Privacy Policy for Posey Property Management, Inc.  (Company)

1. What is personal information?

Personal information is:

(1) information in a consumer report; or

(2) an individual’s first name or initial and last name in combination with any of the following:

(a) birth date;

(b) social security number or other government issued identification number;

(c) mother’s maiden name;

(d) unique biometric data (fingerprint, voice print, retina image);

(e) unique electronic identification number our routing code;

(f) telecommunication access devices including debit or credit card information; or

(g) financial institution account or information.

A consumer report is a report related to a person’s credit worthiness, credit standing, credit

capacity, character, general reputation, personal characteristics, or mode of living prepared

by or obtained from an agency that collects such information such as a credit reporting

agency.

2. How is personal information collected?

This company obtains personal information in the following ways:

(1) in consumer reports from reporting agencies to which this company subscribes in

connection with lease applications, loan applications, or for other reasons that the

consumer may authorize this company to obtain;

(2) in lease applications a prospective tenant completes;

(3) in loan applications a borrower or buyer completes;

(4) in other real estate related forms the customer or client completes in or related to a

transaction; and

(5) in tax reporting forms that the customer or client is required to complete and which are

given to this company.

When completing the forms required above, the customer or client may send the information

to this company by mail, fax, personal delivery, or by e-mail. Customers or clients may

occasionally provide personal information to this company or its agents by other means

such as telephone calls, fax messages, or e-mail messages in order expedite a transaction

in which the customer or client is involved.

3. How and when is the personal information used?

Personal Information from Prospective Tenants: The personal information that prospective

tenants provide to this company is primarily used to obtain consumer reports (credit checks).

It may also be used to perform background checks and rental history searches. The

information in the consumer reports may be discussed with landlords for whom this

company manages property. This company also reports information to credit reporting

agencies and uses personal information to complete those reports.

Personal Information from Owners of Properties Managed by the Company: When this

company acts as a property manager for a property owner, the company uses the property

owner’s personal information only: (a) to deliver the required management services; (b) to

file any required reports with governmental agencies (for example, the IRS); or (c) for other

purposes the property owner may authorize.

Personal Information from Clients: When this company represents a person (buyer, seller,

landlord, or tenant) in a transaction the agent servicing the client may, on the client’s behalf

and at the client’s instruction, convey personal information he or she provides to the agent to

service providers (for example, mortgage lenders and title companies) as those service

providers may require for the products or services the client needs or requests. If this

company represents a prospective tenant in a lease transaction, the personal information

may, on the tenant’s behalf and with the tenant’s knowledge, be discussed with and

provided to landlords or their agents. This company and its agents exercise reasonable

discretion when discussing any personal information with others.

4. How is the personal information protected?

Written files in this company are protected under lock and key. (Describe any additional

precautions or make any necessary modifications.)

Electronic records are protected under an access name and password assigned to persons

in this company.

This company and its agents exercise reasonable discretion when discussing any personal

information with others and releases personal information to others only as described by this

policy.

This company does not permit its employees or agents to make copies of consumer reports

or records of insurance claims. The consumer reports retained in the company’s files are

not to be accessed in the future as a convenience to customers or clients.

The individual agents that work with this company are independent contractors and the

agent with whom a customer or client works with may maintain a separate transaction file.

The company instructs its agents to not permit other persons to access the personal

information in files the agents maintain. The company instructs its agents to protect the

personal information in the agents’ files in the same manner as described in this policy.

Include additional statements about additional protections.

5. Who has access to the personal information?

The following persons have access to personal information in this company’s files:

(1) the agent or broker who is servicing or coordinating the transaction;

(2) the office manager to whom the agent reports; and

(3) the owner of the company.

Property owners for whom the company manages properties do not have access to

personal information in the company’s files. However, the company and its agents may

discuss the information in a tenant’s consumer report or lease application with a property

Model Privacy owner. Copies of such information are provided to the landlord only: (1) with the tenant’s

consent; or (2) if the company ceases to be the property manager and the landlord requests

that the files be sent to the landlord, the landlord’s attorney, or the new property manager.

Personal information from a buyer, seller, landlord, or tenant may be discussed with others

(such as mortgage lenders or prospective landlords) only as is reasonably necessary to

negotiate or close the transaction or to provide the services the customer or client seeks

from this company.

This company may, at the customer’s or client’s request, provide personal information to

service providers in a transaction such as a title company or mortgage company if it is

necessary to expedite or complete a transaction.

If the company is required by law to allow others to access the personal information in the

company’s files, the company will comply with the law (for example, compliance with court

orders, subpoenas, or governmental investigations). The company will also allow law

enforcement agencies access to personal information in order to cooperate with such

investigations.

.

6. How is the personal information disposed?

This company uses reasonable measures to dispose of personal information. Personal

information is usually disposed of by shredding or burning documents, erasing electronic

files by means that make the files unreadable or undecipherable, or by eradicating personal

information from documents or electronic files in ways that make the personal information

unreadable.

7. Erroneous Records:

If this company erroneously reports information to a consumer reporting agency, the

company will act to correct the information in the company’s records and request the

reporting agency to correct the information in its records promptly after the company has

learned and determined that the report was in error.

If this company maintains an erroneous record that a consumer has issued a dishonored

check, the company will promptly delete the record after the company and consumer agree

that the information is in error or after the consumer provides the company with a law

enforcement agency report stating that the dishonored check was not authorized.

Notice: This company asks any person who provides personal information to this

company or one of its agents to identify the information at that time as “personal information.