Redwood Communities Group, LLC ("us" or "Redwood") provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information received from users of this website located at (collectively the "Site").

1. Changes.

This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any material changes to our Privacy Policy. The changes shall take effect after we notify you about the changes.

2. Your Consent.

By using the Site, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing" means using cookies on a computer or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the U.S. your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By visiting our Site and providing information to us, you consent to such transfer to, and processing in, the US. In addition, by registering with and using the tenant portal system, you agree to the Terms of Use provided by our portal provider, Yardi Systems Inc. ("Yardi"), which provides the Rent Café website and mobile application (the "Tenant Portal"). The Yardi Systems, Inc. terms and privacy policy can be viewed here (the "Yardi Terms"). By using both this Site and the Tenant Portal, you consent to the processing of your information on the Tenant Portal by us.

3. Information Collection.

When you use the Site, you provide information about yourself. Depending on how you use the Site, such information that you provide to us includes: (a) your name, gender, email, address, or age (to comply with legal requirements); (b) your interactions with the Site; (c) information you provide to us when you contact us for help; (d) information you upload into our system when using the Site; (e) information you provide on a rental application when you apply to rent from Redwood, including full name, phone number, social security number, date of birth, driver's license number, present and past residence information, present and past employment information, credit references, eviction history, foreclosure or repossession history, bankruptcy history, criminal history, emergency contact information, other proposed occupant information, pet information, vehicle information, a scan of your driver's license or photo ID card, and pay check stubs; and (f) any additional information you choose to provide to us. You may choose to contribute to the content of the Site by submitting original written content, photographs, or other media to be used in articles on the Site.

Registration with the Tenant Portal is optional. However, please keep in mind that you will not be able to use the Tenant Portal unless you register. When you register with and/or use the Tenant Portal, you will share certain information with the Tenant Portal and us. Details about the information that is shared via the Tenant Portal can be found here.

When you browse our site, we also automatically receive your computer's internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. In addition, we collect certain information from the Site, which cannot be used to personally identify any user, and which may be provided to third parties. Such non-personal data ordinarily includes aggregate, summary, or other usage data, and may include, by way of example, statistics regarding total users, information regarding types of Internet browsers used by users, technical information about the device you use to access the Site, and Site usage patterns.

Email marketing (if applicable): With your permission, we may send you emails about our store, new products and other updates. If you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected]

4. Use of Information.

We may use your information from the site or Tenant Portal (a) to deliver the Site and features desired by you, (b) to improve our services to you, (c) to personalize content and offers that may be of interest to you, (d) to respond to your inquiries, (e) process your rental application, including contacting parties listed on the application and running a credit check, (f) to process rental payments from you, (g) fulfill service requests, (h) provide tenant and billing history, (i) provide you information about events at our communities, and (j) to fulfill your other request for products or services.

We may have other individuals or entities provide products or services for us in connection with the Site. These agents may access your personally identifiable information if needed to provide their service but will not be permitted to use such information for other purposes. These agents may include email service providers, credit check providers, spam control services, computer database hosts, analytics companies, fulfillment companies and other administrative service providers.

We will use your contact information to contact you from time to time to provide you with important information or required notices and for promotional and general interest emails sent directly by Redwood. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority or to protect our rights and property or the rights and property of the public. We may also cooperate with law enforcement agencies in any official investigation and we may disclose your personally identifiable information to the relevant agency in doing so.

5. Aggregate Data.

We track usage data from our Site and user traffic patterns throughout our Site to improve the content of our Site and the quality of our Site and allow our third-party affiliates to do the same. We may disclose such data and other information we collect from you in a non-personally identifiable manner to organizations approved by us that conduct research and to advertisers we allow to advertise on the Site. In no event will such information identify you personally unless you have given your prior consent.

6. Cookies.

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. We use cookies to help identify and track visitors, their usage of our websites, and their website access preferences. Redwood visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Site, with the drawback that certain features of the Site may not function properly without the aid of cookies.

7. Do Not Track.

The Site does not currently support Do Not Track protocols and will not respond to a Do Not Track header.

8. Children and Age of Consent.

Any user providing personal data is certifying that he/she is over the age of 18. Children under the age of 18 are not eligible to use our site. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected]. We will delete such information from our files.

9. Acquisition.

We reserve the right to transfer your personal information in the event of a transfer of ownership of Redwood Communities Group, LLC, such as an acquisition by or merger with another company. If an acquiring company should plan to materially change this privacy policy, we will notify you beforehand.

10. Accessing Your Personal Data.

Each user selects a unique username and password that enables their access to the Site. Users may access their account profiles at any time to update personal data contained within that account profile. Subsequent uses or disclosures of information by us will reflect those changes. Certain information is necessary in order for us to provide the services; therefore, if you delete such necessary information you may not be able to use the Site. In the event you desire to discontinue the Site and have your information removed from our systems, please send your request to [email protected].

11. Security.

Redwood is very concerned about safeguarding the confidentiality of your personally identifiable information. We require password protection and use physical, electronic, and procedural safeguards to protect personal information about you. We limit access to personal information about you to employees and authorized parties who need to know that information in order to operate, develop or improve our services. Please be aware that, although we endeavor to provide reasonable security for information in our possession and control, no security system can prevent against all potential security breaches, and we bear no liability for uses or disclosures of personal data or non-personal data arising in connection with the theft thereof. Likewise, you are responsible for safeguarding the confidentiality of passwords to the Site, and we bear no liability for access to, or use or disclosure of personal data if such access, use or disclosure arises in connection with the theft or disclosure (whether intentional or negligent) of such user's password.

12. How to Contact Us.

If you have any questions or concerns about this Privacy Policy or its implementation, or if you believe there are inaccuracies in your account information you may contact us as follows:

Redwood Communities Group, LLC

7510 East Pleasant Valley Rd

Independence, Ohio 44131

Email: [email protected]

Last Updated: July 2018

4852-0828-3415, v. 1


PRIVACY POLICY

PRIVACY POLICY

This privacy policy (the “Privacy Policy”) describes our company’s (“Company,” “we,” “us,” or “our,”) privacy practices regarding information we collect from persons or entities (“you” or “your”) who access our property’s RENTCafé Resident Portal website or our related mobile applications that may be available for download (collectively, the “Site”). To access the Privacy Policy of RENTCafé, please visit: https://www.rentcafe.com/apartments/privacypolicy.aspx.

PURPOSE. The purpose of this Privacy Policy is to inform you about the types of information we gather about you, including information gathered when you visit the Site, and information we may receive from third parties or affiliates in addition to that online information, how we may use that information, whether we disclose that information to anyone, and the choices you have regarding our use of, and your ability to correct, the information. Company strives to help visitors of the Site protect their privacy while using our Site.


THE SITE IS NOT INTENDED FOR CHILDREN AND COMPANY DOES NOT KNOWINGLY SOLICIT OR COLLECT PERSONAL INFORMATION ON THE SITE FROM CHILDREN UNDER THE AGE OF 13. IF COMPANY LEARNS THAT A CHILD UNDER THE AGE OF 13 HAS SUBMITTED PERSONALLY IDENTIFIABLE INFORMATION TO COMPANY THROUGH THE SITE, IT WILL TAKE REASONABLE MEASURES TO DELETE SUCH INFORMATION FROM ITS RECORDS AND TO NOT USE SUCH INFORMATION FOR ANY PURPOSE (EXCEPT WHERE NECESSARY TO PROTECT THE SAFETY OF THE CHILD OR OTHERS, AS REQUIRED BY LAW, OR AS MAY OTHERWISE BE REQUIRED BY LAW).


YOUR CONSENT AND POLICY CHANGES. PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE COLLECTION, USE AND DISCLOSURE OF INFORMATION, INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE SITE

Company may amend this Privacy Policy from time to time. Should the Privacy Policy be modified in any way, the new Privacy Policy will be posted to this webpage. As we may make changes from time to time without notifying you, we suggest that you periodically review the Privacy Policy. By using the Site after the effective date of any modification to the Privacy Policy, you expressly consent, without qualification, to the collection, use and disclosure of information, including Personally Identifiable Information (that you previously provided or later provide), as described in the new Privacy Policy.


TYPES OF INFORMATION COLLECTED. We collect two types of information: personally identifiable information and non-personally identifiable information. Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”). We also may collect information that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data, information about you such as how you use the Site and your communication preferences, and other anonymous statistical data involving the use of our Site (“Non-Personally Identifiable Information”).

Personally Identifiable Information we collect may include, but is not limited to: your name, email addresses, postal addresses, postal codes, user Internet Protocol (IP) addresses, social security/insurance number, driver’s license number, prior addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, user name and password (if you choose to become a registered user of the Site or our products and services), emergency contact information, information about your pets, information about your vehicles including license plate numbers, and other information either desirable or necessary to provide quality services to our customers and visitors. We may also collect information about you such as your use of the Site and communication preferences.

You may choose not to provide your Personally Identifiable Information by not entering it on the Site; however, you will not be able to use certain services and features if those services and features require Personally Identifiable Information in order to function.


USE OF COOKIES AND OTHER TECHNOLOGIES. Like many other website operators, Company may use cookies to customize content specific to your interests and track your use of the Site. “Cookies” are text files that are placed on your computer and may be used to store your personal information. In addition to cookies, Company may use other now known or later developed technologies, to assist Company in observing the behavior of users visiting the Site. These technologies access individual user information but the information is used only to compile aggregated statistics about the Site’s usage.

This Site uses Google Analytics (and in the future may use other similar sites or services), a web analytics service provided by Google, Inc. (“Google”), to better assist Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for Company’s use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. The use of cookies by Google Analytics is covered by Google’s privacy policy: https://www.google.com/policies/privacy/.

You can choose to delete existing cookies, allow or block all cookies, and set preferences for certain websites in your browser’s settings. Please note you may not be able to use the full functionality of the Site if you choose to block all cookies.


HOW WE COLLECT AND USE INFORMATION. We may collect information in several ways by your use of this Site, as well as from forms you submit to us, personal correspondence, such as emails or letters that you send to us, information you include in an application you complete on the Site, information you provide when scheduling a property visit through the Site, or any other activity through which you identify yourself to us. When you visit the Site, our servers may log your IP address, the URL of your request and other information that is provided in the HTTP header. We may also ask you to voluntarily provide us with personal information on this Site. For example, while many of the features of the Site are available without registering, you may be asked to create an account on the Site if you desire to access certain features. Further, in some instances, we may ask you to provide personal information in order to perform screening services. Although you may decline to voluntarily provide Personally Identifiable Information when asked, some features, products and services will be unavailable to you as a result.

Company may use the information collected from you to provide services which you have requested from us, including, without limitation, enabling you to use the Resident Portal. We may also use your personal information to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits.


EMAIL MANAGEMENT. You may receive emails from Company for a variety of reasons. We respect your desire to manage email correspondence. If you have an account with Company on the Site, you can select your preferences through your account settings. You can also manage your receipt of certain types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.


SHARING OF INFORMATION COLLECTED. Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any information we gather from you on our Site.

We may share with third parties, including, without limitation, our corporate partners, aggregated demographic and statistical information that is not personally identifiable.

Company may also disclose an individual’s personal information:

  • to a person who in the reasonable judgment of Company is seeking the information as an agent of the individual;
  • in situations where sharing or disclosing your information is required in order to offer you products or services you desire;
  • to a third party or parties, where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process;
  • if, in the reasonable judgment of Company, it is necessary to enforce compliance with our internal policies or the Terms of Use, to prevent illegal activity or suspected fraud, or to protect our Site, customers, or others; and
  • to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of Company’s assets.

Company may be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena/summons. We also may disclose such information in response to a law enforcement agency’s request.


HOW WE STORE YOUR INFORMATION. Company is committed to protecting the security of any personal information you provide to us. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. In spite of these protections, Company cannot guarantee the security of any data submitted over the Internet. After your information reaches Company, however, it is protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process your personal information in the United States or Canada or any other country in which we or our agents maintain facilities. By using the Site, you consent to the transfer of your information among these facilities, including those located outside your home country.


THIRD-PARTY WEBSITES. This Privacy Policy applies solely to information collected by Company. This Privacy Policy does not apply to other websites that are accessible through this Site, including but not limited to any third-party websites.


DATA RETENTION. In order to provide you with the products and services you request, answer questions you may have about the products and services provided, and for our own accountability to external regulatory bodies, we retain your information for a period deemed reasonable under the circumstances. Information stored is removed, destroyed, or deleted from time to time when it appears we will no longer have a need to contact you. Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law.


ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION. You can see, review and change most of your personal information by logging into your account on the Site and editing your Account Profile or by contacting us at the addresses below. If your personal information changes or is inaccurate, you must change it promptly.

There may be circumstances where your personal information is not accessible, reviewable or able to be modified by you through your account. With some exceptions, you have the right to see what personal information we hold about you. We can help you identify what records we might have about you and we will also try to help you understand any information you do not understand. We may need to confirm your identity before providing you with this access, and we reserve the right to charge a nominal fee for such requests. In some cases, we may require that your request to us for access be made in writing. If we cannot give you access, we will tell you within 30 days or as soon as reasonably practicable and provide you with a reason, as best we can, as to why we cannot give you access.


RIGHTS OF INDIVIDUALS. Site users who wish to correct, update, change, or erase the information they submit on the Site should be able to go back to the applicable web form or their account to edit their user or organization record. For additional information or problems accessing your information from such page, please contact Company using one of the methods listed below.

If you consider that we have processed your personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.


CONTACTING US.

If you have questions regarding this Privacy Policy or the use of information collected, please contact your property manager.


Canada. To the extent it is applicable, this policy is made under the Personal Information Protection and Electronic Documents Act. There are some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

Address: 112 Kent Street, Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: (800) 282-1376
Facsimile: (613) 947-6850
TTY: (613) 992-9190
Website: www.priv.gc.ca/en/


Updated: June 17, 2019