April 21, 2009 PRIVACY POLICY

Carmel Partners, Inc. and its affiliates (“Carmel”) recognize that your privacy is important. This Privacy Policy explains how we gather information and how we use and/or disclose it.

Information we collect and how we use it

We may collect non-public personal information from you when you voluntarily provide personally identifiable information to us through Carmel’s sites or when you visit one of Carmel’s leasing offices. This may include your name and address, age or date of birth, your electronic mail address, number of children, your occupation, employment information, telephone number, education, the kind of service provided to you, your social security number, real property purchased, leased or rented, bank account number(s), debit card number(s), bank or investment account(s), debit card or credit card balance(s), payment history, background report, and information pertaining to your creditworthiness, assets, income or liabilities.

We collect, retain, and use personal information for the reasons stated below:

We do not disclose Personal Information to third parties for their marketing purposes.

Cookies

When you visit Carmel’s sites, we send one or more cookies—small strings of text which uniquely identify your browser—to your browser, which are then stored by your browser on your computer’s hard drive. Our cookies allow us to personalize your experience on Carmel’s sites, make your visit more convenient, and understand how you and others are using Carmel’s sites so that we can improve your experiences on the sites. We use cookies to identify repeat visitors to our sites and to determine the paths visitors take on our sites. We also use cookies to determine whether you visited our site from a particular Internet link or advertisement. We do not use cookies that store personal information or associate cookie information with personal information you may provide us. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it rejects cookies. In order to create a profile on our sites, you must have your cookies on.

Data Security

The security of your personal information is of extreme importance to us. Although the complete security of any transmission over the public internet cannot be guaranteed, we take precautions by using encryption technology to protect data transmitted during the online lease completion process and for online payment of rent. Please check your browser for an indication that the encryption is activated before completing an online lease application or online rent payment.

Links to Third-Party Web Sites

Our sites may contain links to other Web sites. These other Web sites are maintained by third parties and may have different information policies and practices and are not subject to this privacy policy. As we do not control and are not responsible for the privacy policies, practices or content of these third party Web sites, please review the privacy policies on those Web sites to understand their personal information handling practices.

Consent

When you provide Carmel with your personal information through any of Carmel’s sites or by visiting our leasing offices, you agree: 1) to our collection and use of your personal information; 2) that we may contact you by email to provide you with information about various services available to you and notices relating to the property where you reside; and 3) to this Privacy Policy. Carmel reserves the right, at its discretion, to modify, add or remove portions of this Privacy Policy from time to time. The amended Privacy Policy will be effective upon posting on this site. Your continued use of the Carmel sites and/or the services of Carmel’s leasing offices means that you agree to the revised Privacy Policy and our use of your personal information in accordance with the revised policy. Carmel may, but is under no obligation to, provide you notice of any modifications to this Privacy Policy.

Additionally, Carmel may combine or share between current or future Carmel entities and subsidiaries, or other entities that have an interest in Carmel as a result of a sale, merger, reorganization or dissolution, information you provide to Carmel either online or in the Carmel leasing offices.

Carmel reserves the right to report to any law enforcement agencies activities that Carmel believes to be unlawful and may release necessary information in order to protect the rights, safety and/or property of others or of Carmel’s or as required by law.

Email

If you would like to opt out of receiving future commercial email messages from Carmel, please refer to the special link located within Carmel’s commercial emails. This link contains instructions on how to remove your email address from Carmel’s commercial email list. Please note that if you are a resident of a Carmel community and you opt out of receiving commercial emails, you may continue to receive emails from Carmel about matters pertaining to your apartment, your lease, and/or your community. Contact Us

If you have questions or concerns regarding out privacy policy, you may contact us in two ways:

Restrictions

Carmel’s sites are not intended for use by children. Persons under the age of 18 are not allowed to provide any personal information. By using our sites, you represent that you are not under the age of 18.