California Consumer Privacy Act Privacy Notice

The following chart details the categories of Personal Information, as listed in the CCPA, we plan to collect, and have collected and disclosed within the preceding twelve (12) months and to which categories of third-parties Personal Information was disclosed for our operational business purposes or sold:

We share Personal Information with the following categories of third parties:

• “Affiliates.” We share with our affiliates within IRT’s group of companies for the purposes described in this Privacy Notice.
• “Service Providers.” We share with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, background checks, and other similar services.
• “Ad Networks.” We share with third-party ad networks and online advertising partners to permit them to send you marketing communications.
• “Social Networks.” We share with social network platforms, who use the data we share in accordance with their own privacy policies.
• “Business Partners.” We share with our trusted business partners, including distribution partners and other IRT customers, such as renter’s insurance, parcel delivery services, dry cleaning and laundry services, off-site storage or moving services, pet services, and other similar services.
• “Marketing Partners.” We share with our marketing partners to permit them to send you marketing communications, such as cable and Internet providers.
• “Other businesses in the same industry as ours.” We share information with other companies whose offerings may interest you.
• “Other businesses in a different industry from ours.” We share information with other companies whose offerings may interest you.
• “Contest Sponsors.” We share with third-party sponsors of sweepstakes, contests, and similar promotions.
• “Credit Bureaus.” We share information about your credit history with us with credit bureaus.
• “Legal Authorities.” We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
• “Other Parties in Litigation.” We share information in the context of litigation discovery and in response to subpoenas and court orders.

We do not knowingly sell the Personal Information of minors under sixteen (16) years of age. For more on your personal information sale rights, see Your CCPA Rights and Request to Opt-Out, below.

We collect this Personal Information from you and from these other types of sources: our affiliates, other IRT customers, consumer reporting agencies, trusted third-party service providers, data analytics service providers, publicly available databases and websites, government entities and email and joint marketing partners.

We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including:

• Developing, improving, repairing, and maintaining our products and services;
• Conducting research, analytics, and data analysis;
• Maintaining our facilities and infrastructure;
• Undertaking quality and safety assurance measures;
• Managing your residency at one of our communities;
• Processing your application to reside at one of our communities;
• Carrying out our obligations and enforcing our rights arising from contracts entered into between you and us;
• Communicating with you and responding to your inquiries, comments, and suggestions;
• Providing you with, customizing, and improving our products and services;
• Carry out the specific purpose for which you provided us with the personal information;
• Administering and processing payments;
• Completing tasks relating to your transactions and interactions with us;
• Marketing our products and services;
• Managing your employment with us;
• Processing your application for employment with us;
• Performing accounting, audits, and other internal functions;
• Authenticating use and detecting potential fraudulent use;
• Conducting risk and security control and monitoring;
• Complying with law and legal process, maintaining records, and exercising and defending legal claims;
• Anonymizing and aggregating information for analytics and reporting; and
• For any other purpose with your consent.

Requests to Know and Delete and Opt-Out

If you are a California resident, you may make the following requests:
(1) “Request to Know”

You may request that we disclose to you the following information covering the twelve (12) months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
• The categories of Personal Information about you that we sold and, for each, the categories of third parties to whom we sold such Personal Information (if applicable); and
• The categories of Personal Information about you that we otherwise shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2) “Request to Delete”
You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please contact us at CCPA@irtliving.com or 877.525.7264. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. You may make a request on behalf of a child who is under thirteen (13) years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If you are the authorized agent of a consumer, making a Request to Know or a Request to Delete on behalf of the consumer, we will ask you for:

1. Proof of your registration with the California Secretary of State to conduct business in California.
2. Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

If an authorized agent has not provided us with a power of attorney from the California resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:

• Provide us with a written permission signed by the resident to make the Request to Know or Request to Delete on the resident’s behalf;
• Verify the resident’s own identity directly with us;
• Directly confirm with us that the resident provided you permission to submit the Request to Know or Request to Delete.

(3) “Request to Opt-Out”
You may request to opt out of any future sale of Personal Information about you by contacting us at privacy@irtliving.com .

If you are the authorized agent of a consumer, making a Request to Opt-Out on behalf of the California resident, we will ask you for:

1. Proof of your registration with the California Secretary of State to conduct business in California.
2. Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA. You will not be denied goods or services, charged different prices, or provided a different level or quality of service by exercising any of your rights under the CCPA. We do not offer any financial incentive or price or service difference in exchange for the retention or sale of your personal information.

California residents may also have the right to request certain information regarding our disclosure of Personal Information to third-parties for their direct marketing purposes. To make such a request, please contact us as described below in the Contact Us Section below.

We may change or update this CCPA Privacy Notice from time to time. When we do, we will post the revised CCPA Privacy Notice on this page with a new “Last Updated” date. Depending on the nature of the change we make, we may notify you of the change and we may request your consent to the change.

If you have any questions regarding this CCPA Privacy Notice, please contact us at privacy@irtliving.com.