This Privacy Policy explains how Willowby Properties (“Willowby,” “we,” “us,” or “our”) collects, uses, shares, retains, and protects personal information in connection with the management, leasing, and operation of real property. We are committed to respecting privacy and handling personal information in a responsible and lawful manner.

1. Scope of This Policy

This Privacy Policy applies to personal information collected from property owners, tenants, occupants, rental applicants, guarantors, vendors, contractors, and other individuals who interact with the Company through applications, leases, management agreements, websites, portals, communications, or other business activities.

2. Categories of Personal Information Collected

The Company may collect the following categories of personal information, as permitted by law:

• Identifiers: name, mailing address, email address, phone number, government-issued identification information
• Financial Information: payment details, banking information, transaction history, rent or fee records
• Rental and Property Information: rental history, occupancy information, lease terms, maintenance requests
• Application Information: employment information, income verification, references, screening results (where permitted by law)
• Online and Communication Information: IP address, login credentials, communications with the Company
• Legal or Compliance Information: records necessary to comply with fair housing, trust accounting, and regulatory requirements

Willowby Properties does not intentionally collect sensitive personal information except as required for legitimate business or legal purposes.

3. Sources of Personal Information

Personal information may be collected directly from individuals, from property owners, from third-party service providers (such as screening or payment processors), or from lawful public or governmental sources.

4. Use of Personal Information

The Company uses personal information for legitimate and necessary business purposes, including but not limited to:

• Managing rental properties and owner accounts
• Processing rental applications, leases, renewals, and terminations
• Collecting and accounting for rent, fees, and other payments
• Responding to maintenance requests and property-related communications
• Complying with legal, regulatory, and contractual obligations
• Preventing fraud, maintaining security, and enforcing agreements
• Communicating with owners, tenants, applicants, vendors, and service providers

5. Disclosure and Sharing of Information

Willowby Properties may disclose personal information as reasonably necessary for business operations or as required by law. Disclosures may be made to:

• Property owners in connection with the management of their property
• Affiliated real estate brokerages or entities under common ownership or control
• Service providers, vendors, and contractors performing services on behalf of the Company
• Financial institutions, payment processors, or trust account administrators
• Legal, accounting, or professional advisors
• Government agencies or regulatory authorities when required

The Company does not sell personal information and does not share personal information for cross-context behavioral advertising.

6. Data Security

The Company maintains reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. Despite these efforts, no data transmission or storage system can be guaranteed to be 100% secure.

7. Retention of Personal Information

Personal information is retained only for as long as reasonably necessary to fulfill business purposes, comply with legal and regulatory requirements, resolve disputes, or enforce agreements. Retention periods may vary depending on the type of information and applicable laws.

8. California Privacy Rights

California residents may have rights under applicable privacy laws, including the right to request access to, correction of, or deletion of personal information, subject to legal exceptions. The Company may verify identity before responding to such requests as permitted by law.

9. Non-Discrimination

We will not discriminate against any individual for exercising applicable privacy rights.

10. Children’s Privacy

We do not knowingly collect personal information from children under the age of 13. If such information is discovered, it will be handled in accordance with applicable law.

11. Third-Party Websites and Services

This Privacy Policy does not apply to third-party websites, applications, or services that may be linked or used in connection with Company services. The Company is not responsible for the privacy practices of third parties.

12. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes will become effective upon posting or distribution, as required by law.

13. Contact Information

Questions or requests regarding this Privacy Policy may be submitted to the Property Management Company using the contact information provided in applicable agreements, applications, or official communications.