Privacy Policy

S2 Residential and its affiliates (referred to as “S2,” “we,” “us,” or “our”) value the privacy of information that identifies or relates to a consumer or device (“Personal Information”). This Privacy Policy outlines how we process Personal Information across our services and interactions.

This Privacy Policy applies to information we process:
• Through websites and online services operated by S2, including the S2 mobile application.
• During property visits, applications, and offline interactions (e.g., inquiries and events).
• From communications such as postal mail, email, phone, or in person.

Collectively, these interactions are referred to as “services.” This Policy describes:
• Types of Personal Information processed.
• How, where, and why we process it.
• Sharing practices.
• Privacy preferences, rights, and retention practices.
• Location-specific disclosures.
• Additional terms may apply for registration or location-specific disclosures; these will be provided, as necessary.

1. What Information do we Collect and for What Purpose? To provide you services, we process, or you may choose to provide Personal Information that may identify you or relate to you as an individual. Depending upon the type of relationship you have with S2 and subject to applicable laws, we may process the Personal Information described in general terms below.
• Information we collect directly from or about you:

•Basic Information: Name, address, phone number, location, and email address when you sign up for our mailing list, provide a comment, ask a question, schedule a property tour, or otherwise communicate with us.
•Application Information: If you fill out an apartment or job application, we may collect your name, date of birth, driver’s license, Social Security number, taxpayer identification number, passport or other photo ID, professional and employment information, and other necessary details to evaluate your application, communicate with you, and comply with legal obligations. This may include information about your income, disability, and other protected classifications.
•Resident Information: If you are a resident, we may collect security camera footage, resident portal profile information, rent payment details (including bank account/credit card number), insurance coverage, vehicle information, utilities usage, package delivery and locker usage, use of “smart” keys, IoT devices, and other building amenities.
•Job Application Information: Name, email address, phone number, and other contact information, as well as professional and educational background.
•Communications: Any communications between you and us, information you provide in online portals or chats, and recorded phone conversations for quality assurance or other purposes.
•Sensitive Information: Information relating to racial and ethnic origin, mental or physical health diagnosis, citizenship or immigration status, and precise geolocation.
•Third-Party Information: Information from third-party partners such as vendors for background checks, credit screens, fraud detection, payment processing, property management services, and any third party you direct to share information with us.
•We use this information to operate, maintain, and provide the features and functionality of our Service, respond to your requests, send you Service-related notices, and marketing communications. If you choose not to provide certain information, we may not be able to provide certain services or process certain requests.
•Communications: Any communications between you and us, information you provide in online portals or chats, and recorded phone conversations for quality assurance or other purposes.
•Sensitive Information: Information relating to racial and ethnic origin, mental or physical health diagnosis, citizenship or immigration status, and precise geolocation.
•Third-Party Information: Information from third-party partners such as vendors for background checks, credit screens, fraud detection, payment processing, property management services, and any third party you direct to share information with us.

•We use this information to operate, maintain, and provide the features and functionality of our Service, respond to your requests, send you Service-related notices, and marketing communications. If you choose not to provide certain information, we may not be able to provide certain services or process certain requests.

• Information collected automatically from our online services: We and our third-party service providers collect certain types of usage information when you visit our websites, access our Service, read our emails, or otherwise engage with us. This information may include:

• Device and Software Information: IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique device ID.
• Usage Information: Referral and exit information, pages visited, or links clicked, email interactions, and whether you access the Service from multiple devices.
• Location Information: GPS data or inferred location based on IP address or other information.
We may combine this usage information with personal information to enhance and personalize your user experience, monitor, and improve our websites and services, and for other similar purposes.
• Tracking Technologies: We and our third-party partners use tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and file information, to automatically collect the above usage and device information.

• Use of Collected Data. We use the data collected through tracking technologies to:
• Remember the information so you will not have to re-enter it during your visit or next visit.
• Provide custom, personalized content and information, including targeted content and advertising.
• Recognize and contact you across multiple devices.
• Monitor the effectiveness of our Service.
• Track aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns.
• Diagnose or fix technology problems.
• Plan for and enhance our Service.

2. THIRD PARTY TRACKING AND ONLINE ADVERTISING

• Our Sites use cookies and other technologies to enhance your online experience and understand how you use the Sites to improve our services. Information such as browser type, access times, IP address, and hardware and software details are automatically collected through cookies or other tools. You can manage your cookie preferences by changing your browser settings or visiting www.aboutcookies.org.
• We use Google Analytics, a web analytics service by Google, to better understand Site usage. Google Analytics places cookies on your computer to generate information about your use of the Site, including your IP address. This information is used for evaluating consumer use, compiling reports, and providing other services. Google may transfer this information to third parties as required by law. The use of cookies by Google Analytics is covered by Google’s privacy Policy: https://www.google.com/policies/privacy/.
• Our Sites may contain links to third-party sites, which have their own privacy policies. You access these sites at your own risk and should review their privacy policies before disclosing any personal information.
• We participate in interest-based advertising and use third-party advertising companies to serve targeted ads based on your online browsing history and interests. These companies collect information about your visits to our Service over time to display ads on our and other websites, apps, or services you use. We may share a common account identifier or hashed data with our third-party advertising partners to help identify you across devices.
• Do Not Track: Web browsers can transmit Do Not Track signals indicating that a user does not wish to have activity tracked. Currently, there is no universally accepted standard for interpreting such signals, so we do not alter our data collection practices when we see a Do Not Track signal.
• AI Tools: Our website and/or the websites of the properties we manage may offer AI tools, including AI chatbots using Microsoft’s GPT language models. The AI chatbot does not collect personal information unless voluntarily provided by the user. User prompts are used to improve the quality of responses and are shared with Microsoft solely for providing the AI chatbot service. The AI chatbot is not used for automated decision-making.

3. HOW AND WHERE WE PROCESS YOUR PERSONAL INFORMATION
We may process Personal Information through the following:
• Online Services. When you interact with our online services, such as searching for an apartment, communicating with us or an AI chatbot, applying for a job, posting to social media pages, or participating in a survey.
• Mobile Application. We process Personal Information when you use the mobile app which includes creating and updating your account, in providing resident services such as maintenance, and when ensuring the mobile app is performing as expected.
• Property Owners. We process Personal Information from the owners of the properties we manage.
• Property Visits and Offline Interactions. We process your Personal Information when you visit our properties, attend events hosted at our properties, inquire about housing directly with our properties, complete the rental application and/or in our day-to-day relationship with you as a tenant.
• Other Sites and Third Parties. We may use separate sites and third-party service providers for the processing of rental applications and agreements and to assist our residents and service providers with other tasks which are required or helpful to them, such as paying rent online. We may also receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will forward us your email address and other information about you so that we may contact you as requested and in accordance with applicable law.
• Due Diligence. Processing information from third-party vendors/contractors through discussions, documents delivered, and ordinary business relationships.
• Other Sources. We process Personal Information from other sources, such as public databases or credit agencies.
Where legally required, we will obtain your consent before collecting, processing, or transferring your Personal Information and/or Sensitive Personal Information. Otherwise, we will take your receipt of this policy and your provision of Personal Information as consent.

4. HOW & WHY, WE USE YOUR PERSONAL INFORMATION

5. HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION. S2 does not sell any of your personal, SMS, or device information to any marketers, third-party companies outside of our companies without your consent. We may share Personal Information with the following third parties to provide you with services, following a specific request from you, or to fulfill our legal obligations. We may share your Personally Identifiable Information with others only in certain limited situations or as otherwise agreed by you, including:
• Within our corporate group or affiliates that adhere to this Privacy Policy or equivalent privacy policies.
• With service providers and third parties bound by confidentiality agreements, including administrators, professional advisors, lenders, banks, auditors, law firms, governmental agencies, self-regulatory organizations, consultants, placement agents, insurers, technical service providers, and others acting on our behalf.
• With third-party vendors as necessary to meet legal or regulatory requirements and support our operations, such as property managers, payment processors, banks, credit check and recommendation services, identity verification, and background check providers.
• For communication purposes, including responding to your inquiries submitted through our Sites.
• For business development and marketing, to promote products and services, maintain relationships, and inform you about offerings similar to those you use, with your consent or where a pre-existing relationship exists.
• To satisfy contractual requirements and deliver requested services.
• To improve our Sites, products, and services, and notify you of updates.
• To maintain records of your relationship with us and manage ongoing operations, including administrative, accounting, reporting, and account maintenance tasks.
• In connection with corporate transactions, such as reorganizations, mergers, acquisitions, sales of assets or shares, financing, or bankruptcy proceedings.
• To disclose aggregated, non-identifiable information without restriction.
• To ensure security, detect, and respond to security incidents or malicious, deceptive, fraudulent, or illegal activities.
• To comply with applicable laws, rules, and regulations.
• We may also use and disclose your Personal Information as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of S2 employees, residents and other persons, including exchanging information with third parties for fraud protection and credit risk reduction.

6. SMS (Text Messages) Terms and Conditions
• We may send any Text (SMS) message, either directly or via a third-party agent or authorized service provider, through your communication service provider in order to deliver it to you. You agree that your communication services provider is acting as your agent in this capacity. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent, this information will not be shared with any third parties. This includes affiliates or business partners.
• In addition to the information described above, when you communicate with us via SMS, we may collect information such as your name, phone number, and the content of your message, including timestamps. This information will be used for the same purposes described above. We will not use your SMS data for any other purpose without your written consent.

• Sharing Your Information: SMS opt-in or phone numbers for the purpose of SMS are not being shared.

• SMS CONSCENT COMMUNICATION: The information (Phone Numbers) obtained as part of the SMS consent process will not be shared with third parties for marketing purposes. On our online form, there is an SMS Opt-in consent: “By clicking this box, you agree to receive SMS from [INSERT PROPERTY NAME], you can reply Stop to opt-out at any time, reply Help for assistance. Messages and data rates may apply. Message frequency will vary.”

• TYPES OF SMS COMMUNICATIONS: If you have consented to receive text messages from [INSERT PROPERTY NAME], you may receive messages related to the following:
• Leasing & Marketing: Information regarding tour appointments, availability, property information, etc.
•Greetings Joe, this is your confirmation of the upcoming tour today (1/16/25) of [Insert Property Name] at 11:45 am. Reply STOP to opt out of SMS messaging at any time.
• Account Updates: Notifications about your rental application or lease status.
•Thanks for touring [Insert Property Name] today! Click here [insert URL] to complete your rental application – [INSERT AGENT NAME] @ [Insert Property Name]. Reply STOP to opt out of SMS messaging at any time.
• Service Notifications: Important updates about our services or policies.
•Dear [Resident First Name]; If you experience a maintenance emergency tonight at [INSERT PROPERTY NAME], please call [Insert Property #] option 3. Reply STOP to opt out of SMS messaging at any time.
• Customer Check-Ins & Surveys: Invitations to complete a survey or confirm no issues in apartment.
•Dear [Resident First Name], How did we do? Please click here [Insert URL] and tell us about your experience you had. We want to hear from you! – [Insert Property Name]
• MESSAGE FREQUENCY: Message frequency may vary depending on the type of communication. For example, you may receive up to [3] SMS messages per week related to your apartment home, ongoing improvements & community events.
• POTENTIAL FEES FOR SMS MESSAGING: Please note that standard message and data rates may apply, depending on your carrier’s pricing plan. These fees may vary if the message is sent domestically or internationally.
• OPTING IN METHOD: You may opt-in to receive SMS messages from [INSERT PROPERTY NAME] in the following ways:
• Verbally, during a conversation
• By submitting an online form
• By filling out a paper form
• OPTING OUT METHOD: You can opt out of receiving SMS messages at any time.
• To do so, simply reply “STOP” to any SMS message you receive.
• Alternatively, you can contact us directly to request removal from our messaging list.
• After opting out, you will receive a confirmation message, and no further SMS messages will be sent to your number unless you opt in again.
• If you do not wish to receive SMS messages, you can choose not to check the SMS consent box on our forms.

• STANDARD MESSAGE DISCLOSURES.
• Message and data rates may apply.
• You can opt out at any time by texting “STOP.”
• For assistance, text “HELP” or visit our [INSERT Privacy Policy URL] page.
• Message frequency may vary.

• YOUR RIGHTS. You have the following rights with respect to the data we have collected from you:
• You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated or deleted;

• You have the right to choose or change your choices for subscriptions, newsletters, and alerts;
• You have the right to choose whether we can share your personal information with other companies; and
• You have the right to have your personal information deleted from a public forum on our Site.
• If you would like to exercise any of these rights, please contact us through the contact information below.
• Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

8. EMAIL CONSENT & OPT-OUT

• When you provide us your email address, you consent that we may contact you using that email address to provide you with information and notices relating to: the property about which you inquire or where you reside; various similar services available to you at or through that property; and various other properties that may be available and of interest to you in the future. It also means we may email you regarding updates to this Privacy Policy or with updates about us generally.
• You may choose to opt out of receiving future commercial email messages from us because of your use of this Site or residing at a S2 property. Each broadly distributed commercial email sent by us contains a link with instructions on how to remove yourself from our email list. Please note that you will need to opt-out separately from any third-party sites with which you have registered. If you opt out of receiving marketing messages, we will continue to send you transactional messages, which include but are not limited to answers to your questions.

9. PROTECTING YOUR INFORMATION

• S2 takes appropriate technical and organizational measures in accordance with applicable laws and appropriate to the risk of users’ Personal Information that we hold.
• We limit access to Personal Information to employees who we believe reasonably need to receive such information in order to do their jobs, and we take the precautions we deem reasonable to protect the security of users’ Personal Information.
• Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

10.DATA RETENTION.

We will retain your Personal Information for the period we believe reasonable to fulfill the purposes for which we hold it, as outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you and provide the services to you;
• whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
• whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

11. CHILDREN’S PRIVACY

Our Site and services are directed towards a general adult audience and not directed towards children. We do not knowingly collect information about children under the age of 16 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 16 has provided Personal Information through our Site, we will use reasonable efforts to remove that information from our databases.

12. UPDTES TO THIS POLICY

We reserve the right to amend this Statement at our discretion and at any time. When we change this Statement, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our services following the posting of changes constitutes your acceptance of such changes.

13. CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using one of the methods provided on our[INSERT URL FOR PROPRTY CONTACT US PAGE]