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LINCOLN PROPERTY MANAGEMENT PRIVACY POLICY

Effective: January 1, 2020

Last Reviewed: January 2, 2020

Welcome to the Lincoln Property Management Privacy Policy (the “Policy”). For purposes of this Policy, the terms “Lincoln” “we,” “us,” and “our” refer to Lincoln Property Management, LPC Multifamily Holdco LLC, LMH Holdings LLC and all of their respective affiliates, subsidiaries, parents, members, and managers. “You” or “your” refers to you, as a user of our services, including any use of our websites, and software applications, whether operated by us or on our behalf (“Services”). It is important that you read this Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing your Personal Information so that you understand how and why we are using your data. This Policy supplements those other notices and is not intended to override them.

This Policy describes:

• Personal Information We Collect

• How We Collect Your Personal Information;

• How We Use Your Personal Information;

• How Share Your Personal Information With Third Parties;

• How We Protect Your Information

• California Privacy Rights

• Changes to the Policy; and

• Questions About This Policy

PERSONAL INFORMATION WE COLLECT

“Personal Information,” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.

We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

• Identifiers such as first name, maiden name, last name, alias, username or similar unique personal identifier, account name, online identifier, social security number, driver’s license number or other government ID, date of birth, mother’s maiden name, marital status, and identifiers for family members.

• Contact Information such as current address, previous address, billing address, email address, telephone numbers, and emergency contact information and relationship.

• Financial Information such as bank account number, routing number, credit or debit card number, and payment details.

• Commercial Information such as details about payments to and from you, other details of products and services you have purchased from us, or payment history.

• Professional or Employment-Related Information such as your current employer, salary and employment status.

• Vehicle Information such as the type, make, model, year, color, and license plate number for you and any family members living with you.

• Pet Information such as the name, type, breed, color, weight, age, license number, vet information, vaccination and rabies shot records, microhip details for any family pets.

• Audio, electronic, and visual information such as call and video recordings.

• Technical Information includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.

• Usage Data includes information about how you use our Services.

• Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.

Information You Provide To A Third Party. The Services may include links and plug-ins to websites operated by third parties such as Twitter, Facebook, and Instagram buttons (“Third-Party Sites”). Lincoln does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by the privacy policy of such third parties. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.

Children’s Privacy. The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. To the extent that we receive Personal Information of a child under 13 from their parent or guardian, we do not sell this information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect Personal Information from a variety of sources and methods. This includes:

Information You Voluntarily Provide to Us

You may give us your Personal Information by filling in forms, filling out a rental application or lease, or by corresponding with us by post, phone, text, email or otherwise. This includes Personal Information you provide when you:

• Submit a Request for Information form or Guest Card

• Submit a contact form

• Call, email, or text us

• Fill out a rental application

• Sign a lease

• Create an account on our Resident Portal

• Request maintenance or repair services

• Order or purchase other products and services

• Attend our events where we collect information about you

• Submit a review or testimonial

Information We Collect When You Use Our Services

Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Cookies. Cookies are small files that we or our service provider transfers to your computer’s hard drive through your web browser that enables us or our service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Services. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. For more information about cookies and about turning off cookies, please see: http://www.allaboutcookies.org If you turn off your cookies, some of the features of the Services may not function properly.

Information We Collect From Third Parties

We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Third Party Service Providers. We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as online application submission and management platforms, email platforms, and social media platforms.

Third Party Advertising Partners. We collect Personal Data received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles Aggregate Data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.

Third Party Cookies. We may engage third-party service providers, including Google, Facebook, and Instagram to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. You can learn more about Google’s advertising cookies and opt-out options by visiting http://www.google.com/policies/technologies/types/. You can learn more about Facebook’s advertising cookies and opt-out options by visiting https://www.facebook.com/policy/cookies/. You can learn about Instagram’s advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including the Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

HOW WE USE YOUR PERSONAL INFORMATION

Our primary purpose for collecting Personal Information is to provide you with products and services you request. We may also use your Personal Information for the following business purposes:

• To provide you with information, products and/or services you request

• To process rental applications

• To run credit checks in connection with your rental application

• To generate leases for our tenants

• To manage our properties and our customer relationship with you

• To communicate with individuals in written, electronic, and verbal form

• To provide maintenance and repair services

• To obtain payment for services that we provide to you, including your rental payments

• For our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you

• To customize the advertising and content you see

• For internal business purposes such as complying with our internal policies or improving our Services

• To analyze how our Services are being accessed and used

• To verify information

• To protect our interests, including establishing, exercising and defending legal rights and claims

• As necessary to comply with legal requirements, to enforce our lease terms, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities

• For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy

HOW WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES

We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Services and perform any contract we enter into with them or you.

Information You Instruct Us to Share. You may be presented with an option on our Service to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

Service Providers. We may use third-party service providers to perform certain business services on behalf of us or the Service, and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, maintenance and repair services, hosting services, software as a service, document management services, communications services such as email, text, and chat services, software and website development services, collection services, accounting and audit services, compliance services, quality control services, analytics services, call center services, housing services, marketing services, employment and employment verification services.

Internal Third Parties. We may share Personal Information with our parent company, subsidiaries and other companies owned by or controlled by Lincoln who may use the Personal Information for the purposes described above.

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Sales of Personal Information. Like most companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our website, which is then associated with your browser or device. These companies may use this data to serve you more relevant ads as you browse the internet. Under some state laws, sharing data for online advertising may be considered a “sale” of information. Except for this limited sharing, Lincoln does not sell any of your information. Please note that these cookies will be temporarily disabled until we can implement an opt out management system.

HOW WE PROTECT YOUR INFORMATION

We endeavour to incorporate reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.

CALIFORNIA PRIVACY RIGHTS.

California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Upon verification of your identity you may:

o No more than twice in any 12-month period, request disclosure of the following information:

o Categories of Personal Information we collect.

o Categories of sources from which Personal Information is collected.

o Categories of Personal Information sold or disclosed to third parties.

o Categories of third parties with whom such Personal Information is sold or disclosed.

o Business or commercial purpose for collecting or selling Personal Information.

o Specific pieces of Personal Information we collect.

• Request deletion of your Personal Information, subject to the exceptions provided by law.

• Opt-out from having your Personal Information sold to third parties, if applicable.

Requests can be submitted by calling our toll free number (888-597-6599) or through our online request form.

Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Include your full legal name and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. In order to verify your identity, one of our representatives will call you at the phone number provided.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and Lincoln will not discriminate by: • Denying you goods or services.

• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Providing you a different level or quality of goods or services.

• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Other California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted via email to LincolnCCPASupport@lpsi.com and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address in order to process your request. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

CHANGES TO THIS PRIVACY NOTICE

Lincoln may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy. Where changes to this Privacy will have a fundamental impact on the nature of how we collect, use, or share your data, Lincoln will give advance notice of such changes.

QUESTIONS ABOUT THIS POLICY

For questions or comments regarding our Policy, please contact us at:

Email: corporate@lpsi.com

Phone: (214-740-3300)