Privacy Policy

Last updated: October 31, 2024

This Privacy Policy describes how Kairoi Residential (“Kairoi Residential”, “we”, “us”, or “our”) collects, uses, shares, and safeguards your data when you access or use our website at www.kairoi.com, and any other websites, applications, or services that link to this Privacy Policy (collectively, the “Services”).

Depending on the jurisdiction in which you reside, including certain countries and states in the US, you may have additional rights regarding your data. Please see the “Your Privacy Rights” section below for more information.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@kairoi.com or see the “Contacting Us” section below for more information.

You can click on the following links to go directly to the corresponding sections of this Privacy Policy.

• Data We Collect and How We Collect It
• How We Use Data
• How We Share Data
• How We Protect Data
• How Long We Retain Data
• How We Use Artificial Intelligence Technologies
• Your Privacy Rights
• How to Exercise Your Rights
• Children’s Privacy
• Third-Party Links
• Changes To Our Privacy Policy
• Contacting Us

Data We Collect and How We Collect It

Personal Data You Provide to Us

The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Texas Data Privacy and Security Act (TDPSA) defines personal data as any information that can be linked to an identifiable person, including sensitive data. Information that is not considered personal data includes deidentified data and publicly available information.

The Personal Data we collect may include the following:

• Name(s)
• Phone number(s)
• Email address(es)
• Job title(s)
• Username
• Contact and/or authentication information
• Contact preferences
• Sensitive Personal Data, including the following:
  • Contents of emails, phone calls, and/or text messages or other communications you share with us

Examples of interactions with our Services that may lead to the collection of the types of Personal Data listed above include:

• Online Leasing. When you submit an online leasing application, we collect information necessary to process your application. This may include, among other things, employment-related data, family-related data, and certain personally identifiable data, such as your drivers license and Social Security Number. Please note, providing this information is required to rent at any of our communities.
• Account Registration. When you create an account, such as when you access Kairoi Residential’s Investor Portal or other restricted areas of the Services, we collect your name, email address, phone number, general location, and we may collect certain personally identifiable data such as your social security number and account information.
• Newsletter Sign Up. If you choose to sign-up to receive our newsletters, we will collect your name and email address.
• Form Submissions and Other Communications. We collect information when you communicate with us, such as when you request additional information about our company and our products and services, contact us about career opportunities, or submit other inquiries using our contact form. Examples of such information include your name, contact data, the date and time of your communications, and the content of your correspondence.
• Job Applications. If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, employment-related data, education-related data, and your Social Security Number. Please note, providing this information is required for employment.
• Website Chatbots. If you engage with our virtual AI-powered chatbots, we may collect the information you provide during the chat, including transcripts of your conversation with the chatbot. For more information on our use of AI technologies, please see the “How We Use Artificial Intelligence” section below.

Data We Collect Automatically

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact data) but may include device and usage data, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, data about how and when you use our Services, and other technical data. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The categories of data we collect automatically may include the following:

• Device Data:
  • Device type
  • Browser type
  • Internet protocol (IP) address (or proxy server)
  • Location (general location of your device)
  • Operating system
  • Internet service provider and/or mobile carrier
  • Other technical data about your device
• Usage Data:
  • Pages visited
  • Links clicked
  • Access date and times
  • Referring website

Like many businesses, we also collect data through cookies and similar technologies. See the “Cookies and Similar Tracking Technologies” section below for more information.

The information we collect automatically is statistical data and may include Personal Data, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized experience, including, but not limited to, by enabling us to:

• estimate our audience size and usage patterns.
• store information about your preferences, allowing us to customize and improve our Services.
• speed up your searches.
• recognize you when you return to our Website.

Cookies and Similar Tracking Technologies

We and our service providers use cookies and similar tracking technologies to collect certain information when you interact with our Site. We do so in compliance with applicable laws, including obtaining your consent where required. When you first visit our site, you will be asked to consent to the use of cookies and similar technologies. You can manage your cookie preferences at any time through our website. The types of technologies we may use include:

• Cookies
  • Cookies are small files that a website sends to your computer’s hard drive through your web browser that enables the website to recognize your browser and capture and remember certain information. Most web browsers allow you to reject or delete cookies through their settings preferences. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Please see the “Global Privacy Control and Opt-Out Preference Signals” section below for more information.
• Web logs
  • When you visit and interact with our Services, we record certain information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We use the data collected through tracking technologies for several reasons, including to:

• ensure our Services operate properly and efficiently.
• improve our Services.
• understand and save your preferences for future visits.
• help us analyze the use and performance of our Services, including site traffic and site interaction so that we can offer better experiences and tools in the future.
• monitor our networks and the visitors to our Services for security purposes, including detecting and preventing fraud.

Global Privacy Control and Opt-Out Preference Signals

Certain browsers or browser extensions enable you to instruct websites not to share your information for cross-contextual behavioral advertising via the “Global Privacy Control” or other opt-out preference signals. If you have activated Global Privacy Control or an opt-out preference signal in your browser or extension, we will honor those requests that our Sites can recognize by disabling targeting cookies and similar technologies. Please be aware that we may not always be able to link an opt-out preference signal to other user data, such as your email address.

Data We Obtain From Other Sources

We may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check where permitted by law.

• Some of the information we receive from third parties may be collected with the use of artificial intelligence (“AI”). For more information see the “How We Use Artificial Intelligence Technologies” section below.

Third-Party Analytics

We may use third-party analytics services on our Services to monitor and analyze the use of our Services. For example, we utilize Google Analytics, a web analysis service provided by Google, to collect certain data, such as how often users visit the Services or what pages they visit. To learn more about how Google collects and processes data, please visit https://policies.google.com/technologies/partner-sites.  For more information about how to opt out of having your data used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Summary of Our Data Collection Practices

We have collected the following categories of user data in the past twelve (12) months:

How We Use Data

In addition to the purposes and uses described elsewhere in this Privacy Policy, we may collect and process user data in order to:

• administer, maintain, evaluate, and improve our Services and website offerings.
• facilitate account creation and authentication and otherwise manage user accounts.
• deliver and facilitate delivery of services to the user.
• respond to user inquiries.
• send administrative information.
• send marketing and promotional communications.
• detect and protect against malicious, deceptive, fraudulent, or illegal activity.
• debug, identify, and repair errors.
• identify usage trends.
• make decisions about recruitment.
• comply with our legal or regulatory obligations.
• operate and improve upon our lawful business activities.

We may also collect and process user data for such other purposes as you may consent (from time to time).

How We Share Data

We may share your data with the following categories of third parties to support our business operations and Services:

• Sales & Marketing Tools
• Communication & Collaboration Tools
• Data Analytics Services
• AI Platforms
• Government Entities

In addition to the parties enumerated above and the parties/situations discussed elsewhere in this policy, we may also share your data in the following situations and/or with the following parties:

• Affiliates. We may share data with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
• Service Providers. We may share data with third parties that perform services to support our business and internal operations, including data storage and website hosting service providers. Among other things service providers may help us to host and operate our Services, provide technical support, send communications, or assist with the other activities described in this policy. We may disclose your data with our service providers pursuant to a written contract between us and each service provider.
• Legal Requirements and Protection. We may disclose your data in response to subpoenas, warrants, court orders, government inquiries or investigations, or in connection with any other legal process, or to comply with relevant laws and regulations. We may also disclose your data to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
• Business Transactions. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share data with that company, including at the negotiation stage.
• Other Disclosures with Your Consent. If necessary, we may seek your explicit consent to share data with additional third-parties not otherwise covered in this policy.

We have not sold any data to third parties for a business or commercial purpose in the preceding twelve (12) months.

How We Protect Data

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your data from unauthorized access, use, or disclosure, we cannot guarantee the security of your data. For Texas residents, we will notify you as quickly as possible, but no later than 60 days after determining that a breach has occurred. In the event that we are required by law to inform you of a breach to your data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How Long We Retain Data

We will retain your data only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law (such as for tax, accounting, or other legal obligations). For more information on the purposes for our collection of certain types of data, please see the “Summary of Our Data Collection Practices” section above.

Factors that determine our retention periods include:

• the duration of our ongoing relationship with you and the services we provide to you;
• any legal obligations we must comply with (e.g., certain laws may require us to retain records of your transactions for a specific period before we can delete them); and
• whether retention is advisable based on our legal position (such as statutes of limitations, ongoing litigation, or regulatory investigations).

When we no longer have a legitimate business purpose to process your data, we will either delete or anonymize it, or if deletion is not possible (for instance, because your data is stored in backup archives), we will securely store and isolate it from further processing until deletion becomes possible.

How We Use Artificial Intelligence Technologies

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. We use artificial intelligence technologies to enhance our Services and provide you with a better user experience. These AI technologies may be used to collect and process your data in various ways, including but not limited to, personalizing content, providing communications, and improving our Services.

Our AI Products are designed for the following functions:

• User interaction
• Natural language processing
• Voice call monitoring
• AI insights

The terms in this Privacy Policy govern your use of the AI Products within our Services. When you begin an interaction with any of our Services that utilize artificial intelligence technologies, you will be provided with an appropriate notice informing you of the nature of the interaction.

By engaging with our AI-powered Services, you acknowledge that you are interacting with a third-party artificial intelligence bot, that any information you provide in your conversation may be collected and used to generate analytics or otherwise improves our Services, that you have the right to discontinue the interaction at any time, and that you consent to the terms of this Privacy Policy.

Scope of AI Usage

• Website Chatbots. Several of our property websites employ AI-powered chatbots to provide instant responses to your inquiries. These chatbots assist with finding property information, scheduling viewings, and answering general questions about our services.
• Email and Text Responses. We use AI to automate and streamline our email and text communications. This includes responding to your inquiries, sending property alerts, and providing updates on your transactions with us.
• Call Monitoring. To ensure the highest quality of service, we utilize AI technologies to answer, monitor, and analyze phone calls. This helps us improve customer service, ensure compliance with our policies, and train our staff.

How We Process Your Data Using AI

All user data processed using our AI Products is handled in line with our Privacy Policy and our agreements with third parties. This ensures a high level of security and safeguards your data throughout the process, giving you peace of mind about your data’s safety.

Segmentation and Automated Decision Making. We do not use segmentation or automated decision-making without human intervention, including profiling.

How to Opt Out of AI Processing

We believe in giving you the power to decide how your data is used. To opt out, you can:

• decline the AI notice presented on our website when you navigate to an AI-powered Service.
• contact us using the contact information provided.

Your Privacy Rights

Depending on your state (US) or country of residence, you may have rights that allow you greater access to and control over your data. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section “Contacting Us” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For more information, see the “Global Privacy Control and Opt-Out Preference Signals” section above.

Your Rights

Depending on your jurisdiction, you may exercise the following rights relating to our privacy practices. These rights are not absolute and are subject to exceptions, and we may be legally required or allowed to deny your request. We cannot process a request unless it is accompanied with enough detail for us to understand and address it.

• Right to Access. You have the right to request access to the data we hold about you.
• Right to Correction. You have the right to request that we correct any inaccuracies in your data.
• Right to Deletion. You have the right to request that we delete your data, subject to certain exceptions.
• Right to Data Portability. You have the right to request that we transfer your data to another entity, in a structured, commonly used, and machine-readable format.
• Right to Opt-Out of Targeted Advertising. You have the right to opt out of the processing of your data for the purposes of targeted advertising.
• Right to Opt-Out of the Sale of Your Data. You have the right to opt out of the sale of your data to third parties.
• Right to Opt-Out of Profiling. You have the right to opt out of the processing of your data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Appeal. You have the right to appeal any decision we make regarding your privacy rights that you feel does not comply with the law.

Other Jurisdictions

We recognize that there may be other jurisdictions with applicable data protection laws. If you reside in a jurisdiction not specifically mentioned above, you may still have rights regarding your data. Please contact us to inquire about your specific rights and choices based on your jurisdiction. For more information, see the “Contacting Us” section below.

How To Exercise Your Rights

• To exercise your rights, you can contact us by emailing privacy@kairoi.com, or by referring to the contact details at the bottom of this document.
• Under the TDPSA, you may use an Authorized Agent—a person or entity authorized to act on your behalf—to make a request regarding your data. The Authorized Agent can submit the request by emailing us at privacy@kairoi.com. To verify that an Authorized Agent has the authority to make this request, they must provide us with documentation demonstrating your permission (e.g., Power of Attorney or written, signed authorization).
• If we decline to take action in any request that you submit in connection with the rights described in this section or elsewhere in this Privacy Policy, you may ask that we reconsider our response by sending an email to privacy@kairoi.com. You must ask us to reconsider our decision within 45 days after we send you our decision. We will respond to your appeal in accordance with the timeline set forth in the TDPSA.

Children’s Privacy

Our Services are not intended for or directed to children under the age of 18 and we do not knowingly collect personal data from children under the age of 18. If you are under 18, please do not use online leasing, job application and contact form submissions or send any personally identifiable information to us. If we learn that we have collected personally identifiable data from anyone under age 18, we will delete that data as quickly as possible. If you believe that anyone under 18 may have provided us personally identifiable information, please contact us at privacy@kairoi.com.

Third-Party Links

For your convenience, we may provide links to websites and other third-party content that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what data is collected and how it is used and/or shared. For more information on the types of third parties with whom we may share data, please see the “How We Share Data” section above.

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. To the extent that our policy changes in a material way, the Policy that was in place at the time that you submitted personal information to us will generally govern that data unless we receive your consent to the new Privacy Policy. Our Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Contacting Us

If you have any questions or concerns about this Privacy Policy, our data practices, or you would like to submit a request or appeal, please contact us at privacy@kairoi.com or contact us by post at 711 Navarro St No. 400, San Antonio, TX 78205. By continuing to use this website, you agree to our Privacy Policy.

Last Updated: October 31, 2024

Effective Date: October 31, 2024