Introduction This Privacy Policy applies to individuals (“you” or “your”) interacting with ESI Management Group LLC (“ESI,” “we,” “us,” or “our”) and any one of our ESI separately as defined under applicable U.S. privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and Federal Trade Commission (FTC) regulations. This Policy supplements our general privacy practices to ensure compliance with all relevant laws and regulations. Information We Collect We collect and process personal information that identifies, relates to, or is reasonably associated with a specific individual, household, or device (“Personal Information”). This includes: • Identifiers: Name, postal address, email, IP address, Social Security number, driver’s license number, or other unique identifiers. • Personal Records: Contact details, account credentials, and any legally required identification. • Demographic Information: Age, gender, race, national origin, or other protected characteristics. • Commercial Information: Records of transactions, inquiries, and rental applications. • Internet or Network Activity: Website browsing behavior, log data, and usage analytics. • Geolocation Data: Location-based information derived from digital interactions. • Employment Information: Work history, job application details, and references. • Inferences: Consumer preferences and behavioral insights for service improvements. • Sensitive Personal Information: Social Security numbers, account credentials, and authentication data. How We Use Personal Information ESI Management Group may use your Personal Information for the following purposes: • Providing Housing Services: Processing rental applications, executing lease agreements, and maintaining communication. • Customer Support & Communication: Responding to inquiries and service requests. • Marketing & Promotions: Personalizing advertisements, special o ers, and promotional materials (with consent where required). • Legal & Compliance: Ensuring regulatory adherence, fraud detection, and security enhancements. • Artificial Intelligence (AI) & Automation: AI-driven chat interactions, automated application processing, and customer analytics, ensuring responsible AI use in compliance with FTC guidelines. • Research & Development: Enhancing service offerings through trend analysis and consumer behavior insights. • Business Operations: Facilitating mergers, acquisitions, or corporate restructuring while maintaining data protection compliance. Disclosure of Personal Information In the past 12 months, we have disclosed Personal Information to service providers, and third-party partners for business operations, marketing, and analytics. Categories of third-party disclosures include: • Service Providers: Payment processors, IT support, and property management platforms. • Marketing Partners: Advertising networks and customer engagement platforms (with opt out options). • Regulatory & Legal Entities: Government agencies or law enforcement when required by law. • A iliated Businesses: Related entities assisting in service execution or legal transactions. Retention of Personal Information We retain Personal Information for as long as necessary to fulfill service obligations, comply with legal retention policies, and safeguard against potential disputes. Your Rights & Choices You have rights under U.S. privacy laws, including: • Right to Access & Know: Request details about the Personal Information collected. • Right to Correct Information: Update inaccurate Personal Information. • Right to Delete: Request deletion of Personal Information, subject to exceptions. • Right to Opt-Out of Sale or Sharing: Restrict third-party data processing for targeted advertising. • Right to Limit Sensitive Personal Information Processing: Control how sensitive data is used. • Right to Appeal: Challenge decisions regarding your privacy requests. Exercising Your Rights To exercise your privacy rights, submit a request via: • Online Form: https://www.esimanagementgroup.com/contact • Phone: 513.214-1933 • Email: management@esimanagementgroup.com Verification of identity is required before processing any request. AI & Automated Decision-Making ESI Management Group LLC may use AI and automated tools for: • Rental Application Processing: AI-assisted evaluations ensuring fair screening. • Chatbot & Virtual Assistants: Enhancing customer service interactions. • Marketing Personalization: Customizing content recommendations and o ers. We ensure AI implementation aligns with FTC compliance, fairness, and transparency. Children’s Privacy Our websites are not directed at children. We do not knowingly process or maintain information at our sites from those who are considered children in the jurisdiction in which they reside. We do not permit children under 18 years of age (or such higher age specified by applicable law) to become registered users of our sites. By using any of our sites, you represent that you are not under 18 years of age (or such higher age specified by applicable law). If we detect that you do not meet these age requirements, we may take reasonable measures to block and/or delete the Personal Information that you provided. Parents or guardians who believe their child has provided us with Personal Information may contact us to request its removal. Updates to This Policy PLK Communities reserves the right to amend this Privacy Policy at its discretion. Updates will be reflected on our website with the new effective date. Contact Information For privacy inquiries or to request this document in an alternative format, contact us at: • Email: management@esimanagementgroup.com • Mail: ESI Management Group LLC Attn: Data Privacy, 6545 Market Ave N STE 100 Canton OH 44721