Privacy Policy

NE PROPERTY MANAGEMENT COMPANY PRIVACY POLICY

Last updated March 26, 2026

Thank you for reviewing the NE Property Company Privacy Policy (the “Policy”).

The terms “NEPM,” “we,” “our” and “us” are used to refer to NE Property Management Company, LLC, a Texas limited liability company and its affiliates, members and managers as well as owners of residential apartment communities managed by NE Property Management Company, LLC. “You” or “your” refers to you as a user of our services described in this Policy.

We respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, applications and software applications operated by us or on our behalf and that link to this Policy (our “Services”). This Policy also explains our practices for using, maintaining, protecting, and disclosing that information.
This Policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.
• When you interact with our applications (including mobile apps) on third-party websites and services, if those applications include links to this Policy.

It does not apply to information collected by:

• Us through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries) that does not link to this Policy; or
• Any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this Policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree/consent to the collection, use, and sharing of your information as described in this Policy. This Policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, credit card number, social security number, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we may collect, use, store, transfer or otherwise process include:

• Account and contact information, including name, maiden name, address (such as home address, work address, or other address), email address, phone number, username, and other contact information you provide us.
• Account history, including information about your account and transactions.
• Demographic information, including your age, gender, income level, education, family or marital status, veteran or military status, criminal history and, in certain cases, disabilities or related health restrictions so that we can provide you with adequate accommodation, subject, in each case and if required, to you having consented to such information collection.
• Location information, including general geographic location such as country, state or province, or city and precise geolocation, if you have enabled and consented to location information collection.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
• Content and information you elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us.
• Images, voice recordings, and videos collected or stored in connection with the Services, if you have consented to such information collection, if required.
• Identity document information, such as Social Security, driver’s license number and passport number, if you have consented to such information collection if required.
• Commercial information such as details about payments made to and from you including method of payment, other details of products and services purchased, obtained or considered, purchasing histories or tendencies, utility bills, insurance claimant name and contact information, lease information, rental history, rental applicant screening information and other information related to your rental.
• Professional or employment-related information such as employment history, salary/pay history, employment status, job title, education, university or school(s) attended, diploma(s) and other CV information.
• Vehicle information such as the type, make, model, year, color and license plate number for you and other family members living with you.
• Pet information such as the name, type, breed, color, weight, age license number, vet information, vaccination and rabies shot records and microchip details for any family pets on-site.
• Internet and other electronic network activity information including internet protocol address, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
• Usage data including information about how you use our Services.
• Inference data including inferences drawn from the personal information identified in this Policy.

Some of the information identified above, including identification document information, precise geolocation information, and biometric information, may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. We do not use or disclose sensitive personal information for any business purposes other than as permitted by law including providing goods and services, verifying your information and/or as otherwise permitted by applicable regulations. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.
We also collect:

• “Statistics or Aggregated Information.” Statistics or aggregated information does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• “Technical Information.” Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How Long Personal Data Will Be Retained

We only retain your personal data for as long as reasonably necessary to accomplish the purposes for which we collected. That may include satisfying legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period if, for example, a complaint is filed or if we reasonably believe litigation may be initiated involving our relationship with you. To determine the length of retention, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, make a request, use the payment options or communicate with us through the management of a project or otherwise.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

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

• “Cookies.” A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• “Web Beacons.” Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, verifying system and server integrity).

To the extent any of these automated technologies are considered to be not in accordance with applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting NEPM in the manner set forth on the last page of this Policy. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device.

These third parties may include:

• Analytics companies.
• Your device manufacturer.
• Your internet or mobile service provider.
• Companies we engage for operational purposes and with which Tenants will interact.

These third parties may use tracking technologies to collect information about you when you use the Services. An example of a third party is RealPage, which each tenant of one of our apartment communities will use. RealPage uses cookies for operational purposes such as website performance analysis, user experience improvements and marketing effectiveness. RealPage has its own privacy policy regarding any information it collects which can be found at: https://www,realpage.com/legal/privacy-policy/. In other circumstances, a third party may collect personal data about your online activities over time and across different websites, apps, platforms, and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, payment processors, analytics, security and anti-fraud services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information or services that we make available through the Services.
• Fulfill any other purpose for which you provide it. Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training. Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services. We may use your information to model, segment, target, offer, market, and advertise our Services.
• Carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any services we offer or provide through them
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate the number of users and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Recognize you when you return to our Services.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect, or you provide as described in this to our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NEPM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by NEPM is among the assets transferred.
• 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 also disclose your personal data:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The categories of personal data we may disclose include:

• Account and contact information
• Payment information.
• Account history, including information about your subscription, account, transactions, or discounts.
• Demographic information.
• Location information, including general geographic location and precise geolocation
• Device information.
• Content and information you choose to provide for us.
• Images, voice recordings, and videos collected or stored in connection with the Services, if you have consented to such information collection (if such consent is required under applicable law).
• Identity document information.
• Biometric information.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.
Cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked.

Location data choices:

• Location Data. You can choose whether to allow the Services to collect and use realtime information about your device’s location through the device’s privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, considering the information’s nature and processing purpose
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.

Important: The exact scope of these rights may vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.
To exercise any of these rights, please request a review by NEPM at corporate@nemanagement.net. Please indicate “Privacy Policy Inquiry” in the subject line.
With respect to our Colorado residents, your State has adopted a privacy law or laws which are applicable to certain organizations; however, they are not currently applicable to NEPM.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this Policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or any part of the data that identifies an individual will be deleted.

Changes to Our Privacy Policy

We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. The date the Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the “last updated” date and posting the updated Policy on the Services. We may email or otherwise communicate reminders about this Policy, but you should check our Services periodically to see the current privacy policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this Policy or our privacy practices, contact us at:

corporate@nemanagement.net

Please include “Privacy Policy Inquiry” in the subject line.