Privacy Notice

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Online Services collect Personal Information, including:

• Personal contact information (name, nickname, gender, mailing address, email address, phone number)
• Postal address (including billing and shipping addresses)
• Business information (office location, business contact information, department, job title/ description, professional biography)
• Payment information (credit card and other payment card information)
• Log-in credentials (username, password)
• IP address (we may also derive your approximate location from your IP address)
• Profile picture
• Social media account ID
• Any other information you or other STAR customers may upload or enter into the Online Services

Certain of the Online Services may collect additional Personal Information specific to the service. For example:

• We may collect additional information when you create a lease or fill out a leasing application, such as move-in date, reference contacts, co-applicants, guarantors, pets, residence history, employment history, annual income, proof of income, driver’s license, vehicle information, Social Security Number, and date of birth.
• We may collect additional information when you use, access, or request services as a resident, such as renter’s insurance, cell phone or other telephone number, email address, banking account information, and credit card information.

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Online Services.
  • We collect Personal Information through the Online Services, for example, when you enter information into a web form, register an account to use the Online Services, speak with one of our representatives over the phone, enter into an agreement with us, participate in a promotion or contest, or participate in a survey.
• From Other Sources.
  • We receive your Personal Information from other sources, for example:
    • Our affiliates;
    • Other STAR customers;
    • Consumer reporting agencies;
    • Trusted third-party service providers;
    • Publicly available databases and websites;
    • Government entities;
    • email and joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Online Services to you. If you do not provide the information requested, we may not be able to provide the Online Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Online Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Online Services and fulfilling your requests.
  • To provide the Online Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Online Services.
  • To complete your transactions, verify your information, and provide you with related customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
  • To allow you to send messages to another person through the Online Services if you choose to do so.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
  • To send you marketing related emails, with information about our services, new products and other news about our company.
  • To facilitate social sharing functionality that you choose to use.
• Analyzing Personal Information for business reporting and providing personalized services.
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Online Services.
  • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Online Services that we believe will be relevant and interesting to you.
• Allowing you to participate in sweepstakes, contests or other promotions.
  • We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
  • Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
• Accomplishing our business purposes.
  • For data analysis, for example, to improve the efficiency of our Online Services;
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Online Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Online Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We disclose Personal Information:

• To our affiliates within STAR’s group of companies for the purposes described in this Privacy Notice.
• To distribution partners, and other STAR customers and business partners.
• To our third-party service providers, to facilitate services they provide to us.
  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• To third parties, when you use a third-party feature on the Online Services.
• To third party sponsors of sweepstakes, contests, and similar promotions.
• By using the Online Services, you may elect to disclose Personal Information.
  • On message boards, chat, profile pages, blogs, and other services to which you can post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others. We may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Online Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device.
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Online Services (such as the App) you are using. We use this information to ensure that the Online Services function properly.
• Your use of the App.
  • When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Cookies.
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Online Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for analytics, security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Online Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to https://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Pixel tags and other similar technologies.
  • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services and response rates.
  • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Online Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Physical Location.
  • We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by using the unsubscribe mechanism contained in each such email. Depending on the Online Service, you may also be able to manage notification preferences through your account.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, or delete Personal Information, you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Online Services link. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Online Services and other websites or online services.

• You may receive advertisements based on information relating to your access to and use of the Online Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit https://optout.aboutads.info and https://optout.networkadvertising.org.

The Online Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under thirteen (13).

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Online Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Online Services or otherwise to us.

The “LAST UPDATED” legend at the top of this Online Privacy Notice indicates when this Online Privacy Notice was last revised. Any changes will become effective when we post the revised Online Privacy Notice on the Online Services.

If you have any questions about this Privacy Notice, please contact us at Privacy@SteadfastREIT.com or in writing at the following address:

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.