CJ Privacy Principles:

Accountability: The corporate office establishes policies and procedures for each property and their staff responsible for the personal information under the control. Purpose: The purpose personal information is being collected shall be identified at or before the information is collected. Limiting Consent: Obtaining consent from the individual is the expected approach for the collection, use and disclosure of personal information, but it is not always feasible, appropriate or the only legal means of authority. Collection: Information we collect: We collect personal information such as contact information; this includes all applicants for a household, as well as guarantors (name, address, phone number or email address, social security numbers, income verification, assets, etc). When submitting personal information on an online or paper form, we will identify which fields are required in order to fulfill your request. When we collect the information: We will request personal information when you schedule an appointment, request services via a guest card when visiting our properties, application for housing and if for specific program assistance via affordable housing more information is required and authorized for assistance through Department of Housing and Urban Development, Internal Revenue Services or state governmental requirements. How we collect the information: Personal information starts directly with the individual about that individual via paper and/or electronically. In an effort to comply with governmental requirements and sound business practices, a third party such as a credit reporting agency, public records, criminal records, landlord, employer, income source or governmental agency is contact via writing, fax, and phone for personal information. In these instances the applicant/resident is requested to sign a release form for the company to request the information. Use and Disclosure Personal information shall be used or disclosed for the stated purpose for addressing applicant inquiries, qualifying for residency both on initial and based on governmental requirements annual upon lease renewal, except with the consent of the individual as expressly authorized by the law. CJ May need to share personal information with third parties in limited circumstances. For example, we may release personal information to third parties to perform services on our behalf such as fulfilling our customer’s requests, sending out marketing or customer service surveys, processing credit card, debt card or e-payments. We may have to share the information provided to governmental agencies/contract administrators that provide housing assistance or monitor compliance with regulations. Owners, refinancing/purchasing. If we believe unlawful activities are underway, we reserve the right to share personal information with he authorities. CJ does not sell or rent out our consumer, applicant, customer or resident information to third parties. Retention Personal information will be retained in accordance with company document control procedures which were designed with governmental program requirements, as well as in fulfillment of the stated collection purposes or as specified by law. Accuracy Personal information shall be accurate, complete and up to date as is reasonably necessary for purposes for which it is to be used. . Safeguards: Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alternation or destruction of data, we take reasonable precautions to prevent such unfortunate occurrences. CJ Management has implement document control procedures including disposal procedures for all consumer information. We strive to educate our staff and provide the necessary tools need to value the importance of protecting consumer privacy. We cannot ensure or warrant the security of any information provided to our organization transmitted to us via email by yourself and you do so at your own risk. Openness: The privacy principles and the policies and procedures relating to their implementation shall be readily available to our consumers. Access and Correction Upon request, an individual, with proper documentation of identity, shall be given access to their personal information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Access to some information will be denied if it would pose a serious threat to the life or health of any other individual in the property or the request is deemed frivolous or vexatious or the information relates to existing or anticipated legal proceedings between the organization and the individual and the information would not be accessible by the process of discovery in those proceedings; finally it would be unlawful. Compliance and Who do I contact if I have questions or Concerns: An individual may challenge a CJ employees’ compliance with these principles by contacting the Privacy Manager for CJ Management via in writing: CJ Management and Affiliates, Bayside Office Center, 150 Mt. Vernon Street, Suite 520, Boston, MA 02125 Reasonable steps will be taken to investigate claims of inaccurate or incomplete date we collect, use or disseminate, and if appropriate, correct the information. Changes to Policy CJ Management Company reserves the right to change this privacy policy at any time. We will post changes on our company web site. Our web sites, technology and business is changing on a continual basis and we are able to provide features we may not have had option to do so in the past. These changes may assist in protecting the data provided. Therefore we encourage you to review it periodically to see if there have been any changes If we change our policy in such a way that your personal information may be shared in a different manner, we will give you an opportunity to opt-out of having your information used or shared in the new manner, as long as that opt out does not conflict with the program requirements for any governmental agencies. This policy has been created and modified as of November 15, 2006.