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Thalhimer Multifamily (“TMF,” “we,” “us,” or “our”) respects the privacy of individuals who visit our corporate website and the websites of the apartment communities we manage (collectively, the “Websites”). This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with our Websites and related online services.

This Privacy Policy is designed to comply with applicable federal and state privacy laws, including the Virginia Consumer Data Protection Act (VCDPA) where applicable, and relevant North Carolina data security and consumer protection requirements.

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1. Scope

This Privacy Policy applies to personal information collected through: - Thalhimer Multifamily’s corporate website; - Individual apartment community websites managed by TMF; - Online applications, resident portals, prospect and contact forms, and related digital tools.

This Policy does not apply to information collected offline or through third-party websites or platforms not controlled by TMF.

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2. Personal Information We Collect

We may collect the following categories of personal information:

A. Information You Provide Directly

· Name

· Email address

· Phone number

· Mailing address

· Rental application information (including employment, income, and rental history)

· Account login credentials for resident or applicant portals

· Communications you send to us (inquiries, service requests, feedback)

B. Information Collected Automatically

When you visit our Websites, we may automatically collect: - Internet Protocol (IP) address - Device type, operating system, and browser type - Pages viewed, navigation paths, and interaction data - Referring URLs - Date and time of access

C. Cookies and Tracking Technologies

We use cookies and similar technologies to: - Enable core website functionality - Analyze website usage and performance - Support marketing, advertising, and leasing activities

You may manage cookies through your browser settings. Disabling cookies may affect certain Website features.

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3. Purposes for Processing Personal Information

We use personal information for legitimate business and operational purposes, including: - Responding to inquiries and providing requested information - Leasing administration, rental applications, and resident services - Processing applications and supporting housing decisions - Operating resident portals and maintenance request platforms - Improving Website functionality and user experience - Marketing apartment communities and related services - Complying with legal, regulatory, and contractual obligations

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4. Disclosure of Personal Information

We may share personal information with the following categories of third parties: - Property owners and asset managers for communities we manage - Vendors and service providers (e.g., property management software, payment processors, marketing and analytics platforms) - Professional advisors (legal, accounting, insurance) - Governmental or regulatory authorities as required by law

TMF does not sell personal information for monetary consideration as defined under applicable law.

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5. Targeted Advertising

We may engage in targeted advertising through third-party platforms based on information collected from your interactions with our Websites. Where required by law, you may opt out of targeted advertising as described in Section 8 below.

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6. Data Security and Retention

TMF maintains reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

Personal information is retained only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

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7. Children’s Privacy

Our Websites are not directed to children under the age of 13, and TMF does not knowingly collect personal information from children.

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8. State-Specific Privacy Rights

A. Virginia Residents

If you are a Virginia resident and the Virginia Consumer Data Protection Act applies, you may have the right to: - Confirm whether we are processing your personal data - Access your personal data - Correct inaccuracies in your personal data - Delete personal data provided by or obtained about you - Obtain a portable copy of your personal data - Opt out of the processing of personal data for targeted advertising

Exercising Your Rights (Virginia)

You may submit a request by: - Emailing: Info@thalhimer.com - Completing a request form available on our Websites

We will respond to verified consumer requests within the timeframes required by law. If we deny your request, you may appeal our decision using the same contact methods.

B. North Carolina Residents

North Carolina law does not currently provide comprehensive statutory consumer privacy rights equivalent to the VCDPA. However, TMF is committed to honoring reasonable requests to access, correct, or delete personal information, subject to legal and contractual limitations.

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9. Third-Party Websites and Services

Our Websites may contain links to third-party websites or services. TMF is not responsible for the privacy practices or content of third parties, and we encourage users to review applicable third-party privacy policies.

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10. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Updates will be posted on this page with a revised effective date. Continued use of the Websites after such updates constitutes acceptance of the revised Policy.

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11. Contact Information

If you have questions or requests regarding this Privacy Policy or our data practices, please contact:

Thalhimer Multifamily 11100 West Broad Street Email: Info@Thalhimer.com Phone: (804) 648-5881