The Ardent Privacy Policy

Effective Date: November 1, 2022

Sack Management, Inc. and its affiliates (referred to herein as “we”, “us”, or “our”) respect the privacy of consumers consistent with the requirements of the California Consumer Privacy Act of 2018 as amended (“CCPA”), including users of our website and those who contact us and/or interact with us electronically, telephonically or in person in connection with the potential or actual rental of a housing unit and/or related services and opportunities (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard and utilize your information when you visit our website, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) or provide us with personal information by other means, including in person or over the telephone. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Site, telephone us in response to an advertisement or provide us with any personal information electronically, telephonically, in person or by any other means. This Privacy Policy is subject to change at any time.

I. Cookies

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file.

On the Site, we use session cookies to make it easier for you to navigate the Site by remembering your locale preferences and to improve and track the overall Site experience. For the Site, we set a persistent cookie to authenticate your login and authorization to use the services. Persistent cookies enable us to track, store and target the interests of our users to enhance the experience on the Site. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited.

II. Usage Information

We automatically collect information about your interactions with the Site, including information about the device you use to interact with and/or access the Site, such as: IP address, access dates and times, information about your approximate location (as determined through your IP address), hardware and software information, mobile, computer or hardware device information (e.g., operating system version, Hardware model, IMEI number and other unique device identifiers, MAC address, and device settings), device event information, and crash data. This information allows us to understand how you’ve used the Site (which may include administrative and support communications with us or whether you have clicked on links to External Web Sites), and other actions you have taken in connection with your use of the Site. We automatically collect log data when you access and use the Site, even if you have not created an account or logged in.

III. Aggregate Information

We may collect and track the total number of visitors to the Site, the number of visitors to each page of the Site, External Web Sites (defined below) linked to and other aggregated data collected through our services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such information for purposes such as analyzing trends, administering the Site, and to understand how users interact with the Site.

VI. Disclosure of Personally Identifiable Information

We may provide your personally identifiable information and the data generated by cookies and third party analytics tools and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. For example, we engage with G5 Search Marketing, Inc. to assist us in creating and hosting this Site.

We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any investigation, to protect our or our users' rights or to enforce our terms of use. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which we participate or to a purchaser of all or substantially all of our assets to which this Site relates.

V. Links to Third Party Sites

The Site may provide links to other Web sites or resources over which we do not have control ("External Web Sites"). Such links do not constitute an endorsement by us of those External Web Sites. You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

VI. Security

We may employ industry standard procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. We may use, without limitation, firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.

VII. Personal Information Collection

We may collect personal information about you in a variety of ways. The personal information we may collect on the Site or when you communicate with us about a potentially available rental housing unit, or when you apply for or rent a housing unit includes the following categories of personal information. The sources from which the information is collected is also identified below.

Inferences drawn from other personal information

Category	Non Exclusive Examples	Collected
Personal Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes
Characteristics of protected classifications under California or federal law	Age (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital or familial status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), medical conditions, political affiliations or activities, status as a victim of domestic violence, assault, or stalking.	Yes
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information	Fingerprints, facial or hand imagery, voice recordings from which an identifier template can be extracted, keystroke patterns, gait patterns, sleep, health, or exercise data.	Yes
Internet or other similar network activity information	Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data	GPS coordinates or other location tracking information.	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional, tenancy, or employment-related information	Employer, employment history, resumes and CVs, background checks, and other employment-related information. Past postal addresses, landlords, and landlord references regarding tenancy.	Yes
Inferences drawn from other personal information	Inferences drawn from any of the categories described above to create a profile about a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Data Relating to Application for or Rental of a Housing Unit

In addition to the Personal Data described above, if you decide to apply for or rent a rental housing unit at a property we manage, we may also collect personal information bearing on your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living from a consumer reporting agency subject to regulation under the Fair Credit Reporting Act. Such information is not subject to the provisions of this Privacy Policy or the CCPA so long as it is not used, communicated, disclosed or sold except as authorized by the federal Fair Housing Act.

We may also collect information from public records such as past eviction actions, prior landlords or similarly-situated individuals, which information may help us ascertain the likelihood that you will comply with the terms of your lease agreement and applicable laws.

VIII. Personal Information Exceptions (Not Covered by CCPA)

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

IX. Personal Information Use & Processing

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site, telephonically or in person to:

• Deliver targeted advertising, newsletters, and other information regarding promotions, the Site and properties we manage to you

. • Allow you to access amenities, access features, and request service.

• Create and manage your account.

• Email you regarding business-related communications.

• Enable user-to-user communications.

• Increase the efficiency and operation of the Site.

• Notify you of updates to the Site.

• Offer new services and/or recommendations to you.

• Perform other business activities as needed.

• Provide electronic payment alternatives.

• Request feedback and contact you.

• Resolve disputes and troubleshoot problems.

• Respond to service requests.

• Send you a newsletter.

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online or in person is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

X. Personal Information Sharing & Disclosure

We do not sell personal information collected and no such disclosure has occurred in the prior 12 months.

We may provide personal information to third parties for business purposes under limited circumstances, including service providers and vendors. We may only share personal information to the extent reasonably necessary to support our services or for the third party vendors or service providers to perform the services on our behalf. We do not permit third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request of them. However, please note that we do not maintain direct control over the privacy policies and practices of vendors or any other third party companies, agents, or contractors. Our property management software is managed through RealPage, Inc.– for their privacy policy, please visit https://www.realpage.com/privacy-policy/.

XI. Personal Information Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with CCPA guidelines. This section describes your CCPA rights and explains how to exercise those rights.

In response to a verifiable consumer request for these services, we will disclose the following information:

The categories, specific types, and sources of personal information we collected about you.
Our business purpose for collecting the personal information.
The categories of third parties with whom we share that personal information and the purpose for the disclosure.

We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Neither the Site nor our services are intended for children under the age of 18. We do not target our services or this Site to children under 18. We also do not knowingly collect personally identifiable information from children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.

XII. Deletion of Personal Information

You have the right to request that we delete any of your personal information that was collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies

We may deny your deletion request if retaining the information is necessary for us to:

Complete the transaction for which we collected the personal information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your property manager, or otherwise perform our contract with you or your property manager.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or your property manager.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

XIII. Submitting Consumer Requests – Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Sack Management Inc

Attn: Office Manager

111 Pine Street, Suite 1600 San Francisco, CA 94111

Office@sackproperties.com

Toll Free Phone Number: (833) 396-2381

Only you (or someone legally authorized to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

XIV. Consumer Request Responses and Timelines

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). In the event that an extension is necessary, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

XV. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not:

Deny you housing or services.
Charge you different prices or rates for housing or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of housing or services.
Suggest that you may receive a different price or rate for housing or services or a different level or quality of housing or services.

XVI. Other California Privacy Rights

In addition, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users, applicants, and residents who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.