Privacy Policy

What is personal information?

Personal information is:
(1) information in a consumer report; or
(2) an individual’s first name or initial and last name in combination with any of the following:
(a) birth date;
(b) social security number or other government issued identification number;
(c) mother’s maiden name;
(d) unique biometric data (fingerprint, voice print, retina image);
(e) unique electronic identification number our routing code;
(f) telecommunication access devices including debit or credit card information; or
(g) financial institution account or information.

A consumer report is a report related to a person’s credit worthiness, credit standing, credit capacity,
character, general reputation, personal characteristics, or mode of living prepared by or obtained from
an agency that collects such information such as a credit reporting agency.
When completing the forms required above, the customer or client may send the information to this
company by mail, fax, personal delivery, or by e-mail. Customers or clients may occasionally provide
personal information to this company or its agents by other means such as telephone calls, fax
messages, or e-mail messages in order expedite a transaction in which the customer or client is
involved.

How is personal information collected?

This company obtains personal information in the following ways:
(1) in consumer reports from reporting agencies to which this company subscribes in
connection with lease applications.
(2) in lease applications a prospective tenant completes;
(3) in loan applications a borrower or buyer completes;
(4) in other real estate related forms the customer or client completes in or related to a
transaction; and
(5) in tax reporting forms that the customer or client is required to complete and which are
given to this company.

When completing the forms required above, the customer or client may send the information to this
company by mail, fax, personal delivery, or by e-mail. Customers or clients may occasionally provide
personal information to this company or its agents by other means such as telephone calls, fax
messages, or e-mail messages in order expedite a transaction in which the customer or client is
involved.

How and when is the personal information used?

Personal Information from Prospective Tenants: The personal information that prospective tenants
provide to this company is primarily used to obtain consumer reports (credit checks). It may also be
used to perform background checks and rental history searches. The information in the consumer
reports may be discussed with landlords for whom this company manages property. This company
also reports information to credit reporting agencies and uses personal information to complete those
reports.

Personal Information from Owners of Properties Managed by the Company: When this company acts
as a property manager for a property owner, the company uses the property owner’s personal
information only: (a) to deliver the required management services; (b) to file any required reports with
governmental agencies (for example, the IRS); or (c) for other purposes the property owner may
authorize.

Personal Information from Clients: When this company represents a person (buyer, seller, landlord, or
tenant) in a transaction the agent servicing the client may, on the client’s behalf and at the client’s
instruction, convey personal information he or she provides to the agent to service providers (for
example, mortgage lenders and title companies) as those service providers may require for the
products or services the client needs or requests. If this company represents a prospective tenant in a
lease transaction, the personal information may, on the tenant’s behalf and with the tenant’s
knowledge, be discussed with and provided to landlords or their agents. This company and its agents
exercise reasonable discretion when discussing any personal information with others.

How is the personal information protected?

Written files in this company are protected under lock and key.
Electronic records are protected under an access name and password assigned to persons in this
company.

This company and its agents exercise reasonable discretion when discussing any personal
information with others and releases personal information to others only as described by this policy.

This company does not permit its employees or agents to make copies of consumer reports or
records of insurance claims. The consumer reports retained in the company’s files are not to be
accessed in the future as a convenience to customers or clients.

The individual agents that work with this company are independent contractors and the agent with
whom a customer or client works with may maintain a separate transaction file. The company
instructs its agents to not permit other persons to access the personal information in files the agents
maintain. The company instructs its agents to protect the personal information in the agents’ files in
the same manner as described in this policy.

Who has access to the personal information?

The following persons have access to personal information in this company’s files:
(1) the agent, broker or employee who is servicing or coordinating the transaction;
(2) the office manager to whom the agent reports; and
(3) the owner of the company.

Property owners for whom the company manages properties do not have access to personal
information in the company’s files. However, the company and its agents may discuss the information
in a tenant’s consumer report or lease application with a property owner. Copies of such information
are provided to the landlord only: (1) with the tenant’s consent; or (2) if the company ceases to be the
property manager and the landlord requests that the files be sent to the landlord, the landlord’s
attorney, or the new property manager.

Personal information from a buyer, seller, landlord, or tenant may be discussed with others (such as
mortgage lenders or prospective landlords) only as is reasonably necessary to negotiate or close the
transaction or to provide the services the customer or client seeks from this company.
This company may, at the customer’s or client’s request, provide personal information to service
providers in a transaction such as a title company or mortgage company if it is necessary to expedite
or complete a transaction.

If the company is required by law to allow others to access the personal information in the company’s
files, the company will comply with the law (for example, compliance with court orders, subpoenas, or
governmental investigations). The company will also allow law enforcement agencies access to
personal information in order to cooperate with such investigations.

How is the personal information disposed?

This company uses reasonable measures to dispose of personal information. Personal information is
usually disposed of by shredding or burning documents, erasing electronic files by means that make
the files unreadable or undecipherable, or by eradicating personal information from documents or
electronic files in ways that make the personal information unreadable.

Erroneous Records:

If this company erroneously reports information to a consumer reporting agency, the company will act
to correct the information in the company’s records and request the reporting agency to correct the
information in its records promptly after the company has learned and determined that the report was
in error.

If this company maintains an erroneous record that a consumer has issued a dishonored check, the
company will promptly delete the record after the company and consumer agree that the information
is in error or after the consumer provides the company with a law enforcement agency report stating
that the dishonored check was not authorized.

Notice: This company asks any person who provides personal information to this company or
one of its agents to identify the information at that time as “personal information.”