Consumer Data Protection/Privacy Policy

Hometown America (also referred to herein as “Company,” “us,” “we,” or “our”) operates the https://www.hometownamerica.com website (“Website”) and provides various services to our residents, including residency and access to amenities offered within our communities (hereinafter collectively referred to as the “Services”). This Privacy Policy applies both to our residents and to our employees, as it relates to their employment.

This Privacy Policy informs you of our policies regarding the collection, use, protection, and disclosure of your data – including your personal information and the choices you have associated with that data.

Our Privacy Policy is designed to advise you about how we collect, use, protect, and disclose the information that we collect and/or receive about individuals, applicants, and employees. It also explains your privacy rights, and how you can manage the privacy of your Personal Information (defined below). Please note that this Privacy Policy does not govern the practices of third parties, including our partners, affiliates, third party service providers, and/or advertisers, even when those services are branded as, or provided on behalf of, the Company. Information collected from you by others, such as third-party websites that you access through links on the Website, are governed by those entities’ privacy policies. Please note that Hometown America’s practices may differ from those specific to our California residents, consumers, affiliates, and employees (“Hometown California”), and such differences will be pointed out where applicable.

I. Definitions

• Personal Information (also known as “Personal Data”): Personal Information means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession).
• User: Any individual who uses our Services or is employed by us and is the subject of Personal Information collected and/or processed.

II. Information Collection and Use

We use your information to provide the Services that you request, and to improve the Services we offer to you. We use information provided by employees to carry out employee-related functions. By using our Services or by being employed by us, you agree to the collection and use of information in accordance with this Privacy Policy.

a. Types of Data Collected

We collect several different types of information for various purposes to provide and improve our Services to you.

Categories of Personal Information Collected by Hometown America in the Past 12 Months

III. How We Collect Your Information

Hometown America collects and obtains your information in a few ways: there is information that you choose to give to us (a) accessing our Website and filling out an online form, (b) by calling the phone numbers on our Website, (c) by filling out our Residency Application, (d) by providing your information to a sales lead business partner, and by opting into receiving SMS or text messages. We also collect information through the Resident Contact Information form and through payment processes. Finally, information is collected from employees through various employment actions. This information is collected and obtained (a) when you choose to apply for employment and provide information for the application process, and (b) upon hire to enable us to carry out the functions of the employer-employee relationship, such as processing payroll, administering, and maintaining group health insurance and retirement services, and obtaining and maintaining commercial insurance among others.

IV. Purposes for Collecting, Processing, and Using Your Information

a. Business and Commercial Purposes for Collection

Hometown America collects, processes (or asks our service providers to process on our behalf) and uses your information to provide the Services we make available to you. We therefore will collect and use your information for a variety of reasons, including:

• To perform a contract with you, or provide those Services you have requested of Hometown America (for instance, we need to collect and process your information when you become a resident of a community);
• You have otherwise given us your consent and permission to do so (for example, you have consented to receive our newsletter and provided your email address for that purpose);
• To aid in detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation;
• To perform background, credit, and other inquiries to determine suitability for leasing, renting, or purchasing;
• To conduct our business relationship with you and to offer quality products and services that customers seek;
• To identify individuals interested in contact from Hometown America;
• To induce individuals to lease, rent or buy real property;
• To process rents, fees or other charges;
• To ensure compliance with lease documents, including associated documents such as Community Rules and Regulations; and
• To carry out employment-related functions and follow best practices in relation to recordkeeping.

V. How We Use Your Information

As noted elsewhere in this Privacy Policy, Hometown America uses your information to provide our Services to you, including our Website.

Such other general uses include:

• To provide and maintain our Services;
• To notify you about changes to our Services;
• To allow you to participate in interactive features of our Services when you choose to do so;
• To provide customer support to you and our other members, customers, and visitors;
• To gather analysis or valuable information so that we can improve our Services;
• To monitor the usage of our Services;
• To allow you to participate in a voluntary activity, only when consent is obtained, related to information collected by Hometown America (e.g., allow your information to be passed to a third party for participation in a market study);
• To detect, prevent and address technical issues; and
• To provide you with news via our newsletter, special offers, marketing or promotional materials, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or inquired about, or which we believe may be of interest to you, unless you have opted not to receive such information. You may opt out of receiving any, or all, of this communication from us by reaching out to us using the contact information provided in Section XII below.

VI. Retention of Data

Hometown America may sell your information if written consent is obtained from you. If Hometown America were to begin selling your information to any third party, it would not do so without your express written permission and will not sell the Personal Information of anyone under age 16 without applicable consent. Hometown America may disclose your information in a number of ways in order to provide our Services to you. Hometown America will not share SMS consent and phone numbers with third parties or affiliates for marketing purposes and will only share such information if required by law.

We may also disclose or share your information for the following purposes:

• To comply with a legal obligation;
• To obtain financial services for the purposes of financing, refinancing, acquiring, or selling a location/property;
• To protect and defend Hometown America’s rights or property;
• To prevent or investigate possible wrongdoing in connection with the Services; and
• To protect the personal safety of users of the Services or the public and in detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

a. Categories of Third Parties that Receive Personal Information from Hometown America (Categories of Information Shared and Disclosed)

We share or otherwise disclose individuals’ personal information to the following categories of third parties:

• Service Providers: We employ third party service providers, companies, individuals, and agents to facilitate and help us provide our Services to you, such as credit card companies (at your direction, and to process payments), UKG (for employees), and others (collectively, “Service Providers”). Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. These Service Providers are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Lenders: When we are refinancing, financing, acquiring, or selling a location/property, or similar financial services some personal information collected by Hometown America is disclosed to obtain financial services for the purposes of financing, refinancing, acquiring, or selling a location/property.
• Market Studies: Hometown America, excluding Hometown California, may seek residents’ consent to share personal information with a third party for the purposes of a market study. Only if a resident agrees in writing will Hometown America share personal information with a third party for the purposes of a market study.

b. Categories of Personal Information Disclosed

Hometown America has disclosed the following categories of Personal Information in the last 12 months:

• Personal information as it relates to the employee-employer relationship from Categories A, B, C, H, I and K.
• Resident information from Categories A, B, H and I for the purposes described in Service Providers above.
• Employee and resident information from Categories A, B, D, and I for the purposes described in Lenders above.
• Hometown America, excluding Hometown California, may disclose resident information from Categories A, B and C for the purposes described in Market Studies above.

Hometown America will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to provide our Services to you and for your employment, comply with our legal obligations (for example, if we are required to retain your information in accordance with applicable laws), resolve disputes and enforce our legal agreements and policies.

VII. Accuracy of Data

We devote substantial resources and effort seeking to ensure that our records of your information are complete and correct. If an error is noted on your statement or in any other communication from us or if you need to update any personal information, please contact us promptly at the number listed on your account materials.

VIII. Analytics

We may use Service Providers to monitor and analyze the use of our Website.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services.

Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Facebook Ads

Facebook Custom Audiences is used to deliver advertisements to Website visitors on Facebook and their third-party networks based on email addresses and phone numbers. We may also use information associated with visitor social media accounts, such as demographic information, to improve our marketing efforts if that individual connects those social media accounts to a Website profile.

Hometown America may use information we collect from users to display advertisements. One example is if a prospect/customer submits their email address to us either by means of the Website or via social media, then we could potentially serve ads via Facebook or one of their third-party networks to those individuals as well.

For more information on Facebook’s privacy policy and use of cookies, you may learn how to opt-out of receiving advertisements based on your email address/phone number by visiting the section titled, “How can you control Facebook’s use of cookies to show you ads?”

IX. Children’s Privacy

All of our Services, including our Website, are intended for adult audiences, and are not meant to address anyone under the age of 18 (“Children”). As such, children under 18 may not use our Website. If you are under 18, do not attempt to register for or use any of our Services, including our Website and do not provide us any Personal Information about yourself.

We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take steps to remove that information from our servers.

X. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. While we reserve the right to make changes to our Privacy Policy at any time and at our sole discretion, we will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Website prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

XI. Consumer Data Protection/Privacy Policy Coordinator

Hometown America has delegated to its Chief People & Corporate Affairs Officer, in coordination with the data processing manager and the computer operations manager, the authority to appoint an individual to serve as Consumer Data Protection/Privacy Policy Coordinator who will be responsible for the day-to-day application and implementation of this Policy, including the review and approval of forms of Customer Notices and the dissemination thereof.

XII. Your Privacy Rights

You have the following privacy rights regarding your personal information:

• The right to know and right to access the personal information we have collected about you, including the categories of personal information; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom the business discloses personal information; and the specific pieces of personal information the business has collected about the consumer;
• The right to delete personal information that we have collected from you, subject to certain exceptions;
• The right to correct inaccurate personal information that we maintain about you;
• The right to opt-out of processing, sharing, or selling data, subject to certain exceptions; and
• The right not to be discriminated against for exercising your privacy rights.

You can exercise your right to know, delete, or correct your Personal Information by clicking Right to Know, Delete or Correct and completing and submitting the webform, calling 1-877-763-7543 and requesting to speak with the Chief Privacy Officer, or emailing us at Privacy@HometownAmerica.com. To protect the security of your personal information, we will require you to verify your identity by providing us with identifying information such as your personal email address, personal telephone number, home address, and/or other information that we can match with the personal information we have already collected about you to verify your identity.

You may use an authorized agent to exercise your right to know, delete, or correct your Personal Information. We will require your authorized agent to provide us with either (1) a power of attorney authorizing the authorized agent to act on your behalf or (2) your written authorization permitting the authorized agent to request access to your personal information on your behalf. Further, we will require you or your authorized agent to provide us with identifying information to verify your identity. We may also require you to either verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.

XIII. Contact Us