Updated effective May 25, 2018

Greystone Properties, its subsidiaries and related entities (“Greystone Properties,” “we,” “our” or “us“) respects your privacy and is committed to protecting your information. This Privacy Policy (alternatively, “Policy”) describes our privacy practices with regard to information about you that could reasonably be used to identify you personally, or that is associated with information that identifies you (“Personal Information“).

“Personal Information,” also known as “personal data,” may include, where applicable: your name; your home or other physical address; your email address; your telephone number or other contact information; Social Security number; driver’s license or state identification card number; financial information (i.e. bank account number and routing number); your GreystoneGreycard account username and password; and/or any other identifier that identifies with you. “Personal Information” may also include your Greystone Greycard account information – i.e. your username and password.

Greystone Properties is also committed to transparency in the way we use your Personal Information. Please read this policy carefully to understand our policies and practices regarding your Personal Information and how we may use it. By accessing or using this Web site, you agree and consent to the practices described in this Privacy Policy, and as described below, we will ask you for specific consent to use your Personal Information.

This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please review this Policy periodically for updates. If we make significant changes to the way we process or use your data, we will provide specific notification of those changes to you prior to those changes taking effect.

Please note that this Policy does not govern the practices of third parties, such as our partners, third party service providers, or advertisers. Any information you provide to a third party while utilizing their website or service will be governed by the third party’s privacy policy and terms of use, and not this Policy. Please review such third party policies and terms of use carefully.

COLLECTION OF PERSONAL INFORMATION

When you use our Website or other Services, we collect certain information about you. Greystone Properties collects and obtains your information in a few different ways. We collect information that you choose to give to us, information that we obtain through your use of the Web Site, and information that we obtain from third parties or other sources.

Information You Choose to Give Us

Information directly provided

We may ask for your consent to provide Personal Information to use certain services on our Web Site, to communicate with us, to apply for an apartment or employment, or to use other services provided by Greystone Properties. We may ask you to provide certain Personal Information at various places and through various mechanisms on the Web Site. This may include, for example, when you fill out and submit forms (such as forms requesting information needed to consider you for apartment rentals or potential employment opportunities), when you initiate payments to us through the Web Site, when you participate in promotions, contests, or sweepstakes on the Web Site, or when you post information to an interactive forum, bulletin board, or chat room. We may also collect Personal Information when you register for e-mail communications, and when you submit a survey response, question or request to the Web Site or e-mail address link on the Web Site.

Offline collection from you

Greystone Properties may also collect Personal Information and non-Personal Information from you through means other than the Web Site. This may include offline collection, such as when you submit a paper application to rent an apartment, make a rent payment by check, or call or visit the management office at an Greystone PropertiesBay property. It may also include e-mails that you send to us separate from the Web Site. This Privacy Policy does not apply to Personal Information or any other information that you provide to us through means other than the Web Site. However, if we combine Personal Information we collect from you outside of the Web Site with Personal Information that we collect through the Web Site, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

Information We Obtain through Your Use of the Website

Additionally, we will collect other information that you voluntarily provide through your use of the Web Site or our services – for instance, you may ask us questions or provide comments to us via the “Contact Us” page of our Web Site. When using the “Contact Us” form, we will ask you to provide certain Personal Information, such as your name and email address, so that we can respond to your questions or comments. We will also collect any other information that you choose to provide via the “Contact Us” page, including any additional Personal Information beyond your name and contact information. However, we encourage you not to provide or share any Personal Information via the “Contact Us” page that you would not want to be viewed by others or otherwise be made publicly available.

Passive Information Collection.

When you visit the Web Site, we automatically collect certain information about your activities (“Web Site Usage Information”). Web Site Usage Information is information about how our visitors use and navigate the Web Site. This includes, for example, the number and frequency of visitors to each web page, the length of their stays, the type of browser each visitor is using to view the Web Site (for example, Internet Explorer, Firefox), the type of operating system each visitor is using, (for example, WindowsOS, Mac OS), the domain name of each visitor’s Internet service provider, the location data such as the visitor’s IP address, the address (or “URL”) of the web site that the visitor came from before visiting the Web Site, which pages were visited on the Web Site, what was clicked on, and certain other available information. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which our web servers use to identify where to send the information your computer requests. When you request pages from the Web Site, our servers log your IP address as well as information about your activities on those pages. To collect this Web Site Usage Information, the Web Site and any e-mails sent to you by the Web Site (or otherwise by Greystone Properties ) may utilize cookies, web beacons, embedded scripts or similar technologies.

• A cookie is a small data file sent to your browser when you visit the Web Site, and stored on your computer. Cookies automatically identify your web browser to the Web Site whenever you visit the Web Site, and may make navigating and using the Web Site easier for you. Also, by tracking how and when you use the Web Site, cookies help us determine which areas are popular and which are not. Additionally, accepting cookies may allow you to, among other things, personalize and enhance your experience on the Web Site. If you do not wish to allow for use of cookies, you can generally opt-out of providing this information by setting your browser to reject cookies. However, please be aware that some areas of the Web Site may not provide you with an acceptable user experience if you have disabled the use of cookies.
• A web beacon is a small, often invisible, graphic element included in a web page or e-mail. It allows the party that set the web beacon to monitor and collect certain limited information about the viewer of the web page or e-mail message (such as the type of browser downloading the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed, as well as the URL of the page the web beacon comes from). We may use web beacons for many purposes, such as to count visitors to the Web Site, or to monitor how visitors navigate the Web Site, and we may include web beacons or similar technologies in e-mails in order to count how many e-mails (or particular articles, links, etc.) we sent were actually opened.
• An embedded script is programming code that is designed to collect information about your interactions with the Web Site. It is temporarily downloaded onto your computer from our Web server or a third party we work with, is active only while you are connected to the Web Site, and is deleted thereafter.
  Web Site Usage Information is frequently anonymous information, since it is not normally associated with you or your identity. It may be used for a number of purposes, such as system administration, to help us understand the demographics of the visitors to the Web Site, to enhance the performance and usefulness of the Web Site, to report aggregate information to our business partners, or to audit use of the Web Site. If Web Site Usage Information is combined with your Personal Information in a manner that it is directly associated with your identity, then it will be treated as Personal Information under this Privacy Policy.

Information We Collect from Third Parties

Greystone Properties also works with third party web site operators to provide services such as rental applications, resident services, employment application screening, investor relations information, and in-screen chat applications (“Portal Sites”). For instance, third party operators collect your payment card information via their Portal Site in order to complete certain transactions. When you input Personal Information to one of our Portal Sites, you are providing that information to a third party. Our Portal Sites may use framing techniques to make it appear that the user is still on the Web Site when the user is actually on a Portal Site. For example, if you are on a page that has the look and feel of www.Greystone Propertiescommunities.com, but the address listed in your browser is a different web site URL, then you should know that any information you provide is being collected by this third party and not governed by this Privacy Policy. You should carefully review the privacy policy and terms for any third party Portal Site.

Our third party service providers, advertisers, and other companies may use cookies or other similar technologies to collect your information and track your behavior. For instance, our Web Site may use Google Analytics and/or other services to analyze visitor use of the Web Site. These companies may collect non-personally identifying information about your use of our Web Site and other services over time and across different services. Additionally, some companies may use information collected to deliver targeted ads on behalf of us or other companies, including on other websites or online services. Greystone Properties is not responsible for the functioning of cookies or other technologies used and placed by third parties on your computer or device.

How We Respond to “Do Not Track Signals”

Our systems do not respond to browser “Do Not Track” signals.

Information Collected from Other Sources.

We may receive Personal Information about you from other sources. For example, if you are applying for an apartment, condo, corporate housing, or employment, either via the Web Site or offline, we may obtain information from third parties about your creditworthiness, among other information, as part of the application process. Additionally, we may obtain information you provide to a third party via a Portal Site in order to provide certain services to you – for instance, the third party operator of an in-screen chat function may provide us your information in order to review your feedback or resolve a question a question you may have.

Personal Information about you that we receive from other sources may be combined with Personal Information we collect through the Web Site. In those cases, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.

Children

The Web Site is intended only for adults over the age of eighteen (18), and is not directed to children younger than age eighteen (18). Greystone Properties also does not knowingly collect Personal Information from children under the age of thirteen (13) on the Web Site and will delete any information if later determined to be from a person younger than age thirteen (13).

USE OF PERSONAL INFORMATION

At Greystone Properties, we retain and use your Personal Information to: (1) provide you with services or process transactions that you have requested; (2) communicate with you regarding information, features or offers that we believe will be of interest to you; (3) respond to your questions or other requests; (4) contact you with regard to the Web Site or otherwise; (5) process any applications, payments or changes to your account information; (6) process other information or Personal Information that you submit through the Web Site; (7) conduct user surveys; (8) contact you regarding a sweepstakes, contest or promotion in which you have participated; (9) evaluate your application for employment; and (10) fulfill other purposes disclosed at the time you provide your Personal Information. We may also use the information you provide to improve the Web Site or Greystone PropertiesBay’s services, to customize your experience on the Web Site, to serve you specific content, or for other business purposes.

If you are purchasing a service, we will request and collect certain financial information from you. Any financial information we collect is used to bill you for the services you purchased. If you purchase by credit card, this information may be forwarded to your credit card provider. You may also be asked to disclose Personal Information to us so that we may provide online technical support and troubleshooting for these services.

SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES

Non-personally identifiable information

We may share non-personally identifiable information, such as Web Site Usage Information or other aggregated user statistics, with third parties. In addition, we may share your Personal Information as set forth in this Privacy Policy, in any manner in which you expressly consent via the Web Site, or in the following circumstances:

Affiliated or Subsidiary Companies.

We may share Personal Information with our affiliated or subsidiary companies who require access to Personal Information for legitimate business purposes related to your tenancy or to process any application, request, inquiry, or other information or Personal Information you submit via the Web Site. This includes the owner of any community where you make application or where you lease, as well as the management company for such community.

Direct Marketing

We may share information governed by this Policy – including Personal Information – with third party data analytics firms, and/or marking firms for direct marketing or remarketing purposes. Greystone Properties only shares this information collected from users with US-based IP addresses.

Third parties providing services on our behalf

We may share your Personal Information with third parties who perform services on our behalf or on behalf of the owner of one of our properties and who may use this information for their own purposes, including sending advertising to you. This includes, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. We also may share Personal Information with our business partners in order to provide services and offerings to you. These third parties may have access to Personal information in order to provide these services to us or on our behalf.

Legal Requirements and Law Enforcement.

We may disclose Personal Information when we believe in good faith that the law requires it; when we receive and enforceable request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Web Site and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Web Site, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

Sweepstakes and Promotions.

If you choose to enter a sweepstakes, contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

Corporate Change.

We reserve the right to disclose and transfer your Personal Information in connection with a corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change. In addition, when a potential buyer is interested in purchasing one of our properties, we may provide the potential buyer with information about the property and the tenants who live there, which may include your Personal Information. Upon the sale of the property in which you live, all of your Personal Information may be transferred to the purchaser.

SECURITY

While we take reasonable steps to secure your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information on the Web Site or on other servers or databases to which the information may be transferred can be guaranteed to be completely secure. Please consider this prior to submitting your Personal Information to us via the Web Site.

We use current security measures to safeguard your personal information:

• All of the personal information you provide us is stored in a secure computing environment protected by secure firewalls and intrusion prevention systems to avert unauthorized access.
• We protect the confidentiality of your data by encrypting sensitive information.
• We build information security into our systems and networks using internationally recognized security standards, regulations, and industry-based best practices.
• We control access so that only people who need to access the information are able to. All staff of Greystone Properties are required to adhere to our policies on confidentiality and security.
• When you access secure areas of our web sites, we use the Secure Sockets Layer (SSL) protocol to provide you with the safest, most secure web experience possible. SSL technology enables encryption (scrambling) of sensitive information, including passwords and banking information, during your online session. There are two cues to show you that you are using a secure area. First, the web site address (or URL) appears as https:// (instead of just http://) – the “s” is for “secure.” Second, a lock or key indicator appears in the status bar of your web browser. We use https:// only for secure pages, i.e. pages that transfer confidential information. Pages that are only used for product offerings will still use the regular http:// since no sensitive information is being passed through them.
• Secure areas of the site have a time-out feature. If you leave your secure session inactive for some time, it times-out to prevent unauthorized access.

THIRD PARTY CONTENT

When you are on the Web Site, certain content may be served by a third party. These third parties may also drop their own cookies and/or use web beacons or embedded scripts, which may be used to identify some of your preferences or to recognize you if you have previously had contact with those third parties. We do not control the use of such technology by third parties, the information they collect, or how they use such information.

LINKS TO OTHER WEB SITES

The Web Site may contain links to other web sites whose information practices may be different from ours. You should consult the specific privacy policies posted on these sites when linking to them.

PRIVACY POLICY CHANGES

We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Web Site. We will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless we receive your consent to the new or revised policy.

EXERCISING CONTROL OVER YOUR PERSONAL INFORMATION

In general, you may browse the Web Site without providing Personal Information. However, if you choose not to provide certain information through this Web Site or a Portal Site, we may not be able to provide certain services or process certain of your requests. You may not be able to submit an application for employment, may not be able to access resident services online, or otherwise use all of the features and products that we make available online.

Updating your information

Depending on the functionality associated with the Web Site feature you are using, you may be able to update certain of your Personal Information on the Web Site.

Please note that in accordance with our routine corporate record-keeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

Consent to transfer

The Web Site is operated in the United States. Your Personal Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Web Site or providing us with your information, you consent to this transfer and the retention of and processing of your data in the United States.

CALIFORNIA AND CONNECTICUT RESIDENTS

Your California Privacy Rights

We may from time to time elect to share certain information about you collected on this Web Site with our affiliates or partners for their own direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to: Greystone Properties , 7206 Schomburg Rd., Columbus, GA 31909 (Attn: Legal Dept. – CA Privacy Request). Any such request 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 address.

California Minors

As mentioned above, the Web Site is intended only for adults over the age of 18. Any California residents under the age of 18 who have registered to use the Web Site, and who have posted content or information on the Web Site, can request that such information be removed from the Web Site by contacting us at info@greystoneproperties.com. When making such a request the minor must state that the minor personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post and archived copies of it may be stored by search engines or others we do not control.

Connecticut Residents

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.

EU Residents

Greystone Properties provides services exclusively within the United States (“U.S.”), and does not own or manage property outside the U.S., intentionally market its services extraterritorially, or have a presence outside the United States, including in the European Union (“EU”), any EU-Member State, or any state belonging to the European Economic Area (“EEA”). Greystone Properties also does not market its services to individuals in Europe, including EU residents. To the extent that an EU resident chooses to visit and/or use Greystone Properties’s Web Site and services, they consent to the practices described in this Privacy Policy and agree to its terms.

Retention

Greystone Properties retains all data collected according to this Policy. While we do not currently purge such data, it is encrypted in the storage database.

QUESTIONS

If you have any questions about this Privacy Policy, you may contact us by email at info@greystoneproperties.com.