Pedcor Homes' Privacy Policy & Statement

We collect and store information that you give us directly. For example, when you:

• Contact us regarding occupancy of one of the housing communities we manage, we may collect your name, postal address, email address, and telephone number
• Submit an application to be a resident at one of the housing communities, we may collect your name (and any alias), postal address, email address, telephone number, Social Security number, passport number, signature, driver’s license or state identification card number, homeowners or rental insurance policy number, educational information (if you are a student), employment-related information, financial information such as a bank account number, and demographic information such as your age and gender.
• Create an account on our resident portal (a “Resident Account”), we may collect your name (and any alias), postal address, email address, telephone number, account name, password, driver’s license or state identification card number, bank account number, credit card number, debit card number or other financial information, Social Security number and passport number
• Request service support, we may collect your name, email contact information, phone number, and any other information you choose to provide to us regarding your request
• Email us, sign up for notifications, subscribe to our newsletters or mailing lists, we may collect your name, email, phone number, and address

We also receive and store certain types of information automatically when you interact with us online or with the Websites. For example, we use:

• Cookies, web beacons, links, and other tracking technologies to gather Information regarding your use and interaction with the Websites, our email correspondence, third party services and certain other online activities (including sites you visit, your browser type, operating system, and interactions with our content and emails)
• Third Parties, who manage our advertising on other sites, provide us information regarding your browsing activities and interests, as well as any information you may have provided when interacting with our online advertisements
• Unique Identifiers (such as a universally unique identifier), which we may store (including remotely) on your device persistently and may access, collect, or monitor in order to help you log in and navigate through the Websites
• Data and Mobile Analytics, by use of Google Analytics and similar methods, to collect anonymous information about your website usage, performance data, app errors, and debugging information from where the Websites were downloaded. If you choose to opt-out of Google Analytics, you can install a browser add-on in your browser across all websites (please note that Pedcor is not responsible for the content of external websites)
• Log File Information to learn your IP address, browser type, access times, domain names, operating system, the referring web page(s), pages visited, location, mobile carrier, device information (including IDs), search terms, and cookie information
• Information about your precise location when you permit an online service to access device location.

Pedcor also learns about you through information you make publicly available, such as on a social network. Please note, any content or information you share with or provide to third parties regarding Pedcor, your communications with Pedcor, or using or related to the Websites may not be private or confidential and is not the responsibility of Pedcor.

Pedcor may use and process information about you for one or more of our legitimate business purposes. For example, Pedcor (and/or our Service Providers) may use your information to:

• Fulfill or meet the reason your information was collected or provided, including our suite of resident services, and to provide the necessary support to you
• Deliver communications, information or services
• To improve our marketing and promotional efforts and for direct marketing
• Present, optimize, and maintain the security of our Websites and its contents
• Register, maintain, and provide notifications to you about your Resident Account
• Detect and prevent fraud or other crimes
• Respond to law enforcement requests and as required by applicable law or court order
• Research, test, analyze, and develop our products, Websites and services
• Allow you to participate in interactive features on our Websites
• Personalize your website experience and to deliver content and service offerings relevant to your interests
• Comply with our legal obligations such as state and federal audits
• For any other purposes identified in an applicable privacy statement or other agreement you have with Pedcor

We do not believe that we “sell” your personal information as such is defined by applicable privacy laws and, accordingly, we do not offer a “do not sell” opt-out. We will not sell personal information that we collected without giving you an opportunity to opt-out and unless we first give you notice of our intent to sell along with an express opportunity to opt-out of that sale. We have not sold personal information in the past twelve (12) months.

We may share information about you, including personal information, with subsidiaries who are subject to this Privacy Statement or follow practices at least as protective as those described here, or with Service Providers with whom we have entered into contracts that require personal information be kept confidential and prohibit the retention, use, or disclosure of personal information for any purpose other than the services specified. Pedcor does not share or disclose information for commercial purposes without your consent, except as described below:

• Within the Pedcor Family: We may share personal information internally within Pedcor and with our subsidiaries and affiliates. Pedcor’s personnel may have access to personal information as needed to provide and operate the Websites and provide resident services in the normal course of business.
• Service Providers: We employ other companies and individuals to perform functions on our behalf, including sending mail, analyzing data (such as Google Analytics), providing marketing assessments, providing analytics information, processing payments, and providing data hosting (as specified below). They have access to personal information needed to perform their functions, but not for other purposes.
• Business Transfers: If we purchase other businesses or their assets, sell our business assets, or are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information, including any category of personal data collected by Pedcor, may be among assets sold or transferred and may be subsequently used by a third-party.
• Lawful Requests and Safety: We release personal information when we believe it is appropriate to comply with the law, it is necessary to protect our interests, to prevent fraud or other illegal activity, and to protect the safety of any person. Nothing in this Privacy Statement is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
• Business and Marketing Partners: We may disclose de-identified, aggregated, non-personal data received via the Websites with certain trusted business partners, without restriction. Pedcor does not share non-aggregated information or information that has not been de-identified with third-party business partners.

The information Pedcor gathers about you may be transferred, processed, maintained on and/or accessed by us outside of your state or in a jurisdiction with different, and less protective, privacy laws. If you are in the European Union or other regions/countries with laws that may differ from the United States and choose to allow us to collect information about you, please be aware that Pedcor (or our Service Providers) may transfer, process, and store that information in the United States, or another jurisdiction that does not have the same data protection laws.

Website Hosting

Pedcor works with the web hosting services providers, Microsoft Azure and Amazon Web Services (AWS), for managing its website services and to host data.

Data Retention

We generally retain the information we collect only for as long as necessary to fulfill the purposes for which it was collected, to fulfill our contractual and legal obligations, or as otherwise required by law. Following the termination of your residency with us or deactivation of a Resident Account, we may retain your information and content for a commercially reasonable time for backup, archival and audit purposes or may delete your personal data from our systems as part of our data retention plan and cyber-hygiene policies.

We realize that you trust us to protect your personal information. We take that trust seriously and maintain physical, electronic and procedural safeguards that are consistent with industry standards, to help protect the privacy, accuracy, and reliability of personal information and to protect it from loss, misuse, unauthorized access, disclosure, acquisition, exfiltration, alteration and destruction. We also take reasonable steps to ensure that our Service Providers protect your information. If Pedcor becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.

While we attempt to protect the information in our possession, and account for the protection of information provided to our Service Providers through us, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances. Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and Resident Account(s), and for all activities that occur under your password or Resident Account. Pedcor specifically reserves the right to terminate your access to the Websites and any contract you have with us related to the Websites in the event we learn or suspect you have disclosed your Resident Account or password information to an unauthorized third party.

We welcome you to contact us at privacy@pedcor.net regarding how we communicate with you and the information we have collected about you, including how we use that data, the nature and accuracy of that data, to request an update, modification, or deletion, or to opt-out of certain uses. Under certain circumstances, you may also request to withdraw consent previously provided. We will endeavor to accommodate your request to the extent feasible and where required by law.

If you are a resident of Virginia, Colorado, or Utah, you may have the right to request that Pedcor:

• Provide you access to recorded personal information that you have previously provided to us
• Correct or amend inaccurate information we have about you
• Delete the collected information assuming that request does not conflict with our legal obligations or other legitimate business purposes for maintaining information
• Honor your request to opt-out of processing of personal data for purposes of targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Virginia and Colorado residents may also have the right to appeal our decision about your request.

To exercise these rights or to appeal our decision about your request, as described above, please:

• Call us at 1.866.720.9238
• Email us at privacy@pedcor.net

The California Consumer Privacy Act (the “CCPA”) and as amended by the California Privacy Rights Act (the “CPRA”), provide California Residents (as defined in the CCPA and CPRA), specific rights regarding their personal information. For purposes of the CCPA, personal information does not include: publicly available information from government records; de-identified or aggregated consumer information; and, information excluded from the CCPA’s scope, including: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, certain information covered by sector-specific privacy laws, such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA). Any terms defined in the CCPA have the same meaning when used in this Notice.

The rights conferred by the CCPA and CPRA apply solely to visitors, users, and others who reside in the State of California. The following sections describe your rights and explains how to exercise those rights.

Right to Request Access to Specific Information and Data Portability Rights

The CCPA grants California Residents the right to ask Pedcor about its collection and use of the personal information it has collected, used, and disclosed over the past twelve (12) months. Instructions on how a California Resident can submit a verifiable consumer request for access to this information (referred to as a “Request to Know”) are below. Once we receive and confirm that you have made a verifiable consumer Request to Know, we will make an individualized disclosure to you about:

• Categories of personal information we collected about you;
• Categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting the personal information;
• Categories of third parties with whom we share that personal information;
• Certain, specific pieces personal information we collected about you (“Data Portability Request”); or,
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (1) sales, identifying the personal information categories that each category of recipient purchased; and, (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion of Your Data

California Residents have the right to request that we delete the personal information that we have collected and retained (“Requests to Delete”). Upon Pedcor’s receipt of a verifiable request to delete personal information (see below), we will delete—subject to the exceptions explained below—the personal information from our records and will direct our service providers to delete your personal information from their records.

However, please note that Pedcor may deny your request to delete and need not comply with such a request (and need not ask third-party service providers to comply) if retaining the information is necessary to perform certain functions or commitments, including: completing the transaction for which the personal information was collected; providing a service requested; otherwise performing our contract with you or taking reasonably anticipated actions within the context of our ongoing business relationship with you; detecting security incidents and protecting against malicious, deceptive or otherwise illegal activity or to prosecute those responsible for those activities; complying with a legal obligation or otherwise using the personal information, internally, in a lawful manner; complying with the California Electronic Communications Privacy Act; fulfilling the terms of a written warranty or product recall conducted in accordance with federal law; or, for a purpose otherwise contemplated by Cal. Civ. Code Section 1798.105(c)-(d) or as otherwise amended.

Right to Correct Inaccurate Personal Information

The CPRA provides an additional right for California Residents to request that we correct inaccurate personal information that we maintain about them (the “Right to Correct”). Pedcor will use commercially reasonable efforts in order to comply with California consumer requests to correct.

Use and Disclosure of Sensitive Personal Information

Pedcor only uses and discloses sensitive personal information (“SPI”) for the following purposes provided by Section 7027(m) of the CCPA regulations. Specifically, Pedcor may use or disclose SPI to: provide goods or services reasonably expected by California consumers; to prevent, detect and investigate security incidents; to resist malicious, deceptive, fraudulent or illegal actions directed at Pedcor; to ensure the physical safety of natural persons; for short-term transient use related to your interaction with Pedcor; to perform services on behalf of Pedcor, including maintaining or servicing Resident Accounts, providing customer service, verifying resident information, processing payments, and other similar services; to verify or maintain the quality or safety of a product or service; and, to maintain the necessary security and quality control over Pedcor’s stored information. Since Pedcor does not use or disclose SPI for purposes other than these exempted purposes, we are not required to post a Notice of Right to Limit or provide a method for submitting a request to limit use or disclosure of SPI.

How to Exercise Your Access, Data Portability, Deletion and Correction Rights

You may make a verifiable request to exercise your right to access or data portability twice within a 12-month period. To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by either:

• Call us at 1.866.720.9238
• Email us at privacy@pedcor.net

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to the personal information about you. If the request is made through an agent, we reserve the right to require a signed authorization or verification of the agent’s identify from you in order protect the privacy of the personal information requested. You may also make a verifiable consumer request on behalf of your minor child.

We cannot provide you with the information sought in a Request to Access, or comply with a Request to Delete or Correct, if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. A verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We reserve the right to require additional information from you to verify your request before we respond. Any information provided to us in a verifiable customer request will be used only to verify the requestor’s identity or authority to make the request.

Resonse Timing and Format

We will acknowledge your request or exercise of the foregoing Rights within ten (10) days of receipt with information regarding how we will process your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time to provide a response, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

As mentioned above, we may collect or process sensitive data as needed or required to deliver services you have requested, to inform you of other products or services, and to contact you via surveys to conduct research about your opinions. You may request that we delete this information, subject to certain exceptions as provided by the CCPA.

Other California Privacy Rights

Under California Civil Code Section 1798.83 (known as the "Shine the Light" law), residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or email privacy@pedcor.net with "Request for California Privacy Information" on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

Non-Discrimination

We will not discriminate against you for exercising any of the rights conferred by California statute, including the CCPA. Unless permitted by law, we will not: deny you goods or services; charge you different prices or rates; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate or a different level or quality of goods or services. We may offer certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.

Pedcor may modify this Privacy Statement from time to time. The most current version of this Privacy Statement will govern our use of your information and will be located at https://www.pedcorcompanies.com/privacy. We will notify you of material changes to this policy by posting a notice at the Websites or by emailing you at an email address associated with your Resident Account, if applicable, and provide an “at a glance” overview of any changes.