VILLAGE COOPERATIVE SENIOR HOUSING COMMUNITIES

REAL ESTATE EQUITIES DEVELOPMENT, LLC

REAL ESTATE EQUITIES ARCHITECTURE, LLC

PRIVACY NOTICE

Real Estate Equities Development, LLC (“Real Estate Equities Development”, “we”, “our”, or “us”) serves as the cooperative service agent for Village Cooperatives.  We respect and are committed to protecting your privacy.  That is why we have adopted this Privacy Notice.  This Privacy Notice lets you know how and for what purposes we are collecting, processing, and using your Personal Information (as defined herein).  We pledge that we will take reasonable steps to ensure that your Personal Information and Usage Information (as defined herein) will only be used in ways that comply with this Privacy Notice.

This Privacy Notice applies to any web page, mobile application, email list, onsite data collection, generic information, and Personal Information collected and/or owned by us, including but not limited to the websites located at www.villagecooperative.com, www.reedevelopment.com, and www.reearchitecture.com. This Privacy Notice is in effect no matter the method of collection (such as by mail, in-person appointment, sign-up/sign-in page or survey), including collection through our website and any online features, products, services, and/or programs we offer (collectively, the “Web Properties”). Real Estate Equities Development will treat any offline collection, uses, and disclosures of your Personal Information consistently with our online privacy practices set forth in this Privacy Notice. This Privacy Notice is not applicable to any web page, mobile application, social media site, generic information, or Personal Information collected and/or owned by any entity other than us.  

Types of Information Collected

Real Estate Equities Development and any third party that we hire for the purpose of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Web Properties may collect two types of information when you visit the Web Properties: Personal Information and Usage Information.

Personal Information:  The types of information that we collect may include, among other things, the following categories of information (collectively, “Personal Information”):

• contact information (e.g., your name, address, phone number, email address);
• demographic information (e.g., date of birth, age, gender);
• banking information (e.g., bank account and credit/debit card numbers, and billing address information);
• social security number (SSN), driver’s license, and other government ID numbers and government documents;
• information about your home or prospective home, and related income and asset verification (e.g., home value, mortgage balance, asset statements, social security statements, interest earnings); and
• other information specific to you.
  

You are not required to provide any of this information, but if you choose not to provide certain information, we may not be able to provide you the requested service or complete your transaction.

Usage Information: The types of usage information that we collect may contain generic information about you when you visit the Web Properties, which may include, among other things, the following categories of information (collectively, “Usage Information”):

• Internet Protocol (or IP) address or device ID/UDID, protocol and sequence information;
• browser language and type;
• domain name system requests;
• browsing history (such as, time spent at a domain, time and date of your visit) and number of clicks;
• http headers, and operating system and fingerprinting data; and
• aggregated information.
  

How Information Is Collected

We may collect Personal Information and Usage Information about you from the following sources:

• the correspondence you and others send to us, including when you complete any online forms or send us an email;
• applications or other forms we receive from you or your authorized representative, which may include information about your assets and income and identifying information, such as name, address and SSN;
• information we receive from you when we meet with you in person or when we speak with you over the phone;
• information we receive from you through the Web Properties and as a result of your use of our services;
• information about your transactions with, or services performed by, us, our affiliates or nonaffiliated third parties;
• information we receive from your computer or mobile device;
• information we receive from our affiliates, partners or service providers; and
• information we receive from other sources, as permitted by applicable laws, rules and regulations.
  

You may be able to sign up to join our mailing list.  If you sign up, we may from time to time send you an email newsletter or other literature with information about one or more of our Web Properties and general information about us. You can unsubscribe to our newsletter at any time by the means set forth in that communication.  

We may collect Usage Information from you in the following ways:

Browser Log Files. Our servers may automatically log each visitor to the Web Properties and collect and record certain browsing information about each visitor. The Usage Information includes only generic information and reveals nothing personal about the user.

Cookies: From time to time, we may use “cookies” to keep track of your visit and your use of the Web Properties sand to improve your experience on the Web Properties.  A cookie is a small piece of data that your browser stores on your computer’s or device’s hard drive and is used to collect information, such as identifying those areas of the Web Properties that you have visited in the past in order to enhance your next visit to the Web Properties.  You can choose whether to accept cookies by changing the settings of your browser, but some functionality of the Web Properties may be impaired or not function as intended if you choose not to accept cookies.  Each browser is a little different, so look at your Help menu to learn the correct way to modify your cookies. Cookies can be deleted by you, at any time, and will not collect any information when you are not accessing the Web Properties.  By using our Web Properties, you consent to our use of cookies.

Web Beacons: Some of our web pages and electronic communications may from time to time contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides.  These Web Beacons do not carry any Personal Information and are only used to track usage of the Web Properties and activities associated with the Web Properties.

Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information that you see on the Web Properties and some of the electronic communications you receive from us.  We keep this information for our internal use.

Use of Collected Information

Information collected by us may be used for the following primary purposes:  

• To provide products and services to you or any affiliate or third party who is obtaining services on your behalf or in connection with a transaction involving you.
• To improve our products and services.
• To personalize your experience on the Web Properties.
• To communicate with you and to inform you about products and services.
• To inform you about investment, development, or management services.
• To help protect the integrity of the Web Properties and our users.
  

When Information Is Disclosed and Shared

We might disclose Personal Information and/or Usage Information when required by law or in the good-faith belief that such disclosure is necessary:

• To comply with legal processes and applicable law.
• To enforce this Privacy Notice.
• To take precautions against liability and respond to any claim that any information provided by you violates the rights of a third party.
• To assist government enforcement agencies.
• To protect our rights, property, or the safety or the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies.
• To investigate potential unauthorized access or misuse of the Web Properties.
• To otherwise enforce or apply our other agreements.

We may transfer your Personal Information to third parties, including our hosting partners and other trusted third parties who assist us in operating the Web Properties.  We may also transfer your Personal Information to a lender financing a specific Village Cooperative project to which you have subscribed, as well as to the U.S. Department of Housing and Urban Development (“HUD”) if HUD will be insuring the mortgage loan.

We maintain reasonable safeguards to keep your Personal Information secure. When we provide Personal Information to our affiliates or third party service providers as discussed in this Privacy Notice, we require that these parties agree to process such information in compliance with our Privacy Notice or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own privacy notice.

We may now or in the future share Usage Information with third parties to demonstrate the usage patterns for advertisements, content, functionality, promotions, and/or services on the Web Properties and/or on third party websites, or as we otherwise see fit, consistent with applicable law. Non-personally identifiable information, in an aggregated, anonymized form, such that you are not individually identified, may be provided to other parties for marketing, advertising or other uses, as we see fit.

We reserve the right to transfer your Personal Information, as well as any information about or obtained from you, in connection with the merger, sale or other disposition of all or part of our business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of our creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us.

We may disclose your Personal Information for any purpose disclosed by us when you provide the information. We may also disclose your Personal Information with your permission or as directed by you.

Security

While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.  

Data Retention

We will retain your Personal Information for as long as you maintain an account with us, or as needed to provide you the products and services we provide. We will also retain and use your Personal Information as necessary to comply with our legal obligations, comply with our internal business practices and standards, resolve disputes, and enforce our agreements. Personal Information is destroyed when it is no longer necessary for these purposes. The specific destruction process and method are as follows: (i) Personal Information printed on paper is shredded, pulverized, or incinerated; and (ii) Personal Information that is stored in electronic form is deleted using technology designed to prevent the recovery of the Personal Information.

Information from Children

The Web Properties are not intended or designed to attract children under the age of thirteen (13).  You affirm that you are more than eighteen (18) years of age, or you are an emancipated minor, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Notice, and to abide by and comply with this Privacy Notice.  In any case, by using the Web Properties, you affirm that you are over the age of thirteen (13), as THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER THIRTEEN (13) WHO ARE UNACCOMPANIED BY THEIR PARENT(S) OR LEGAL GUARDIAN(S).

Parents and legal guardians should be aware that this Privacy Notice will govern our use of Personal Information, but also that information that is voluntarily given by children (or others) in email exchanges, bulletin boards, or the like, may be used by other parties to generate unsolicited communications.  We encourage all parents and legal guardians to instruct their children in the safe and responsible use of their Personal Information while using the Internet.

Privacy Outside the Web Properties

The Web Properties may now or in the future contain various links to other websites.  We are not and cannot be responsible for the privacy practices or the content of any of those websites.  Other than under agreements with certain reputable organizations and companies, and except for third party service providers (as described in this Privacy Notice), we do not share any of the Personal Information that you provide to us with any of the websites to which the Web Properties link.  Please check with those websites in order to determine their privacy policies and your rights under them.  

We may use the services of third party service providers to process transactions on our behalf. By using our Web Properties, you grant us all necessary rights and consents under applicable laws to disclose to our third party service providers -- or allow those third party service providers to collect, use, retain and disclose to us -- any Personal Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

European Union Users

The Web Properties and our products and services are hosted in the United States and are governed by United States law. If you are using the Web Properties or our products or services from outside the United States, please be aware that your Personal Information and/or Usage Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Web Properties or our products and services, you consent to your Personal Information and Usage Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

We will only process your Personal Information when we have a legal basis to do so. When we do process your Personal Information, we will do so with your consent as set forth in this Privacy Notice, or because the processing is necessary for the performance of services or to provide products to you, to comply with our legal obligations, to pursue our legitimate interests, or to establish or defend a legal claim.

If applicable, you may have the following rights under some circumstances, as follows: (1) you may request information about what Personal Information we have about you; (2) you may request rectification, deletion, and limitation of the processing of your Personal Information as long as this is legally permissible and possible within the framework of an existing contractual relationship; (3) you have the right to transfer the Personal Information that you have provided to us on the basis of a consent or a contract; and (4) if you have given us consent for Personal Information processing, you can revoke it at any time in the same manner that you granted it. Please remember that the revocation of consent does not affect the legality of the processing done before you revoked your consent.

To exercise your rights, please contact us by one of the methods set forth at the end of this Privacy Notice, and we will respond to your request in a prompt manner. We may not be able to accommodate your request in every situation, but if that is the case, we will let you know why. We may charge you an administrative fee for subsequent requests, as permitted by applicable law.

Not Financial Advice

You acknowledge and agree that by providing you with access to and use of the Web Properties, we are not providing financial opinions or advice on any of the matters discussed or included on the Web Properties, and we will not be liable to any party for any act or failure to act relating to any information included on the Web Properties. You further acknowledge and agree that none of the information contained on the Web Properties constitutes a solicitation, offer, opinion, or recommendation by us to buy or sell any security, or to provide legal, tax, accounting, or investment advice or services regarding the profitability or suitability of any security or investment.

Choices with Your Personal Information and Opting Out

Whether you submit any Personal Information to us is entirely up to you.  You are under no obligation to provide any Personal Information to us.  However, this information is essential for the provision and quality of some of the services that we offer to you, so we cannot provide you with certain services or provide you with access to certain features if you choose to withhold requested information.   

You may choose to prevent us from disclosing or using your Personal Information under certain circumstances (“opt out”).  You may opt out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Notice, or by following the procedures set forth in an electronic communication from us, if applicable.  Furthermore, even where your Personal Information is to be disclosed and used in accordance with the stated purposes in this Privacy Notice, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent.  There are some uses from which you cannot opt out, such as to provide products, features or services that you have requested from us.

Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party that we do not own or control may copy the posting and repost it elsewhere.

Access and Correction

Please contact us in the manner specified at the end of this Privacy Notice to access your Personal Information in our possession and correct inaccuracies of that information in our records.  We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances, as permitted by applicable laws, rules and regulations.

Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us (once per calendar year) information about the customer information that we shared (if any) with other businesses for their own direct marketing uses.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.  To obtain this information, please send an email message to info@reedevelopment.com with “Request for California Privacy Information” in the subject line and in the body of your message.  We will provide the requested information to you at your email address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.

Under California Civil Code Section 1789.3, California residents who use the Web Properties are entitled to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through the Web Properties, please send an email to info@reedevelopment.com. You may also contact us by writing to 1400 Corporate Center Curve, Suite 100, Eagan, MN 55121, or by calling us at (651) 760-8306. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

“Do Not Track” Signals

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit.  Like many websites and online services, we currently do not alter our practices when we receives a “Do Not Track” signal from a visitor’s browser.  To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Your Consent to this Privacy Notice

By accessing and using the Web Properties, you consent to the collection and use of your information (including Personal Information) by us as specified above or as we otherwise see fit, in compliance with this Privacy Notice, unless you inform us otherwise by means of the procedure identified below.  If we decide to change this Privacy Notice or some part of it, we will make an effort to post those changes on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others.  Your use of the Web Properties following our publication of any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future.  We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

If you have questions or comments or would like to access your Personal Information or opt out of certain sharing, please let us know by sending your comments or requests to:

‍

Real Estate Equities Development
1303 Corporate Center Drive
Suite 400
Eagan, MN 55121

Phone: (651) 760-8305
Email: info@reedevelopment.com

‍

Copyright © 2023.  Real Estate Equities Development, LLC.  All Rights Reserved.

‍

Effective as of: January 1, 2021

Last updated: February 9, 2021