The purpose of this policy is to outline some of our procedures relating to the confidentiality and security of sensitive personal information, including social security numbers, disclosed to us by prospective and existing residents. For the purposes of this policy, the term "sensitive personal information" shall mean an individual's first name or first initial and last name in combination with any one or more of the following items, if the name and the items are not encrypted: (i) social security number, (ii) drivers license number or government-issued identification number, or (iii) account number credit or debit card number in combination with any required security code, or password that would permit access to an individual's financial account. This term does not include publicly available information that is lawfully made available to the general public from the federal government or a state or local government.

1. Collection and use of sensitive personal information. When you apply to rent a unit in our community, we will ask you to disclose certain sensitive personal information on your rental application and possibly other lease documentation. This sensitive personal information will be used by us for business purposes including confirmation of your identify and determination of your eligibility for rental.

2. Protection and access to sensitive personal information. We will keep the sensitive personal information you provide to us in our files. If you become a resident in our community, we will keep the sensitive personal information in a resident file. If you do not become a resident, we will keep your sensitive personal information in a general file. Personnel with the owner and Management Company, if applicable, will have access to our files. We also reserve the right to disclose sensitive personal information in a manner allowed by law.

3. Disposal of records containing sensitive personal information. It is our policy to dispose of records that contain sensitive personal information by shedding, erasing, or by others means making the sensitive personal information unreadable or undecipherable.

4. Take corrective action. In the event that you experience identify theft or we discover that there has been unauthorized acquisition of computerized data that compromises the security, confidentiality, or integrity of sensitive personal information, as defined about, we will comply with all applicable law with respect to taking appropriate corrective action.

This policy has been designed to meet the requirements of applicable law with respect to the adoption of a privacy policy. Nothing contained in this policy shall constitute a representation or warranty of any type whatsoever that sensitive personal information will not be misplaced, duplicated, or stolen. No liability is assumed with respect to any such occurrences.