WE ARE COMMITTED TO AND MAINTAIN THE FOLLOWING PRIVACY VALUES AND PRACTICES

We are committed to and maintain the following Privacy Values and Practices regarding the information we collect, maintain, disclose, and disseminate about consumers.

TENANTTRACKS VALUES

Use

We believe that we should behave responsibly when we use information about a consumer. TenantTracks's process of collecting, disseminating and disclosing information is designed to comply with all applicable federal, state, and local statutory requirements, governing the use of consumer data, including those found in the FCRA. Furthermore, any consumer information that is distributed to our clients is done with a commitment, under the terms and conditions of the TenantTracks Screening Service Agreement, that each client will handle all consumer information provided to them in an appropriate, secure, and confidential manner.

Accuracy

TenantTracks takes reasonable steps to help ensure the accuracy of the data we collect, use and disseminate. Where possible, we take reasonable steps to investigate claims of inaccurate or incomplete data we collect, use, and disseminate, and if appropriate, correct inaccurate information that we maintain using the FCRA as our guide. In cases where we receive inquiries about information we do not maintain and manage, we take reasonable steps to refer the consumer to the source of the data which they believe to be erroneous.

Public Record

TenantTracks believes that an open public record is of significant value to society, enhances consumer choice, and ultimately creates consumer opportunity. We support an open public record and recognize its importance to the economy, to society, and to the safety of the general public.

Education

TenantTracks endeavors to educate employees, clients, and others in the multifamily housing industry about the importance of consumer privacy. It is our goal to ensure consumers are informed as to how TenantTracks, and our clients, use the consumer information we maintain, manage and disseminate. We also encourage all parties, with whom we conduct business, to collect and use information in a responsible manner. We are open with consumers about the various types of information we maintain and will also discuss with a consumer the source of that information.

Confidentiality and Security

We strive to ensure utilization of appropriate facilities and systems to protect against unauthorized access to or corruption of the data we collect, maintain and disseminate. We use various identity verification methods to determine the accurate identity of a consumer making a request. We employ security procedures for handling consumer information as well as maintaining physical security and limiting access to our facilities in order to safeguard information we collect, maintain, and disseminate.

TENANTTRACKS PRIVACY PRACTICES

Applicability

TenantTracks is committed to safeguarding consumer information. As a consumer requesting a copy of your file, you provide TenantTracks with certain contact information such as, your name, phone number(s), address, or email address. We understand that you may be concerned about the information you provide and have a right to know how we utilize this information. We generally use consumer inquiry information for the purpose of expediting our response to your request.

Types of Information

The types of information we may collect include, but are not limited to:

• Information we receive from you either verbally or in writing
• Information you disclose on a form
• Any communication in writing, by telephone or by e-mail
• Any previous consumer dispute or request you may have initiated
• Information we receive from a filing agency
• Information we receive from public records
• Information provided by a law enforcement agency or government entity
• Information provided by a previous landlord or property manager

Use of Information

Our customer relations department may request information from you in an effort to resolve your question or concern with information maintained in your file and only does so for legitimate business purposes. We do not release your information to any party other than to a client making an inquiry with your approval as permitted by laws set forth under the FCRA. We may use any information received from a consumer to update the accuracy of the information we maintain. TenantTracks holds its clients to standards established by the FCRA and other applicable laws. We reinforce our standards through screening agreements we have in place with our clients that state our products and services are only intended for permissible purposes established under the FCRA. If we believe that a client is using TenantTracks's information in a manner that does not comply with applicable laws or agreements we will pursue corrective action. We periodically review the use of information by our clients to ensure appropriateness of use of information we provide.

Special Message for Connecticut Residents Regarding the Confidentiality of Social Security Numbers.

Connecticut's legislature passed Public Act 08-167 requiring that filing agencies, like TenantTracks, display to Connecticut residents how TenantTracks, protects the confidentiality of social security numbers; prohibits the unlawful disclosure of social security numbers; and, limits access to social security numbers. TenantTracks. takes the same protective measures described above with regard to other nonpublic personal information when handling a social security number and, generally, also does the following in addition: TenantTracks does not release the full social security number in reports produced from its own databases, even when a consumer has requested a copy of his/her own report. A description of our basic security for nonpublic personal information is described above and applies to the social security number.

QUESTIONS ABOUT TENANTTRACKS PRIVACY VALUES AND PRACTICES

How can I review my TenantTracks consumer file or dispute information TenantTracks maintains or provides?

As a consumer, you have the right to obtain a copy of you file maintained by TenantTracks. You may initiate a request to obtain a copy of such information by contacting TenantTracks. If you believe any information in your file is inaccurate, incomplete or has been obtained without permissible purpose, you have the right to dispute the information under the guidelines set forth by the FCRA and/or other applicable laws. We are open with consumers about the types of information we maintain and will also discuss the source of information upon receiving the proper identity verification documents. TenantTracks is always mindful of the urgency that accompanies a consumer initiated request. In handling such requests we maintain standards of professionalism and expediency ensuring timelines in line with those outlined by the FCRA.

Where else can I find consumer information?

Federal Trade Commission - http://www.ftc.gov

Direct Marketing Association - http://www.the-dma.org

Consumer Data Industry Association - http://www.cdiaonline.org

Coalition for Sensible Public Records Access - http://www.cspra.org

Experian - http://www.experian.com/consumer/credit_education.html

Equifax - https://www.econsumer.equifax.com

To obtain additional information about the privacy practices and policies of TenantTracks in connection with its preparation and processing of investigative files, please contact:

Paul A. Jenney, Compliance Director