Fenton may collect personal information that falls into the following categories of information from residents, potential residents or consumers:

• Category A: Identifiers, such as a real name, alias, usernames, social media handles, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, medical information or health insurance information.
• Category C: Protected classification characteristics, which includes age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex, including gender, protected medical leaves and related medical conditions, sexual orientation, veteran or military status.
• Category D: Internet or other similar network activity, such as browsing history, search history, personal social media activity, personal email, online transactions, information on a consumer’s interaction with a website, application, advertisement, or information posted to social media channels, websites, or applications owned or managed by Fenton.
• Category E: Geolocation data, such as physical location or movements within properties via surveillance cameras.
• Category F: Professional or employment-related information, including current or past job history.
• Category G: Sensitive Personal Information, including Government ID, account log-in, financial accounts information in combination with any required access credentials, precise geolocation, and racial or ethnic origin; however, this information is collected and used consistent with the permissible uses under the CCPA.

Fenton obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, e-mail, text, or voicemail communications from you, and other Fenton Services you may interact with.
• Indirectly from you. For example, from observing your actions on our Website and other Services we may provide.
• From third parties. For example, from brokers or third parties we use to learn of prospective tenants, from government agencies such as the DMV pursuant to background checks, application processing or payment processing service providers, and from publicly available sources.
• From social media or other sites where you post content. For example, our Websites may showcase or embed a social media feed that pulls content from other sites and that may contain information about you.

Fenton may have collected personal information that falls into the following categories of information from its employees, job applicants and contractors:

• Category A Identifiers, such as a real name, alias, usernames, social media handles, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, medical information or health insurance information.
• Category C: Protected classification characteristics, such as age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex, including gender, protected medical leaves and related medical conditions, sexual orientation, veteran or military status.
• Category D: Internet or other similar network activity, such as browsing history, search history, personal social media activity, personal email, online transactions, information on your interaction with a website, application, advertisement, or information posted to social media channels, websites, or applications owned or managed by Fenton.
• Category E: Geolocation data, including physical location or movements within properties via surveillance cameras.
• Category F: Professional or employment-related information, including current or past job history.
• Category G: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
• Category H: Inferences drawn from other personal information, such as profile or personality tests reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Category I: Sensitive Personal Information, including Government ID, account log-in, financial accounts information in combination with any required access credentials, precise geolocation, and racial or ethnic origin; however, this information is collected and used consistent with the permissible uses under the CCPA.

Fenton obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms, applications, leave requests, or tests you complete.
• Indirectly from you. For example, from observing your interactions with company systems, services or products offered by us.
• From third parties. For example, from employment agencies, government agencies such as the DMV, and vendors used for background checks.
• From social media or other sites where you post content. For example, our Websites may showcase or embed a social media feed that pulls content from other sites and that may contain information about you.

Fenton may use or disclose your personal information for one or more of the following business purposes:

• To fulfill a contract with you or meet the reason you provided the information. For example, if you share your name and contact information to request a tour of a property, we will use that personal information in order to process an application to lease or for payment of rent or other sums due to us.
• To provide you with support and to respond to your inquiries and requests for services, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with email alerts and other notices concerning our Services or events or news that may be of interest to you.
• To keep a record of contact and address information and correspond with you about the Services.
• To create, maintain, customize, and secure your account with us and to prevent transactional fraud.
• To provide, support, personalize, and develop the content on our dynamic Website and Services.
• To communicate with you, including through our social media channels.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• As we believe necessary or appropriate, under applicable law, including to (i) comply with legal process or legal obligations, (ii) to respond to law enforcement requests and as required by applicable law, court order or governmental regulations, (iii) to protect our operations or those of any of our affiliates, (iv) to protect the rights, privacy, safety or property of us, our clients or others, or (v) to allow us to pursue available remedies or limit the damages that we may sustain.
• To help maintain the safety, security, and integrity of our Website, Services, databases and other technology assets, and business.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fenton’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Fenton is among the assets transferred.
• To help maintain the safety and security of all employees, visitors, and contractors to all H.G. Fenton properties or facilities

Fenton may use or disclose your personal information for one or more of the following purposes:

• To evaluate applicants for potential employment.
• To fulfill or meet the reason you provided the information. For example, to conduct payroll and timekeeping activities, administer benefits, or deliver parking benefits.
• To permit remote log-in access while ensuring data security.
• To ensure compliance with IRS reporting and withholding laws.
• To investigate and help prevent fraud or otherwise ensure compliance with policies and procedures.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• As we believe necessary or appropriate, under applicable law, including to (i) comply with legal process or legal obligations, (ii) to respond to law enforcement requests and as required by applicable law, court order or governmental regulations, (iii) to protect our operations or those of any of our affiliates, (iv) to protect the rights, privacy, safety or property of us, our clients or others, or (v) to allow us to pursue available remedies or limit the damages that we may sustain
• To help maintain the safety, security, and integrity of our Website, Services, databases and other technology assets, and business
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fenton’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Fenton about our users is among the assets transferred.
• To help maintain the safety and security of all employees, visitors, and contractors to all H.G. Fenton properties or facilities.

Disclosures of Personal Information for a Business Purpose

Fenton has disclosed or may disclose the following categories of personal information for a business purpose:

• Category A: Identifiers. The personal information from this category may be disclosed to service providers that support our business, including third party payment processing providers; parking vendors; insurance providers; security vendors; including onsite at properties and cyber; government agencies; financial institutions; professional service providers; including attorneys and accountants; social media feed plugin providers.
• Category B: California Customer Records personal information categories. The personal information from this category may be disclosed to service providers that support our business, including third party payment processing providers; parking vendors; insurance providers; security vendors; including onsite at properties and cyber; government agencies; financial institutions; professional service providers; including attorneys and accountants; social media feed plugin providers.
• Category C: Protected classification characteristics. The personal information from this category may be disclosed to third party payment processing providers; parking vendors; insurance providers; security vendors; including onsite at properties and cyber; government agencies; financial institutions; professional service providers; including attorneys and accountants.
• Category D: Internet or other similar network activity. The personal information from this category may be disclosed to IT service providers; and security vendors, including cyber; and social media feed plugin providers.
• Category E: Geolocation data. The personal information from this category may be disclosed to IT service providers; onsite security vendors; government agencies; professional service providers, including attorneys.
• Category F: Professional or employment-related information. The personal information from this category may be disclosed to third party payment processing providers; parking vendors; insurance providers; security vendors; including onsite at properties and cyber; government agencies; financial institutions; professional service providers; including attorneys and accountants.
• Category G: Sensitive Personal Information. The personal information from this category may be disclosed to human resources information service providers; financial investment and financial institution service providers; insurance providers; payroll service providers; third party payment processing providers; professional service providers such as attorneys.

Sales and Sharing of Personal Information

Fenton has not sold personal information as that term is defined under applicable law.

Fenton has not shared your personal information for purposes of targeted or cross-contextual behavioral advertising.

Disclosures of Personal Information for a Business Purpose

Fenton has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers. The personal information from this category may be disclosed to human resources information service providers; financial investment and financial institution service providers; insurance providers; payroll service providers; third party payment processing providers; parking vendors; security vendors, including onsite at properties and cyber; government agencies; professional service providers, including attorneys and accountants; social media feed aggregators; and wellness program service providers.
• Category B: California Customer Records personal information categories. The personal information from this category may be disclosed to human resources information service providers; financial investment and financial institution service providers; insurance providers; payroll service providers; third party payment processing providers; parking vendors; security vendors, including onsite at properties and cyber; government agencies; professional service providers, including attorneys and accountants; social media feed aggregators; and wellness program service providers.
• Category C: Protected classification characteristics. The personal information from this category may be disclosed to professional service providers, such as attorneys.
• Category D: Internet or other similar network activity. The personal information from this category may be disclosed to IT service providers; and security vendors, including cyber; and social media feed aggregators.
• Category E: Geolocation data. The personal information from this category may be disclosed to IT service providers; onsite security vendors; government agencies; and professional service providers, including attorneys.
• Category F: Professional or employment-related information. The personal information from this category may be disclosed to your listed references in some circumstances.
• Category G: Non-public education information. The personal information from this category is not disclosed to third parties.
• Category H: Inferences drawn from other personal information. The personal information from this category is not disclosed to third parties.
• Category I: Sensitive Personal Information. The personal information from this category may be disclosed to human resources information service providers; financial investment and financial institution service providers; insurance providers; payroll service providers; third party payment processing providers; professional service providers such as attorneys.

Sales and Sharing of Personal Information

Fenton has not sold personal information as that term is defined under applicable law.

Fenton has not shared your personal information for purposes of targeted or cross-contextual behavioral advertising.

• Category A: Identifiers. The personal information from this category may be retained for four (4) years after either of: (i) the date of resident’s move-out, (ii) the date of application, or (iii) the date of sale of property where resident lived.
• Category B: California Customer Records personal information categories. The personal information from this category may be retained for four (4) years after either of: (i) the date of resident’s move-out, (ii) the date of application, or (iii) the date of sale of property where resident lived.
• Category C: Protected classification characteristics under California or federal law. The personal information from this category may be retained for four (4) years after either of: (i) the date of resident’s move-out, (ii) the date of application, or (iii) the date of sale of property where resident lived.
• Category D: INTENTIONALLY OMITTED.
• Category E: Geolocation data. Personal information obtained through surveillance cameras will be retained for a maximum of 120 days, unless the information is needed for a legal or business purpose. Information associated with key FOBs may be retained for the duration of a resident’s tenancy.
• Category F: Professional or employment-related information. The personal information from this category may be retained for four (4) years after either of: (i) the date of resident’s move-out, (ii) the date of application, or (iii) the date of sale of property where resident lived.
• Category G: Sensitive Personal Information. The personal information from this category may be retained for four (4) years after either of: (i) the date of resident’s move-out, (ii) the date of application, or (iii) the date of sale of property where resident lived.

• Category A: Identifiers. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date of termination of employment.
• Category B: California Customer Records personal information categories. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category C: Protected classification characteristics under California or federal law. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category D: Internet or other similar network activity. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category E: Geolocation data. The personal information from this category may be retained for the period during which we have a legitimate need to maintain the information. This time period may be shorter than the standard period of time employment data may be retained by the company.
• Category F: Professional or employment-related information. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category G: Non-public education information. The personal information from this category may be retained for four up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category H: Inferences drawn from other personal information. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.
• Category I: Sensitive Personal Information. The personal information from this category may be retained for up to, but no longer than, seven (7) years after either: (i) the date the information is collected, or (ii) the date termination of employment.

Access to Specific Information and Data Portability Rights

You may have the right to request that Fenton disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will disclose to you the information as required by applicable law.

Correction Request Rights

You may have the right to request Fenton correct any inaccurate personal information we may hold about you. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will use commercially reasonable efforts to correct inaccurate personal information, taking into the account the nature of the personal information and the purpose for our processing.

Deletion Request Rights

You may have the right to request that Fenton delete your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Appeal Rights

You may have the right to appeal a decision regarding your request (see Exercising Rights).

Exercising Rights

For residents, potential residents, or consumers: To exercise the access, data portability, correction and deletion rights described above, or to appeal a refusal to take action on a request, please submit a verifiable consumer request to us by either:

• Calling us toll-free at: (833) 965-2107
• Emailing us at: privacy@hgfenton.com
• Filling out the form at: https:/hgfenton.com/contact-us/

For employees, job applicants, and contractors: To exercise the access, data portability, correction and deletion rights described above, please submit a request to us by either:

• Visiting https://www.hgfenton.com/contact-us-2/
• Emailing atanaka@hgfenton.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent to make a request on your behalf, please provide us with a written authorization that identifies the agent and describes the specific authority that has been assigned to the agent. Please note we may need to verify the identity of the agent before we can comply with your request.

To make a request, please:

• 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 cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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.