Fairfield Privacy Notice

Effective Date: March 2024

This is the Privacy Notice of Fairfield Residential Company, LLC, FF Properties L.P. and their respective subsidiaries and affiliates (collectively, "Fairfield", “we”, “us” or “our”). This Privacy Notice applies to our websites, including fairfieldresidential.com and any other website or mobile app that links to this Privacy Notice. This Privacy Notice also describes our other interactions with you in which we provide you with a link to this Privacy Notice, such as when you fill out a rental application or job application. The services that we may provide to you that are subject to this Privacy Notice are referred to below as our “services.” Please read this Privacy Notice carefully to understand how your personal information is collected, used and disclosed by Fairfield in connection with our services.

Please refer to the Additional United States Privacy Disclosures below for additional disclosures that may be applicable to you.

Please note: this Privacy Notice does not address our privacy practices relating to Fairfield personnel or to individuals whose personal information is provided to us by Fairfield personnel in the employment context, such as emergency contacts and designated beneficiaries under Fairfield’s employee benefits programs. For more information about Fairfield’s privacy practices with respect to its personnel and related persons, please contact HR@ffres.com.

This Privacy Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law.

I. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

The categories of personal information we collect depend on how you interact with us and our services. For example, you may provide us your personal information directly when you sign up for our mailing list, register for an account, submit a rental application or job application, schedule a property tour, post a review, or otherwise contact us or interact with us, including through any automated live chatbot available on our website.

We also collect personal information automatically when you interact with our websites and other services and may also collect personal information from other sources and third parties.

a. Personal Information We Collect Directly From You

We collect the following categories of personal information individuals provide us:

• Contact Information, including first and last name, mailing address, phone number, and email address. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Rental Application Information, including your name, date of birth, driver’s license, passport or other photo ID details, professional and employment information, and information about your income, disability and other protected classifications. We use this information primarily to evaluate your housing application, communicate with you, and comply with our legal and regulatory obligations, including to determine your eligibility for certain housing programs where permitted or required by law.
• Resident-Related Information, including security camera footage of you, resident portal account credentials and profile information, rent payments, insurance coverage, vehicle make, model and license plate, utilities usage, package delivery and locker usage, and your use of “smart” keys, IoT devices and other building amenities. We use this information to provide our services including our property management services and to maintain security at Fairfield communities.
• Job Application Information, including, if you fill out a job application, your name, email address, phone number and other contact information as well as information about your professional and educational background. We use this information to evaluate your eligibility and to communicate with you.
• Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). We use this information primarily to process your rent payments.
• Promotion and Survey Information, including information provided when you enter a promotion, complete a survey, or submit a testimonial. We use this information primarily to administer and facilitate our services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business, and facilitate the related promotion or survey.
• Communications Information, including information that you communicate to Fairfield or Fairfield representatives, and information and user content you submit in online portals or chats, such as in an online marketplace on one of our resident portals. Please note that your communications with us may be monitored and recorded. For example, if you call us by phone or interact with one of our virtual online leasing agent chatbots, we may record the conversation for quality assurance or other purposes described in this Privacy Notice. We use communications information primarily to investigate and respond to your inquiries, to communicate with you, and to improve our services. Specifically with regard to chatbot communications, at your direction the conversation data will also be shared with the third parties that run the virtual leasing assistant chatbots on our behalf. These third parties may use this data to improve the quality of the services they provide to prospective Fairfield residents.
• Sensitive Information, including, where permitted by law, information relating to racial and ethnic origin, mental or physical health diagnosis, citizenship or immigration status, and precise geolocation. For more information about our privacy practices with regard to sensitive information, please refer to the Additional United States Privacy Disclosures below.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. Note that if you choose not to provide us with certain information, we may not be able to provide certain of our services to you or process certain of your requests. We may provide additional privacy disclosures where the scope of the request we receive or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

b. Personal Information Collected Automatically

We and our third-party partners automatically collect information you provide to us and information about how you access and use our services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We primarily use this information to enhance and personalize your user experience and to monitor and improve our services. In some instances, we and our third-party service providers may combine this usage information with the personal information described above. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, to recognize and contact you (where permitted) across multiple devices.
• Information About the Way Individuals Use Our Services and Interact With Us,including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our services or engage in chat features or other communication platforms we provide.
• Information About Your Location, including general geographic location that we or our third-party providers may infer your location based on IP address or other information, as well as more precise geolocation when you grant us access through your device settings.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our services; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below. For additional details about the cookies we use on our websites and to adjust your preferences with regard to those cookies, please click the cookie icon or visit the “Your Privacy Choices” cookie link in the footer of our websites.

c. Personal Information from Other Sources

We may receive the same categories of personal information as described above from the following sources and other parties:

• Our Affiliates: We are able to offer you our services because of the hard work of our team members across all Fairfield entities, including but not limited to Fairfield Residential Company, LLC and FF Properties L.P. To provide our services, Fairfield entities receive personal information from other Fairfield entities for purposes and uses that are consistent with this Privacy Notice.
• Fairfield Residents: We may receive your personal information from residents of Fairfield communities. For example, a resident may provide us with your contact information as a part of a referral.
• Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.
• Advertisers and Publishers: We engage in advertising both on our services and through third-party services. Advertisers and publishers may share personal information with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.
• Business partners: We may receive your information from our business partners, such as companies that offer their products or services as a part of or in connection with our services. For example, certain of our services allow our customers to integrate third-party services. If you choose to leverage these third-party service integrations, we may receive confirmation from our business partner regarding whether you are an existing customer of their services.
• Service Providers: Our service providers that perform services on our behalf, such to provide background checks, credit screens, fraud detection, payment processing services, and property management services, collect personal information and often share some or all of this information with us.
• Other Sources: We may also collect personal information about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We may also receive information from any third party you direct to share information with us.

Additional Uses of Personal Information

In addition to any purposes for using personal information described above, we may also use personal information we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our services, or to deliver the services requested;
• Manage our organization and its day-to-day operations;
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Facilitate the relationship we have with you and, where applicable, the company you represent;
• Request you provide us feedback about our service offerings;
• Address inquiries or complaints made by or about an individual in connection with our services;
• Create and maintain accounts for our users;
• Verify your identity and entitlement to our services;
• Register you for and provide you access to events, promotions, and surveys;
• Market our services to you, including through email, phone, text message and social media;
• Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our services;
• Identify and analyze how you use our services;
• Infer additional information about you from your use of our services, such as your interests.
• Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
• Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
• Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
• Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including resident leases), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Fairfield and others;
• Facilitate business transactions and reorganizations impacting the structure of our business;
• Comply with contractual and legal obligations and requirements;
• Fulfill any other purpose for which you provide your personal information, or for which you have otherwise consented.

II. OUR DISCLOSURE OF PERSONAL INFORMATION

We may disclose or otherwise make available your personal information in the following ways:

• To Our Affiliates: We are able to offer you our services because of the hard work of our team members across Fairfield entities. To provide our services, Fairfield entities disclose personal information to other Fairfield entities for purposes and uses that are consistent with this Privacy Notice, including but not limited to Fairfield Residential Company, LLC and FF Properties L.P.
• To Marketing Providers: We coordinate and share personal information with our marketing providers in order to advertise and communicate with you about our services.
• To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
• To Service Providers: We engage vendors and other service providers that may process personal information on our behalf or have access to personal information while performing services on our behalf, including mailing services, tax and accounting services, analytic services, marketing services, and providing resident management services. For example, we use Yardi Systems to host our resident portal.
• To Other Businesses as Needed to Provide Services: We may share personal information with third-party vendors as necessary to fulfil our legal and regulatory obligations and facilitate our business operations, such as property managers, payment processors, banking institutions, and vendors that provide credit checks, identity verification or background check services.
• To Business Partners: We may share personal information with our business partners, or we may allow our business partners to collect personal information directly from you in connection with our services, such as rewards programs or moving services. Our business partners may use your personal information for their own business and commercial purposes, including to send you information about their services. For example, we may work with resident rewards platforms such as Rentgrata to connect current and prospective residents, and we may work with moving platform service providers such as Updater to facilitate the move-in and move-out process for residents. If you choose to create an account with one of these partners directly, they may use your personal information according to their own privacy policies and practices.
• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings. We may disclose, transfer, or assign personal information to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal information may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
• To Facilitate Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement, (a) as required by law or subpoena, or if we reasonably believe that such action is necessary to comply with the law and the reasonable requests of law enforcement; (b) to enforce our contractual rights or to protect the security or integrity of our services and property; (c) to exercise or protect the rights, property, or personal safety of Fairfield, our personnel, our visitors, or others; (d) to detect, suppress, or prevent fraud; or (e) where permitted by law, to reduce credit risk and collect debts owed to us.
• With Your Consent or Direction: We may disclose your personal information to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

III. OUR PRIVACY CHOICES

The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal information depending on your location or residency. Please refer to our Additional United States Privacy Disclosures below for information about additional privacy choices that may be available to you.

Communications preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt out of service-related communications (e.g., account verification, transaction confirmation, technical and security notices).
• Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out of promotional phone calls (where available), or replying STOP to any one of our promotional text messages. Please note we may need to continue to communicate with you via phone for certain service-related messages (such as, sending a verification code to your phone via call or text for purposes of verifying the authenticity of a log-in attempt).
• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.
• Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us at privacy@ffres.com. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.

Automatic Data Collection Preferences

Certain of our services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. For example, there is a cookie preferences manager linked in the footer of our websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).

You may also be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies, or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Modifying or Deleting Your Information

If you have any questions about accessing, modifying, or deleting your information, you can use our rights request form. We may not be able to modify or delete your information in all circumstances.

Targeted Advertising Preferences

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on predictions of your preferences and interests developed using personal information we maintain and personal information our third-party partners obtain from your online browsing history across nonaffiliated websites and other services. We permit third party online advertising networks, social media companies, and other third-party services to collect information about your visits to our services over time so that they may play or display ads on our websites, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies, and logging technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices or otherwise target advertising to an individual on a third-party website or platform. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

• Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.
• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://myadcenter.google.com/personalizationoff?hl=en&sasb=true&ref=ad-settings for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program.
• Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1#!%2F to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program.
• Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal information, or automatically impose limitations on the way we can use personal information in connection with the services they provide:

• Device-Specific / Platform-Specific Preferences: The device or platform you use to interact with us (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.
• Google Analytics and Advertising. We may use third party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Sites. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://adssettings.google.com/authenticated?hl=en, or by vising NAI’s online resources at http://optout.networkadvertising.org/?c=1#!/. You can learn more about Google’s practices at https://policies.google.com/privacy.

IV. CHILDREN’S PERSONAL INFORMATION

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If an individual is under the age of 18, they should not use our services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information that we have collected has been provided by a child under the age of 18, we will promptly delete that personal information.

V. RETENTION OF PERSONAL INFORMATION

We will usually retain the personal information we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if that is not possible (for example, because personal information has been stored in backup archives), we will securely store the personal information and isolate it from further active processing until deletion or deidentification is possible.

VI. INTERNATIONAL VISITORS

Fairfield provides services exclusively within the U.S. and does not own or manage property outside the U.S., intentionally market its services extraterritorially, or have a presence outside the U.S., including in the European Union, the United Kingdom, Switzerland, or any state belonging to the European Economic Area (“EEA”). If you choose to use our services from one of these regions, please note that we will transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as your jurisdiction.

VII. LINKS TO OTHER WEBSITES

Our services may contain links to other websites, plug-ins, application, and other services that are not owned or controlled by Fairfield. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal information practices of third parties. To learn about the personal information practices of such third parties, please visit their respective privacy notices.

VIII. UPDATES TO THIS PRIVACY NOTICE

We reserve the right to modify this Privacy Notice from time to time. If we decide to update our Privacy Notice, we will change the date at the beginning of this Privacy Notice. When we update this Privacy Notice in a material manner, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. If you object to any changes, you may close your account.

IX. CONTACT US

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please email privacy@ffres.com or write to us at:

Fairfield
Attn: Privacy Team
5355 Mira Sorrento Place, Suite 100
San Diego, CA 92121
Last Updated: March 1, 2025

X. ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

The following disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal information processing practices relating to individual residents of certain states in the United States. For additional information about how we collect, use, disclose, and otherwise process personal information, please read the remainder of our Privacy Notice above.

Personal Data Sales and Targeted Advertising

Our disclosure of personal information to the following categories of third parties qualifies as the sale of personal information or the sharing or processing of personal information for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws: (i) other brands and affiliates in our family of Fairfield companies; (ii) our service providers and advisors, including third-party providers with services integrating with our services; (iii) marketing and business partners; (iv) analytics providers; (v) ad networks and advertising partners; and (vi) certain third parties where you have provided consent or where otherwise required or permitted by law.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

Please note that we do not sell the personal information of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.

Sensitive Personal Information

The following personal information elements we collect may be classified as “sensitive” under certain privacy laws:

• Government ID numbers, including social security number, driver's license number, state identification card number, or passport number.
• Race, ethnicity or national origin
• Citizenship or immigration status
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• The contents of a consumer’s mail, email, or text messages where the business is not the intended recipient.
• Genetic data
• Biometric data
• Health data, including information regarding an individual’s medical history, mental or physical health condition, or medical treatment or diagnosis
• Information about an individual’s sexual orientation, sex life or status as transgender or non-binary
• Status as a victim of a crime
• Precise geolocation data
• Personal information collected from a known child under the age of 13

We only use or disclose sensitive personal information where reasonably necessary and proportionate for the purposes of providing services you have requested, verifying and improving our services, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal information without the purpose of inferring characteristics about the relevant individual, and we do not sell sensitive personal information or process or otherwise share sensitive personal information for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Automated Decision-Making and Profiling

We do not conduct automated processing of personal information for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.

Your Additional U.S. Privacy Choices

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• Right to Know: The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including:
  • The categories of personal information collected;
  • The categories of sources of the personal information;
  • The purposes for which the personal information were collected;
  • The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom this personal information were disclosed;
  • The categories of personal information shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for these purposes; and
  • The categories of personal information sold (if any) and the categories of third parties to whom the personal information were sold.
• Right of Access & Portability: You may have the right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information you have provided to us in a portable, and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
• Right to Correction. You may have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• Right to Deletion. You may have the right, in some circumstances, to require us to delete personal information we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party).
• Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal information for certain targeted advertising purposes.
• Right to Opt-Out of Sales: The right to direct us not to sell personal information to third parties, including the right to opt-out of the disclosure of personal information to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Appealing Privacy Rights Decisions

In the event that we decline to take action on a request exercising one of your rights set forth above, depending on your state of residency, you may appeal our decision. All appeal requests should be submitted by replying to the communication resolving your original request.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by either:

• Filling out our Consumer Rights Request Form, or
• Calling (833)-437-3254

To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal information or the use of personal information for targeted advertising purposes, please click the “Your Privacy Choices” cookie settings link in the footer of the website and adjust your preferences accordingly. If you are visiting our site with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Notice to further exercise control over automatic data collection technologies.

Before processing your request (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the required right(s), which may require us to request additional personal information from you or require you to successfully log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, where you are not a resident of one of the eligible states, or as permitted by law.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Additional California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

California Categories of Personal Data

California law requires we provide disclosures to you about what personal information we collect by reference to the enumerated categories of personal information set forth within California law. To address this obligation, we have identified the relevant enumerated California personal information category for the personal information described in the Our Collection and Use of Personal Data section of our Privacy Notice below:

• Identifiers, such as such as first and last name, phone number, email address, unique personal identifiers, and online identifiers.
• Customer records, such as contact information and account information.
• Protected classification characteristics, such as age, gender, and health status.
• Commercial information, such as such as records of transactions and user histories and tendencies.
• Internet / network information, such as the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network.
• Geolocation data, including general geographic location, as well as more precise geolocation when you grant us access through your device settings.
• Sensory information, including voice prompts / recordings and security /service images and video.
• Professional / employment information, such as employer and job title.
• Sensitive personal information, such as social security or driver’s license number, information relating to racial and ethnic origin, health information, citizenship or immigration status, and precise geolocation.
• Other Personal Data, such as your communication preferences and any other Personal Data you choose to share in custom messages sent through our forms and email address.
• Inferences, including individuals’ preferences, predispositions, and characteristics.

Additional Nevada-Specific Disclosures

The following disclosures only apply to residents of the State of Nevada.

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at (833)-437-3254 or privacy@ffres.com to submit such a request.