Effective date/last updated: June 1, 2026

Holland Partner Group and its affiliates, subsidiaries successors and assigns (collectively, “Holland,” “we,” “our” or “us”) respects your privacy. This Privacy Policy (“Policy”) describes our policies and practices regarding the collection, use and disclosure of information we collect in connection with your use of our websites that link to this Policy and mobile apps (collectively “Site”) as well as through offline channels including when you use our services, visit our offices or properties, or attend our events (“Services”).

This Policy is incorporated into and subject to the website Terms of Use.

Please read this Policy carefully before using the Site or otherwise submitting personal information to us. BY ACCESSING OR USING THE SITE OR OTHERWISE SUBMITTING YOUR INFORMATION, YOU CONSENT TO THE COLLECTION, USE, SHARING AND RETENTION OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information.

Categories of Sources

Holland collects your personal information from a variety of sources, including:

Categories of Personal Information

As described below, we may collect the following categories of personal information about you, depending on the nature of our relationship with you. We may add to the categories of personal information we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy. If you do not provide us with personal information when requested, we may be unable to provide the requested information or services, or process your application for tenancy or employment.

We do not collect additional categories of personal information or use the personal information we collected for materially different or incompatible purposes without providing you notice.

In general, Holland Partner Group will use the personal information we collect about you only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy.

As an example, we may use your personal information for one or more of the following purposes:

1. To manage and present our Site and its contents to you including enabling your access.
2. To manage and administer your account.
3. As necessary to process your application for tenancy or manage the landlord-tenant relationship.
4. To communicate with you, including sending notices concerning our services with email or SMS alerts.
5. To schedule and conduct tours and events.
6. To process payments.
7. To verify identity and/or provide access to our services, property and facilities including storage lockers or fitness centers.
8. For testing, research, analysis and product/services development and improvement.
9. For security and fraud prevention; as necessary or appropriate to protect the rights, property or safety of us, our tenants or others.
10. For everyday business purposes such as financial account management; records management; property maintenance; contract management and debt collection; IT support; website administration and improvement; fulfillment services; security and fraud prevention; enforcing company policies; corporate governance; meeting reporting and legal compliance obligations.
11. For marketing and advertising including to manage, measure or understand the effectiveness of advertising that we provide to you and others, and to deliver relevant advertising to you including cross-context marketing. We may show you ads on the Site using data from advertising technologies on the Site such as web beacons, pixels, ad tags, cookies, device identifiers or information from advertising partners. We may also show you ads targeted to your interests across the Internet.
12. At your direction and request.

We reserve the right to use and disclose current or past personal information collected about you: (a) if such information is subpoenaed; (b) to comply with federal, state, or local laws; (c) to comply with a civil, criminal, or regulatory inquiry, investigation, or summons by federal, state, or local authorities; (d) to cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; (e) to conduct an investigation, exercise or defend a legal claim, (f) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information in connection with the due diligence process associated with a potential M&A Transaction); (g) if we are the subject of bankruptcy proceedings; and/or (h) when we deem it necessary or appropriate. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission. We may also use and disclose your personal information at your direction.

In general, we will not disclose your personal information except with your consent, as described in this Privacy Policy, or as permitted or required by law. We disclose your personal information for the same reasons that we may use it. In doing so, we may disclose your personal information to the following categories of third parties:

• Our employees and personnel with a need to know based on job responsibilities. 
• Service providers, contractors or vendors. Holland shares information with entities who collect or process information on our behalf or provide us with certain services. For example, third parties that process your reservations to our events, help schedule tours, and execute our services and events. These third parties may also provide us with identity verification services, background or security checks, marketing and promotional services, communications and email services, business support, IT services, cloud storage, fulfillment services, data analysis, security, and fraud prevention support. They may operate our newsletter offerings and operate or host our website, process payments, or perform or assist with property maintenance, and similar services.
• Related entities, affiliates, agents, and business partners. We share information with our related entities including without limitation our parent, subsidiaries and sister companies, or to their employees, agents, contractors, representatives, legal counsel and/or accountants, for operational, management and administrative purposes; internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes; to third party partners participating in our promotions or events; or as otherwise permitted or required by law. We might also disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. 
• Professional advisors, including lawyers, accountants, auditors, bankers, and insurers as necessary for the professional services they provide to us.
• Social networks and Ad networks in connection with marketing.
• Third parties as directed by you. We disclose personal information at your direction, such as when we contact a family member listed as your emergency contact. 

We also reserve the right to disclose current or past personal information collected about you as noted in “How do we use the personal information we collect from you?”, above.

We employ reasonable and appropriate administrative, physical and technical measures designed to protect the security of the personal information we collect from you. However, no data transmitted over the Internet or stored digitally can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or receive from us. We encourage you to use caution when using the Internet.

Our Site may use web technologies such as cookies, browser analysis tools, server logs and web beacons for purposes which may include recognizing you when you return to the Site, estimating our audience size, tracking visits to the Site, helping us improve the quality of the Site, processing your requests, and providing you with relevant advertising based on your interests. Some of these technologies may be set by us or a third party.

Cookies are small files consisting of letters and numbers that automatically collect certain information. These files uniquely identify and recognize your browser or device and transmit information back to the server. Depending on the type of cookie, it can perform different functions. We may use the following cookies on the Site:

When you visit or use our Site, cookies and similar technologies may be used by our online data partners or vendors to associate your activities with additional information they or others have about you, including by association with your name, email or home address.

Controlling cookies. You can control cookies through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a website. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to our Site. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work. For more information, see the Help section of your browser. You can also find information about managing cookies at the following links:

The Site may also use web technologies such as:

Email pixels. We may embed email pixels in emails we send you. When you open the email, it sends back information to us including how many people open our emails, click on links, the percentage of recipients who read email on their phones, etc. We use this information for marketing purposes and to learn more about our audience.

IMPORTANT: By using the Site, you consent to the collection and processing of any information for the purposes and functions described above.

“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. We may track Site users over time and across third party websites; however, since the Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

We retain your personal information for as long as necessary to achieve the purpose for which we collect it. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you. 

To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements. 

The Site may contain links to other websites or resources for informational purposes. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as accepting job applications, sending newsletters, chatbots, maps, etc. Holland has no control over those websites or platforms and they are not subject to this Privacy Policy. Please check the privacy policies of those websites to determine among other things how your personal information will be used. You acknowledge and agree we are not responsible for the availability of third party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or is collected by, such sites.

The Site contains embedded content (e.g., YouTube videos, external media or content). Embedded content may place third-party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect, and you should refer to their website privacy policy for additional information.

Our services/products are not intended for children under 13 years of age, and you must be at least 13 years old to have permission to use our services and/or access our website/application. We do not knowingly collect, use, or disclose personal data from children under 13. If you believe that we have collected, used, or disclosed the personal data of a child under the age of 13, please contact us using the contact information provided in this Policy, so that we can take appropriate action.  

STATE SPECIFIC SECTION: CALIFORNIA, NEBRASKA, NEVADA, AND TEXAS 

This state-specific section (“State Section”) of our Privacy Policy supplements and amends the Privacy Policy as it pertains to residents of California, Nebraska, Nevada, and Texas; the other provisions of the Privacy Policy continue to apply except as modified by this State Section.

With the exception of the California section, these state specific provisions do not apply to personal information we obtain about you in a commercial or employment context.

Any terms defined within the applicable state consumer data protection law has the same meaning when utilized within that relevant state section. All other terms shall have the meaning set forth in the Privacy Policy or Terms of Use: https://www.hollandresidential.com/privacy-policy, as applicable.

Please read this State Section carefully before using the Site or submitting personal information to us. This State Section is incorporated into and subject to our Terms of Use. BY ACCESSING OR USING THE SITE AND SERVICES, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS STATE SECTION AND THE TERMS OF USE. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this State Section, please do not provide us with such information.

Consumer Rights. These state-specific provisions list the rights you may have and how to exercise them under the applicable state consumer data protection law. Where permitted by law, we reserve the right to respond only to a verifiable request to exercise a right. A verifiable request may be made by any of the following:

• the consumer who is the subject of the request,
• a consumer on behalf of the consumer’s minor child, or
• a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer, where permitted by applicable law.

Verification. If we request, you must provide sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive personal information to verify your identity. We may not be able to respond to your request if we cannot verify your identity or authority to make the request and/or confirm the personal information relates to you. Please note that making a consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the personal information we collect from an individual to determine a verifiable request for any other purpose, except as required by law.

Fees. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require up to ninety (90) days to respond, under which circumstances we will notify you of the need for an extension.

Response. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request except for California residents. With respect to personal information collected on and after January 1, 2022 from California residents, and to the extent expressly permitted by applicable regulation, you may request that the disclosure cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us.

Agents. Subject to certain limitations, and where permitted by applicable law, you may authorize a natural person or a business registered with the applicable Secretary of State to exercise certain rights on your behalf under a state section. Unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent with written permission (signed by you) to act on your behalf and verify their identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Right to Appeal. If we deny your request, certain states permit you to appeal our decision. To do so, email dataprivacy@hollandpartnergroup.com and include your name, email address and a copy of the denial letter. Please do not use email to send us any sensitive information.

Global Opt Out Signals. This Site recognizes and processes opt-out preference signals that indicate your intent to opt out of the processing of Personal Information for a Sale or Sharing (see CA rights), a Sale, and/or Targeted Advertising (see Texas and Nebraska). Please note that any opt out is specific to the browser you use and you may need to opt out on every browser that you use.

Exercising Your Rights. To exercise a right under a state consumer data protection law, please contact us at:

No Discrimination. We will not discriminate or retaliate against you for exercising your rights under an applicable state consumer data protection law.

CALIFORNIA

This section applies only to California residents and supplements and amends the information contained in this Privacy Policy.

A. Shine the Light. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. Such requests must be submitted to us in accordance with the instructions in the Contact Us section of this Policy. Please mention when contacting us that you are making a “California Shine the Light” inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. To obtain such a notice, please contact us as described below. We reserve our right not to respond to requests submitted other than in accordance with the instructions specified in this paragraph.

B. Eraser Law. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information at the end of this Policy. Please be aware that such request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

C. Electronic Commerce Act. In accordance with California Civil Code Sec. 1789.3, California residents may file grievances and complaints regarding our Site with the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 1625 North Market Blvd., Sacramento, CA 95834, by telephone at (916) 445-1254 or (800) 952-5210, or by email to dca@dca.ca.gov.

D. California Consumer Privacy Act of 2018, as amended (“CCPA”). 

We collect or have collected in the preceding 12 months the categories of personal information listed in the Categories of Personal Information section of the Privacy Policy, above.

We disclose or have disclosed in the preceding 12 months the following categories of personal information to service providers or contractors:

Consumer Rights. California residents have the following rights with respect to the personal information we collect about them, subject to certain limitations.

Right to Opt Out of Having Your Information Sold or Shared. You have the right to opt-out of our selling or sharing your Personal Information. We do not sell personal information under the more commonly understood meaning of that word - i.e., providing personal information to third parties in exchange for money. However, we engage in common marketing and advertising practices to provide more relevant content and ads to users of our websites and services. Certain of these practices may constitute the “selling” or “sharing” of personal information, as those terms are defined in the CCPA. We may sell or share, or sold or shared in the preceding 12 months, the following categories of personal information to social networks and ad networks:

You may exercise your right to opt out by clicking the Do Not Sell or Share My Personal Information link located in the webpage footer, emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

This Site recognizes and processes opt-out preference signals. We will not charge you a fee or require any valuable consideration if you use the opt out signal nor will we change your experience with our Site or the products and services we offer. Please note that any opt out is specific to the browser you use.

We do not have actual knowledge of selling or sharing the personal information of minors under the age of 16.

Right to Limit the Use and Disclosure of Sensitive Personal Information. In certain circumstances, you can request that we limit our use and disclosure of your Sensitive Personal Information to purposes that are necessary to provide products and services (as reasonably expected by an average consumer requesting those goods and services). However, please note that we do not use or disclose your sensitive personal information for purposes beyond these permitted uses.

Right to Delete. You have the right to request that we delete your personal information from our records, subject to certain exceptions. For example, we may deny your request if we must retain the information to comply with a legal obligation or if it is needed to perform a contract between Holland and you.

Right to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding Holland’s receipt of your request:

Right to Correct. You have the right to request that we correct any inaccurate personal information we maintain about you.

Right to Withdraw Consent. Where we rely on your express consent to process your personal, you may withdraw it; however, if you do so, we may be unable to provide certain products or services.

Submitting Consumer Rights Requests. To submit a California consumer rights request, please contact us by emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

NEBRASKA

The following applies solely to consumers who are residents of the State of Nebraska in accordance with the Nebraska Data Privacy Act (NDPA). For a list of the personal data we collect and how we use and disclose it, please see the following sections in the Privacy Policy, above: Categories of Personal Information, How Do We Use the Personal Information We Collect From You, and With Whom We Share Your Personal Information and For What Purposes.

Consumer Rights. Nebraska consumers have specific rights with respect to personal data we collect about them. Subject to verification and certain limitations, these rights include the following:

Right to Opt Out of the Sale of Personal Data, Targeted Advertising and Profiling.

Sale. The Company does not sell your personal data, as that term is defined by the NDPA.

Targeted Advertising. You have the right, subject to certain limitations, to opt-out of our processing your Personal Information for targeted advertising. We engage in common marketing and advertising practices to provide more relevant content and ads to users of our websites and services. Certain of these practices may involve the use of such information for “targeted advertising” or “profiling,” as those terms are defined in the NDPA. You may exercise this right by clicking the Opt Out of Processing of My Personal Data for Targeted Advertising link located in the webpage footer, emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157. Please note that any opt out is specific to the browser you use and you may need to opt out on every browser that you use.

Profiling. We do not process personal data for profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning a consumer.

Right to Confirmation and Access. You have the right to request that we confirm whether we are processing your personal data and to access such data.

Right to Correct. You have the right to request that we correct any inaccurate personal data we maintain about you. 

Right to Delete. You have the right to request that we delete personal data we collected or maintain about you. 

Right to Obtain a Copy. You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format where the processing is carried out by automated means.

Right to Withdraw Consent. Where we rely on your express consent to process your personal, you may withdraw it; however, if you do so, we may be unable to provide certain products or services.

Submitting Consumer Rights Requests. To submit a Nebraska consumer rights request, please contact us by emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

Appeal. If we deny your request, you may appeal our decision by contacting us at dataprivacy@hollandpartnergroup.com within 30 days from the date of our denial. 

NEVADA

Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and do not have plans to do so. In accordance with Nevada law, you may submit to us a verified request instructing us not to sell your covered information. Such requests can be submitted to dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

TEXAS

The following section applies solely to consumers who are residents of the State of Texas in accordance with the Texas Data Privacy and Security Act (TDPSA). For a list of the personal data we collect and how we use and disclose it, please see the following sections of the Privacy Policy, above: Categories of Personal Information, How Do We Use the Personal Information We Collect From You, and With Whom We Share Your Personal Information and For What Purposes.

Your Rights and How to Exercise Them. Texas consumers have specific rights with respect to personal data we collect about them. Subject to verification and certain limitations, these rights include the following:

Right to Opt Out of the Sale of Personal Information, Targeted Advertising and Profiling.

Sale. The Company does not sell your personal data, as that term is defined by the TDPSA.

Targeted Advertising. You have the right, subject to certain limitations, to opt-out of our processing your Personal Information for targeted advertising. We engage in common marketing and advertising practices to provide more relevant content and ads to users of our websites and services. Certain of these practices may involve the use of such information for “targeted advertising” or “profiling,” as those terms are defined in the TDPSA. You may exercise this right by clicking the Opt Out of Processing of My Personal Data for Targeted Advertising link located in the webpage footer, emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157. Please note that any opt out is specific to the browser you use and you may need to opt out on every browser that you use.

Profiling. We do not process personal data for profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning a consumer.

Right to Confirmation and Access. You have the right to request that we confirm whether we are processing your personal data and to access that data.

Right to Correct. You have the right to request that we correct any inaccurate personal data we maintain about you.

Right to Delete. You have the right to request that we delete personal data we collected or maintain about you.

Right to Obtain a Copy. You have the right to obtain a copy of personal data that you previously provided in a portable and, to the extent technically feasible, readily usable format.

Right to Withdraw Consent. Where we rely on your express consent to process your personal, you may withdraw it; however, if you do so, we may be unable to provide certain products or services.

Submitting Consumer Rights Requests. To submit a Texas consumer rights request, please contact us by emailing dataprivacy@hollandpartnergroup.com or calling us at 1-888-212-2157.

Appeal. If we deny your request, you may appeal our decision by contacting us at dataprivacy@hollandpartnergroup.com within 30 days from the date of our denial.

Please note that we reserve the right to change this Policy at any time.  We will take reasonable steps to advise you of any material changes to this Policy, including by posting the revised Policy on our Site. 

Changes will be effective immediately upon posting to the Site and will apply to your use of the Site after the “effective date” listed above. You understand and agree that your continued use of the Site after the effective date means the collection, use, and sharing of your information is subject to the updated Policy. Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your information in accordance with the terms of the Policy in effect at the time of the collection.

We recommend that you review this Policy from time to time to obtain the current version.  You may contact us at the address, email address or telephone number listed below to obtain a current copy of this Policy.

If you have any comments or questions in connection with this Policy, or for further information on our personal information processing practices and your rights in relation to your personal information, please contact us via email at dataprivacy@hollandpartnergroup.com or 1-888-663-1069.