1. Background and scope

This Privacy Notice (“Notice”) is issued on behalf of the Hines (“Hines”,
“We”, “Our”, “Us”) group of entities, including Hines Living US LLC. Hines
is sensitive to the confidentiality of your Personal Information and has
created this Notice in order to demonstrate Hines’ commitment to privacy.
This Notice applies to all information you provide to Hines, or Hines
obtains from you, or about you.

If we change our Notice we will post the changes on this page and may place
notices on other pages of the web site, so that you may be aware of the
information we collect and how we use it at all times.

2. 
   
   What Personal Information do we Collect?
   

Personal information refers to data that could
be used, alone or in combination with other data, to identify you as an
individual. Personal Information also includes information designated as
such under California law. Personal Information does not include publicly
available information, or information that is deidentified or aggregated
information.

The personal information we collect about you is to facilitate the provision
of residential housing on your behalf and associated services.

Hines may collect the following categories of personal information:

• Identifiers

  • contact information (such as name, alias, postal address,
    telephone number, email address, zip code);

  • passport details, driver’s license number, social security
    number;

  • online identifiers (such as IP address, online account name,
    or other unique online identifier);

  • Other similar identifiers

• Personal information not otherwise
  described in another category, including, but not limited to,
  signature, insurance policy number, bank account number, credit card
  number, debit card number, or any other financial information.

• Characteristics of protected classifications under California or
  federal law (such as gender or age);

• Commercial Information, including records of services obtained or
  considered;

• Internet or other electronic network activity (such as browsing
  history, search history, the device and network you are using to
  connect, web server logs, and information regarding a consumer’s
  interaction with an internet website application, or
  advertisements), as further described in Section 11;

• Geolocation data;

• Audio (such as voice recordings used for quality control and dispute
  resolution), electronic, and visual information (such as video
  surveillance);

• Professional or employment-related information (including
  occupation, job title, department, and name of organization and job
  history);

• Inferences drawn from other information to create a profile
  reflecting a consumer’s preferences, characteristics, psychological
  trends, dispositions, behavior, attitudes, intelligence, abilities,
  and aptitudes; and

• Sensitive information, such as social security, driver’s license,
  state identification card, or passport number

With respect to minors, we may collect the names of minors as occupants of
your household if you fill out an application or become a resident. We do
not intentionally collect Personal Information from minors without the
consent of a parent or guardian. Any Personal Information of minor is
protected according to this Notice.

3. How do we collect personal information?

Hines collects personal information from the following categories of
sources:

• You, we collect personal information directly from our interactions
  with you, for example:

  • When you make inquiries or provide information through our
    website, in person, or by contacting us directly by
    telephone or through email. When you complete a residential
    application. When you submit information through an online
    form, survey, or other interactive area of our website. When
    you submit information through our resident accessible
    portal. When you visit our website, use an application, or
    open an email including from data analytic providers and
    other service providers. When you interact with us on social
    media.

• Service providers that manage and maintain our services, for
  example:

  • Property management platform providers

  • Data analytics providers for our website and applications

  • Network security providers for our IT environment

Analytics

Some pages on this web site use a technology called “cookies”. A cookie is a
token that a server gives to your browser when you access a web site.
Cookies are capable of storing many types of data. Cookies help provide
additional functionality to the web site or help us analyze web site usage
more accurately. For instance, our server may set a cookie that keeps you
from having to enter a password more than once during a visit to the web
site. We use cookies to collect both Personal Information and non-Personal
Information. In all cases in which cookies are used, we will not collect
personally identifiable information except with your explicit permission.
With most Internet browsers, you can erase cookies from your computer hard
drive, block all cookies, or receive a warning before a cookie is stored.
Please refer to your browser instructions or help screen to learn more about
these functions.

4. 
   
   Why do we collect your personal information?
   

Hines may use your Personal Information to
contact you about the offerings or services in which you have expressed an
interest. We collect and use Personal Information for the following
purposes:

• providing you with residential services,
  including processing your residential application, enabling your
  residential lease, maintaining your residential lease, creating and
  maintaining a tenant account, processing your payments, subscribing
  you to our e-newsletter and other residential notification
  materials;

• developing and improving our residential services, including
  conducting market research, tenant satisfaction surveys, and
  requesting feedback on your tenant experience;

• operating, evaluating and improving our business (including
  developing new products and services; managing our communications;
  determining the effectiveness of and optimizing our advertising;
  analyzing our products, services, websites, mobile applications and
  any other digital assets; facilitating the functionality of our
  websites, and mobile applications and any other digital assets);

• responding to your enquiries;

• sending marketing and promotional materials related to our products
  and services, including, physical mailers, electronic marketing and
  notifications, and telephone calls;

• managing, maintaining, and protecting our digital environment, such
  as our network environment, our websites, and our applications,
  including detecting, deterring, protecting against, and
  investigating fraudulent, unauthorized, unlawful, or illegal
  activities and enforcing our Terms and Conditions;

• managing, maintaining, and protecting our physical environment,
  including detecting, deterring, protecting against, and
  investigating fraudulent, unauthorized or illegal activities;

• protecting the health and safety of tenants, visitors, employees,
  contractors, and others at any of our facilities;

• complying with and enforcing our legal requirements, including
  regulatory reporting and compliance, requests from law enforcement,
  requests of governmental authorities, and valid court orders or from
  other valid legal process; and

• performing business functions necessary to support and maintain the
  business of Hines, including internal accounting and administration.

We also may use the information in other ways for which we provide specific
notice at the time of collection

5. 
   
   Is personal information sold or shared with third parties?
   

In the preceding 12 months we have not “sold” (as the term “sale” is defined
in the CCPA) or “shared” (as the term “share” is defined in the CCPA)
Personal Information.

This web site is not directed to children. To our actual knowledge we do not
sell or share the Personal Information of consumers under 16 years of age.
We do not knowingly collect information from children under the age of 13 on
the web site. If you are under the age of 13, please do not provide any
Personal Information to us. If we become aware that we have collected
Personal Information from a child under the age of 13, we will make
commercially reasonable efforts to delete such information from our
database.

6. 
   Is personal information disclosed to persons or entities?
   

Hines may have disclosed your Personal Information to the persons or
entities described in this Section. We do not disclose your Personal
Information to persons or entities, except as described in this Notice.
Entities to whom we disclose Personal Information in this Section are
required to maintain the confidentiality of such Personal Information and
are prohibited from using your Personal Information for purposes other than
those agreed. As used in this section, “disclose” means transfer, send, or
otherwise made available or accessible to another person or entity, but does
not include selling or sharing as those terms are defined under the CCPA.

Your Personal Information may be disclosed to the following types of persons
or entities:

• Affiliated companies of Hines;

• Professional advisors, service providers, contractors, and suppliers
  who perform services to facilitate the business of Hines or your
  residential lease with us, such as accountants, auditors, attorneys,
  tax advisors, financial advisors, insurance brokers, entities
  assessing our compliance with industry standards, investigation
  providers, payment processing providers, printing and mailing
  companies, marketing and advertising suppliers, email delivery
  providers, on-site property management providers, security vendors,
  data analytics providers, information technology vendors, platform
  providers, resident services providers, and other similar services
  (“Service Providers”);

• Property owners;

• Intermediaries, brokers, real estate agents, renters’ agents, and
  other individuals and entities that partner with us (“Broker
  Partners”)

• Transactional parties, in the event of any contemplated or actual
  re-organization, merger, sale, joint venture, assignment, transfer,
  or other disposition of all or any portion of our business, assets,
  or stocks (“Transactional Parties”);

• Competent authorities, national and/or international regulatory
  agencies, law enforcement authorities, statutory or public bodies,
  or judicial body, court or other form of tribunal (“Governmental
  Authorities”);

In the preceding 12 months we disclosed personal information as follows:

We do not use or disclose your sensitive personal information for purposes
other than those allowed under the CCPA, including Section 7027, subsection
(m).

7. 
   
   What are your rights concerning your Personal Information?
   

Under the CCPA, you have the following rights:

• Right to Know. You have the right to know the Personal Information
  we have collected about you during the previous 12 months, including
  the categories of Personal Information and the specific pieces of
  Personal Information we have collected about you, the categories of
  sources from which the Personal Information is collected, the
  purpose for collecting, selling, or sharing personal information,
  and the categories of third parties to whom we disclose Personal
  Information.

• Right to Delete. You have the right to delete or have your Personal
  Information deleted, subject to certain exceptions. If an exception
  prevents us from deleting your Personal Information, we will inform
  you at the time you make the request.

• Right to Correct Inaccuracies. You have the right to correct
  inaccurate Personal Information or request inaccurate Personal
  Information be corrected.

• Right to No Retaliation. You have the right to exercise the above
  rights free from retaliation, including we will not deny of goods or
  services, charge different prices where the difference is not
  related to the value of the Personal Information, or offer different
  level of quality of goods or services. Denial of services or change
  in service level due to exercise of your rights does not constitute
  retaliation.

To make a request regarding your rights, contact us by telephone at
888.928.6029 or by email at [email protected]. At any time, our
residents may visit their resident portal to manage their personal
information.

In order to verify your identity, we request that you provide your name and
the address of the Hines property associated with your name. We may also
request a copy of your driver’s license if we are unable to verify your
information. In addition, we request that you provide an email address in
order to contact you regarding your request.

We will respond to your request within the 45-day period required by
applicable law. In the event we cannot respond to your request, we will
notify you of the reasons for the delay and the extended period for
response. If we determine that we cannot respond to your request for any
reason, we will notify you of the reasons for taking no action and for any
instructions as to how to appeal.

You may use an authorized agent to exercise your rights on your behalf. The
authorized agent must provide us with proof of your written permission (for
example, a power of attorney) that demonstrates authorization to submit a
request on your behalf. An authorized agent must follow the process
described above to make a request and must verify the agent’s own identity.

Further correspondence regarding questions, comments, or concerns should be
made in writing to [email protected].

8. How secure is my Personal Information?

We have put in place various security procedures as set out in this Notice.
Hines takes the security and privacy of Personal Information extremely
seriously. We have strict internal procedures which cover the storage,
access, and disclosure of your information.

We maintain an information security program designed to protect your
Personal Information, including reasonable security procedures and practices
appropriate to the nature of the Personal Information to protect the
Personal Information from unauthorized or illegal access, destruction, use,
modification, or disclosure.

9. How long do we keep your Personal Information?

We will hold your personal information on Hines’ systems for as long as is
necessary to fulfill the purpose for which it was collected or to comply
with legal, regulatory, or internal policy requirements.

10. Do you maintain linked sites?

Our websites may contain links to third party websites over which we have no
control. We are not responsible for the privacy practices or the content of
such websites. We encourage you to read the privacy policies of any linked
third party websites you visit as their privacy policies and practices may
differ from ours.

The Site may provide you with links to other web sites. This Privacy Policy
does not apply to any information that you may provide to third parties,
such as through other sites linked to through the Site. Hines is not
responsible for those sites and cannot control the content of what is
offered on those sites, or on links from those sites, or the privacy policy
or data security, if any, of those sites.

11. 
    
    Terms of Use
    

Please take the time to read our Terms, including the limitations on damages
and application of the law of the state of Texas. These terms govern our
interactions as a legal contract, and we welcome and encourage the time you
spend becoming familiar with these legal terms as much as we welcome the
time you spend on our web site and your support of Hines.

12. 
    Who do I contact to give feedback, ask questions, or make
    complaints?
    

Questions, comments, or concerns related to this Notice or our privacy
practices, can be made by contacting us at 888.928.6029 and
[email protected].

If you wish to exercise any of your Rights, please see Section 7 of this
Notice.

13. Changes to our Notice

We reserve the right to amend this Notice from time to time. As required, we
will notify you of an updated and amended copy of this Notice. If we change
our Notice, we will post the changes on this page and may place notices on
other pages of the web site, so that you may be aware of the information we
collect and how we use it at all times.

This Privacy Notice was last updated on April 1, 2024.