AvalonBay Communities, Inc. California Privacy Notice

Effective Date: April 4, 2020

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to AvalonBay Communities, Inc.’s (“Company“us” “we” our”) other privacy policies or notices. In the event of a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any privacy policy or notice of general applicability posted or referenced on our websites, apps, products, or services including, without limitation, avaloncommunities.com; avalonbay.com; and AvalonAccess.com.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA. This Notice also covers rights California Consumers have under the CCPA, as well other notices to Californians required by other laws. The description of our data practices in this Notice, as required by the CCPA, covers only calendar year 2019 and will be updated annually. Our practices in calendar year 2020 may change, however, if materially different such that we think a Consumer would reasonably expect notice we will provide notice in connection with the applicable collection, which may include reference to other applicable privacy policies and notices.

Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. However, our Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available at Title 1.81.5 of the California Civil Code, Sections 1798.100 - .199, and in some places in this Notice we cite specific CCPA sections for your reference. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

You can click on the following links to navigate to the different sections in this Notice.

1. PI We Collect

(A) Sources of PI

(B) Collection and Use of PI

2. Sharing of PI

(A) Disclosures for Business Purposes, at Your Direction and In Corporate Transactions and Intra-Company Transfers

(B) Sale

3. California Privacy Rights

(A) The Right to Know

i. Information Rights

ii. Obtaining Copies of PI

(B) Do Not Sell

(C) Delete

(D) Non-Discrimination and Financial Incentive Programs

(E) Authorized Agents

(F) Our and Other’s Rights

4. Additional California Notices

(A) Third Party Marketing and Your California Privacy Rights

(B) Online Privacy Practices

(C) Tracking and Targeting

(D) California Minors

5. Contact Us

1. PI WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information” or “PI”) about California Consumers including the following categories of PI collected within the last 12 months:

Category of PIExamples of PISources of PIBusiness or Commercial Purposes for PI Collection
1.Identifiers
(as defined in CCPA §1798.140(o)(1)(A))
This may include but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Marketing; Processing interactions and transactions; Screening applicants; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
2. Personal Records
(as defined in CCPA §1798.140(o)(1)(B))
This may include information such as: physical characteristics or description, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information medical information, or health insurance information, or emergency contact details.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Processing interactions and transactions; Screening applicants; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
3. Consumer Characteristics
(as defined in CCPA §1798.140(o)(1)(C))
This may include, but is not limited to: age, sex, marital status, religion, veteran status, familial status, disability, gender identity, citizenship status.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
4. Customer Account Details / Commercial Information
(as defined in CCPA §1798.140(o)(1)(D))
This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Marketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
5. Internet Usage Information
(as defined in CCPA §1798.140(o)(1)(F))
This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Marketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
6. Geolocation Information
(as defined in CCPA §1798.140(o)(1)(G))
This includes your location in person or when engaging in internet activity.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Marketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
7. Sensory Data
(as defined in CCPA §1798.140(o)(1)(H))
This may include, but is not limited to: audio recordings of customer care calls.Directly from the consumer, from service providers, including those that list our apartment homes or joint marketing partners.Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Auditing related to a current interaction with the Consumer and concurrent transactions.
8. Professional or Employment Information
(as defined in CCPA §1798.140(o)(1)(I))
This may include, but is not limited to: professional, educational, or employment-related information.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
9. Non-public Education Information
(as defined in CCPA §1798.140(o)(1)(J))
This includes education information that is not publicly available.Directly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.
10. Inferences Drawn from Any of the Above
(as defined in CCPA §1798.140(o)(1)(K))
This includes inferences drawn from any PI to create a profile about a consumer reflecting preferences, characteristics, trends, predispositions, behaviorsDirectly from the consumer including through email accounts and online activities, from service providers, including those that list our apartment homes or joint marketing partners, from publicly available non-government data, from publicly-available government data, or from consumer reporting agencies.Marketing; Data Analytics; Business process improvement

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers.

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A. Sources of PI

We may collect your PI directly from you or from service providers, vendors and suppliers, credit reporting agencies, our affiliates, or other individuals and businesses, as well as public sources of data such as government databases. For more specifics tied to each category of PI, see the chart above.

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B. Collection and Use of PI

Generally, we collect, use and disclose your PI to provide you services and as otherwise related to the operation of our business. For more specific detail on our disclosures of PI, see the next section Sharing of PI. As noted in that section, we may collect, use and disclose the PI we collect for one or more of the following business purposes:
  • Processing Interactions and Transactions (§1798.140(d)(4));
  • Managing Interactions and Transactions (§1798.140(d)(1));
  • Performing Services (§1798.140(d)(5));
  • Research and Development (§1798.140(d)(6));
  • Quality Assurance (§1798.140(d)(7))
  • Security (§1798.140(d)(2));
  • and Debugging (§1798.140(d)(3)).
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes.
In addition, we may collect, use and disclose your PI for the following additional or specific operational business purposes for which we are providing you notice as permitted by the CCPA: Auditing, Data Analytics, Business Process Improvement, Resident Screening, Payment Processing. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an additional business purpose for which we are providing you notice.
In addition, we may collect, use and disclose your PI as required or permitted by applicable law.

For more specifics tied to each category of PI, see the chart above.

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2. SHARING OF PI

Including Disclosures for Business Purposes, at Your Direction and In Corporate Transactions and Intra-Company Transfers We may share your PI (as described above in PI We Collect) with our service providers and other qualified vendors for the same business purposes for which we collect such PI as described above in the Collection and Use of PI, including as follows:

 

Category of PIShared with Third Parties?Business Purposes for DisclosuresCategories of Third Parties
1. Identifiers
(as defined in CCPA §1798.140(o)(1)(A))
YesMarketing; Processing interactions and transactions; Screening applicants; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, including without limitation Internet Listing Services, analytics providers, operating systems and platforms, purchasers of communities, credit reporting agencies, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
2. Personal Records
(as defined in CCPA §1798.140(o)(1)(B))
YesProcessing interactions and transactions; Screening applicants; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, including without limitation Internet Listing Services, analytics providers, operating systems and platforms, purchasers of communities, credit reporting agencies, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
3. Consumer Characteristics
(as defined in CCPA §1798.140(o)(1)(C))
YesProcessing interactions and transactions; Managing interactions and transactions;Performing services;Research and Development;Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, purchasers of communities, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
4. Customer Account Details / Commercial Information
(as defined in CCPA §1798.140(o)(1)(D))
YesMarketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, purchasers of communities, credit reporting agencies, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
5. Internet Usage Information
(as defined in CCPA §1798.140(o)(1)(F))
YesMarketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, and governmental entities; Business Partners; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
6. Geolocation Information
(as defined in CCPA §1798.140(o)(1)(G))
YesMarketing; Processing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
7. Sensory Data
(as defined in CCPA §1798.140(o)(1)(H))
YesProcessing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, including without limitation analytics providers, operating systems and platforms, and governmental entities; Business Partners; Customer Service Reps; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
8. Professional or Employment Information
(as defined in CCPA §1798.140(o)(1)(I))
YesProcessing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, purchasers of communities, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
9. Non-public Education Information
(as defined in CCPA §1798.140(o)(1)(J))
YesProcessing interactions and transactions; Managing interactions and transactions; Performing services; Research and Development; Quality assurance; Security; Data analytics; Auditing related to a current interaction with the Consumer and concurrent transactions.Service providers, analytics providers, operating systems and platforms, purchasers of communities, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.
10. Inferences Drawn from Any of the Above
(as defined in CCPA §1798.140(o)(1)(K))
YesBusiness process improvementMarketing; Data Analytics; Business process improvement Service providers, analytics providers, operating systems and platforms, and governmental entities; Business Partners; Customer Service Reps; Board of Directors; External Agencies; External Auditors; Finance/Accounting Teams; Internal Auditors; Internal Employees on a need to know basis; Legal Teams; Public Authorities/Government Bodies.

Notwithstanding anything to the contrary in our other privacy notices, we typically restrict use of your PI that is governed by the CCPA’s Consumer rights provisions and is shared with our vendors to business purposes, or we treat such disclosures as sales of your PI subject to your Do Not Sell rights.

In addition, if you direct us to share PI we may, and that is not a sale. Also, disclosures amongst the entities that constitute Company as defined above are not a sale.

A. Sale:

Although we do not currently sell your information, we provide the option to exercise do not sell rights for the future. For more information on how to exercise your do not sell rights, click here.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

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3. CALIFORNIA PRIVACY RIGHTS.


We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our Consumer Rights Request page here or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday, and respond to any follow up inquires we may make. You may also obtain information on how to make a request by asking a manager at any of our communities.

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your social security number, driver’s license number or other government-issued id number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

Your California Consumer privacy rights are as follows:

i. Information Rights:

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties to whom we have shared your PI.
  • The specific pieces of PI we have collected about you.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
    • The categories of your PI we have sold.
    • The categories of third parties to which we sold PI, by categories of PI sold for each third party.
To make a request, you may click here or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday. For any request using any of these methods, we will undertake to verify your request which will require that you provide us with additional data so that we may connect your identity to data that retain, as well as verify that the person making the request is the subject of that data. For your specific pieces of information, as required by the CCPA, we will apply the heightened verification standards set forth in subsection (ii) below.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

ii. Obtaining Copies of PI:

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. To make a request, click here, or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday. For any request using any of these methods, we will undertake to verify your request which will require that you provide us with additional data so that we may connect your identity to data that retain, as well as verify that the person making the request is the subject of that data.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

Although we do not currently sell your information, we provide the option to exercise do not sell rights for the future.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate

If you are 16 years of age or older, you have the right to direct us to not sell your PI.

To make a request, you may click here or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday.
We do not knowingly sell the PI of Consumers we know are under 16 unless we receive an opt-in from the Consumer who is at least 13 but under 16, or from the parent or guardian of a Consumer younger than 13. Consumers who opt-in to PI sales may opt-out at any time.

C. Delete:

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you. To make a request, you may click here or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday. For any request using any of these methods, we will undertake to verify your request which will require that you provide us with additional data so that we may connect your identity to data that retain, as well as verify that the person making the request is the subject of that data.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

An Authorized Agent may be able to make a request relating to your PI by following the instructions included in this notice if we are able to verify both your identity and the identity and legal authority of your agent.

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

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4. ADDITIONAL CALIFORNIA NOTICES

In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

A. Third Party Marketing and Your California Privacy Rights:

California's "Shine the Light" law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.

Separate from your CCPA "Do Not Sell" rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:

We may from time to time elect to share certain “personal information” (as defined by California’s “Shine the Light” law) about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2019 will receive information about 2018 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request by emailing us at privacy@avalonbay.com, or in writing at: 4040 Wilson Blvd.,Suite 1000, Arlington, VA 22203, (Attention: Legal Counsel). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

B. Online Privacy Practices:

For more information on our online practices and your California rights specific to our online services see our online Privacy Policy. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

C. Tracking and Targeting:

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our online Privacy Policy.

D. California Minors:

Although our online service(s) are intended for an audience over the age of 18, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us at privacy@avalonbay.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

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5. CONTACT US

For more information on your California privacy rights email us at privacy@avalonbay.com, or write to us at: 4040 Wilson Blvd., Suite 1000, Arlington VA 22203, Attn: Legal Counsel. To make a request, you may click here or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday.

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