Click here for the Portuguese translation of this Privacy Notice

Important to Note:

Entrata provides a suite of products and services (collectively, the "Entrata Platforms" or "Platforms") for use by our business clients ("Clients"), which are typically residential and commercial real estate property managers and property owners. Our Clients use our Platforms for many purposes, such as to manage the leasing lifecycle, and to facilitate communication with their end users and residents ("End Users"). Entrata typically has no direct relationship with End Users; we simply process and store End Users' personal information ("Client Data") on our Clients' behalf, as their service provider; Clients are responsible for directing Entrata in the processing of such information. Any use of Client Data by us is carried out pursuant to an agreement (and/or our applicable Terms of Service) in place between Entrata and our Client.

If you, as an End User, have any questions or concerns about the data handling practices of a Client using our Platforms to process and store your personal information, please contact the relevant Client directly.

Our ProspectPortal Platform permits our Clients to create their own websites, which facilitate communication and transactions between prospective and current tenants and our Clients. While these websites are built using our Platforms, and Client Data obtained through these websites are stored on our systems, this data is considered Client Data and is governed by our Clients' privacy notices/policies.

Finally, our Entrata Sites may contain links to other third-party websites. The information practices and content of such third-party websites are governed by their own privacy notices. We encourage you to review the privacy notices of such third-party websites to understand their information practices.

Entrata, Inc. and its affiliated entities (collectively, "Entrata", "we", "us", "our") are committed to protecting individual privacy and maintaining the trust of our Clients, the actual users of our services who are employed or contracted by our Clients ("Client Staff"), and visitors to our websites ("Visitors") (collectively, "you," "your"). It is important to us that we provide transparency regarding our collection, use, and disclosure of information that can be reasonably linked with you ("Personal Information").

To help us meet this commitment to you, we have created this Privacy Notice ("Privacy Notice"). This Privacy Notice governs data protection matters across the websites we control and which link to this Privacy Notice ("Entrata Sites") including related services other than the Platforms we provide to our Clients (collectively, "Services"). This Privacy Notice, along with our Terms of Use (available here, https://www.entrata.com/terms-of- use), form an integral part of our relationship with you.

This Privacy Notice describes how we use, share, and protect the Personal Information of Clients, Client Staff, and Visitors who visit the Entrata Sites which:

1. the data processing operation is carried out within the Brazilian territory.
2. the data processing activity aims to offer or supply goods or services to individuals located in Brazil.
3. the personal data object of the processing has been collected in Brazil.

This Privacy Notice also describes the rights and choices regarding use, access to, and correction of Personal Information available.

This Privacy Notice does not govern websites created by our Clients using our ProspectPortal Platform to facilitate communication and transactions between Clients and their prospective and current tenants. Client Data obtained through these Platforms websites is governed by our Clients' privacy notices/policies.

Finally, our Entrata Sites may contain links to other third-party websites. The information practices and content of such third-party websites are governed by their own privacy notices. We encourage you to review the privacy notices of such third-party websites to understand their information practices.

We and our service providers collect Personal Information in various ways, such as when you: enter into a transaction or contractual arrangement with us; provide us with your Personal Information via the Services; participate in our programs or activities (e.g., our contests, online webinars, Entrata Connect, and Basecamp); provide Personal Information at industry events and trade shows; visit our facilities or we visit you at your offices; contact our customer service; provide suggestions, reviews, ideas, concepts, or other information (“Feedback”) related to the Services or make any inquiries and communications with us. More information is set out below. We also collect Personal Information from other sources, including publicly-accessible databases and joint marketing partners.

Personal data includes:

1. Contact information: First and last name, email address, employer, phone number (work), physical address (work), job title.
2. Marketing preferences and customer service interactions: Marketing preferences; responses to voluntary surveys.
3. Operational data: Transactions, sales, purchases, uses, supplier information, credentials to online services and platforms, Feedback, and electronic content produced by individuals using company systems (including online interactive and voice communications such as blog, chat, webcam use, and network sessions).

We will indicate which information is mandatory and must be provided for us to provide the requested Services to you at the point of collection. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so.

We also collect data through our Entrata Sites, such as browser and device information, application usage data, information collected through cookies, pixel tags and other similar technologies, and IP addresses.

We also use cookies and similar technologies on our Entrata Sites. Cookies are small files used to recognize, track and store your navigation as a user on the Internet. You can change your browser settings to block cookies or manage your use of cookies by blocking cookies from all or specific websites. Some or all of the Services may be adversely affected by such blocking. Please refer to your browser instructions to learn more about configuring cookies. "Do Not Track" Notice: "Do Not Track" is a preference that you can set in your browser to let websites you visit know that you do not want them collecting certain information about you. Entrata does not currently respond to, or honor, Do Not Track signals or requests from your browser.

We and our service providers use Personal Information for the following purposes:

1. Communicating with Clients and Client Staff for the purpose of our legitimate interest (providing our Clients with market-leading property management tools and Platforms). This includes:
   • Informing Clients about our various Platforms and solutions, and providing access to our Platforms where the Client enters into an agreement with us.
   • Providing back-end access to the Platforms for Clients and Client Staff.
   • Tracking and responding to Clients' inquiries, reports, reviews or correspondence regarding products and services.
   • Administering Client account(s).
   • Providing and improving our customer service.
   • Facilitating communications generally in the context of our business activities.
   • Sending administrative information to Clients, such as changes to our terms, conditions and policies.
   • Enforcing our Terms of Use and any other contractual terms and conditions that govern the relationship between Entrata and Clients.
2. Operating our business for the purpose of our legitimate interest (continuously improving, customizing and personalizing our Services). This includes:
   • Analyzing and improving the safety and security of our Services.
   • Supporting internal Entrata operations, including CRM and Client technical support.
   • Providing Clients and Client Staff with access to our 'App Store' to allow Clients to directly enable third-party application.
   • Carrying out machine learning, data extracting and loading data in data warehouses, in order to support Entrata enterprise software, data access, modifications, and operations.
3. Contacting Client Staff at prospective Clients in order to set up demos of our Platforms. This includes:
   • For marketing purposes, such as re-engaging with prospective Clients who have expressed an interest in our Services.
   • Administering account access to our Platforms for the purposes of providing demos/tutorials of the Platforms to prospective Clients.
   • Responding to your inquiries, for example, when you send us questions, suggestions, compliments or complaints, or when you request further information about our services.
4. Providing you with our newsletter and/or other marketing materials and facilitating social sharing or for the purpose of our legitimate interest (making it easier for you to get the benefit of your social sharing functionalities). This includes:
   • Sending you marketing related emails, with information about our services, new products and other news about our company.
   • Facilitating social sharing functionality that you choose to use.
   • Aggregating and/or anonymizing or de-identifying Personal Information so that it will no longer be considered Personal Information, for the purpose of our legitimate interest (to anonymize and aggregate for business purposes). We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. Where we maintain or use de-identified data, we will continue to maintain and use the de- identified data only in a de-identified fashion and will not attempt to re-identify the data.
5. Carrying out general organizational activities, for the purpose of our legitimate interest (to keep the Services updated and relevant and to develop our organization) and where necessary to comply with our legal obligations. This includes:
   • Data analysis, for example, to improve the efficiency of our Services.
   • Audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
   • Fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
   • Enhancing, improving, repairing, maintaining, or modifying our current Services.
   • Identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
   • Operating and expanding our organization's activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users' interests.
6. Carrying out general organizational activities that you may consent related to the Services. This includes:
   • capturing pictures with the device’s camera, accessing photo library, and making phone calls as offered in certain features of the Facilities App.
   • Sharing identifying information, and Client information with Entrata when submitting Feedback through the Facilities App.

How We Disclose Personal Data

We will not disclose any Personal Information that we collect from you to any external parties except as indicated below:

1. Our Affiliates. We may disclose Personal Information to any of our subsidiaries and affiliates within the Entrata corporate group (including Entrata India Private Limited).
2. Service Providers. We may disclose Personal Information to our service providers who perform certain services necessary to run our business (for example, data hosting and development, data analysis, customer service, auditing and other services), provided that these service providers have entered into legally binding agreements with us to protect the Personal Information shared, limit their use, retention, and disclosure of the Personal Information, and assist us with our compliance requirements.
3. Legal Request. We may disclose Personal Information to comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
4. Business Transfer. We may disclose Personal Information to a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Entrata’s assets, business, or stock, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which Personal Information held by Entrata are among the assets to be transferred.
5. API Transfer. We may disclose Client Data, at the direction of our Clients, through API to third parties. All API transfers are governed by a separate agreement between Entrata and the third party requesting API access, and all data usage and processing is governed by our Clients' agreements with such third parties.
6. Enforcement of Our or Others' Rights. We may disclose Personal Information to external parties the extent that this is necessary to enforce or protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others, including enforcing our Terms of Use and any other agreements (such as for billing and collection purposes and fraud prevention).
7. International Transfer. We shall ensure that transfers of personal data abroad comply with the provisions of the LGPD. In this regard, personal data may be transferred abroad in the following cases:
   • for countries that provide an adequate personal data protection level, as determined by the National Data Protection Authority ("ANPD");
   • by specific contractual clauses for a certain transfer, contractual standard clauses, global corporate rules or stamps, certificates, and codes of conduct, all to be approved by the ANPD;
   • when the data subject has provided his/her specific and prominent consent for the international transference, with prior information on the international character of the operation, clearly distinguishing it from other purposes.
   • for the performance of an agreement.

Children and Adolescents

We do not knowingly collect Personal Information people under the age of eighteen (18) that should not be included by the Client. If you believe that we may have collected Personal Information from or about a child under the age of eighteen (18), please send an email to dataprivacy@entrata.com with the subject line "Personal Information of a Minor."

How We Protect Your Personal Information

We seek to use commercially reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section below.

Where we collect your payment card information, we will comply with all applicable Payment Card Industry Data Security Standards (PCI-DSS).

Retaining Your Personal Information

We retain personal information for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law. The criteria used to determine our retention periods include:

1. The length of time we have an ongoing relationship with you or our Client, and provide the use of our Platforms to you or our Client (for example, for as long as you have an account with us or keep using the Platforms);
2. Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
3. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Choices Regarding Your Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by following the "unsubscribe" option contained in any such email.
2. Receiving other promotional text communications, like SMS. If you no longer want to receive marketing related texts, you may opt out by replying "STOP" to any message you may receive from us.

Keeping Your Information Updated

It is up to you to keep your Personal Information on our Services up to date. You can update your Personal Information by logging into your account. If you are unable to update your Personal Information, you can contact us in accordance with the "Contact Us" section below.

End Users should contact our relevant Client with which they have a primary relationship. If our Client is unable to assist the End User, we will endeavor to assist our Client with updating the End User’s information.

Rights of personal data subjects guaranteed by the LGPD

The LGPD assures the personal data subjects certain rights which may be exercised before our Clients, as data controllers, upon request of the respective personal data subject.

Since Entrata is a Service Provider engaged by the Client, we act as a data processor under LGPD. It means that the data subject's rights are generally exercisable against Entrata's Clients and not against Entrata.

These rights are only exercisable directly against Entrata when we determine the purposes and means of processing your Personal Information, which we generally only do if (1) you are an employee of one of our Clients; or (2) someone we are sending marketing communications to. Thus, please contact our Clients directly if you wish to exercise any of the rights described below. You can find some of the information our Clients are required to provide you in various sections of this Privacy Notice or on our Clients' respective privacy notices.

1. Rights of personal data subjects guaranteed by the LGPD. These rights are expressed in Article 18 of the LGPD, as follows:
   • confirmation of the existence of processing;
   • access to personal data;
   • correction of incomplete, inaccurate or outdated personal data;
   • anonymization, blocking or deletion of unnecessary, excessive or processed in breach of the provisions of the LGPD;
   • portability of personal data to another provider of a service or product, subject to the regulations of the national authority;
   • delete or anonymize personal data processed based on your consent, unless the law authorizes the maintenance of such data on another basis;
   • obtain information concerning the public and private entities whose controller has shared the personal data of the data subjects;
   • obtain information on the possibility of not giving consent to the processing of their personal data and the consequences of such denial; and
   • revoke the consent, as applicable.

To exercise any of your rights, you should contact the Client with whom you have a direct relationship by emailing dataprivacy@entrata.com. Your request will be responded to within fifteen (15) days from the date of your request. Before complying with your request, our Clients may need to verify the request's authenticity. To accomplish this, you may be requested to (1) confirm specific pieces of Personal Information that our clients already know about you or (2) provide our Clients with appropriate identification depending on the sensitivity of the information requested.

It is our policy to post any changes we make to our Privacy Notice on this page, with a notice that it has been updated on our main homepage. If we make material changes to how we treat your Personal Information, we will notify you through a notice on the homepage. The date that this Privacy Notice was last revised is listed at the top of the page ("Effective Date"). You are responsible for visiting our site and this Privacy Notice to check for any changes.

If you have any questions or complaints related to our practices with respect to the collection, use, or disclosure of Personal Information, please feel free to contact us at dataprivacy@entrata.com.

Entrata Legal Department

4205 Chapel Ridge Road

Lehi, UT 84043