1. Introduction

Gorman and Company, LLC (together with its subsidiaries, divisions, and brands, collectively, “Gorman,” “we,” “us,” or “our,” as the context may require) is a real estate development firm working to revitalize communities through innovative housing partnerships. This Privacy Policy (this “Policy”) describes our privacy practices for the website where this Policy appears (www.GormanUSA.com, the “Site”), including the types of information we may collect from you when you visit the Site and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of our customers and visitors of the Site (“you” or “your,” as the context may require) and we are committed to respecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our practices regarding your personal information and how we will treat it. By accessing or using the Site, you agree to this Policy and our [Terms of Use]. If you do not agree with this Policy, please do not visit, access, use, or otherwise interact with the Site.

This Policy may change from time to time (see Section 11 (Changes to this Policy)). Your continued use of the Site after we revise this Policy means you accept such revisions and agree to abide and be bound by the most recent version of the Policy, so please check this page periodically for updates.

2. The Interactions this Policy Covers

Except as otherwise required by applicable law, this Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Site and in texts, emails, and other electronic communications sent through or in connection with the Site.

Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website, or third party other than the Site, including through any application or content that may be linked to or otherwise accessible from the Site. If you visit an application, website, or third party that we mention or link to on the Site, be sure to review its privacy policy before providing any information, as that privacy policy will apply to your interactions with that application, website, or third party. For example, our resident portals are provided by third parties. Please read such third party’s privacy policy before creating an account or providing it with any other information.

Except as otherwise provided in this Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, or information not otherwise considered “personal information” under applicable law.

3. Information We Collect

We collect several categories of information from and about you as a result of your use of the Site and as a result of your communications with us. This information may include:

• Personal information, including:
  • Identifiers, such as your name, postal address, email address, phone number, and other similar identifiers, including any identifiers you use when you create an account in the resident portal.
  • Geolocation information, if you have granted us access to that information. We may also derive your approximate location from your IP address.
  • Professional or employment information, including education and work history, when you apply to work with us.
• Information that is about to or relates to you but is not personal information and which does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.
• Information about your internet connection, the equipment you use to access the Site, IP address and other unique device identifiers, your activity on the Site, and other usage details collected through your use of the Site.
• Any other information, including personal information, which you publicly disclose or share on the Site, or disclose to or share with us in any manner.
  Inferences drawn from any of the categories above.

4. How We Collect Personal Information

We may collect personal information:

• Directly from you when you provide it to us.
• Automatically when you use or access the Site.
• From third parties, to the extent permitted by applicable law.

However, we will not intentionally collect or process your sensitive information without your affirmative consent. “Sensitive information” includes personal information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship status; genetic or biometric information; or personal information from a known child. If you believe we have collected your sensitive information without your consent or your consent to collect or process your sensitive information has been given mistakenly, please contact us as provided in Section 12 (How to Contact Us).

A. Information We Collect Directly

The personal information we collect directly from you when you use or access the Site includes:

• Details of correspondence and transactions you carry out through the Site.
• Information that you provide by filling in forms on the Site. This includes information provided at the time of requesting further information or reporting a problem with the Site.
• Records and copies of your correspondence if you contact us.
• Your search queries on the Site.
• Resume and employment information when you apply to work with us.

B. Information We Collect Automatically

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site, such as which parts of the Site you visit and how long you spend there.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Location information, including the state and/or country you are accessing the Site from.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain the information or associate it with personal information we collect in other ways or receive from third parties. This information helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and overall usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site, and overall functionality of the Site may be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
• Web Beacons. Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count visitors who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may also use web beacons or pixel tags to compile anonymized tracking reports regarding website visitor demographics and website traffic patterns. We may then provide these reports to advertisers and others. For our own research purposes, we may link such reports with personal information voluntarily provided to us. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy.
• Analytics. We may utilize third party companies and analytics to help us market, sell, and provide information about us, our developments, and the Site. We may use web analytics tools provided by service providers, including, but not limited to, Google Analytics, which is a third-party service that transmits website traffic data to Google Site in the United States. Google Analytics does not identify individual visitors or associate your IP address with any other data held by Google. We may use reports provided by Google Analytics and similar service providers to help us understand traffic on the Site. For more information, concerning Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners Web Sites or Apps,” located at www.google.com/policies/privacy/partners. We may use the information provided by these tools to improve our Site and our online advertisements. These tools place session and persistent cookies in your browser to identify you as a unique visitor the next time you visit, access, or use the Site. Each cookie cannot be used by anyone other than the service provider (e.g., Google Analytics).

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including service providers who collect or process information on our behalf. For example, we partner with RealPage for our resident portals and individual apartment websites and Paycor for collecting employment and employment application information, and we collect personal information from both of these service providers. We generally require these service providers to use your personal information only as we direct, in a manner consistent with this Policy. However, please note that these service providers may have their own privacy policies.

We may offer the opportunity to engage with our website and content we produce on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, you may allow us to have access to certain information associated with your social media account, which may include personal data (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in, or application. When you provide information from your social media account, we may, through third party advertisers or the social media host website or application, use this information to personalize your experience on the third-party social networking websites, plug-ins, and applications, and to provide you with other services you may request. We do not build profiles based on this information. The sharing of such information is exclusively controlled by the social media platform you are using. If you do not wish to share such information or exercise any data subject rights related to such information, please refer to the privacy notices or policies of the social media platform you are using.

5. How We Use Your Personal Information

Any personal information we collect is information adequate, relevant, and limited to what is reasonably necessary in relation to the purposes described in this Section 5 (How We Use Your Personal Information). We may use the personal information that we collect about you or that you provide to us:

• To provide you with the Site, the resident portals, all related content, and any other information or services that you request from us.
• To communicate with you regarding certain special offers; apartment, condo and other real estate opportunities and availability; and information and news about us.
• To process your requests, such as when you contact us or fill out a form for further information regarding one of our properties.
• To evaluate your qualifications for employment.
• To determine your general geographic location and provide localized content.
• To notify you about changes to the Site or any services we offer through it.
• To identify your preferences and customize our communications to you.
• To provide, support, personalize, and develop the Site.
• To prevent transactional fraud and monitor for other types of fraud, abuse, and illegal activity.
• To help maintain the safety, security, and integrity of the Site, as well as our services, databases, and other technology assets.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• For testing, research, analysis, and development, including to understand our audience, develop and improve the Site, as well as our customer service and developments.
• To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
• To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and visitors is among the assets transferred.
• To fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

6. Disclosure of Your Personal Information

We may disclose personal information that we collect or you provide from any category identified above in Section 3 (Information We Collect):

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. For instance, we use third parties to service our resident accounts and to process your online rental payments.
• To a prospective or actual buyer or other successor in connection with the negotiation or consummation of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
• To protect the rights, property, or safety of Gorman, our customers, or others, in circumstances when we believe disclosure is necessary or appropriate.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may use or disclose aggregated information about our customers and visitors and information that does not identify any individual without restriction

7. Your Privacy Rights and Choices

We provide all customers and visitors with rights to:

• Confirm whether we process their personal information.
• Access, correct, and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.
• Opt-out of certain types of profiling or behavioral tracking.

To exercise any of these rights, please contact us as provided in Section 12 (How to Contact Us). We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

To appeal a decision regarding a privacy rights request, please contact us as provided in Section 12 (How to Contact Us).

8. Other Privacy Choices

We strive to provide you with as many choices as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.
• Promotional Offers from Us. If you do not wish to have your contact information used by the us to promote us, our developments, or the Site, please contact us as provided in Section 12 (How to Contact Us). If you no longer wish to receive our e-mail newsletters or promotions, you may unsubscribe using the link provided in every e-mail or contact us as provided in Section 12 (How to Contact Us).
• Accessing and Updating Your Information.

To update your personal information (name, postal address, email address, and phone number), you can contact us as provided in Section 12 (How to Contact Us).We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, https://thenai.org/opt-out. Similarly, you can opt out of receiving targeted ads from members of the Digital Advertising Alliance (“DAA”) on the DAA’s website, https://www.privacyrights.info.

9. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

10. Children’s Privacy

The Site is not directed to nor intended for use by children under 18 years old. We do not knowingly collect personal information from children. Children are not authorized to use the Site. If you are a child under 18 years old, please do not provide any personal information to, on, or through the Site. If we learn we have collected or received personal information from a child, we will delete that information. If you believe we might have any information from or about a child, please contact us by any of the methods listed in Section 12 (How to Contact Us).

11. Unsolicited Ideas

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to notify you or obtain your affirmative consent. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting the Site and this Policy to check for any changes. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

12. How to Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us via any of the following methods:

Via mail:
Gorman and Company, LLC
200 N Main St
Oregon, WI 53575

Via email: info@GormanUSA.com

Via phone: 1-608-835-3900