Maximus Privacy Policy

Your privacy is important to Maximus Real Estate Partners, its subsidiaries and affiliates (collectively, “Maximus,” “we,” “us” or “our”). This privacy policy (“Privacy Policy”) describes the online collection of personal information by Maximus, and how we use that information. By using an official Maximus website or any of our affiliated residential websites which are listed at https://maximusrepartners.com/investments/ (collectively, the “Site”), you acknowledge you have read and understood the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Site.

If you are a California resident, see “Your California Privacy Rights” section below for information provided pursuant to the California Privacy Rights Act (“CPRA”), including information about how to exercise your data access rights.

For purposes of this Privacy Policy, unless otherwise required by applicable law, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This may include, without limitation information that directly identifies you or which could be used to identify you such as your name and contact details, or your user account information. “Personal information” does not include information that is considered publicly available, aggregated, or deidentified under applicable law.

The categories of personal information we may collect and process (but only to the extent and in a manner consistent with applicable law), and the sources from which we collect them are as follows:

• Personal identifiers and personal details. Maximus collects personal identifiers (such as your name, email address, work address, telephone number, or contact details) and relevant personal characteristics directly from you when you communicate with us or otherwise interact with our Site.
• Internet, Cookies/Pixels and Network Activity Information. We may collect your IP address when you visit our Site. We also use tracking tools like cookies and pixels to passively collect information about how you interact with our Site and online content. This might include device identifiers, the type of browser and operating system you are using, your browsing history on our Site, what areas of our Site you visit and for how long, what content you view and click on, what site you came from to get to us and what site you go to when you leave us, and your interactions with our digital ads and content on other sites. We may collect and record page interaction information and other electronic communications and content from your use of the Site, including mouse movements, clicks, scrolls, and methods used to navigate away from the page. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. For example, we may use tools that enable our customer support team to monitor your sessions on our Site for quality assurance purposes and to make improvements to the Site and our services. We may engage or otherwise allow other parties to also collect information on our Site in these ways. To offer you a consistent and personalized experience in your interactions with us, information collected through one service we provide may be combined with information obtained through other services.
• Payment Information. We collect billing information, such as your account number, credit card number, expiration date, card verification number, and billing address if you make a purchase through our third party service provider.
• Geolocation information. We may automatically collect information about your geolocation when you access our Site, including information about your general location using your IP address and your zip code.
• Employment-Related Information. We may also process your personal information if you apply to work at Maximus or at any of Maximus’ affiliated companies via our careers pages. If you apply for a job, we may collect information about your work experience and previous employment, your education history, your resume, the URL to your personal or professional website, your workplace skill sets and certifications, whether you need a visa to work in the United States, and salary expectations. If you apply for a job, you can choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status. If you are a California resident, please also see the California Notice of Collection of Personal Information for Job Applicants, which is posted on our careers pages and can also be found here.
• Audio information. We may monitor and collect activity and communications made using Maximus communications and computing devices and systems (such as our phone devices and email systems). For example, we may record audio during customer service calls for quality assurance purposes.
• We may draw inferences from any of the above categories, and we use such inferences for the same purposes as the purposes for which the information was collected.
• Sensitive personal information. We do not intend to collect any sensitive personal information or sensitive personal data as those terms are defined under applicable laws.

We collect these categories of personal information to carry out the purposes described in the “USE OF YOUR PERSONAL INFORMATION” section below.

We may use your personal information to provide services and to support our business functions, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including the following:

• to enable us to carry out our obligations arising from any contracts and to provide you with the information and services that you request from us;
• to operate and improve our Site and services;
• to enable us to respond to an inquiry or other request you make when you contact us via our Site, including for customer service support;
• to provide you with more effective customer service;
• performing research and analysis aimed at improving our services and technologies;
• displaying content and advertising that are customized to your interests and preferences;
• to communicate with you to provide you information about other services we offer that are similar to those that you have already purchased or inquired about as we feel may interest you; and
• to enable us to process and consider your application to join Maximus.

Maximus does not sell and has not sold your personal information or transferred personal information to third parties to use for their own benefit in the preceding 12 months. Maximus also does not share your personal information for targeted or cross-context behavioral advertising. Relatedly, we do not sell or share personal information of California residents under 16 years of age.

For purposes of this Privacy Policy, “sell” means the sale or transfer of your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions in applicable law.  For purposes of this Privacy Policy, “share” means transferring, making available or otherwise disclosing your personal information to another party for purposes of sending advertising to you based on your personal information obtained from your activities across distinctly-branded sites. “Share” and “sharing” as used in this section, does not include transfers of personal information described in this Privacy Policy as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or in the event of insolvency, bankruptcy, or receivership. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Policy.

Please see the section on “COOKIES” below for information about the collection and use of personal information by third parties who process information collected by cookies and similar technologies that we permit them to use on the Site.

We disclose personal information to certain third parties to enable them to fulfill the purposes described in the “Use of Your Personal Information” section of the Privacy Policy above, and without limitation, for the following business purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us. However, your personal information will not be disclosed to an unaffiliated third party and will not be used to build a profile about you or otherwise alter your experience outside the current interaction with us.
• Performing services on our behalf,including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
• Providing advertising and marketing services, except for cross-context behavioral advertising as defined under applicable law.
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We will only use your personal information as reasonably necessary and proportionate to achieve these purposes. Where we provide your personal information to third-party service providers, they are contractually required to keep your personal information confidential and secure, and must only use your personal information as instructed by us.

In the preceding 12 months, we have disclosed the categories of personal information described above in the “Categories and Sources From Which We Collect Personal Information” section, with the following categories of service providers:

In general, the third-party providers used by us will only collect, use and disclose your personal information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction that either you or us.

Our Site contains links to other sites. In general, we are not responsible for the privacy practices or content of such other sites. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy unless the third-party website says that the collection of personal information is subject to our Privacy Policy, for example, in the case of our Resident Portal, which links to a site hosted by Yardi, one of our third-party service providers.

In particular, our Site uses the following social media plug-ins: Facebook, Twitter, and Instagram. The plug-ins can be identified by the social media buttons marked with the logo of the provider of the respective social media networks. We have implemented these plug-ins using a 2-click solution, which means that when you use our Site, personal information will not initially be collected by the providers of these social media plug-ins. Only if you click on one of the plug-ins will your personal information be transmitted. By activating the plug-in, information is automatically transmitted to the respective plug-in provider and stored by them. We neither have influence over the information collected and processing operations conducted by the providers, nor are we aware of the full extent of information collection, purposes, or the retention periods. Information on the purpose and scope of information collection and its processing by the plug-in provider can be found in the respective privacy policies of these providers, where you will also find further information on your rights and options for privacy protection.

• Facebook Inc.
• Twitter, Inc.
• Instagram.

Where necessary, this Site uses cookies to store information about a visitor’s preferences and history in order to better serve the visitor and/or present the visitor with customized content. We, and third parties we allow, use cookies and other similar technologies. We may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:

Essential. Some cookies are essential in order to enable you to move around our Site and use its features, such as accessing secure areas of our Site. Without these cookies, we cannot enable appropriate content based on the type of device you are using.

Analytics. Personal information collected via cookies for analytics purposes may include: information about your browser, network, and device; web pages you visited prior to coming to our Site; IP address; clicks; internal links; pages visited; scrolling; searches; and timestamps. We use this information to learn about site traffic and activity. In particular, we use Google Analytics to measure how you interact with our Site and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page here. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics, view here.

Targeted Advertising. Third parties, such as Google, may use cookies and other similar technologies to collect or receive information from our Site and elsewhere on the Internet and use that information to provide you with targeted ads. If you would like to opt-out of such advertising practices on the particular device on which you are accessing this Privacy Policy, please go to here.

There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

Maximus is committed to protecting the security of your personal information. We take reasonable steps (including appropriate technical and organizational measures) in an effort to ensure your personal information is processed securely to protect the confidentiality, integrity and availability of your personal information in accordance with this Privacy Policy. The nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.

Maximus will store your personal information for as long as we have to by law, and where there is no legal requirement, we will only store your personal information for as long as necessary to fulfill the purpose for which the personal information was collected.

We receive and process Global Privacy Control Signals (“GPC Signal”) for requests to opt-out of sale or sharing.  We process the commonly used and industry standard GPC Signals but because this is new technology and new providers may offer solutions, we will do our best to recognize, process, and honor a GPC Signal that meets the legal standards and is widely adopted in the industry.

The Site and our services are intended for users age sixteen and older. Maximus does not knowingly collect personal information from children. If we discover that we have inadvertently collected personal information from anyone younger than the age of sixteen, we will delete that information. We do not sell personal information for valuable consideration or share the personal information for behavioral or targeted advertising of any individual we know to be under the age of 16.

California Shine the Light

Although we do not currently share your information for other companies’ direct marketing purposes, residents of California have the right to request information from us regarding other companies to whom we have disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy@maximusrepartners.com or write to us at:

Maximus Real Estate Partners

One Maritime Plaza, Suite 1900

San Francisco, CA 94111

Your Privacy Rights Under the CPRA

1. Right to Know and to Access. Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including whether we sell or share such information. You also have the right to request access to personal information collected about you and information regarding the following:

• The categories of personal information we collected about you;
• The categories of sources of that information;
• The business or commercial purposes for which we collect, sell or share personal information about you;
• The categories of personal information about you that we have disclosed about you and the categories of persons or vendors to whom it was disclosed for a business purpose; and
• The specific pieces of personal information we have collected about you.

We provide this information in this Privacy Policy, but you may also submit a request for this information as described below. To protect your personal information, we may request additional information to verify your identify before we act on your request. To the extent legally required, we will provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.  We may provide this data to you via email to the email address you have provided with your request.

2. Right to Correction. You have the right to request that we correct any inaccurate personal information we maintain about you. In response to your request, we may request additional information showing that the information you want to correct is inaccurate.

3. Right to Deletion. You may request that we delete your personal information. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

4. Right to Opt-Out of the Sale or Sharing of Personal Information to Third Parties. You have the right to opt out of the sale or sharing of your personal information by Maximus to third parties. We do not sell or share your personal information, as those terms are defined under California law.

5. Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to fulfill the purposes reasonably expected by an average consumer who requests those goods or services. California law considers the following pieces of personal information to be “sensitive:” social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data. We do not intend to collect or use sensitive personal information for any purposes, including to infer characteristics about you.

6. Non-Discrimination or Retaliation. We will not discriminate or retaliate against you for exercising any of your data privacy rights.

How to Submit a Request

You or an authorized agent may submit a request to exercise your rights through one of the following means:

1. By filling out a Consumer Data Request Form available here.

2. By emailing us at privacy@maximusrepartners.com.

Consumers may be required to submit name, email address, the website they have visited, and their city and state so that we can verify the request. We will not collect additional personal information from you for the sole purpose of your exercising your rights under the data protection laws.  Similarly, we will not require you to create an account of any sort, solely for the purpose of exercising your rights under applicable data protection laws.

Authorized Agent

California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agency must follow the process described above to make a request, and we will additionally require the authorized agent to verify his/her own identity and we will confirm the agent’s authority with the California consumer about whom the request was made.

Job Applicants

California residents who use job application features of the Site should see our Notice of Collection of Personal Information for California Residents, which may be posted on the job application webpage(s) and is also available here.

California Do Not Track Disclosure

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this policy, we will update the “Effective Date” below and notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

For more information, contact us at: info@maximusrepartners.com, or Maximus Real Estate Partners, One Maritime Plaza, Suite 1900, San Francisco, CA 94111.

June 27, 2023