MRK Partners Company-Wide Website Privacy Policy

MRK Partners, Inc. (“MRK Partners,” “we,” “us,” or “our”) respects the privacy of visitors to our websites and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit the websites we and our affiliated property-management brands operate, including our corporate, Ingerman, Birchwood, and The Willows community websites (collectively, the “Site”), or otherwise interact with us online, including through contact forms, inquiries, rental or leasing applications, job applications, email communications, and newsletter sign-ups.

This Privacy Policy applies to visitors and users of the Site in every state, regardless of where you live. MRK Partners is headquartered in California and develops and manages affordable housing communities in nine states: California, Delaware, Missouri, Michigan, Pennsylvania, New Jersey, Maryland, Virginia, and Florida. Residents of certain states, including California, have additional rights under their state privacy laws, which we honor to the extent they apply (see Section 9). These rights depend on your state of residence and applicable law, not on where any particular community is located.

By using the Site, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please do not use the Site.

Scope: This Privacy Policy covers the public Site. It does not govern separate tenant or resident portals, online rental or leasing applications, or third-party platforms (such as resident portal providers), which are governed by their own privacy notices.

Information You Provide Directly

• Name, email address, phone number, and mailing address.
• Content of messages submitted through contact or inquiry forms.
• Newsletter sign-up information.
• Leasing or rental inquiry details (property preferences, move-in dates, etc.).
• Job application materials, including resume and employment history.

Information Collected Automatically

• IP address and general geolocation (city/region level).
• Browser type, device information, and operating system.
• Referring and exit URLs, pages viewed, date/time stamps, and clickstream data.
• Information collected through cookies and analytics tools (see Section 6).

Information from Third Parties

• Analytics providers (e.g., Google Analytics).
• Advertising and marketing partners.
• Service providers who assist with Site operations.

• Directly from you when you complete forms, contact us, sign up for communications, or submit inquiries or applications.
• Automatically through cookies, web beacons, pixels, and similar tracking technologies as you navigate the Site.
• From third parties such as analytics services (e.g., Google Analytics) and marketing partners.

We may use the information we collect for the following purposes:

• Respond to your inquiries, requests, and applications and provide information about our properties, services, and availability.
• Operate, maintain, improve, and personalize the Site and user experience.
• Send newsletters, property updates, and marketing communications where permitted by law. You may opt out at any time by clicking the “unsubscribe” link in any email or replying STOP to text messages.
• Analyze usage trends, measure Site performance, and conduct internal research.
• Detect, prevent, and address security incidents, fraud, and technical problems.
• Comply with legal obligations, respond to lawful requests, and enforce our terms and policies.

We may also anonymize or aggregate personal information so that it can no longer identify you. Anonymized or aggregated data is not personal information and may be used for any lawful business purpose.

MRK Partners does not sell your personal information for monetary consideration. We do not sell the personal information of consumers we know to be under 16 years of age.

We may “share” (as defined under the California Consumer Privacy Act) certain personal information—such as identifiers and internet activity data—with advertising and analytics partners for cross-context behavioral advertising. You may opt out of this sharing through the mechanisms described in Sections 6 and 9.

We may also disclose your information in the following circumstances:

• Service Providers and Vendors: Third parties that perform services on our behalf (website hosting, analytics, email delivery, marketing, IT support) under written contracts that require them to protect your information and limit its use.
• Affiliates and Related Entities: Our parent company, subsidiaries, and affiliated entities for internal business purposes.
• Legal and Compliance: When required by law, in response to legal process (such as a subpoena or court order), or to protect the rights, property, or safety of MRK Partners, our users, or others.
• Business Transfers: In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets. In such an event, your information may be among the assets transferred.
• With Your Consent: When you direct us to share your information or provide your consent.

We use cookies and similar technologies (web beacons, pixels, tags) to collect information about how you interact with the Site. These technologies fall into the following categories:

• Strictly Necessary Cookies: Essential for core Site functionality (e.g., security, network management). These cannot be disabled.
• Performance/Analytics Cookies: Help us understand how visitors use the Site so we can measure and improve performance (e.g., Google Analytics).
• Functional Cookies: Remember your preferences and settings to enhance your experience.
• Targeting/Advertising Cookies: Used by our advertising partners to deliver relevant advertisements and measure campaign effectiveness.

Your Choices:

• You can adjust your browser settings to block or delete cookies. Note that disabling certain cookies may affect Site functionality.
• Opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout).
• Opt out of interest-based advertising through the Digital Advertising Alliance (DAA) at aboutads.info/choices or the Network Advertising Initiative (NAI) at optout.networkadvertising.org.

Opt-Out Preference Signals / Global Privacy Control (GPC): We honor Global Privacy Control and similar recognized opt-out preference signals where required by applicable law. If your browser transmits a GPC signal, we will treat it as a valid request to opt out of the “sale” or “sharing” of your personal information for that browser/device.

We do not currently respond to “Do Not Track” (DNT) browser signals, as no uniform industry standard for DNT has been adopted.

We retain personal information only as long as reasonably necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, unless a longer retention period is required or permitted by law.

In determining appropriate retention periods, we consider:

• Legal and contractual requirements (including applicable statutes of limitations).
• Whether there is any pending or reasonably anticipated litigation, investigation, or dispute.
• Regulatory obligations (tax, accounting, or reporting requirements).
• Generally accepted industry best practices.

When personal information is no longer needed for any of these purposes, we securely delete, destroy, or anonymize it.

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. Any transmission of information to us is at your own risk.

Depending on your state of residence, you may have certain rights regarding your personal information. These may include the right to:

• Access or know what personal information we have collected about you.
• Request correction of inaccurate personal information.
• Request deletion of your personal information, subject to certain exceptions.
• Opt out of marketing communications at any time.

Residents of states that have comprehensive consumer privacy laws, such as California, may have additional rights under those laws, including rights of access, correction, deletion, portability, and the right to opt out of targeted advertising or the sale or sharing of personal information. We honor the rights required by applicable law. To exercise any privacy right, please contact us using the information in Section 10.

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), California residents have specific rights regarding their personal information. This section describes those rights and how to exercise them.

Your Rights Under the CCPA:

1. Right to Know/Access. You may request that we disclose: the categories and specific pieces of personal information we have collected about you; the categories of sources from which it was collected; the business or commercial purpose for collecting or sharing it; and the categories of third parties to whom we have disclosed it.
2. Right to Delete. You may request that we delete personal information we have collected from you, subject to certain exceptions (e.g., legal obligations, ongoing transactions, security, exercising free speech).
3. Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
4. Right to Opt Out of Sale or Sharing. You may direct us to stop “selling” or “sharing” your personal information for cross-context behavioral advertising.
5. Right to Limit Use of Sensitive Personal Information. You may direct us to limit the use and disclosure of sensitive personal information to purposes authorized by law. (Note: we do not intentionally collect sensitive personal information through the Site.)
6. Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights (e.g., by denying services, charging different prices, or providing a different quality of service).

Categories of Personal Information Collected:

In the preceding 12 months, we may have collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email address, phone number, mailing address, IP address).
• California Customer Records (Cal. Civ. Code § 1798.80(e)) (name, address, telephone number, and similar contact information).
• Commercial Information (property inquiries, transaction-related interactions, preferences).
• Internet or Other Electronic Network Activity (browsing history, search history, and interactions with the Site).
• Geolocation Data (general/approximate location inferred from IP address).
• Inferences (drawn from any of the above to create a profile reflecting preferences or characteristics).

Do Not Sell or Share:

MRK Partners does not “sell” personal information for monetary consideration. We may “share” certain information (such as identifiers and internet activity) with advertising and analytics partners, which may constitute “sharing” for cross-context behavioral advertising under the CCPA. You may opt out by:

• Submitting a request via email to legal@mrkpartners.com.
• Calling us at 424-999-4580.
• Enabling Global Privacy Control (GPC) in your browser. We honor GPC signals as a valid opt-out of sale/sharing.

How to Submit a Verifiable Request:

You (or your authorized agent) may submit a verifiable consumer request by:

• Emailing legal@mrkpartners.com with the subject line “Privacy Request.”
• Calling 424-999-4580.
• Using the “Contact Us” form on the Site.

To protect your privacy, we will verify your identity before fulfilling a request. We may ask you to provide information that matches what we have on file. If you use an authorized agent, we may require the agent to provide signed written authorization and may verify your identity directly.

Response Timeframe:

We will confirm receipt of your request within 10 business days. We will respond substantively within 45 calendar days of receipt. If we require additional time (up to an additional 45 days), we will notify you of the extension and the reason for it. If we deny a request in whole or in part, we will explain the basis for the denial.

California “Shine the Light” Law:

Under California Civil Code Section 1798.83, California residents may request information about categories of personal information we may have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please contact us using the information in Section 10 below.

If you have questions or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise any of your privacy rights, please contact us:

When submitting a privacy-related request, please include “Privacy Request” in the subject line and provide your name and contact information so we can respond.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, technology, or other factors. When we make changes, we will revise the “Effective Date / Last Updated” date at the top of this page.

For material changes, we may provide more prominent notice, such as posting a banner on the Site or sending a notification to the email address we have on file. Your continued use of the Site after any changes constitutes your acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.