Privacy

A. Information about You that You Provide.
Landmark Properties, and/or its Service Providers (defined below), may collect information you provide directly to Landmark Properties and/or its Service Providers via the Service.  For example, Landmark Properties collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service.  In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.  For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.Information Landmark Properties, its Service Providers and/or Third-Party Services may collect includes: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, Social Security number, government-issued identification number, education or employment information, criminal history, vehicle information, and full payment account number (“Personally Identifiable Information” or “PII”); (2) demographic information, such as your gender, age, citizenship, zip code, interests, and recent and upcoming purchases (“Demographic Information”); and (3) commercial information such as your apartment preferences, desired budget, lease term, move-in date, and any additional information you wish to provide (“Commercial Information”). Except to the extent required by applicable law, Demographic Information is “non–Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy).  In addition, Personally Identifiable Information, including, without limitation, Landmark Properties-Collected PII (defined below), once “De–identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law.  To the extent any non-Personally Identifiable Information, or PII collected outside of the Service,  is combined by or on behalf of Landmark Properties with Personally Identifiable Information Landmark Properties itself collects directly from you on the Service (“Landmark Properties–Collected PII”), Landmark Properties will treat the combined data as Landmark Properties-Collected PII under this Privacy Policy. The definition of “personal information” under certain California laws differs from the definition of PII used in this Privacy Policy. California residents can learn more about their privacy rights here.

B. Information Collected Automatically. Landmark Properties, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”).  Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device).  Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Landmark Properties with Landmark Properties-Collected PII, Landmark Properties does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Landmark Properties-Collected PII.  For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.

The methods that may be used on the Service to collect Usage Information include:

• Log Information:
• Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
• Information Collected by Cookies and Other Tracking Technologies:  Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.

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• Cookies
  • A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work.  A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device.  HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them.  To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com settings manager.  The Service may associate some or all of these types of cookies with your devices.
• Web Beacons (“Tracking Pixels”)
  • Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content view.
• Embedded Scripts
  • An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Landmark Properties’ web server, or from a third party with which Landmark Properties works and is active only while you are connected to the Service and deleted or deactivated thereafter.
• Location-identifying Technologies
  • Geo-filtering and other location-aware technologies locate you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location.  If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties.
• Device Recognition Technologies.
  • Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
• Device and Activity Monitoring
  • Technologies that monitor, and may record, certain of your interactions with the Service, including without limitation, keystrokes, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.

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Landmark Properties is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.

C.Information Landmark Properties Collects From Other Sources. Landmark Properties may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Landmark Properties-Collected PII.  Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Landmark Properties with Landmark Properties-Collected PII, this Privacy Policy is not intended to limit Landmark Properties’ activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as Landmark Properties-Collected PII to the extend it is combined with Landmark Properties-collected PII. Landmark Properties is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.

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Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.  Browsers offer different functionalities and options, so you may need to set them separately.  Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies.  For information on disabling Flash cookies, go to Adobe’s website helpx.adobe.com/. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Like many online services, Landmark Properties currently does not alter Landmark Properties’ practices when Landmark Properties receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com, but Landmark Properties is not responsible for the completeness or accuracy of this third party information.  Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites you visit and privacy and opt-out policies and options of the parties operating those cookies.  Landmark Properties is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms.   For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.

Analytics and Advertising Tracking Technologies. You may exercise choices regarding the use of cookies from Google Analytics by going to Analytics Opt Out or downloading the Google Analytics Opt-out Browser Add-on.  You may exercise choices regarding the use of cookies from Adobe Analytics by going to Adobe Opt Out under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

You may choose whether to receive some Interest-based Advertising by submitting opt-outs.  Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.  To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit aboutads.info/choices, and aboutads.info/appchoices ffor information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads).  Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see networkadvertising.org/choices/.  Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads.  Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).  Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.  Landmark Properties supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Landmark Properties directly engages to serve you Interest-based Advertising will do so as well, though Landmark Properties cannot guaranty their compliance. Landmark Properties is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”).  This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the third-party services.  For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services.  We are not responsible for these Third-Party Services, including without limitation their security of the data.  If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads.  If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter.  We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from Landmark Properties at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from Landmark Properties to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable.  Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.  If you opt-out of only certain communications, other subscription communications may continue.  Even if you opt out of receiving promotional communications, Landmark Properties may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Landmark Properties’ ongoing business relations.

Cross-Device Data. To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the section above regarding the DAA’s Interest-based Advertising choices.

California Residents. This California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and describes how and why Landmark Properties, its affiliates, and subsidiaries (collectively, “Landmark”) collects, uses, and discloses Personal Information of California consumers (“you”), the rights afforded to you by the CCPA, and how to exercise those rights. This Notice does not apply to California job applicants, current and former employees, contractors, or beneficiaries. If you are a California consumer and interacted with us in one of these capacities, please contact us as provided below for more information.

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal information does not include information that is publicly available, de-identified, or aggregated.

Unless otherwise noted, the disclosures in this Notice cover our activities in the twelve (12) months prior to the Effective Date, as well as our current practices.

Collection, Use, and Disclosure of Personal Information

Landmark may collect, use, and disclose Personal Information for business purposes consistent with applicable laws as identified below. Where we transfer applicable Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.

Category of Personal Information	Purposes for Collection, Use, or Disclosure	Categories of Recipients to whom Personal Information is Disclosed
Identifiers, including real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, state ID number, passport number, or other similar identifiers	To communicate with you To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites To evaluate and improve our business operations To comply with legal obligations	Service providers Affiliates Advertising providers Data analytics providers IT vendors
Personal information described in Cal. Civ. Code § 1798.80(e), including physical characteristics or description, signature, telephone number, date of birth, education, employment, bank account number, or any other financial information, medical information	To communicate with you To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites To evaluate and improve our business operations To comply with legal obligations	Service providers Affiliates IT vendors
Characteristics of protected classifications under California or federal law, including age, citizenship, familial status, disability	To comply with legal obligations To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites	Service providers Affiliates
Commercial Information, including the location and type of apartment, home, or building you are interested in, desired budget, lease term, and move-in date, whether you have pets, and any additional details you wish to provide	To comply with legal obligations To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites	Service providers Affiliates
Internet Usage Information, including browsing, search, and usage histories	To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites	Service providers Affiliates Advertising providers Data analytics providers Internet service providers IT vendors
Geolocation Data, including physical location inferred from your IP address	To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites	Service providers Affiliates Advertising providers Data analytics providers Internet service providers IT vendors
Sensory Data, including audio and/or visual recordings of customer care calls, and security cameras footage	To manage and facilitate business operations, including transactions, safety and security, and fraud detection and prevention	Service providers IT vendors
Professional or Employment Information, including professional, educational, or employment-related information, including personal or professional references	To comply with legal obligations To manage and facilitate business operations, including transactions, advertising and marketing services, safety and security, fraud detection and prevention, quality assurance, and our websites	Service providers Affiliates
Non-public Education Records, including education records directly related to a student maintained by an educational institution or party acting on its behalf, or student financial information	To manage and facilitate business operations, including transactions, safety and security, fraud detection and prevention, and quality assurance	Service providers Affiliates
Other Categories of Personal Information, including national identification information, vehicle information, and criminal history	To comply with legal obligations To manage and facilitate business operations, including transactions, safety and security, and fraud detection and prevention	Service providers Affiliates

Sources of Personal Information

We collect the Personal Information identified above from the following sources:

• Directly from you.   For example, during the purchase or rental application process, through our websites or online systems, and other processes where you may submit Personal Information to us.
• Automatically when using our digital services or visiting our premises. For example, when you use our websites or online services, and when you access our facilities.
• Landmark affiliates. For example, we receive Personal Information from our affiliates, as permitted, to enable us to manage our business.
• Parties to corporate transactions. As permitted by law, we may receive Personal Information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of a business or assets.
• Business partners. We may receive information about you from service providers, business partners, or other vendors. For example, we may receive employment-related information about you from your references, or through a background check service provider.

Disclosing Your Personal Information

We may disclose each of the categories of Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Personal Information was collected including, but not limited to:

• Auditing ads;
• Helping to ensure security and integrity;
• Debugging, repairing, and improving functionality;
• Short-term, transient use;
• Performing services on our behalf;
• Providing advertising and marketing services, as applicable;
• Internal research for technological development; and
• Verifying quality and/or safety.

In addition to the other purposes for collection, use, and disclosure of Personal Information described in this Notice, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to other parties in connection with a sale, assignment, merger, reorganization, or other transfer of Landmark.

Data Retention

We generally maintain Personal Information according to our retention obligations and policies, operational business purposes, and other legal and regulatory requirements. We discard this Personal Information when reasonably practicable.

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected it;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
• Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where your Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

Sales and Sharing of Personal Information

We do not sell Personal Information in exchange for money, but some of the ways in which we share Personal Information may be considered a sale under the CCPA. We may sell and/or share the following categories of personal information with third parties for the purposes of cross-context behavioral advertising:

• Identifiers
• Internet or other electronic network activity
• Geolocation data

We sell and/or share this Personal Information with third parties for advertising purposes. The third parties to whom this Personal Information is sold and/or shared are advertisers and analytics vendors.

California residents may opt out of sales and sharing of your Personal Information as set forth in the “Right to Opt Out of Sales and Sharing of Personal Information” section below.

We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.

California Privacy Rights

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please email us at privacy@landmarkproperties.com, or call us at 1 (888) 914-9661 PIN 493149.

If you make a privacy request, we may take steps to verify your identity before responding to your request. You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

1. The categories of Personal Information we have collected about you, including:
   1. The categories of sources from which the Personal Information was collected;
   2. Our business or commercial purposes for collecting, disclosing, or sharing Personal Information;
   3. The categories of recipients to which we disclose Personal Information;
   4. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information;
   5. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
2. The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe the Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information and to request that we do not share your Personal Information for cross-context behavioral advertising.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

Notice of Financial Incentives

From time to time, Landmark may offer a financial incentive such as a gift card or merchandise to consumers who choose to sign up for additional information about our properties, to register as an active sales lead, to visit one of our properties for a tour, or sign a lease. Participation in these activities requires you to provide some Personal Information, such as your Identifiers and Commercial Information. These incentives are designed to encourage participants to visit our properties or sign a lease.

We have made a good faith estimate that the value of this Personal Information provided in connection with our incentives is equivalent to the relevant expenses related to the collection and retention of that Personal Information. Any difference in price or benefits provided to participants who receive an incentive is reasonably related to the value of the Personal Information provided.

Should you wish to withdraw your participation in any program associated with a financial incentive as described above, please email us at privacy@landmarkproperties.com, or call us at 1 (888) 914-9661 PIN 493149.  Please visit our Privacy Policy [link] for more information about our privacy practices and how we may collect, use and disclose your Personal Information.

Third Party Marketing and Your California Privacy Rights

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of Personal Information to third parties or affiliates for their own direct marketing purposes. We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us as provided below.

Contact Us

For more information on your California privacy rights please email us at privacy@landmarkproperties.com, or call us at 1 (888) 914-9661 PIN 493149.

Nevada Residents. Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us here and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.

Connecticut Privacy Notice. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

Sources of PI

We may collect your PI directly from you or from service providers, vendors and suppliers, credit reporting agencies, our affiliates, or other individuals and businesses, as well as public sources of data such as government databases.

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Use of PI

Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures and sale of PI, see the next section Sharing of PI.

We may collect, use and share the PI we collect for one or more of the following business purposes:

• Processing Interactions and Transactions
• Managing Interactions and Transactions
• Performing Services
• Research and Development
• Quality Assurance
• Security
• and Debugging

Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the consumer or other parties at the consumer’s request, for the additional purposes explained in our Privacy Policy, and  to assignees as part of a merger or asset sale (“Other Business Purposes”).

Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.

We may collect and use your PI for commercial purposes such as for interest based advertising.

In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.

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A. The Right to Know:

B. Do Not Sell

We do not believe that we sell your PI as “sell” is defined under the CCPA, and until such time as we change this policy by updating this Privacy Notice, and provide a method to opt-out of sale, we will treat PI collected under that policy as subject to a do not sell request. To make a request, follow the instructions at our Consumer Rights Request page here.

There may be cookies and other tracking technologies associated with our online services that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. While there is not yet a consensus, we do not believe that data practices of third-party cookies and tracking devices associated with our online services constitute a sale of PI by us and therefore we do not currently treat these activities as a “sale.” Currently, a do not sale request to us will not affect these third-party activities. However, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices.  In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available at https://www.ghostery.com/. You can learn more about how to exercise certain choices regarding cookies and interest-based advertising at http://www.aboutads.info/choices/,  http://www.aboutads.info/appchoices, and http://www.networkadvertising.org/choices/.

For easy access, here are links on how to manage cookies from some of the more popular browsers:

• Google Chrome
• Firefox
• Internet Explorer
• Edge
• Safari

We do not represent that these third-party tools, programs or statements are complete or accurate. Clearing cookies or changing settings may affect your choices and you may have to opt-out separately via each browser and other device you use. Cookie-enabled opt-outs signals may no longer be effective if you delete, block or clear cookies. We are not responsible for the completeness, accuracy or effectiveness of any third-party notices or choices.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. Further, there is not currently a consensus as to how various user-enabled privacy or “do not track” signals or settings should be treated or what they mean, so we will not look for or respond to any that are not expressly listed here as programs in which we participate or otherwise accept, which may change as programs evolve. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

We do not knowingly sell the PI of Consumers under 16.

We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Landmark Properties as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

C. Delete:

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.

To make a request,follow the instructions at our Consumer Rights Request page here email us here or call us at 1 (888) 914-9661 PIN 493149and indicate that you are making a request to delete your PI. In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. We are required to verify a consumer’s request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the consumer posted by unauthorized deletion. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.

However, you may alternatively exercise a more limited control of your PI by instead exercising one of the following more limited opt-out, such as op exercising a more limited opt-out, such as opting out of marketing communications.

D. Non-Discrimination and Financial Incentive Programs:

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.  We do not currently offer financial incentive programs or charge a different price or rate, or offer a different level or quality of good or service that relates to your data.  If this policy changes, the material aspects of that policy will be explained and described in its program terms in accordance with the CCPA.

E. Authorized Agents:

If a Consumer chooses to submit a request through an authorized agent, we require the Consumer to:

• Provide the authorized agent signed permission by the Consumer to submit a request, a copy of which must be provided to us;
• Verify their own identity directly with us;
• Directly confirm with us that they provided the authorized agent permission to submit the request.

If the authorized agent has a power of attorney issued under California Probate Code sections 4000 to 4465, then the written agreement is not necessary. Pursuant to Probate Code Sections 4121 and 4122, a power of attorney is only valid if it is notarized or witnessed by two adults other than the attorney-in-fact. Where witnesses are used rather than a notary, we require verification of the witnesses’ identities, and verification that they in fact witnessed the appointment. The power of attorney must be sufficiently broad, or specific, to establish agency to make a CCPA request. We are entitled to reject any request submitted through a power of attorney if the attorney-in-fact cannot reasonably verify the validity of the power of attorney.

If the authorized agent is not authorized by a power of attorney, we require an agent that is an entity be registered with the Secretary of State to conduct business in California. We are entitled to verify the legitimacy of an agency appointment, such as through a representation under the penalty of perjury with two verified witnesses. We are entitled to require a natural person acting on behalf of an entity agent to attest under penalty of perjury with two verified witnesses that (1) they are authorized to act on behalf of the entity and the consumer; (2) they are who they claim to be; and (3) everything they have submitted is valid and accurate. We are entitled to require the same of an individual acting as an agent, except for the qualification that they be registered with the Secretary of State to do business in California.

In the absence of any of the general conditions detailed above, we are entitled to reject any request submitted through an agent. In addition, the agent is subject to the verification standards applicable to the type of request(s) made.

F. Limitation of Rights:

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

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A. Third Party Marketing and Your California Privacy Rights:

Separate from your CCPA “Do Not Sell” rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:

We do not share personal information as defined by California Civil Code § 1798.83 (the “Shine the Light law”) with third parties, other than Landmark Property affiliates, for their direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by request information about our compliance with the Shine the Light law, by emailing us here or by sending a letter to us at 315 Oconee Street, Athens, Georgia, 30606, (Attention: Legal Counsel). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

B. Online Privacy Practices:

For more information on our online practices and your California rights specific to our online services see our online Privacy Policy. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

Landmark Properties California Applicant Privacy Notice

Effective Date: January 1, 2023

The purpose of this California Applicant Privacy Notice (“Applicant Notice”) is to inform job applicants of Landmark Properties, its affiliates, and subsidiaries (“Landmark”) who are residents of the State of California (“Applicants” or “you”) of the categories of Personal Information we may collect about them and how we use their Personal Information. This Applicant Notice is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and should be read in conjunction with all other policies that govern your relationship with us.

As used in this Applicant Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Applicants. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.