Privacy Policy

This web site (the” Web Site”) is provided by National Apartment Management, a Nevada limited liability company, Executive Affiliates, Inc., an Illinois corporation and their affiliates, subsidiaries and related entities and the successors and assigns of the aforementioned (“Company,” “we,” “our” or “us”). This Privacy Policy describes our privacy practices with regard to information about you that could reasonably be used to identify you personally or that is associated with information that identifies you (“Personal Information”); provided, however that we do not treat Unique IDs (defined below) as Personal Information except to the extent required by applicable law. Unless specifically stated otherwise, this Privacy Policy applies to Personal Information that we gather or collect via the Web Site and any other Company web site or online service that posts a link to this Privacy Policy, as well as Personal Information that we collect offline. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Web Site at any particular time, or at all.

PLEASE REVIEW THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT CONSENT TO OUR PRACTICES AS STATED HEREIN DO NOT CONTINUE USE OUR WEB SITE. YOUR USE OF THE WEB SITE REPRESENTS ACCEPTANCE OF OUR PRIVACY POLICY AND AGREEMENT TO OUR TERMS OF USE, WHICH GOVERN YOUR USE OF THE WEB SITE.

You should read this entire Privacy Policy, but here is a partial list of some key topics. Any capitalized terms have the meanings given to them where defined in the Privacy Policy.

We may ask you for, and use Tracking Technologies (defined below) to detect, information about you, and third parties may also do so in connection to our Web Site (defined below). As examples:

• • Third parties, including without limitation advertisers and advertising services providers, may collect information about you. They may use Tracking Technologies in connection with our Web Site, which may include the collection of information about your online activities over time and across third-party sites or services. Their privacy policies, not ours, govern their practices.
  • We do not monitor or take any action with respect to so-called browser do not track signals, but you have certain other options regarding tracking and/or targeting.
  • We associate Tracking Technologies with your device so we can send you ads about us when you are on other sites, however, you may have certain opt-out options.

You consent to our practices detailed in our Privacy Policy. Each time you use the Web Site, the version of our Privacy Policy then posted will apply to that use, subject to Section 11, so check for updates each time you access the Web Site.

Table of Contents

1. Collection of Information about You.
   1.1 Active Information Collection.
   1.2 Passive Information Collection.
   1.3 Offline Collection from You.
   1.4 Information Collected from Other Sources.
   1.5 Children.
   2. Use of Personal Information.
   3. Sharing of Personal Information with Third Parties.
   3.1 Affiliated or Subsidiary Companies.
   3.2 Third parties providing services on our behalf.
   3.3. Legal Requirements and Law Enforcement.
   3.4 Corporate Change.
   3.5 Equal Employment Opportunity Reporting.
   4. Non-Personal Information.
   5. Exercising Choices Regarding Analytics and Advertising.
   6. Updating Your Information.
   7. Data Security.
   8. Third Party Content and Services.
   9. Links to Other Web Sites.
   10. Privacy Policy Changes.
   11. Consent to Transfer.
   12. Questions.
2. Collection of Information About You.

1.1 Active Information Collection.
We may collect Personal Information from you at various places and through various mechanisms on the Web Site or offline. As examples, this may include without limitation, now or in the future, when you fill out and submit forms (such as forms requesting information needed to consider you for apartment rentals or potential employment opportunities), when you initiate payments to us through the Web Site or otherwise, when you participate in promotions, contests, or sweepstakes, when you post to any interactive forum, bulletin board, chat room that we may make available on the Web Site, when you register for e-mail communications, and when you submit a survey response, question or request to the Web Site using a form or the e-mail address links on the Web Site.

1.2 Passive Information Collection.
When you visit the Web Site, we automatically collect certain information about your activities (“Web Site Usage Information”). Web Site Usage Information we automatically collect about your activities may include information about your device, including browser and device identifiers such as IP address (“Unique ID”), and information about how our visitors use and navigate the Web Site. This may include, for example, the number and frequency of visitors to each web page, the length of their stays, the type of browser each visitor is using to view the Web Site (for example, Internet Explorer, Firefox), the type of operating system each visitor is using, (for example, Windows 10, Mac OS X), the domain name of each visitor’s Internet service provider (for example, AT&T, Charter, Comcast, Cox, Time Warner, Verizon), the visitor’s IP address and/or device ID, the address (or “URL” ) of the web site that the visitor came from before visiting the Web Site, which pages were visited on the Web Site, what was clicked on, and certain other available information. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which our web servers may use to identify where to send the information your computer requests. When you request pages from the Web Site, our servers may log your IP address as well as information about your activities on those pages
To collect this Web Site Usage Information, the Web Site and any e-mails sent to you by the Web Site (or otherwise by Company) may utilize cookies, web beacons, embedded scripts or other tracking technologies now and hereafter devised (“Tracking Technologies”)
Cookies. A cookie is a small data file placed on a device when it is used to visit the Web Site. A Flash cookie (or locally shared object) is a data file placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device HTML5 cookies can be programmed through HTML5 local storage. To identify local shared objects on your computer and adjust your settings, please Visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs,” “Pixel Tags,” or “Web Bugs”) may be included in our Web Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Web Site, to monitor how users navigate the Web Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Web Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Web Site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of other information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at the URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of UID. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets which attempt to recognize or make assumption about users or devices (e.g., that a user of multiple devices is the same user of household).

In addition, third parties may use Tracking Technologies in connection with the Web Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Web Site and accept that our statements under this Privacy Policy regarding our practices do not apply to the Tracking Technologies or practices of such third parties.

Also, various third parties are developing or have developed signals or other mechanisms known as “do not track signals”. For instance, some browsers may have such signal options, though they differ as to if the signal is set as default or must be turned on by the user. Further, there is not yet an industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these signals or other mechanisms, though we may consider doing so if an understandable and practical standard is developed and widely adopted.

Some third parties may offer you certain choices regarding their Tracking Technologies practices associated with our Web Site. For example, you can find information on choices regarding analytics and interest-based advertising in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out or other choice options. One way to potentially identify cookies on our Site is to add the free Ghostery plug-in to your browser (Ghostery.com), which according to Ghostery will display for you traditional , browser-based cookies associated with the web sites (but not mobile apps ) you visit and privacy and opt-out policies and options of the parties operating those cookies. We are not responsible for the completeness or accuracy of this tool.

1.3 Offline Collection from You.
Company may also collect Personal Information from you through means other than the Web Site. This may include offline collection, such as when you submit a paper application to rent an apartment, make a rent payment by check, or call or visit the management office at a Company managed property. It may also include e-mails that you send to us separate from the Web Site. This Privacy Policy also applies to Personal Information that you provide to us through means other than the Web Site.

1.4 Information Collected from Other Sources.
We may receive Personal Information about you from other sources. For example, if you are applying for an apartment, condo, corporate housing, or employment, either via the Web Site or offline, we may obtain information from third parties about your creditworthiness, among other information, as part of the application process. We may combine the information we receive from these other sources with Personal Information we collect through the Web Site. In those cases, we may apply this Privacy Policy to the combined information.

1.5 Children.
We are a general audience service and do not use the Web Site to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (” COPPA”) without such parental consent. If you are a child under thirteen (13) years of age, you are not permitted to use the Web Site and should not send any information about yourself to us through the Web Site.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us by mail at National Apartment Management, 47W210 US Highway 30, Big Rock Illinois 60511 (attn.: Legal Department).

2. Use of Personal Information.
   We retain and use Personal Information to: (1) provide you with services or process transactions that you have requested; (2) communicate with you regarding information, features or offers that we believe will be of interest to you; (3) respond to your questions or other requests; (4) contact you with regard to the Web Site; (5) process or communicate with you about applications, payments or changes to your account information; (6) process other information or Personal Information that you submit through the Web Site; (7) conduct user surveys; (8) contact you regarding a sweepstakes, contest or promotion in which you have participated, and (9) fulfill other purposes disclosed at the time you provide your Personal Information. We may also use the information you provide to improve the Web Site or Company’s services, to customize your experience on the Web Site, to serve you specific content, or for any other purposes not inconsistent with this Privacy Policy or prohibited by applicable law.
3. Sharing of Personal Information with Third Parties.
   We do not share your Personal Information with third parties (other than our affiliates) for such third parties’ own direct marketing purposes without your consent. We may share non-personally identifiable information, such as Web Site Usage Information or other aggregated user statistics, with third parties without restriction. In addition, we may share your Personal Information as set forth in this Privacy Policy, in any manner in which you expressly consent via the Web Site, or in the following circumstances

3.1 Affiliated or Subsidiary Companies.
We may share Personal Information with our affiliated or subsidiary companies, or related parties who require access to Personal Information for business purposes related to your tenancy or to process any application, request, inquiry, or other information or Personal Information you submit via the Web Site, and for our affiliates’, related parties, or subsidiaries own marketing purposes. This includes without limitation the owner of any community where you make application or where you lease, as well as the management company for such community.

3.2 Third parties providing services on our behalf.
We may share your Personal Information with third parties who perform services on our behalf or on behalf of the owner of one of our properties, or give them access to collect it. This may include, without limitation, third parties that send communications, process payments, analyze data, assist with utility billing or renters insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. These third parties may have access to Personal information in order to provide these services to us or on our behalf. These third parties may also receive, or be given access to collect, Web Site Usage Information and other non-Personal Information for their own use.

3.3 Legal Requirements and Law Enforcement.
We may disclose Personal Information when we believe in good faith that the law requires it; at the request of governmental authorities conducting an audit or investigation (except as prohibited by applicable law); pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Use or other agreements or policies governing the Web Site and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Web Site, its users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

3.4 Corporate Change.
We reserve the right to disclose and transfer your Personal Information in connection with a corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change, including for transaction due diligence. For instance, when a potential buyer is interested in purchasing one of our properties, or a property managed by any entity included in the definition of the Company, we may provide the potential buyer with information about the property and the tenants who live there, which may include your Personal Information. Upon the sale of the property in which you live, all of your Personal Information may be transferred to the purchaser.

3.5 Equal Employment Opportunity Reporting.
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”),
the Office of Federal Contract Compliance Programs (” OFCCP” ) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.

4. Non-Personal Information.
   We may share non-Personal Information, such as aggregated user statistics, with third parties. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. Except where prohibited by applicable law, we may share your Unique IDs with third parties along with data (other than Personal Information) related to you and your activities as non-Personal Information under this Privacy Policy
5. Exercising Choices Regarding Analytics and Advertising.
   Company may use Google Analytics, Adobe Analytics or other web site providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Company analyze how users use the Web Site Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by Google Analytics, Adobe Analytics and other web site providers on servers in the U.S. (or elsewhere) and these web site provider may use this information for purposes such as evaluating your use of the Web Site, compiling statistic reports on the Web Site’s activity, and providing other services relating to Web Site activity and other Internet usage. Company only retains aggregated data from Google Analytics and Adobe Analytics. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their websites or tailor their online ads for you”
   Company may engage and work with third parties to serve advertisements on behalf any of the entities included in the definition of Company on the Web Site, and/or on Third Party Services, and to provide analytics about the performance of Company’s ads. Some information about your browsing of the Web Site and certain Third Party Services may be collected across time and services shared with third parties to deliver ads and/or other content to you on the Web Site and certain Third Party Services. Company may receive information about Third Party Services that you have visited and use if for marketing purposes – a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising,” (collectively, “Interest-based Ads” ). We may participate in online advertising networks and exchanges that display Interest-based Ads to you on Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of the Web Site.
   We may work with certain companies to serve Interest-based Ads that participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads on the ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices .com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges we may work with to serve Interest-based Ads may participate in the Network Advertising Initiative (“NAI’). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool,
   see http://www.networkadvertising.org/choices/. Please be aware that even if you are able to opt out of certain kinds of Interest-bases Ads, you will continue to receive non-targeted ads. Further, opting out of one of more NAI or DAA members only means that those selected members should no longer under the DAA/NAI rules deliver certain targeted ads to you. This selective opting out will affect this Web Site and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g ., from other ad networks ). Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g ., mobile app), your NAI/DAA browser-based opt-out may not, or may no longer, be effective. Mobile devices opt­outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third­ parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expect that ad networks we directly engage to serve you Interest-based Ads will do so as well, though we cannot guaranty their compliance
6. Updating Your Information.
   Depending on the functionality associated with the Web Site feature you are using, you may be able to update certain of your Personal Information on the Web Site. If so, we may but shall not be required to make requested changes in our then active databases and we may retain prior information as business records. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Please note that in accordance with our routine corporate record keeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.
7. Data Security.
   While we take reasonable steps to secure your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information or other information on the Web Site, or on other servers or databases to which the information may be transferred, can be guaranteed to be completely secure. Please consider this prior to submitting your Personal Information to us via the Web Site.
8. Third Party Content and Services.
   The Web Site may include functionality that allows certain kinds of interactions between the Web Site and a third-party web site, platform, tool, application or other service, and accessing or display of third-party content via the Web Site (“Third Party Services”). The use of Third Party Services may involve the third-party operator thereof (“Third Party Operator ‘ ) providing certain information, including Personal Information, to us. For example, when you register with the Web Site, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Web Site, or otherwise link accounts. In addition, you may be able to access our Web Site, your account and/or Web Site content via a third party platform, site, app or other service, and those Third Party Operators may collect Personal Information and other data about you in connection therewith, and may provide some or all of it to us (e.g., the third party may handle the billing of transactions for us via the Third Party Service and then tell us what you purchased so we can process the transaction).

If we offer and you choose to use Third Party Services to access or use our Web Site, the Third Party Services may send Personal Information about you to us. If we discontinue use of any Third Party Service (e.g., your Facebook or any other account as an access mechanism for the Web Site), you consent that we may nevertheless retain any Personal Information, and other information and data, we may have already received in connection therewith in accordance with this Privacy Policy
In addition, we may provide Third Party Services’ interfaces or links on the Web Site to facilitate your sending a communication from the Web Site. For example, we may use third parties to facilitate e-mails, tweets, “likes,” content submissions or postings of comments on Facebook or other social media platforms. We may also enable access to or display of third party content via the Web Site, that is actually being served or published by the third party, and such third party may be collecting data from you in connection with that content. These third parties may collect and retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy
The Web Site may contain content that is supplied by a Third Party Operator, and those third parties may collect Web Site Usage Information, including Unique ID, when such content is served to you. Third Party Services may also be available via the Web Site. We are not responsible for the data collection and privacy practices employed by such third parties or their services and they may be collecting data about you and may be sharing it with us and/or others. These third parties and their services may also associate their Tracking Technologies with you, track you across sites and time, serve you their own ads (including Interest-based ads) and may or may not have their own published privacy policies. When you use Third Party Services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third party privacy policies before using such Third Party Services in connection with our Web Site. We are not responsible for the availability, completeness or accuracy of such third parties’ policies or notices.

9. Links to Other Web Sites.
   The Web Site may contain links to other web sites whose information practices may be different from ours. You should consult the specific privacy policies posted on these sites when linking to them. We are not responsible for the availability, completeness or accuracy of such third parties’ policies or notices.
   We are not responsible for the availability, completeness or accuracy of any third parties’ web sites linked in this Privacy Notice.
10. Privacy Policy Changes.
    We reserve the right to prospectively alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Web Site, so review the Privacy Policy each time you visit and discontinue use of the Web Site if you do not consent. Your use of the Web Site will be deemed as your consent to the Privacy Policy and Terms of Use. However, we will continue to use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you use the Web Site and thereby give your consent to the new or revised policy.
11. Consent to Transfer.
    The Web Site is operated in the United States. Your Personal Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Web Site or providing us with your information, you consent to this transfer.

12. Questions.
If you have any questions about this Privacy Policy, you may contact us by mail at National Apartment Management, 47W210 US Highway 30, Big Rock Illinois 60511(attention law department)