Introduction

CRP Affordable Housing and Community Development, LLC ("Company," "CRP," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy ("Privacy Policy") explains what personal information we collect, how we use it, disclose it, and safeguard it when you use our website (the "Website"), access any content, functionality, and/or services offered on or through the Website, or otherwise interact with us online (collectively, the "Services").

By using our Website or Services, you acknowledge this Privacy Policy and agree to our Terms of Use.

Categories of Personal Information We Collect

In the preceding 12 months, we may have collected the following categories of personal information from or about users of our Website or Services. The categories and descriptions align with the definitions provided in the CCPA/CPRA and are included for transparency. A "Yes" designation means we may collect some information within that category (not necessarily all types), depending on your interaction with the Website or Services.

Sensitive Personal Information

Some personal information we collect may be considered "sensitive personal information" as defined under the CCPA. We do not "sell" or "share" your sensitive personal information, and we do not use or disclose it for purposes other than those permitted under the CCPA.

Sources of Personal Information

• Directly from you: leasing interest forms, housing applications, and other request forms.
• Indirectly: device and browser data via Google Analytics, cookies, and website tracking technologies.
• Third-Party Sources: credit reporting agencies, background check providers, government agencies, references, and other housing authorities.

Purpose of Collection and Use of Personal Information

We collect and use your personal information for the following business or commercial purposes ("Business Purposes"):

• To assess eligibility, process housing applications, verify income, and comply with affordable housing requirements.
• To communicate with applicants regarding application status and housing opportunities, request additional documentation, and provide tenant services.
• To maintain applicant and tenant records for pre‑leasing and leasing purposes, rent calculation, and compliance.
• To conduct necessary background checks, verify employment and rental history, and confirm other criteria required under affordable housing regulations, in accordance with law.
• To comply with federal, state, and local housing regulations, including fair housing laws and mandatory reporting obligations.
• To detect and prevent fraud and misrepresentation and ensure program compliance.
• To manage leases, renewals, and services provided to tenants or applicants.
• To maintain our business operations, IT systems, and records.
• To streamline our application workflow and data authenticity by using applicant and tenant data to train internal artificial intelligence (AI) models solely for internal business purposes (e.g., streamlining application processing or detecting potential fraud). We do not use AI models to determine eligibility or housing outcomes, and we do not use personal information for marketing or share it with third parties for their AI training.
• To comply with legal and regulatory obligations.
• For performance of obligations under our contract/agreement with you, or to take steps at your request before entering into a contract/agreement.
• Any other business or commercial purpose described at the time of collection or as otherwise permitted by law.

We do not use or disclose your personal (including sensitive) information beyond the purposes outlined in this Privacy Policy. If our practices change, we will update this Privacy Policy.

Disclosure of Information

We may disclose your personal information to the following categories of recipients, solely in ways compatible with the Business Purposes for which it was collected or authorized by you:

• Subsidiaries and affiliates;
• Contractors and service providers (e.g., IT, application processing, background checks, analytics, payment processing, document storage, communications, compliance) that are contractually obligated to use the information only for specified purposes;
• Property management companies and on‑site property managers that help operate and administer our affordable housing communities;
• Credit reporting agencies, screening/background check companies, government agencies, or regulatory authorities, as required by law;
• A successor entity in the event of a merger, acquisition, or sale, while maintaining confidentiality;
• As required by law or in response to a subpoena or other legal request.

We do not permit service providers, contractors, and/or third parties to use your personal information for their own purposes, except as required by law.

Sharing and Selling of Personal Information

We do not sell or share your personal information for purposes of cross‑context behavioral advertising as defined under the CCPA/CPRA. In the preceding 12 months, we have not sold or shared your personal information for such purposes. If this changes, we will update this Privacy Policy and provide a "Do Not Sell or Share My Personal Information" link, as required by law.

Your Privacy Rights Under California Law

Right to Know and Access

• Categories of personal information collected (including sensitive personal information);
• Categories of sources of personal information;
• Business or commercial purposes for collecting, selling, or sharing personal information;
• Categories of third parties to whom personal information is disclosed; and
• Specific pieces of personal information collected about you.

Right to Know What Personal Information Is Sold or Shared and to Whom

• Categories of personal information collected;
• Categories of personal information sold or shared and the categories of third parties to whom it was sold or shared; and
• Categories of personal information disclosed for a business purpose and the categories of recipients.

Right to Delete

Upon receiving a verifiable request, we will delete your personal information from our records and direct service providers/contractors and applicable third parties to do the same, unless an exception applies (e.g., to complete a transaction, ensure security and integrity, debug, comply with law, enable internal uses aligned with expectations, or other permitted purposes).

Right to Correct

If we maintain inaccurate personal information about you, you may request correction. We will use commercially reasonable efforts to correct the inaccurate information upon a verifiable request.

Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale of your personal information or sharing for targeted behavioral advertising. We do not sell or share your personal information for these purposes.

Right to Limit Use and Disclosure of Sensitive Personal Information

You may limit use and disclosure of sensitive personal information to that which is necessary to perform requested services or provide goods reasonably expected by an average consumer. We do not use or disclose sensitive personal information beyond what is required to provide affordable housing services.

Right of No Retaliation (Non‑Discrimination)

We will not discriminate against you for exercising your rights, including by denying goods or services, charging different prices/rates, providing a different level or quality, or suggesting you will receive a different price or level of service.

How to Exercise Your Rights

• Call us at [toll‑free phone number] during normal business hours, Monday through Friday, except public holidays; or
• Email/write to us at [contact information]; or
• Complete our [Webform + link].

We will confirm receipt of your request within 10 business days and respond within 45 days (or 90 days, if extended). To verify your identity, we may require certain information based on the right you wish to exercise. Any personal information collected for verification will be used solely for that purpose. If you submit a request on behalf of another person, you must provide a signed authorization or a legal power of attorney.

Cookies, Analytics, Ads and Tracking Technologies

We use Google Analytics in a manner designated not to constitute “selling” or “sharing” under California law, to understand how visitors use our website. We do not use such information for targeted advertising or cross‑context behavioral advertising.

We do not use cookies or tracking technologies for targeted advertising or cross‑context behavioral advertising. Our Website may use essential cookies for security and core functionality. You can disable cookies in your browser; doing so may affect your experience.

We may use Facebook Ads to promote affordable housing opportunities. If you submit your information via a Facebook lead form, Facebook may collect information (e.g., name, email, phone, city, zip code) and share it with us solely for the Business Purposes described in this Privacy Policy. We do not use this for cross‑context behavioral advertising or any other purpose except to respond to your inquiry or process your interest.

If our cookie, analytics, or ad practices change in a manner that constitutes “selling” or “sharing” under CCPA/CPRA, we will provide a “Do Not Sell My Personal Information” link and update this Privacy Policy.

Data Retention

We retain each category of personal information for a period reasonably necessary to fulfill the purpose for which it was collected. Certain application information must be retained to comply with applicable laws. If your application is approved, your information will be retained for the duration of your tenancy and as required by law. If denied, your information will be retained for a period necessary to defend against legal claims or comply with record‑keeping requirements. Retention periods are determined based on the nature of the information, applicable program regulations, legal requirements, and operational needs. When no longer required, we securely delete or anonymize the information in accordance with applicable laws.

Children’s Privacy

Our Website and Services are intended for individuals 18 years or older interested in affordable housing opportunities. We do not knowingly collect, use, or disclose personal information from children under 13 without verified parental or guardian consent. Any information about minors is collected only as part of household information when an adult (18+) submits an application. If you believe a child under 13 has provided personal information without consent, please contact us. Upon verification, we will promptly delete the information as required by law.

Data Security

We take reasonable measures in accordance with applicable laws to safeguard your personal information, including encryption, access controls, and secure servers. While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We strictly limit access to your information to employees who reasonably require it to perform their duties.

Background Checks

As part of the housing application process, we may conduct background checks—including credit, rental history, and other checks—in accordance with applicable laws. These checks help assess eligibility for affordable housing and compliance with program requirements. For details on your rights under the Fair Credit Reporting Act (FCRA) and other applicable laws, please contact us.

Opt‑out Communications

We may send communications related to your application or tenancy. We do not send advertising, marketing, or solicitation emails unless you have expressed interest in certain properties. You may opt out of non‑essential communications (e.g., promotional emails) at any time by contacting us at [__________] or following the opt‑out instructions in our communications. We may still send essential communications such as application updates or compliance notices.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time at our sole discretion. All changes are effective immediately upon posting on this page. For material changes, we will provide prominent notice on the Website. Your continued use of the Website and Services after changes are posted constitutes acceptance of the revised Privacy Policy.

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