitive Personal Information for any purpose other than permissible business uses under the law.

You may not be discriminated against for exercising your California privacy rights. You may submit a request to exercise your rights under the CCPA through one of two means:

Submit a request using this FORM
Call 1-844-671-0040 to submit a request

Upon receiving your request, we will confirm receipt of your request by email or if you are registered in our customer portal, we may do so by a message directed to you in the portal. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.

We aim to respond to your request as soon as reasonably practicable and consistent with any applicable laws. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

California residents are also entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to privacy@gid.com with the subject heading “California Privacy Rights,” or (b) a letter to us at the address listed in the “How to Contact Us” section. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

Additional Notice to Other U.S. Residents

If you are a resident of certain U.S. States, you may have some or all of the following rights. Among others, these states include Nevada, Virginia, Colorado, Connecticut, Utah, and Iowa. These rights are based upon residency status, and the Company will honor your request based upon your residency. You may have the right to request the following:

Disclosure of what Personal Information the Company Processes,
Deletion of Personal Information, subject to certain exceptions,
Correction of inaccurate or incomplete Personal Information,
Opt-Out of the sale of Personal Information,
Opt-Out of Targeted Advertising,
Opt-Out of Profiling for decisions that produce legal or similarly significant effects about you,
The right to not receive discriminatory treatment by the Company for exercising these rights.

Opt Out of Email Marketing

You may opt out of any future commercial email messages from us by choosing the link described as such within the email, 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.

CHANGES TO THIS POLICY

We reserve the right, at any time, to make changes to this Policy. We will post Policy changes on this page and, if the changes are material, we may provide a more prominent notice (including, for certain services or programs, email notification of privacy notice changes) for a reasonable period of time. Nevertheless, 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 Sites. Your continued use of the Sites after any changes have been made will constitute acceptance of the revised Policy.

Should you have other questions or concerns about this Policy, please send us an email at privacy@gid.com.