Privacy Policy FPA Multifamily, LLC

PRIVACY POLICY

FPA Multifamily, LLC and their respective subsidiaries and affiliates (“FPA”, or the “Company”) respects your privacy and is committed to protecting your information. This Privacy Notice applies to our websites, including fpamf.com and any other website or mobile app that links to this Notice (collectively, our “Service”). Please read this notice carefully to understand how your personal information is collected, used and disclosed by the Company. By accessing our website you agree and consent to the practices described in this Privacy Notice.

THE PERSONAL INFORMATION WE COLLECT

To provide you services, we collect or you may choose to provide Personal Information that may identify you or relate to you as an individual. Depending upon the type of relationship you have with FPA, we may collect the Personal Information described in general terms below.

Contact Information such as name, postal address, email address, date of birth, picture, and emergency contact details.
Other Personal Identifiers such as user/account name, social security number, taxpayer identification number, driver’s license number, identity card or student card, and resident identification number.
Financial and Insurance Information such as bank account/credit card number, insurance policy number, credit history, and other financial or tax documentation.
Demographic Information such as age, race, color, ancestry, national origin, citizenship, marital status, sex, veteran or military status, in each case subject to applicable laws. In certain jurisdictions, you may also choose to share with us any disabilities or other health-related restrictions so that we can provide you with adequate accommodations.
Commercial Information such as records of services purchased, obtained, or considered, other purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, and rent amount.
Internet or other electronic network activity information through the use of our websites such as browsing history, search history, internet protocol address, cookie identification number, information regarding consumer’s interaction with a website, and internet postings.
Sensory data such as pictures, videos, and sounds.
Employment, Investment or other professional information such as education, employment history, job title, university or school attended, pay history, income, net worth, source of your subscription funds, wire transfer instructions, and risk tolerance.

HOW AND WHERE WE COLLECT YOUR PERSONAL INFORMATION

We may collect Personal Information through the following:

Online Services. We collect Personal Information when you interact with our Online services which may include, but are not limited to, searching for an apartment, communicating with us, applying for a job, posting to social media pages, or participating in a survey.
Property Owners. Our properties may be owned by other investors who share personal information with us for the purposes of managing the property and providing you services.
Property Visits and Offline Interactions. We collect your Personal Information when you visit our properties, attend events hosted at our properties, and/or inquire about housing directly with our properties.
Other Sites and Third Parties. We may use separate sites for the processing of applications and agreements and to assist our residents and service providers with other tasks which are required or helpful to them, such as paying rent online. We also use separate sites for booking corporate or flexible stays. We may also receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward us your email address and other information about you so that we may contact you as requested and in accordance with applicable law.
Investor and Third-Party Due Diligence. When you invest in a private fund advised by us or when you provide services to FPA as a third-party vendor/contractor, we will collect certain information through our discussions with you, from documents that you may deliver to us, and in the ordinary course of our business relationship.
Other Sources. We collect Personal Information from other sources, such as public databases or credit agencies. Where legally required, we will obtain your consent before undertaking these checks.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may also collect “Other Data” that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data includes:

Your browser or device. We collect certain data through your browser or automatically through your device, such as your operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the online services (such as the apps) you are using. We use this data to ensure that the online services function properly.
IP Address. We collect your Internet Protocol (IP) address which is a number that is automatically assigned to your computer whenever you are using the Internet. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Trinity collects IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users, and auditing the use of our sites. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We may seek to link your IP address to your identity when we feel it is necessary to protect our sites and other users from harm and to prevent criminal misconduct.
Cookies. We collect certain data from cookies, web beacons, and other technologies. (“Cookies”) which are pieces of data stored directly on your device or browser and may, in certain jurisdictions, be considered Personal Information. We also use third-party Cookies for our advertising and marketing efforts, to measure the success of our marketing campaigns, and to compile statistics about usage of the online services.

Cookies are necessary for the website to function and cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these Cookies, but some parts of the site will not work.

Cookies also allow us to monitor website traffic and sources so we can measure and improve the performance of our sites. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site and will not be able to monitor its performance.

Cookies may be set through our site by our advertising partners and may be used by those companies to build a profile of your interests to show you relevant advertisements on other sites. These work by uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.

Most browsers are set up to accept Cookies. If you want to change your cookie preferences, you can do so through your browser settings or by updating your Cookie preferences, where applicable, when you enter any of our websites.

WHY WE USE YOUR PERSONAL INFORMATION

PURPOSE	DESCRIPTION OF ACTIVITIES	LEGAL BASIS
Engage with prospective residents	The activities associated with this purpose may include providing property tours and contacting prospective residents.	Legitimate interests for leasing an apartment, for example, communication regarding your property preferences
Applications and Contracts	The activities associated with this purpose may include collecting and processing applications or contracts and communicating with you regarding your application or account. Personal Information will be used to perform credit checks, background checks, or other screenings as necessary for the Company’s know your customer andanti-money laundering requirements.	Performance of a contract to initiate a lease or an employment relationship Legitimate interests for ensuring prospective residents are financially solvent Legal obligations, such as sanctions screenings, background checks, anti-money laundering screenings, and identity confirmation
Operations and General Business	The activities associated with this purpose may include processing or communicating with residents about payments, performing debt collection, providing maintenance or other on-site services, and managing the property. Processing this information also helps us better understand how we can help prospective and current residents.	Performance of a contract to fulfill your lease Legal obligations relating to financial transactions, such as the obligation to maintain books and records.
Marketing and Surveys	The activities associated with this purpose may include communicating with you about our properties and promotions and conducting resident surveys about your experience.	Consent, such as honoring communication preferences Legitimate interests, such as providing advertisements for our similar products and services
Security and Legal Obligations	The activities associated with this purpose may include detecting security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, as well as ensure the safety of our residents.	Legitimate interests to protect against malicious activity Legal obligations relating to data protection and to report illegal activity and security incidents

HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

We may share Personal Information with the following third parties to provide you services, following a specific request from you, or to fulfill our legal obligations.

Company Affiliates. We disclose your Personal Information and Other Data with our affiliated companies as necessary to communicate with you, provide you services, fulfill our contract with you and to accomplish our business purposes.
Service Providers. We disclose Personal Information and Other Data to third parties who perform services such as hosting our websites, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice.
Property Owners. We disclose Personal Information to the Owners of the properties we manage. Owners may use your Personal Information for their own purposes and legal obligations and are therefore considered separate data controllers for multiple processes during your tenancy journey.
Partners. We disclose Personal Information and Other Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.

We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of FPA employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.

BUSINESS TRANSITIONS

In the unlikely event FPA goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, Personal Information may be transferred as part of that transition. By using our websites and providing your Personal Information, you consent to this transfer, provided use of the Personal Information will remain in accordance with the Privacy Statement in place at the time of the transfer.

YOUR PRIVACY PREFERENCES AND RIGHTS

We provide you with options, information, and choices below to express your preferences.

Email Consent and Opt-out

Each of our commercial emails contain a link with instructions on how to remove yourself from our email list. Please note that if you are a resident or guest of a FPA property and you use this site and your property site, you will need to opt-out of your property site separately. You will also need to opt-out separately from any third-party sites you have registered with.

Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Information

You may have the right under applicable privacy laws to request that FPA inform you as to whether Personal Information relating to you is being processed. Subject to certain exceptions under applicable privacy laws, you may also have the right to submit a request to access, change, delete, restrict the use of, or object to the processing of your Personal Information that was previously provided to us. If you wish to exercise your rights, please visit our portals and complete one of the following forms. For your protection, we will verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

Please submit your request using the link or email address in the Contact section below.

INFORMATION

FPA takes reasonable technical and organizational measures to safeguard users’ Personal Information. While the Company strives to protect your Personal information and therein your privacy, we cannot guarantee the security of any Personal Information you disclose online and therefore you must be aware of this risk.

We limit access to Personal Information to those individuals and organizations who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take precautions we deem reasonable to protect the security of users’ Personal Information. However, as in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc. may be injurious to the confidentiality of users’ Personal Information notwithstanding the actions we take to prevent this.

Because the security of all Personal Information associated with our users is of utmost concern to us, we periodically review and improve our security when new technology becomes available. This includes use of software which encrypts data submitted to us relating to an online rental application or employment application.

RETENTION

We will retain your Personal Information for the period we believe reasonable to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the services to you

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

CHILDREN’S PRIVACY

Our websites are not directed at children. We do not collect or maintain information from those we know are under 16. By using any of our sites, you represent that you are not under 16 years of age.

NOTICE TO CALIFORNIA RESIDENTS

Individuals who reside in California and have provided their Personal Information to us may exercise their rights under the California Consumer Privacy Act (“CCPA”).

NOTICE TO RESIDENTS OF CERTAIN STATES

Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.

CONTACT US

You can submit Privacy Requests through our privacy portal at https://privacy.fpamf.com or email privacyrequests@fpamf.com

Last Revision: 06/14/2021