1. GENERAL

This SRM Urban Privacy Policy (“Privacy Policy”) describes how SRM Urban and its affiliates (collectively, “SRM,” “we” “us” or “our”) treat and use data and information about you (“user”, “you” or “your”) that SRM collects and receives directly and indirectly from you, about you through and from the Websites (as defined below), the Services (as defined below), and third parties. This policy applies to all visitors, users, residents, prospective residents, tenants, prospective tenants, employees, job applicants, contractors, consumers and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. The “Websites” means all websites operated now and in the future by or for SRM, any websites or internet locations to which this Privacy Policy is linked and include without limitation: srmurban.com and all other SRM websites linked to these Terms now or in the future. The “Services” means those services, products or features SRM may offer from time to time to residents, employees, job applicants, contractors, and consumers, including, without limitation, listings of available residential and commercial properties, online rental application services, online rental or lease payment services, online service request capability, community classifieds, online career center and job application capability, testimonial submission center, community rewards programs, and event calendars and newsletters. We want you to understand how we collect, use, and disclose data collected online and offline, including your interactions with our Services and Websites, specifically the portions of the Websites or Services that require you to register and/or log in to gain access, fill out forms or otherwise provide information about you. 2. ACCEPTANCE OF PRIVACY POLICY This Privacy Policy is made part of, and incorporated into, SRM’s Terms of Use (“Terms”) by reference. As described in the Terms, by accessing or using each Website and Service, and moving forward to provide your personal information, you acknowledge that you have read, understood and agree to be bound by the Terms, including this Privacy Policy, which form an agreement that is effective as if you had signed it. 3. TYPES AND COLLECTION OF INFORMATION We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device ("personal information"). In each case, we collect and disclose your personal information for legitimate business purposes. SRM will not collect additional categories of personal information or collect personal information from additional sources without notifying you. For residents, potential residents, or consumers, learn more about SRM’s collection of your personal information. 4. USE OF PERSONAL INFORMATION We may use or disclose the personal information we collect from you for one or more business purposes. SRM will not use the personal information we collect from you for materially different, unrelated, or incompatible purposes without providing you notice. For residents, potential residents, or consumers, learn more about SRM’s use and disclosure of your personal information. 5. SHARING OF PERSONAL INFORMATION SRM may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. For residents, potential residents, or consumers, learn more about SRM’s sharing of your personal information. 6. COOKIE AND OTHER TRACKING TECHNOLOGIES · Cookies. Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Websites and Services, we may place one or more cookies on your computer or other electronic device. We may use cookies to connect your activity on the Websites with other information we store about you in your account profile or your prior interactions on the Websites to, for example, store your preferences. The use of cookies helps us improve the quality of the Websites and Services for you, by identifying information which is most interesting to you, tracking trends, measuring the effectiveness of advertising, or storing information you may want to retrieve on a regular basis, such as your favorite properties. At any time, you may adjust settings on your browser to refuse cookies according to the instructions related to your browser. You may also adjust settings on your mobile device and mobile browser regarding cookies and sharing of certain information, such as your mobile device model or the language your mobile device uses, by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or mobile device manufacturer. However, if you choose to disable cookies, many of the Websites and Services will not operate properly. · Web Beacons. The pages on the Websites may include Web beacons or pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or Internet Protocol address. We may, for example, implement a pixel on the pages of the Websites where you view a certain advertisement so that we can track whether you visit a website associated with that advertisement at a later time. · Third Party Analytics and Other Tracking Tools. We use Google Analytics, which collects information about our users of our Websites and reports usage trends to us, without identifying individual visitors. Google Analytics may collect similar information from you when you are on other websites. To learn more about Google Analytics, including how to opt out, please visit https://tools.google.com/dlpage/gaoptout. Other than the use of cookies set forth above, we do not currently use other third party analytics programs or knowingly permit third parties to use cookies, web beacons, or other tracking on or from our Websites. · Do Not Track. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. 7. THIRD PARTY WEBSITES Please be aware that our Websites may contain links to other sites on the Internet that are owned and operated by third parties, including, without limitation, third party providers of certain Services such as our third-party payment processing providers. The information practices of those websites linked to our Websites are not covered by this Privacy Policy and, except as required under applicable law, we are not responsible for the privacy policies of websites to which the Websites link. If you provide any information to such third parties websites, different rules regarding the collection and use of your personally identifiable information may apply. We strongly suggest you review such third party’s privacy policies before providing any data to them. These other sites may send their own cookies or web beacons to users, collect data or solicit personally identifiable information. We cannot control this collection of information. You should contact these entities directly if you have any questions about their use of the information that they collect. 8. YOUR RIGHTS AND CHOICES The CCPA provides consumers (California residents) with specific rights regarding their personal information, including the right to access specific information, the right to data portability, and the right to request deletion of your information in certain circumstances. For residents, potential residents, or consumers, learn more about your rights under the CCPA. 9. NON-DISCRIMINATION We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: · Deny you goods or Services. · Charge you different prices or rates for goods or Services, including through granting discounts or other benefits, or imposing penalties. · Provide you a different level or quality of goods or Services. · Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or Services. 10. INFORMATION SECURITY, RETENTION AND STORAGE We have implemented various reasonable security measures for the purpose of protecting your personal information against unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against other unlawful forms of processing. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting personal information to the Websites and Services. Any transmission of personal information is at your own risk and SRM is not responsible for circumvention of any privacy settings or security measures contained on the Websites. We will retain your personal information for as long as you have an active account, as needed to provide you with the Services, to comply with our legal, financial reporting, or compliance obligations, and to enforce this Privacy Policy and our Terms. 11. CHILDREN The Websites are directed to persons 18 years of age or older. SRM and the Websites do not knowingly collect information from or provide Services to children under age 18. If you are under age 13, you are not permitted to use the Websites or any Services therein, or to submit any personally identifiable information to the Websites. Please see the Terms for more information regarding use of the Websites and Services by persons under age 18. 12. OTHER CALIFORNIA PRIVACY RIGHTS California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to communications@srmurban.com or call us at the toll-free number: (833) 965-2107. 13. INQUIRIES, CORRECTIONS AND COMPLAINTS If you have questions or concerns regarding this Privacy Policy or about privacy at our Websites, please contact us by sending an email to communications@srmurban.com or calling us at the toll-free number: (833) 965-2107. 14. MODIFICATIONS OF THE PRIVACY POLICY We reserve the right to modify this Privacy Policy at any time. We encourage you to frequently review the Privacy Policy for any modifications. You can determine when the Privacy Policy was last revised by referring to the “Last Revised” legend at the top of this page. When we make material changes to this privacy notice, we will notify you of the changes and post the updated notice on our Website and update the notice's effective date. Your continued use of our Services, Website, and other offerings following the posting of changes constitutes your acceptance of such changes. SRM Urban Previous Privacy Policy effective until October 14, 2020 15. CONTACT INFORMATION If you have any questions or comments about this notice, the ways in which SRM collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Phone (toll-free): (833) 965-2107 Email: communications@srmurban.com