TGM Associates L.P. Privacy Policy Effective April 1, 2009

How Our Privacy Policy Applies

This Privacy Policy explains how we collect, use, and disclose Personal Information (defined below) you may provide to us through this Site and all TGM Associates L.P. (“TGM”) sites (collectively, the “Site”) and Personal Information that you may provide to us offline or indirectly through third party advertiser sites. This statement may be revised from time to time, so please revisit this page to remain fully informed of our commitment (see “Consent” Section below). Your provision of Personal Information to us indicates your consent to this Privacy Policy as modified from time to time.

Types of Personal Information We Collect

In this Privacy Policy, “Personal Information” means any information by which you can be personally identified, and includes your name and address, age or date of birth, your electronic mail address, number of children, your occupation, employment information, telephone number, education, the kind of service provided to you, your social security number, real property purchased, leased, or rented, bank account number, debit card number, bank or investment account, debit card, credit card, credit card number, credit card balance, payment history, and information pertaining to your creditworthiness, assets, income or liabilities. If you are applying for employment at TGM, these additional categories of information will also be deemed to be Personal Information:

• Race
• Background report
• Results of drug screenings
• Employment verification

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

How We Use and Disclose Personal Information

We collect, retain, and use Personal Information for the reasons stated below:

• To complete the leasing process;
• To request a credit report in connection with leasing or job applications;
• To process job applications;
• To contact you in response to your inquiries, comments and suggestions;
• To contact you otherwise when necessary;
• For the specific purpose for which it was volunteered (for example, to receive notice from us);
• To track our visitors’ use of the Site for internal market research;
• To improve the Site and the services TGM promotes or provides through the Site or through other means;
• For special promotions, contests or survey registrations;
• To customize the content and/or layout of our Site for each individual visitor;
• To ask for your participation in brief surveys;
• To complete any purchases or other transactions you may perform at the Site;
• To notify visitors about updates to the Site or services;
• To notify you about promotions, special offers, etc., regarding products and services provided by us or our affiliates or partners.
• To be provided to third party service providers on behalf of TGM;
• As required by law or regulation, or as requested by government authorities;
• To be provided to a purchaser, successor, or assignee in connection with an acquisition, merger, sale or other transfer of all or any portion of our business; and
• For our internal business purposes.

We do not disclose Personal Information to third parties for their marketing purposes.

Cookies

In order to personalize and enhance your experience on our Site, we also may collect information through “cookies.” Cookies are small strings of text that are sent by our Site to your browser and then stored by your browser on your computer’s hard drive. Our cookies allow us to personalize your experience on our Site, make your visit more convenient, and understand how you and others are using our Site so that we can improve your experience on the Site. We use cookies to identify repeat visitors to our Site and to determine the paths visitors take on our Site. We also use cookies to determine whether you visited our Site from a particular Internet link or advertisement. We do not use cookies that store Personal Information or associate cookie information with Personal Information you may provide us. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. In order to create a profile on our Site you must have your cookies on.

Data Security

The security of your Personal Information is important to us. We use encryption technology to protect data transmitted during the online lease completion process and for online payment of rent or other charges. Your browser will indicate when such encryption is activated (i.e., a padlock icon will be shown in Microsoft’s Internet Explorer). While our security measures are intended to protect your Personal Information, the complete security of any transmission over the public internet cannot be guaranteed.

Children’s Policy

We do not collect or maintain information at our Site from those we know are under 13, and we do not permit children under 13 years of age to become registered users of our Site. No part of our Site is structured to attract anyone under 13. By using our Site you represent that you are not under 13 years of age.

Links to Third-Party Web Sites

Our Site may offer links to other Web sites which may have information policies and practices different from ours. We do not control and are not responsible for the privacy policies or practices or the content of any third party Web sites. Consent Use of this site constitutes your consent to our collection and use of Personal Information. TGM reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy Policy from time to time. We will notify you of amendments to this Privacy Policy by posting the amended policy on the Site. The amended Privacy Policy will be effective upon posting on the Site. Your continued use of the Site and/or the services means that you agree to the revised Privacy Policy and our use of your Personal Information in accordance with the revised policy. TGM may, but is under no obligation to, provide you notice of such modifications to this Privacy Policy via email or other communications.

Email Consent and Opt-Out

Your provision of Personal Information through our resident access site constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to the property where you reside, and various services available to you at or through that property. You may choose to opt out of receiving future commercial email messages from us. Each mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. If you are a resident of a TGM community and you opt out of receiving commercial email from us, you will continue to receive email from us regarding operational issues surrounding your apartment, your lease, and/or your community.

Non-U.S. Residents

If you do not reside in the U.S. and are visiting our Site, if you provide Personal Information to us it may be transferred to and processed on computers in the U.S. and other countries. Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. Your provision of Personal Information to us will be handled in accordance with this Privacy Policy. From time to time, your Personal Information may be transferred to a country different from where you are located, and processed there in accordance with this Privacy Policy. You hereby consent to such transfers and processing as described in this Privacy Policy. Your provision of Personal Information to us through this Site means that you agree to the terms of this Privacy Policy.

Access

If you are a resident of a TGM community, we provide you with the ability to ensure that your Personal Information is correct and current. For security purposes, we require user verification via user’s user name and password to receive Personal Information. To edit your Personal Information, you must login to Resident Access using your user name and password and access the myProfile/Update My Profile page. You will then have the ability to make the desired modifications or additions to your Personal Information. Fields marketed with “*” are required to be completed in order to save your desired modifications or additions. You must click submit for the changes to be updated and effective.

How to Contact Us

Should you have other questions or concerns about this Privacy Policy, please send us an email at privacy@TGMAssociates.com. Please note: Only inquiries regarding TGM’s Privacy Policy can be answered via this address.