Privacy Policy

PRIVACY POLICY

Updated as of: 9/1/2023

TDI Administrative Services and its affiliated companies (collectively, “JPI”) are committed to keeping the personal data collected from employees, potential, current and former investors, clients, and other individuals confidential and secure. The proper handling of such personal data is a high priority. Please read this policy carefully to understand how we collect, use, share, and protect your personal data. In this policy, “you” and “your” refers to the individual to whom such personal data relates.

Data We Collect

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.

We collect Personal Information through the Site. When you make a payment through the residential portal, we collect information about your payment history and payment information. Although we use a Third Party Payment Processor to facilitate any payments made on our Site through the residential portal, we retain this information for accounting purposes and to respond to inquiries, communicate with you about your account, and for other business purposes. We may collect Personal Information directly from you and automatically through our use of cookies and other data collection technologies on our Sites. We may also collect your Personal Information from third-party sources, such as social media platforms (if you interact with us through your social media account), background check providers, credit bureaus, and third parties to whom you direct us to collect your Personal information. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party policies or practices.

The categories of Personal Information that we collect from you depend on your interactions and engagement with us. For example, we collect:

Direct Identifiers, such as your name, address, date of birth, social security number, drivers’ license number and information, gender, age, IP address, online identifiers, email address, phone number, payment card or financial account numbers and related information required to process payments, and other similar identifiers. We collect this information to verify your identity and information, screening potential residents, collections activity, communicate with you, process your payments, and provide you with access to your resident portal account. We collect this information from JPI employees and applicants for the recruitment process (including to verify employment eligibility and conduct background checks), to conduct employee onboarding, to maintain and administer payroll and employee benefit plans (including enrollment and claims handling), to maintain personnel records and complying with record retention requirements, to provide employees with human resources management services and employee data maintenance and support services, to communicate with employees and their emergency contacts and plan beneficiaries, to comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws, to prevent unauthorized access to or use of the Company property (including information systems, electronic devices, network, and data), to ensure employee productivity and adherence to Company policies, to conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy, to respond to law enforcement requests and as required by applicable law or court order, and to exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.

California Customers Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information. We collect this information from JPI employees and applicants for the same reasons as set forth above with respect to the Direct Identifiers.
Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information). We collect this information from JPI employees and applicants to comply with federal and state equal employment opportunity laws, design implement, and promote the Company’s diversity and inclusion programs, to perform workforce analytics, data analytics, and benchmarking, to conduct internal audits, grievances, and suspected violations of Company policy, and exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
Sensory and surveillance data, such as COVID-19 related temperature checks and call monitoring and video surveillance. We collect this information from JPI employees and applicants to comply with applicable state and federal laws (including those on workplace health and safety), to prevent unauthorized access, use, or loss of Company property, to improve customer service, and to exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts. We collect this information from JPI employees and applicants to evaluate an individual’s appropriateness for hire, or promotion or transfer to a new position at the Company.
Commercial Information, such as the property, leases and services purchased from us, real property purchased, rented or leased from others, insurance information, and number of occupants. We collect this information to maintain client records, identify trends in our client relationships, processing insurance claims, screening potential residents, collections activity, and conduct business analytics.
Internet Activity Information, such as your browsing history, search history, cookies, browser and device type, and information regarding your interactions with pages you visit on the Sites. We collect this information to understand your use of the Sites and your Account and for targeted marketing and lead management.
Professional and Employment-Related Information, such as information about your current employment, salary, professional degrees and certifications, and education background. We collect this information to verify your identity, perform background and regulatory compliance checks, and other related processes.
Profile Information, such as information about your preferences and characteristics. We collect this information in order to understand your preferences and tailor our services and communications to you.

We intend to implement this Privacy Policy in a manner consistent with applicable employment laws. To the extent that such applicable employment laws are in conflict with this Privacy Policy, we will act in accordance with such applicable employment laws.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate investor or client (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us or our oversight of your account, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Use of Personal Data

The legal basis for our processing of your personal data generally includes one of the following: (a) you have consented to our processing of your personal data; (b) processing is needed to fulfill a request made by you or our contractual obligations; (c) processing is required to comply with a legal or regulatory obligation; or (d) processing is necessary for reasons that are in our legitimate interest as a company, such as to protect our business. For example, we may use personal data:

to provide you notices about your subscription to our projects, including any transaction notices;
to notify you about changes to our website or any of the products or services we offer or provide through it;
for the purposes for which you provided it to us (e.g., to evaluate your eligibility to invest in our projects and accounts and in connection with managing, or our oversight of, such projects and investments therein);
for employment and employment application purposes;
to comply with federal, state, and local labor and privacy law;
to respond to your inquiries and communications to us;
to improve, maintain, and operate our offerings;
to fulfill our obligations and enforce our rights arising under our customer contracts;
to market to you about products and services in which you may be interested, unless you have opted out of our marketing messages;
in any other way that we may describe when you provide the information; and
for any other purpose with your consent.

Sharing of Personal Data

We do not sell your personal data to any third parties for monetary consideration. We may share your personal data as needed to fulfill the purposes described in the “Use of Personal Data” section above, including:

to our subsidiaries and affiliates;
with nonaffiliated persons and entities that assist us in managing and operating our advised projects or that perform services for us, such as attorneys, brokers, administrators, accountants, auditors and custodians;
to lenders who provide financing for our projects;
with other investors in our projects (unless you have opted out of such sharing);
to our affiliates, for marketing purposes unless you have opted out of such sharing, or for purposes
of facilitating your investments or requests for information;
to the relevant funds in which you have invested or are interested in investing;
to third party companies or individuals that contract with us to perform servicing functions such as
record-keeping, accounting and administrative services and computer-related services;
as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements;
for any other purpose disclosed by us when you provide the information; and
as requested or approved by you (including to your advisors, which can include, among others, accountants, investment advisors, and/or attorneys).

Companies we hire to provide services are not authorized to use your personal data for their own purposes and are obligated to maintain confidentiality of such data. We do not provide your personal data to mailing list vendors or solicitors for any purpose. We do not use or provide any information provided by employees and/or applicants except for the specific employment-related purposes for which it was collected.

In the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets which would generally be transferred is the data we have collected. We will advise a successor or successors in interest of the terms of this policy and our expectation that the successor(s) in interest will comply with the terms hereof.

We may also disclose your personal data to comply with any court order, law, or legal, process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements (including any agreement for the your investment into any of our funds); and if we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers, or others.

Opt Out Options

Natural persons may opt out of our disclosure of your personal data for the following purposes:

internal marketing efforts (regarding our offerings);
external marketing efforts (regarding our affiliates’ offerings); or
providing current and potential investors a list of investors in our projects.

JPI employees and applicants may also opt out of our disclosure of personal data for any reason not necessary for JPI to perform certain employment-related obligations (such as background checks, employment verification, and administration of benefit and other employment related plans).

To opt out, please contact us in writing or by email as set out at the end of this policy. Please be specific about which of the above purposes you wish to opt out from, so we can efficiently process your request.

Do Not Track Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Site does not respond to “Do Not Track” signals and consequently, the Site will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

Employee Access to Data

We have implemented policies and procedures designed to restrict access to nonpublic personal data to those employees with a legitimate business reason to have access to such personal data. These employees are educated on the importance of maintaining the confidentiality and security of this data and are required to abide by our data handling practices.

Protection of Data

We maintain commercially reasonable administrative, physical, and technical security standards designed to protect your personal data, whether written, spoken or electronic. The safety and security of your information also depends on you. Where you have been provided a password for access to our website or your account, you are responsible for keeping this password confidential. We ask you not to share your password with anybody. We urge you to be careful about giving out sensitive or confidential information through email, as email may not provide a means for complete security and private communications between us and yourself. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us, including to our website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any private settings or security measures we deploy.

Data Retention

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. For JPI employees and applicants, we retain the data as required by federal, state, and local law. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

Children

Our website and services are not directed toward children under 18, and no one under the age of 18 may provide any information to us, including on the website. We do not knowingly collect personal data directly from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us as set forth at the end of this policy and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable legally required or permitted retention standards).

Cross-border Transfers of Personal Data

We are based in the United States, and personal data collected by us and our affiliates worldwide may be transferred to the United States for processing. By using our services or submitting personal data to us or our affiliates, you consent to the transmission of your data outside your own country. We are generally the “data controller” as that term is used under applicable laws.

Your personal data may be processed either locally in the jurisdiction where you work or reside, or in any other jurisdiction where we or our approved third-party service providers operate, worldwide, depending on the needs of the business, to the extent necessary and as permitted by

Your California Privacy Rights

California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:

information regarding your personal information we have collected in the past 12 months (including the categories of personal information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
notice of whether we have disclosed your personal information to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
a copy of your personal information collected by us in the past 12 months; and that your personal information be deleted.

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. For JPI employees, JPI is required to retain certain employment related information and records for up to four years following termination of employment.

You may exercise your right to know and your right to deletion two-times a year free of charge. To exercise your right to know or your right to deletion, contact us at (972) 556-1700 or email us at privacy@jpi.com.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. We may request additional information about you so that we can match the information you provide to information we already maintain about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Shine the Light: California Civil Code Section 1798.83 gives California residents the rights to request from us once per calendar year certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We may share your Personal Information with affiliated third parties, some of which do not share the name of Mill Creek Residential, for their own direct marketing purposes. You may request information regarding the disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes by contacting us at Privacy@jpi.com.

CCPA Notice At Collection For California Employees and Applicants.

Revisions to this Policy

We recognize and respect the privacy concerns of individuals. We are committed to safeguarding this data. As a member of the financial services industry, we are providing you this policy for informational purposes and will update and distribute it as required by law. It is also available to you upon request. We may revise this policy from time to time. If we make a material change to this policy, we will post the updated version (with the date of change(s) noted in the policy) on our website and other places we may deem appropriate, and/or notify you by mail or email, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.

Questions about our Privacy Policy

If you have any questions about our privacy policy, please contact us as set forth below, because your privacy and the confidentiality of your data are very important to us.

Email: privacy@jpi.com

Mail: Attn: JPI Privacy Team, 600 E. Las Colinas Blvd Suite 1800, Irving TX 75039 Phone: (972) 556-1700