Last Updated: October 29, 2025

Table of Contents

Purpose

The purpose of this policy and notice is to: (i) comply with the requirements of section 501.052 of the Texas Business & Commerce Code relating to the confidentiality of social security numbers disclosed to us by prospective and existing residents; and (ii) comply with the Texas Data Privacy and Security Act (the “Act”) pursuant to subtitle C of chapter 541 of the Texas Business & Commerce Code.

Definitions

  1. Controller: An individual or other person that, alone or jointly with others, determines the purpose and means of processing Personal Data.
  2. Deidentified Data: Data that cannot reasonably be linked to an identified or identifiable individual, or a device linked to that individual.
  3. Personal Data: Any information, including Sensitive Data, that is linked or reasonably linkable to an identified or identifiable individual. The term includes pseudonymous data when the data is used by a Controller or Processor in connection with additional information that reasonably links the data to an identified or identifiable individual. The term does not include Deidentified Data or publicly available information.
  4. Personal Information: An individual’s first name or first initial and last name in combination with a social security number.
  5. Processor: A person that processes Personal Data on behalf of a Controller.
  6. Sensitive Data: A category of Personal Data. The term includes: (i) Personal Data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnoses, sexuality, or citizenship or immigration status; (ii) genetic or biometric data that is processed for the purpose of uniquely identifying an individual; (iii) Personal Data collected from a known child; or (iv) precise geolocation data.

Privacy Policy

  1. Collection and use of Personal Information. When you apply to rent a unit in our community, we will ask you to disclose Personal Information on your rental application and possibly other documentation as necessary to meet our business purposes including confirmation of your identity, determination of your eligibility for rental and continued occupancy, enforcement of lease documents, community policies and rules and collection of amounts owed and other purposes as allowed by applicable law.
  2. Protection and access to Personal Information. We will keep Personal Information you provide to us in our files. If you become a resident in our community, we will keep Personal Information in a resident file. If you do not become a resident, we will keep Personal Information in a general file. Personnel with the owner and management company, if applicable, will have access to our files. We also reserve the right to disclose Personal Information to others to aid us in confirming your identity, determining your eligibility for rental or continued occupancy, enforcing lease documents, community policies and rules, collecting amounts owed and confirming other information as allowed by applicable law.
  3. Disposal of records containing Personal Information. It is our policy to dispose of records that contain Personal Information by shredding, erasing, or by other means making the Personal Information unreadable or undecipherable.
  4. Taking corrective action. In the event that you experience identity theft or we discover that there has been unauthorized acquisition of computerized data that compromises the security, confidentiality, or integrity of Personal Information, as defined above, we will comply with all applicable law with respect to taking appropriate corrective action.

Privacy Notice

Pursuant to section 541.102 of the Texas Business & Commerce Code, you are hereby notified as follows:

  1. The categories of Personal Data processed by us includes all information necessary for us to confirm your identity, determine your eligibility for rental or continued occupancy, enforce lease documents, community policies and rules and collect amounts owed. This information includes, but is not limited to, the following:
    • Records of earned income including paycheck stubs, W-2 forms, income tax returns, wage and tax receipts;
    • Records of other income including pension and annuities, social security benefits, SSI award letters, workers compensation, alimony, child support and income from any assets;
    • Asset information including bank statements, stock and bond certificates, mortgage notes and certificates of deposit;
    • Photo Identification including a driver’s license or passport or other government documentation;
    • Records to confirm citizenship and immigration status;
    • Credit scoring information including credit scores, bill-paying history, number and type of bank accounts, collection actions, outstanding debts and bankruptcy information;
    • Criminal history information; and
    • Rental history information including information regarding evictions, skips and money owed to previous owners.
  2. The purpose of processing Personal Data information is to confirm identity, determine eligibility for rental or continued occupancy, enforce lease documents, community policies and rules, collect amounts owed or other purposes allowed by applicable law.
  3. You may exercise certain consumer rights under the Texas Data Privacy & Security Act at any time by submitting a request to us by email or mail to the management office specifying the consumer rights you wish to exercise. These rights include, but are not necessarily limited to, the following:
    • Confirming whether we are processing your Personal Data and to access the Personal Data;
    • Correcting inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purpose of the processing of your Personal Data;
    • Deleting Personal Data provided by or obtained about you;
    • If the Personal Data is available in digital format, obtaining a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another Controller without hinderance; or
    • Opting out of the processing of the Personal Data for purpose of targeted advertising, the sale of Personal Data or profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you.

    We will provide information in response to your request free of charge, at least twice annually. If your request is manifestly unfounded, excessive or repetitive, we may charge you a reasonable fee to cover the administrative costs of complying with this request or may decline to act on the request. If we are unable to authenticate the request by using commercially reasonable efforts, we are not required to comply with your request and may request that you provide additional information reasonably necessary to authenticate your identification.

    If we refuse to take action on your request within a reasonable period of time, you may appeal our refusal to our corporate office at 20333 Hwy 249, Suite 650, Houston, TX 77070.

  4. The categories of Personal Data that we will share with third parties is the data that is subject to being verified by applicable third parties to confirm your identity, determine eligibility for rental or continued occupancy, enforce lease documents, community policies and rules, and collect amounts owed.
  5. You may submit requests to exercise your rights as provided above through email or mail to the management office at the property.

Note: The collection, maintenance, disclosure, sale, communication, or use of any Personal Data bearing on your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency or furnisher that provides information for use in a consumer report, and by users of a consumer report is not the type of information that is subject to this Privacy Notice to the extent that the activity is regulated by and authorized under the Fair Credit Reporting Act (15 U.S.C., Section 1681 et seq.).

 

Change log

  • October 29, 2025 – Updated Privacy Policy and Notice to comply with new Texas Data Privacy and Security Act and Section 501.052 of the Texas Business & Commerce Code; added consumer rights, appeal process, and Fair Credit Reporting Act exemption.
  • October 2, 2025 – Updated “Using Personal Information” to clarify that pre‑application communications are informational only and not solicitations; replaced “Opting Out of Communications and Advertisements” with “Managing Communication Preferences”; confirmed that marketing communications occur only with explicit opt‑in consent; added cross‑reference to Terms of Service.
  • August 18, 2022 – Published Second Revision.
  • June 29, 2022 – Published First Revision.