Last Updated: September 1, 2025

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 ("Website"), access any content, functionality, and/or services offered on or through the Website, or otherwise interact with us online ("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. Please note that the following categories and descriptions align with the definitions provided in the CCPA/CPRA and are included for transparency. However, they are merely indicative of the category of personal information we collect.

A 'Yes' designation for a category means that we may collect some personal information within that category, but not necessarily all types of information listed herein. The actual information collected depends on your interaction with the Website or Services.

Category of Personal Information	Collected for a Business Purpose	Disclosed for a Business Purpose
Identifiers: Such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver's license or state identification number, passport number, or other similar identifiers.	Yes	Yes
Personal information categories listed in the California Customer Records statute: Such as name, address, telephone number, Social Security number, driver's license or state identification number, employment history, bank account number, income, and financial information.	Yes	Yes
Protected classification characteristics under California or federal law: Such as age, race, sex, ethnicity, nationality, citizenship status, marital status, disability status, military and veteran status, and dependent information.	Yes	Yes
Commercial information: Such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes
Internet or other electronic network activity information: Such as browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.	Yes	Yes
Professional or employment-related information: Such as current and past job history.	Yes	Yes
Education Information: Such as names of schools attended, dates of attendance, and degrees or certificates earned.	Yes	Yes

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" (as defined by the CCPA) your sensitive personal information, and we do not use or disclose your sensitive personal information for purposes other than those permitted under the CCPA. Sensitive personal information we collect includes:

	Collected for a Business Purpose	Disclosed for a Business Purpose
Government identifiers: Such as Social Security number, driver's license or state identification number, or passport number	Yes	Yes
Financial account information: Such as bank account number, certain credit check information, and other financial information.	Yes	Yes
Demographic information: Such as race, ethnicity, marital status, and disability status.	Yes	Yes
Citizenship and immigration status.	Yes	Yes
Health information: Such as about disabilities.	Yes	Yes

Sources of Personal Information

We collect personal information about you from the following sources:

Directly from you:

Leasing interest form, housing application and/or 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 only 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 their application status and housing opportunities, to request additional documentation, if needed, and to 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 as well as 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 our internal artificial intelligence (AI) models. Please note that these models are used solely for internal business purposes such as streamlining application processing or detecting potential fraud. We do NOT use AI models to determine eligibility or housing outcomes. All decisions regarding eligibility, leasing, and housing assignments are made by qualified staff in accordance with applicable laws and program requirements. We do NOT use your personal information in AI models for marketing, or advertising, nor do we share your information with third parties for their own AI model training.

To comply with legal and regulatory obligations.

For the performance of obligations pursuant to 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 to you at the time of collection or as otherwise permitted by law.

We do not use or disclose your personal information and sensitive personal information for any purposes beyond those outlined in this Privacy Policy or as reasonably required to provide affordable housing services. If our practices change and we use your personal information for purposes beyond those described in this Privacy Policy, we will update this Privacy Policy.

Disclosure of Information

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

Subsidiaries and affiliates

Contractors and/or service providers

That assist in operating our business, providing services, or fulfilling legal obligations and are contractually obligated to use the information only for the purposes specified by us, including but not limited to entities providing services related to IT, application processing, background checks, analytics, payment processing, document storage, communications, and compliance.

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 ensuring that confidentiality is maintained.

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-contextual behavioral advertising, as defined under CCPA. In the preceding 12 months, we have not sold or shared your personal information (as these terms are defined by CCPA/CPRA) for purposes of cross-contextual behavioral advertising, or any other purpose. If this ever 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

If you are a California resident, you have certain rights under the CCPA/CPRA, including:

Right to Know What Personal Information is Being Collected and Right to Access Personal Information

You have the right to know and request disclosure of:

The categories of personal information we have collected about you, including sensitive personal information;

The categories of sources from which the personal information is collected;

The business or commercial purpose for collecting, selling, or sharing personal information;

The categories of third parties to whom we disclose personal information, if any; and

The specific pieces of personal information we have collected about you

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

In connection with any personal information that a business may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information the business collected about you.

The categories of personal information about you that the business sold or shared and the categories of third parties to whom the personal information was sold or shared; and

The categories of personal information that the business disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

Right to Delete Personal Information

You have the right to request the deletion of the personal information that we have collected from you. Upon receiving a verifiable request, we will:

Delete your personal information from our records; and

Direct any service providers or contractors to delete your personal information from their records.

Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

We may deny your request to delete if it is reasonably necessary to maintain your personal information in order to:

Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipate within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes;

Debug to identify and repair errors that impair existing intended functionality;

Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;

Comply with the California Electronic Communications Privacy Act;

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; or

Comply with an existing legal obligation.

Right to Correct Inaccurate Personal Information

If we maintain inaccurate personal information about you, you have the right to request that we correct or update that information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right to Opt Out of Sale or Sharing of Personal Information

You have the right to opt-out of the sale of your personal information or sharing of your personal information for targeted behavioral advertising.

We do not sell your personal information or share it for purposes of cross-contextual behavioral advertising, as defined under CCPA.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right, at any time, to limit the use and disclosure of your sensitive personal information to the use that is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.

We do not use or disclose sensitive personal information for any purposes beyond those outlined in this Privacy Policy, as required for providing affordable housing services.

Right of No Retaliation Following Opt Out or Exercise of Other Rights

You have the right not to be discriminated against by us upon exercise of your rights under the CCPA/CPRA. We will not discriminate against you for exercising your rights under the CCPA/CPRA and will not, among other things:

Deny goods or services to you;

Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

Provide a different level or quality of goods or services to you; or

Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights

If you would like to exercise any of your rights as a California resident, as described in this Privacy Policy, you may:

Email/write to us at info@crpaffordable.com.

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 we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. We are not obligated to fulfill such requests if we cannot verify the identity of the person making such request. If you are submitting 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 only in a way designated not to constitute 'selling' or 'sharing' under California law. We use Google Analytics to understand how visitors use or interact with our website. Google Analytics collects device and usage information, including IP address and browser data. 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. However, our Website may use essential cookies that are necessary for security and core functionality. You can choose to disable cookies through your browser settings; however, doing so may affect your experience on the Website.

We may use Facebook Ads to promote our affordable housing opportunities. If you choose to submit your information through a Facebook lead form, Facebook may collect information from you, such as your name, email address, phone number, city, and zip code, and share that information with us for the Business Purposes described in this Privacy Policy. We do not use this for cross-context behavioral advertising or for any other purpose except to respond to your inquiry or process your interest in our affordable housing opportunities.

If our cookie, analytics or ad practices change in the future 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 accordingly.

Data Retention

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

Children's Privacy

We value children's privacy and do not direct our services to minors. Our Website and Services are intended for individuals interested in affordable housing opportunities who are 18 years or older. We do not knowingly collect, use, or disclose personal information from children under the age of 13 without prior verified parental or guardian consent. Any information about children or minors is only collected as part of the household information and only when an adult household member (age 18 or older) submits an application with the requisite details. If you believe a child under 13 has provided personal information without prior verified parental or guardian consent, please contact us. Upon verification, we will promptly delete the information from our records in compliance with applicable laws.

Data Security

We take reasonable measures in accordance with applicable laws to safeguard your personal information and implement appropriate security measures to protect the information stored with us. These measures include, but are not limited to, implementing encryption methods, implementing access control, and storing data on secure servers. While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee its absolute security. We strictly limit access to your personal information to employees who reasonably require it to perform their duties to provide services to you. We take precautions we deem reasonable to protect your information in the process.

Background Checks

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

Opt-out Communications

We may send you communications related to your application or tenancy. However, 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, such as promotional emails, at any time by contacting us at info@crpaffordable.com or by following the opt-out instructions provided in our communications. However, we may still send you essential communications, such as application updates or compliance notices.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy from time to time at our sole discretion. All changes will be 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 have been posted will constitute your acceptance of the revised Privacy Policy.

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