Northland Privacy

Privacy Policy

February 2020

Northland Investment Corporation (“Northland,” “we,” “us” or “our”) is committed to maintaining your privacy and informing you of our privacy practices. This privacy policy and agreement (the “Privacy Policy”) covers how we collect, use, and treat data and information, including Personal Information (as defined below), that we collect, receive, process, or store in connection with our business and business activities (the “Business Practices”), which includes the services we offer in connection with such Business Practices, including by way of limited example, developing, managing, and owning Properties (the “Services”) (the Business Practices and Services are collectively referred to as the “Business”). The term “Property” refers to a specific Northland physical location or community, such as, by way of limited example, Stonelake at the Arboretum. 1. Scope of this Privacy Policy. 1.1 Application of this Privacy Policy. This Privacy Policy applies to anyone providing us information including:

  • Tenants (residential and commercial), and employees of commercial tenants, and any guarantors of such tenants, of any of our Properties (collectively, “Tenants”);
  • Contractors, vendors, and other service providers, including their employees, that provide us with services (collectively, “Contractors”);
  • Potential Tenants or applicants that have submitted a lease application or other related information to Northland by any means, including electronically or in person, in connection with the Business (collectively, “Applicants”);
  • Users that have registered an account with Northland (“Registered Users”); and
  • Casual visitors of (i) our website (the “Website”), or (ii) Properties (collectively, “Site Visitors”). We use the term “you” to refer to (i) Tenants; (ii) Contractors; (iii) Applicants; (iv) Registered Users; and (v) and Site Visitors (as the context permits). 1.2 Exclusions from this Privacy Policy. This Privacy Policy does not apply to our current or prospective employees providing us information with respect to their actual or potential employment with Northland. Similarly, this Privacy Policy does not apply to persons who execute a subscription agreement or other similar investment agreement, or who interact with us via the Investor Portal located at https://investors.northland.com/ . Additionally, if we provide you with links to other websites, then they are solely for your convenience and reference and we are not responsible for the privacy practices or content on, or accessed through, such links or websites. 2. Your Consent. Please read this Privacy Policy carefully because once you consent to this Privacy Policy and its terms, it creates legal obligations on you and on Northland. As set out below, the procedures for consenting to this Privacy Policy are obtained in different ways depending on the type of user you are: 2.1 Your Consent if you are a Site Visitor. By accessing and using our Website or Properties as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy, and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from accessing or using our Website or Properties. 2.2 Your Consent if you are Not a Site Visitor. Except as provided in Section 2.3 (Consent by User Acting in a Representative Capacity), your consent to, and your affirmative agreement that you have read and agree to, this Privacy Policy shall be by providing us information in connection with our Business. For example, you may become a Registered User by using the registration form provided under the “Create a New Account” heading (or similar heading) to create an account on our Resident Portal, and a link to this Privacy Policy is included near the “Create Account” button. Or, for example, you may consent to this Privacy Policy by submitting information to us related to your lease application in accordance with the procedure set out in Section 4.12 (Provision of Personal Information Offline). In any case, by providing us information, including Personal Information, you are affirmatively agreeing that you have read and agree to this Privacy Policy, and to be legally bound by it. 2.3 Consent by User Acting in a Representative Capacity. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization”), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting. 3. The Information We Collect. Information that you may provide or that we may collect from or about you in connection with our Business falls into two broad categories: (i) Personal Information, and (ii) Anonymous Information. 3.1 Personal Information. We use the term “Personal Information” to mean any information that identifies you as an individual. The Personal Information we collect may include the following:
  • Your name;
  • Your address;
  • Your email address;
  • Your phone number;
  • Your social security number;
  • Information about your income and other employment demographic information;
  • Information obtained from background checks related to your lease or application to a Property;
  • Your birthday;
  • Your payment information;
  • Your other transaction history (i.e. if you are a Tenant, then your maintenance requests, package notifications, etc.);
  • Time and location data as to when you access other control mechanisms offered in connection with our Business (such as smart home features);
  • Your browsing history when logged into our website;
  • Your vehicle information;
  • Device identifiers, such as cookies;
  • Device information, such as hardware and software settings;
  • Other characteristics of a user device, which, by themselves or taken in conjunction with other information, are sufficient to distinguish that user device over time from a population of other user devices;
  • IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
  • Tracking information that we, or a third party, collects. 3.2 Anonymous Information. We may also collect, process, and use information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individuals cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information. 3.3 Treatment of Combined Information. To enable us to better understand your characteristics and/or to conduct the Business, we may link the Personal Information you have provided with Anonymous Information. If we combine or link any Anonymous Information with your Personal Information, the resulting combination will be treated and protected as Personal Information under this Privacy Policy. 4. How We Collect Personal Information. We collect the above information through the following means and technologies: 4.1 Registered Users; User Names. In order to participate in certain Services we offer to Registered Users, we require that you use the process described in Section 2.2 (Your Consent if you are Not a Site Visitor) to complete the registration process by consenting to become a Registered User. Upon request at certain Properties, our employees may provide you with in-person assistance with the registration process. After completing the registration process, Registered Users may be provided with an email username and password, which allows them to gain access to password-protected portions of our Website and to otherwise use certain functionality available on our Website. This information is used by Northland in providing the Website and conducting its Business, as further detailed below. 4.2 Payment Processing. Through our Business, you may be able to pay rent or other fees (including application fees), which require that we collect Personal Information, including contact information and payment information (such as credit card number, expiration date, and security code), in connection with your transaction. We may already have this information on file if you have previously accessed paid rent or other fees through our Business. This information is used for billing purposes, contacting you about your transaction, and sending you other related communications. Please note that Northland uses a reputable company (the “Payment Processing Company”) to collect and process your payment information. We have taken reasonable steps to ensure that the Payment Processing Company protects Personal Information it collects from you in compliance with our Privacy Policy. 4.3 Resident Services. If you are a Tenant, we may provide you with a convenient platform to submit a maintenance request, get announcements, communicate with your Property manager, add vehicle information, get notified that a package has arrived, and access other Services related to the Property in which you reside. In these instances, we use any information you provide to us for the purposes for which you submit the information. 4.4 Emails; Live Chat; Social Media. You may have the ability to contact us via email, “live chat” functionality, instant messaging, Facebook Messenger, Snapchat, and other social media platforms with questions, comments, or feedback concerning our Business. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we use any information you provide to us for the purposes for which you submit the information. 4.5 Questionnaires and Surveys. We may allow you to participate in surveys and questionnaires, which we may post or otherwise provide to you from time to time. You are free to choose whether you participate in a survey or questionnaire. We may ask that, in addition to providing your responses, you also provide Personal Information. In these instances, we use any information that you provide to us for the purposes for which you submit the information. We may also add your Personal Information to your customer profile, as well as for advertising and marketing purposes. Survey and questionnaire information may be used for the purposes of monitoring or improving our Business. As further set out in Section 10.2 (Opt-Out), please understand that you will not be allowed to “opt out” of formal notices related to our Business, such as the operation of the Website and App, and legal, and other related notices concerning safety (such as notices related to fire alarm testing, repairs, or other exigent circumstances) and your relationship with us. 4.6 Newsletters and Special Offers. You may choose to sign up to receive optional communications from us including, for example, emails, mobile notifications, or “push” notifications with information related to our Business, including deals, news, and other events. In addition, if you are a Registered User or if you have previously provided Northland with your email address (such as through the means described in Section 4.12 (Provision of Personal Information Offline)), then we may choose to send news, bulletins, marketing materials, or other information. We will use Personal Information to determine which communications may interest you, and to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 10 (Changing or Removing Information; Opting Out). 4.7 User-Generated Content. As further set out below, we may provide you with the ability to submit content to us for our internal use or to submit content to us for public consumption (collectively, “User-Generated Content”). If you include any Personal Information relating to others in your User-Generated Content, then you represent that you have full permission and authority to do so. 4.7.1 User-Generated Content Provided to Us for Internal Use. We may provide you with the ability to submit User-Generated Content to us (either directly or through a third party service), and we may also provide content to you, in order for us to better provide Services. For example, we may allow you (i) to submit a photo in connection with a maintenance request and we may also take photos related to the maintenance request (if such photos are combined with your Personal Information, then the resulting combination will be treated and protected as Personal Information under this Privacy Policy), or (ii) to submit responses to resident surveys or otherwise provide us with feedback related to your Property, the Services, or the Business. If you provide us with such User-Generated Content, we will protect it in accordance with this Privacy Policy. 4.7.2 User-Generated Content Provided to Us for Public Consumption. We may give you the ability, for example, through our Website or a third party social media platform, to engage with us and others in public exchanges by providing User-Generated Content, which may include opportunities for you to provide comments, reviews, recommendations, and other input. Please understand that, if you include Personal Information in such User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use such Personal Information. We are not responsible for Personal Information that you decide to include in such User-Generated Content, and we will not take down, remove, or edit User-Generated Content, except as required by applicable law. 4.8 Verifying Identity. If you submit requests or information to us, then we may use Personal Information (and other information that we have about you) to verify your identity and to process your request. This is designed to further protect you and to reduce the threat of identity theft and fraudulent transactions. 4.9 Tenant Eligibility; Background Checks. If you are an Applicant (that is applying for a lease with us), then we will request that you disclose certain information, including Personal Information, on your rental application or other documents to determine your eligibility to lease from us. We will use such information, or provide such information to our Contractors, to: (i) determine your eligibility to lease from us when you apply; (ii) determine that you continue to meet eligibility requirements during your lease term with us; (iii) complete the leasing process; and (iv) request credit and background check reports and other information about you from third parties in connection with your lease eligibility (collectively, “Eligibility Information”). To allow appropriate control over Personal Information, we will make some of this Eligibility Information available to you and you will be able to view, change, or update such Eligibility Information that you have previously submitted to us and certain information that we have used to make decisions about you (including for your lease) to ensure that such decisions made about you are based on accurate information by contacting us in accordance with Section 19 (Contact Us). If you determine that such Eligibility Information is inaccurate or contains discrepancies, you will be able to identify and provide evidence of such inaccuracies or discrepancies to us and we then will evaluate any decisions we made based on such identified inaccuracies and discrepancies. 4.10 Smart Home Features. We may collect information from you, including Personal Information, in order to provide you with smart home features such as (i) Wi-Fi connected smart thermostats; (ii) Wi-Fi connected smart outlets; (iii) Wi-Fi connected smart ceiling fans and lights; (iv) Wi-Fi connected smart door locks; (v) video conferencing and facial recognition; and (vi) other smart home products. If smart home features are offered to you, then we will use the information we collect from them, or provide such information to our Contractors, in order to provide you with such smart home features. 4.11 Other Uses. In addition to the uses specifically identified in this Section 4 (How We Collect Personal Information), there may be instances where you request information or other Services from us that are not described in this Privacy Policy. In that instance, we will use Personal Information that you submit in order to provide such information or Services to you. 4.12 Provision of Personal Information Offline. If you visit one of our Properties in person and meet with our employees and/or leasing agents, we may ask you to provide us with Personal Information (“Offline Personal Information”). Offline Personal Information may be collected using: (i) in person communications and dealings with us, such as in-person events like open houses; (ii) paper lease applications you provide us in person; and (iii) other related Personal Information you provide us in person. If you provide Offline Personal Information to us, we will strive to provide you with either verbal and/or written notice of this Privacy Policy so that you can review it. For the avoidance of doubt, we treat any Offline Personal Information that you provide to us as Personal Information under this Privacy Policy. 4.13 Geolocation Information and Beacons. Northland may provide you with access to a mobile application (the “App”) may utilize the GPS feature on your mobile device or beacons to determine your location (your “Geolocation Information”). You must enable the GPS/location services for the App on your mobile device in order for this feature of the App to function effectively. We may also collect precise location information when your mobile device is near a physical “beacon” system that we (or our vendors) operate. You may also prevent this by disabling location information in your device settings. To the extent your Geolocation Information is combined with any Personal Information, we will treat it as Personal Information. We may use your Geolocation Information to send communications to you as further described in Section 4.6 (Newsletters and Special Offers), and for other purposes set out in this Privacy Policy, including smart home features and advertising. 5. How We Collect Anonymous Information. We use Anonymous Information to analyze the effectiveness of, and improve, our Business and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics related to our Business, including users and the use of our Website and App, and we may share Anonymous Information with third parties, including Advertisers (if any) and our Contractors (in accordance with Section 7.1 (Northland Contractors)). Anonymous Information provided to third parties as outlined in this Section 5 (How We Collect Anonymous Information) will not allow anyone to identify you. We may collect Anonymous Information through features of the software that support our Business (such as those on the Website and the App), through cookies and through other means described below. 5.1 IP Addresses; Logs. Northland may automatically receive and record information in our server logs from your browser or mobile device, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser or mobile device operating system, referrer addresses, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes. 5.2 Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your computer or mobile device from a website or a mobile application and stored on your hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website or a mobile application upon future visits. We may include cookies on our Website or the App, and use them for a variety of purposes, such as to recognize you when you return to our Website or the App and to remember your preferences. You may set your browser or mobile device so that it does not accept cookies. Cookies must be enabled, however, if you wish to access certain personalized features of the Website or the App. 5.3 Tags. We may use so-called “pixel tags” – small graphic images (also known as “web beacons” or “single-pixel gifs”) – to tell us what parts of our Website or the App have been visited or to measure the effectiveness of searches you perform on our Website or the App. Pixel tags also enable us to send email messages in a format that you can read and they inform us whether emails have been opened. Pixel tags also help us ensure that our messages are of interest to you. You can “opt-out” of receiving these types of emails from us by following the directions provided in Section 10 (Changing or Removing Information; Opting Out). Any Personal Information collected using such tools will be subject to the terms of this Privacy Policy. 5.4 Click-Throughs. We may send email messages, which use a “click-through URL” linked to content related to our Business. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We may track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 10 (Changing or Removing Information; Opting Out). 5.5 Configuration. In order to determine whether your computer or mobile device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, the presence of any software that our Website or the App may require to operate with your computer or mobile device, or other third party software on your computer or mobile device. We will treat such information in accordance with this Privacy Policy. 6. Internal Uses of Information. We may use your Personal Information and Anonymous Information to perform internal administration, auditing, operation, and troubleshooting in connection with our Business, including to evaluate and improve our Business, and to develop and test new Business Practices and/or Services. 7. How We Share the Collected Information. We will not disclose your Personal Information to unaffiliated third parties without your express consent, except as set out in Section 9 (Advertising) and in the following limited circumstances: 7.1 Northland Contractors. We may employ Contractors, including Payment Processing Companies, to perform functions on our behalf, such as collecting or providing information, responding to and sending electronic mail, or other functions necessary to our Business. We may need to share your Personal Information with these Contractors. We will provide Contractors with only that information necessary or desirable to perform their functions, and we will not allow them to use your Personal Information for any other purpose. 7.2 Legal. Northland will reveal your Personal Information to the extent we reasonably believe that we are required to do so by applicable law. 7.3 Transfer of Business. Northland shall be entitled to transfer to a third party information that we collect, including any Personal Information, in connection with: the sale of (i) a Property (or Properties); (ii) an entity that holds a Property (or Properties); or (iii) all or substantially all of the assets of such entity, provided the acquiring third party has agreed to safeguard your Personal Information with protections that comply in material respects with this Privacy Policy. 8. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information. We will retain your Personal Information for as long as reasonably necessary to conduct the Business or provide the Services to you or as necessary for compliance with applicable law. You may request that we delete your information in accordance with the procedures and limitations set out in Section 10.3 (Deleting Information). 9. Advertising. We participate in advertising to keep our customers apprised on product offerings, Property promotions, and associated content. As further set out below, we may use the information you provided to us to provide you with advertising or promotions based on your interaction with our Business. These advertisements and promotions may be related to the Business, or for other third party services and products that we think may interest you. 9.1 Our Use of Anonymous Data for Advertising. Like many companies, we utilize targeted Northland banners and ads and may display these to you when you are on other websites and mobile applications. We do this using a variety of digital marketing networks and ad exchanges in addition to using a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks. The banners and ads that you may see displayed will be based on information we hold about you, such as your previous use of our Website or the App. This may include your search history on our Website or the App, the content you read on our Website or the App, or on Northland banners or ads you have previously clicked on. 9.2 Advertisers Use of Anonymous Data for Advertising. Additionally, we may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided, in some cases, by a third party ad service provider or advertiser (collectively, “Advertisers”). Additionally, Advertisers may place or utilize their own cookies on your browser and may use Anonymous Information about your visit to our Website or your use of the App. If an Advertiser requests that you provide Personal Information to it or otherwise accept its cookie on your browser, please be aware that the Advertiser’s use and collection of this information and use of any cookies will be governed by its privacy policy or other relevant agreement, and not our Privacy Policy. We recommend that you review the Advertiser’s privacy policy before providing Personal Information. You may choose not to receive targeted advertising from certain ad networks, data exchanges, marketing analytics, and other service providers as indicated at: http://www.aboutads.info/choices/. 9.3 Promotional Partners Use of Limited Personal Information. We may also provide a limited subset of your Personal Information to promotional partners that provide us with performance based incentives if you subscribe to, or use, their services (collectively, “Promotional Partners”). This may include, by way of limited example, if we provide a cable TV provider with your contact information and we receive an incentive if you subsequently subscribe to the cable TV provider’s services. Such limited subset of your Personal Information may include: (i) your name; (ii) your address; (iii) your email address; and (iv) your telephone number. We will never provide Promotional Partners with: (a) your social security number; (b) your payment information; or (c) your other transaction history (as described in Section 3.1 (Personal Information)). 10. Changing or Removing Information; Opting Out. 10.1 Access and Transparency. To allow appropriate control over Personal Information, you will be able to view, change, or update your Personal Information, including Eligibility Information that you previously submitted to us in accordance with Section 4.9 (Tenant Eligibility; Background Checks). 10.2 Opt-Out. If we choose to send to you bulletins, updates, mobile notifications, or other marketing-related materials, we will provide you with the ability to decline – or “opt out” – of receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. For example, if you no longer wish to receive email messages from us, you can opt out of this service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 19 (Contact Us). Please understand that you will not be allowed to “opt out” of formal notices related to our Business, such as the operation of the Website and the App, and legal, and other related notices concerning safety (such as notices related to fire alarm testing, repairs, or other exigent circumstances) and your relationship with us. 10.3 Deleting Information. If you request, we will take reasonable steps (or such other steps that may be required by applicable law) to remove your name and all other Personal Information from our databases. Please understand, however, that deletion requests are subject to certain limitations and it may be impossible to remove this information completely due to backups, records of deletions, and other requirements. In addition, we may retain Personal Information as permitted by law, such as for recordkeeping purposes, to maintain an active account, comply with litigation holds, and to process transactions and facilitate customer requests. For example, we may be required to, and shall, retain your Personal Information for a certain period of time based on the payment method you use to complete a transaction with us. As such, if certain Personal Information remains in our databases following the deletion of your account, then we will continue to treat such remaining information in accordance with this Privacy Policy and applicable law. In addition, please understand that, if you request the deletion of your information, you will be unable to utilize certain associated features that require such information. You may not remove de-identified, anonymous, or aggregate data from our databases. 10.4 Third Party Personal Information. To the extent that you provide Northland with Personal Information of third parties, you represent and warrant that you have permission from such third parties to provide us with their Personal Information. 11. Security. We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law. However, no information or communication system can be 100% secure, so Northland cannot guarantee the absolute security of your information. In addition, Northland is not responsible for the security of information that you transmit over networks that Northland does not control, including the Internet and wireless networks. 12. COPPA Advisory and Procedures. Our Services and this Website are not directed to children under 13 years old (each a “child,” as set forth in Children’s Online Privacy Protection Act (“COPPA”)). We understand, however, that there may be instances where a Tenant, as parent or guardian of a child, permits the child to access Services or otherwise directly provide us with information. For example, a Tenant may allow his or her child to submit a maintenance request. If we receive information that we know is from a child, we will use such information solely for purposes of fulfilling or responding to the specific request made by the child. You authorize Northland to collect and act upon, in that limited manner, information provided by your child (or children), including personal information (as such term is defined under applicable law), (a) by signing a lease with Northland and/or (b) by paying rent or other fees to Northland that relate to such Services. If you believe that we have received or collected information from your child in a manner with which you do not agree, please submit a deletion request and we will follow the procedures set out in Section 10.3 (Deleting Information) to delete the information. 13. Notice of Privacy Rights to California Residents. 13.1 Shine the Light Law. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes. 13.2 California Consumer Privacy Act Disclosure. The California Consumer Privacy Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of Personal Information that we have collected about California residents. We use the term “resident” to refer to a California resident to whom the CCPA applies. Among other rights under the CCPA, as further set out in this Section, a resident may request that we (i) disclose to the resident Personal Information that we have about such resident (including Personal Information about you that is sold), and (ii) subject to certain exceptions, delete Personal Information that we have about such resident. A resident may request a copy of the following using the mechanism set out in Section 13.3 (Submission of a Consumer Request): (a) the categories of Personal Information we collected about such resident; (b) the categories of sources from which the Personal Information is collected; (c) the business or commercial purpose for collecting or selling the Personal Information; (d) the categories of third parties with whom we share such resident’s Personal Information; and (e) the specific pieces of Personal Information we have collected about such resident. Residents may submit a request for such information no more twice in any twelve (12) month period, and our disclosure of such requested information shall only cover the twelve (12) month period preceding our receipt of such request. Additionally, a resident may request that we delete such resident’s Personal Information using the mechanism set out in Section 13.3 (Submission of a Consumer Request). A resident’s rights as to such deletion requests are set out in Section 10.3 (Deleting Information). 13.3 Submission of a Consumer Request. We are in the process of implementing a web-based form and toll-free number for residents to submit a request to us to access or delete their Personal Information. In the interim, please submit such requests to the email address provided in Section 19 (Contact Us) or in person to a leasing agent. We will respond to your request within forty-five (45) days or as permitted by applicable law. 14. Feedback. We want to encourage your feedback. If you have a suggestion on how we can improve our Business or concerns you would like us to address, please contact us at the address set out in Section 19 (Contact Us). Certain states may provide you with additional avenues for lodging complaints. Please check with your state’s consumer protection authority. 15. Notification of Changes. Northland may change its Privacy Policy from time to time for our business purposes and to comply with changes in applicable law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated privacy policy on the Website or the App and/or notifying you of the change via the Website, the App, email, or other methods. Your continued use of, or access to, the Business following such notice constitutes your agreement to follow and be bound by the updated privacy policy. 16. Our Affiliates. We may choose to rely on, and share information with, divisions within our company or other companies closely related to us – our “Affiliates” – for certain purposes under this Privacy Policy. By “Affiliate,” we mean (unless otherwise defined by applicable law) an entity that controls, is controlled by, or is under common control with Northland Investment Corporation. You agree that Northland Affiliates will be entitled to enjoy our rights under this Privacy Policy and, in exchange, we agree to be responsible for our Affiliate’s failure to comply with this Privacy Policy. We ensure that our Affiliates agree to protect Personal Information in a manner no less protective of your interests than the protections set out in this Privacy Policy. 17. Relationship to Terms of Use. This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Use are incorporated herein. If Terms of Use conflict with the terms of this Privacy Policy, then the terms of this Privacy Policy shall control. If the terms of any other contract between you and Northland conflict with the terms of this Privacy Policy, then the terms of this Privacy Policy will control with respect to your use of this Website. 18. Further Resources. If you wish further information concerning privacy policies in general, you should visit the following site: http://www.ftc.gov/privacy/index.html. 19. Contact Us. If you have any questions about this Privacy Policy, the Business, or your dealings with Northland, please contact us using the methods provided on our Contact Us page or email us. 20. Do Not Track Notice. Our Website does not change its behavior when receiving “Do Not Track” signals from browser software. 21. Effective Date. The effective date of this Privacy Policy is February 3, 2020. 22. Copyright and Legal Notice. Copyright ©2020 Northland Investment Corporation. All Rights Reserved.