Privacy Policy

CORVIAS GROUP LLC PRIVACY POLICY

Corvias Group, LLC ("Corvias", "we", "us", or "our") respects your privacy. This privacy policy (this "Privacy Policy" or "Policy") explains how we collect, use, and treat information that we receive about you when we provide you with our services: (i) through our website (our "Website" or "Site"); (ii) by contacting us directly by phone, email, or other communications channels; or (iii) when visiting one of our physical properties. Our Privacy Policy applies to anyone using our services (collectively, the "Services").

1. Your Consent. Please read this Privacy Policy carefully because it creates legal obligations on you and us. You show your consent to this Privacy Policy by using our Website, visiting one of our locations, or otherwise using our Services. We may further confirm your consent by asking you to click an "I Accept" or similar button. In any event, by providing your consent, you are acknowledging that you have read and understood this Privacy Policy, and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from using our Services.

2. Types of Information We Collect. We collect the categories of information described in this Section 2 (Types of Information We Collect).

2.1. Personal Information. We use the term "Personal Information" to mean any information that identifies you as an individual, and any other information we associate with it. Personal Information that we may receive from you includes:

Your name, email address, and password;
Other contact information, including a physical address and phone number;
Lease application information;
Information about your spouse;
Your payment and billing information;
Information or feedback you provide in communications with us, such as through our Website or via social media, email, or text messages;
Your transactions with us.

If you provide us with any Personal Information relating to another individual, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

2.2. Online Activity Information. We collect technical and device-related information through our Website and third party analytics tools we use (collectively, "Online Activity Information"). Sometimes Online Activity Information can be associated with your Personal Information. If any statutes, regulations, and any other laws that apply to the Services establish that Online Activity Information constitutes Personal Information, and such applicable law applies to information we collect from you, then we will treat the Online Activity Information as Personal Information.

2.3. Anonymous Information. In addition to Personal Information, we may also have (i) information that does not identify you or your devices, and (ii) de-identified Personal Information that no longer identifies you (collectively, "Anonymous Information"). Information that meets either of these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information. We use Anonymous Information for our business operations, for example, to improve our Services. Because Anonymous Information does not include Personal Information, any Anonymous Information is not subject to this Privacy Policy, including the rights and obligations associated other types of information that we collect about you, such as Personal Information.

2.4. Disclosing Personal Information Where it is not Specifically Requested. If we have not specifically asked for your Personal Information in a particular portion of an online form or submission area on a paper form, then you should not provide any Personal Information in that portion of the form or submission area.

3. How We Collect Personal Information. As set out in this Section 3 (How We Collect Personal Information), we may collect information at different points when you use our Services (for example, when you request information, submit housing applications to us, or apply for jobs through our Website), including when you fill out a housing application or submit a maintenance request. In some instances, we may also receive information about you from third parties, such as our service providers.

3.1. Account Registration; User Names. In order to access information, products, and services on our Website that are limited to registered users, we require that you complete a registration form. This form asks for certain Personal Information.

3.2. Website Visitors. As a Website visitor, you decide whether to provide us with your Personal Information. We allow you to visit our Site and review other information about our Services without revealing your identity or otherwise providing Personal Information. In that case, the only information that we collect from your visit will be Online Activity Information or Anonymous Information.

3.3. Contacting Us. You can contact us with questions or comments using the contact methods available on our Website, using the information provided in Section 16 (Contact Us), or submitting a written request to us. In order to communicate with us, you must provide certain Personal Information. We may use Personal Information and other information submitted to provide you with the information, products and services (such as housing services and maintenance services) that you have requested. For example, as the occupant of a home in one of our communities, you may submit a maintenance request through our Website or in person, and we use the information you submit to provide the requested service.

3.4. Employment Applications; E-Verify. In the employment section of our Website and through other public job postings, we may invite you to apply for employment opportunities with us by submitting your Personal Information, employment information, resume and other, similar kinds of information. Regardless of the method you choose to submit your employment application to us – for example, if you send us an employment application by email – we will treat the Personal Information you provide to us in such application as if you provided such Personal Information to us via our Website. Because we receive a large volume of applications, we do not guarantee that we will contact you after you submit an employment application. Additionally, it may be necessary or advisable for us to use Personal Information to verify employment eligibility through the E-Verify system.

3.5. Verifying Identity. When you request a product, service, or information from us, we may use Personal Information (and other information that we have about you) to verify your identity and to process your request. This is designed to further protect you and to reduce the threat of identity theft and fraudulent transactions.

3.6. Promotions; Submitted Content. We believe that your experiences with us can often act as the strongest promotion for our products and services. To promote and illustrate our products and services, we may wish to post on our Website, or elsewhere, endorsements from, or other descriptions of experiences by, you, as well as comments, feedback, and other information that you wish to share (collectively, "Submitted Content"). You agree that we may use and adapt your Submitted Content (including, but not limited to, your name, military rank (if applicable), state of residency, experiences with us, and other provided feedback) for these purposes and without the need for compensation. Please review our Terms of Use for more information on how we treat Submitted Content. We are not responsible for Personal Information you decide to include in Submitted Content, and we will not take down, remove, or edit Submitted Content, except as required by applicable law.

3.7. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, e-newsletters, and other information to you using provided Personal Information. For example, we may send you information that we believe is relevant to them, including information about severe weather, neighborhood watch advisories, AMBER Alerts, and surveys, all via email, automated voice messages, and SMS text message. In certain circumstances we or our Vendors may ask you to further confirm their consent to receiving these communications. You may also incur, and shall be responsible for, all messaging and data fees charged by their service providers (such as their wireless carriers) in connection with their receipt of these communications. You may opt out of receiving these communications as provided in Section 9 (Your Choices Regarding Your Personal Information; Opting Out), provided, however, that there are certain communications for which you cannot opt out. Please refer to Section 9 (Your Choices Regarding Your Personal Information; Opting Out) for more details.

3.8. Surveys. We may initiate surveys on our Website, through the mail, or by other means, and we may request Personal Information from you in connection with such surveys. You are free to choose whether you participate in this type of survey. Survey information will be used for purposes of monitoring or improving the use and appeal of our Website, improving our homes and services, or for other business purposes.

3.9. Personal Information Received from Third Parties. We may receive information from third parties such as advertising and marketing partners, public databases (e.g., National Change of Address records), and social media platforms, to supplement the information we have about you. If we do so, this Privacy Policy governs how we can use that information.

3.10. Collection of Personal Information Offline. We may ask you to provide us with Personal Information via offline interactions, such as during a resident move-in inspection. Personal Information may include, for example, your name, address, email address, and other identifying information. If you provide information to us at our request, then we will strive to provide you with either verbal and/or written notice of this Privacy Policy upon your request for a copy of the Privacy Policy. We treat any information that you provide to us as Personal Information under this Privacy Policy.

3.11. Other Uses. In addition to the uses specifically identified in this Section 3 (How We Collect and Use Personal Information), there may be instances where you request information, products, and services from us that are not described in this Privacy Policy. We will use Personal Information that you submit in order to provide such information, products, and services.

4. How We Collect Online Activity Information and Anonymous Information. We collect Online Activity Information and Anonymous Information to analyze the effectiveness of our Website, to improve our products, services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our services and the characteristics of visitors to our Website, and may share this information with third parties, including advertisers. We may collect Online Activity Information and Anonymous Information through features of the software that supports our services, such as cookies or other means described below.

4.1. IP Addresses; Logs. Either directly, or through our hosting service provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used and for security and monitoring purposes.

4.2. Cookies. A cookie is a small amount of data, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website on a future visit. For example, we may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies. Cookies must be enabled on your web browser, however, you may need to enable cookies if you wish to access certain personalized features of our services.

4.3. Tags.We may use so-called "pixel tags" – small graphic images (also known as "web beacons," "single-pixel GIFS," or "Web bugs") – for purposes such as: (i) to tell us what parts of our Website have been visited; (ii) in connection with advertisements we may include on the Website; (iii) to measure the effectiveness of searches you perform on our Website; and (iv) for other purposes. Pixel tags also enable us to send email messages in a format that you can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users and others. These technologies provide us with Anonymous Information, Online Activity Information, and, in certain instances, Personal Information.

4.4. Click Throughs. We may send email messages which use a "click-through URL" linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications.

4.5. Computer Configuration. We may collect certain Anonymous Information in order to determine whether your computer is supported by our system. This information includes, but may not be limited to, your operating system and browser, the presence of any software that our Website may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.

5. How We Use the Information We Collect

We use the information we collect or process, including Anonymous Information, Online Activity Information, and Personal Information, as permitted under applicable law and consistent with the terms of this Privacy Policy. More specifically, we use the information that we collect for the following purposes:

To provide you with the Services you request (on the Website, by phone, in person, or otherwise) including, for example, to process your housing application, to provide maintenance services, and to provide you with other services that we make available in our communities;
To allow you to post Submitted Content, such as photographs and other reviews, and participating in surveys and questionnaires;
To respond to your inquiries;
To customize and enhance your use of our Services;
To provide communications that might interest you, including marketing messages and to inform you of products and services that we think would be appealing to you, whether the products or services are provided by us or by others, and whether the products or services are available via our Site or via a third party;
To verify your identity and to securely process requests for Services;
To perform analytics, quality control, market research, and to determine the effectiveness of our Services;
To perform internal administration, auditing, operation, and troubleshooting for our Services; and
To share the information with third parties strictly as permitted in Section 8 (How We Share Your Information) below.

In addition to those uses specifically identified above, there may be instances where you request Services from us that are not described in this Privacy Policy. In our discretion, we can use any information that we have about you in order to provide such information and Services to you.

6. Treatment of Combined Information.To enable us to better understand the characteristics of our customers and/or to provide Services tailored to your needs, we may link your Personal Information with Online Activity Information associated with you or other Anonymous Information. If Online Activity Information or other Anonymous Information is ever associated or combined with your Personal Information (such as a name or email address), we will treat it as your Personal Information subject to the terms of this Privacy Policy.

7. Other Essential or Internal Uses of Information. We may also use information we collect as we believe to be necessary or appropriate for certain essential purposes, including:

To comply with applicable law and legal process;
To respond to requests from public and government authorities;
To detect, prevent, or investigate potential security incidents or fraud;
To facilitate the functionality of the Website;
To enforce our terms and conditions;
To protect our operations or those of our affiliates;
To protect our rights, privacy, safety or property, security and/or that of our affiliates, you, or others; and
To allow us to pursue available remedies or limit the damages that we may sustain.

8. How We Share Your Information. .We will not disclose Personal Information about you to third parties without express consent, except in the circumstances specified below.

8.1. Corvias Vendors. We employ other companies to perform functions on our behalf, such as providing services related to our products and Services, maintaining, developing, and hosting the Website, collecting information, responding to and sending electronic mail and other communications (including, but not limited to, those described in Section 3.7 (Informational Notices and Bulletins)), or other functions necessary to our business (collectively, the "Vendors"). We may share Personal Information with our Vendors so that they can provide the services that we request from them. We will only provide Vendors with information necessary to perform their functions, and we will not allow them to use Personal Information for any purpose inconsistent with this Privacy Policy. We require that our Vendors agree contractually to comply with privacy laws and to maintain protections for Personal Information that are consistent with this Privacy Policy. We may share Online Activity Information with our Vendors or other third parties that provide cookies, pixel tags, or other similar technologies for use on our Website to manage and improve our Services and marketing activities.

8.2.Government Regulators. We are periodically required to disclose Personal Information to third parties, such as credit reporting agencies, and federal and state regulators, in order to do business with you.

8.3. Military Personnel. We disclose Personal Information to the United States Military as the military requires, in accordance with our reasonable interpretation of applicable law, or as necessary to provide the products and services that we have agreed to supply as part of our contracts with the military. We will not disclose more information than is necessary to comply with these obligations.

8.4. Affiliates. In order to provide you with valuable product and service offerings, we share Personal Information with our affiliates. Our affiliates will be subject to the terms of this Privacy Policy.

8.5. E-Verify System. We will comply with the E-Verify program where applicable. Accordingly, it may be necessary or advisable for us to disclose Personal Information you to the federal government.

8.6. Questions of Harm Legal Process. We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigators, where it is necessary, or where we have a good faith belief that it is necessary:

To comply with legal process;
To protect and defend our rights and property, including the Website, other Services, and associated content;
To protect against misuse or unauthorized use of our Website, other Services, and associated content;
To protect the personal safety and property others or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

8.7. Corporate Transaction. We may transfer to a third party all of the information that we have collected, including any Personal Information, in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). In

9. Your Choices Regarding Your Personal Information; Opting Out.

9.1. Unsubscribing to Marketing Communications. If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, then you can opt out of this Service by either (i) following the "unsubscribe" instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 16 (Contact Us).

9.2. Discretionary Account Information. To allow appropriate control over Personal Information, you can view, change, or update discretionary information that you have previously submitted either by contacting us as provided in Section 16 (Contact Us) below or by accessing your account on our Site (if such functionality is available to you).

9.3. Access, Deletion, and Do-Not-Sell Requests. CORVIAS IS CURRENTLY IMPLEMENTING INTERNAL CHANGES TO FULFILL REQUESTS SUBMITTED UNDER THIS SECTION 9.3 (Access, Deletion, and Do-Not-Sell Requests). UNTIL SUCH CHANGES ARE COMPLETED, CORVIAS MAY NOT BE ABLE TO FULFILL CERTAIN REQUESTS. CORVIAS WILL NOTIFY THOSE MAKING A REQUEST IF SUCH REQUEST IS IMPACTED BY ONGOING INTERNAL CHANGES. PLEASE NOTE THAT THESE REQUESTS MAY ONLY BE AVAILABLE TO CALIFORNIA RESIDENTS AT THIS TIME.

We provide the following additional rights with respect to your Personal Information:

9.3.1. Copy of Personal Information. You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you.

9.3.2. Deletion of Personal Information. You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected.

9.3.3. Do-Not-Sell Requests. You may request that we do not share your Personal Information with third parties to be used for purposes not described in this Privacy Policy. The California Consumer Privacy Act refers to this as a "Do Not Sell" request. Corvias only shares Personal Information with Vendors and others described above for purposes identified in this Privacy Policy, but Online Activity Information or Anonymous Information collected by Vendors providing pixels or other third party technologies on our Website could potentially be used by those Vendors for their own purposes, some of whom may be able to associate such information with you based on other information they have collected independently (not from Corvias). We will endeavor to block such sharing upon request.

9.3.4. Submission of Requests. You can submit any of these requests by clicking here: Information Requests, by contacting us at 1-866-937-3777, or by visiting us at one of our offices. You may authorize another person (your "Agent") to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it. Please be advised that these requests are unrelated to an opt-out of marketing communications, which can be done as provided in Section 9.1 (Unsubscribing to Marketing Communications) above.

9.3.5. Response to Requests. Please be advised that Corvias will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please contact us as provided in Section 16 (Contact Us).

10. Accuracy and Minimization of Data; Data Retention. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information. We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (a) the duration of our relationship with you; (b) the existence of a legal obligation as to the retention period; and (c) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

11. How We Safeguard the Information We Collect. We have implemented security measures and other safeguards designed to prevent unauthorized access to, or disclosure of, Personal Information that you provide to us. Corvias' employees are directed to respect the confidentiality of individuals' Personal Information. Additionally, we direct affiliates and Vendors to implement security measures and handle Personal Information in a manner consistent with this Privacy Policy. Access to Corvias' databases containing Personal Information is restricted to a need-to-know basis. Our security measures and other safeguards are aimed at deterring and preventing hackers and others from unauthorized access to information that you provide to us. We also monitor network traffic for unauthorized attempts to access or change information, or otherwise cause damage to our systems or Personal Information we maintain. However, due to the nature of internet communications and information technology, we cannot provide, and expressly disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

12. Website Participation by Children and Teens; Advisory. Our Website is not directed at children and we will not accept or request Personal Information from individuals that we know to be under 13 years old. If you are between 13 and the applicable age of majority, please review this Privacy Policy with your parent or guardian.

13. Notice of Privacy Rights to California Residents. The following provisions of this Section 13 (Notice of Privacy Rights to California Residents) apply if you are a California resident.

13.1. Shine the Light Law. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.

13.2. California Consumer Privacy Act. Corvias makes the following disclosures regarding the California Consumer Privacy Act:

13.2.1. No Financial Incentives. Corvias does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send promotions and other offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or "Do Not Sell" request has been submitted. Corvias does not offer financial incentives to deter customers from making such requests. Corvias will not discriminate against any customer for exercising their privacy rights, including those provided by applicable law.

13.2.2. Customer Reporting. Corvias will endeavor to report customer request metrics when they become available.

13.2.3. Job Applicants. If you are a job applicant submitting Personal Information to Corvias in connection with an application for employment, you will be provided with a privacy notice regarding how we handle such information as part of the application process.

13.2.4. Questions. If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 16 (Contact Us).

14. Notification of Changes. From time to time, we may update our Privacy Policy for our business purposes and to comply with changes in applicable law. If we make any substantive or material changes to our Policy, we will post the new Policy via the privacy link on our Website, notifying you of the change via the Website, email, or other methods, and/or make the new Policy available in paper-form upon request. Your subsequent acceptance of the Privacy Policy pursuant to Section 1 (Your Consent) constitutes your agreement to be bound by the Privacy Policy, as updated.

15. Feedback. If you have a suggestions on how we can improve or issues and concerns that you would like us to address, please contact us as set out in Section 16 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state's consumer protection authority.

16. Contact Us. If you have any questions about this Privacy Policy or our practices, please contact us at: privacy@corvias.com.

17. Relationship to Other Contracts and the Terms of Use.This Privacy Policy must be read in conjunction with any agreement entered into by you and us that references this Privacy Policy or that otherwise relates to Personal Information (collectively, the "Other Contracts") as well as our Terms of Use. The provisions of our Terms of Use are incorporated herein. To the extent that the Terms of Use conflict with this Privacy Policy, this Privacy Policy shall control. To the extent that the Other Contracts conflict with this Privacy Policy or the Terms of Use, the Privacy Policy shall control with respect to our treatment of Personal Information.

18. Third Party Sites; International Considerations. Our Site may link to (or be linked from) another website, mobile application, social media platform, or other online service. We have no control over such third parties and are not responsible for the content, availability, or security of such linked third party websites, so please read the privacy policies of such third party websites carefully. Third parties may use your information for their own purposes, including behavioral or advertising purposes. The inclusion of a link on our Site to a third party does not necessarily imply endorsement of the third party website or its products or services, and is provided for your convenience only. If you decide to access any of the third party websites linked to our Site, you do so subject to the terms and conditions of use for such third party websites. Any Personal Information that you provide through a third party website, mobile application, social media platform, or other online service will be subject to the privacy policy of its operator and not this Privacy Policy. Our Services are primarily intended for use within the United States. While our primary data centers are in the United States, we may transfer information outside of the United States. In addition, we may employ Vendors, other companies, and other individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to our employees outside of the United States, then we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy. By providing your Personal Information, you consent to any transfer and processing in accordance with this Privacy Policy and understand that we operate under applicable laws within the United States.

19. Do Not Track Notice. Our Website does not change its behavior when receiving "Do Not Track" signals from browser software, and handles all Personal Information consistent with this Privacy Policy.

20. Effective Date. The effective date of this Privacy Policy is December 20, 2019.

#71876309_v5