Berkshire Residential Privacy Policy 

Last Updated: April 10, 2026 

This privacy policy (this “Privacy Policy”) describes the ways in which Berkshire Residential Investments and our affiliates (together, “we”, “us”, or “our”) collect, use, and disclose your personal information (i.e., information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household) when you use our website (i.e.,https://berkshireresidentialinvestments.com/) (our “Website”) or otherwise interact with us, including through the company's relationship management platforms, including CRM, employment relationship management software, and other related applications, platforms, and software. 

We reserve the right to modify or amend this Privacy Policy at any time. We will indicate via the “Last Updated” date when this Privacy Policy was last updated . 

1. Gramm-Leach-Bliley Act Covered Data

If you obtain a financial product or service from us, we will collect, use, and disclose any “nonpublic personal information” (as defined by the Gramm-Leach-Bliley Act and Regulation S-P) that we collect from or obtain about you in connection with providing such financial product or service in accordance with the Privacy Notice that is provided to all investors upon initial investment and annually thereafter. This Privacy Policy does not apply to such nonpublic personal information. 

2. Categories of Personal Information We Collect

We may collect the following categories of personal information: 

  • Contact Information. Such as name, postal address, email address, and telephone number. 
  • Account Information. Such as username and password. 
  • Device and Website Usage Information. Such as IP address, browser type, operating system information, and information about when and how you interact with our Website (e.g., pages visited, time spent on each page, and referring/exit pages). This information is automatically collected using cookies and other tracking technologies, including third-party cookies and tracking technologies. 
  • Communications with Us. Such as the contents of your communications with us when you email us or have telephone conversations with our employees or other staff members, which may be recorded. 
  • Tenant Application and Resident Information. When you submit a tenant application or become a resident at one of our properties, we may also collect: 
  • Identification Numbers. Such as Social Security number, insurance number, and driver’s license number. 
  • Demographic and Income Verification Information. Such as prior addresses, monthly rent paid at prior residences, employers, job titles, income, date of birth, gender, age, and marital status. 
  • Emergency Contact Information. Such as name and telephone number of your emergency contact. 
  • Vehicle Information. Such as vehicle make, vehicle model and license plate numbers. 
  • Payment Information. Such as payment card information (including cardholder’s name, credit or debit card number, expiration date, security code, and billing address) and bank account information (including account and routing number). 
  • Biometric Information If you choose to schedule a self-guided tour and/or use our identity verification services, we may also collect biometric information or biometric identifiers. 
  • Smart Device Information. If you choose to use Smart Home or the Home IQ Device(s) or Home IQ Hub, we may also collect information relating to when the smart device is on or off, when a door is locked, unlocked, opened, or closed, and the unit with which the door is associated. 
  • Job Application Information Such as name, address, phone number, email address, work eligibility status, employment and education history, skills, including language abilities, employment eligibility, and other information provided by you and/or third parties, such as recruiters, online application portals, your current employer, references, and background check providers, when you apply for a job with us. 
  • Employee Information
  • Background Information. Such as prior residences. 
  • Demographic Information. Such as date of birth, gender, age, disability status, and marital status. o Emergency Contact Information. Such as name and telephone number of your emergency contact. 
  • Beneficiary Information. Such as name, date of birth, social security number for your beneficiaries. 
  • Bank Account Information. Such as routing number and account number, if direct deposit is elected for payroll. 
  • Work Authorization Information. Such as work authorization type and copies of authorization documentation. 
  • Medical Information. In the case of team members requesting a leave of absence for their own medical care or that of a family member. 
  • Other Information You Choose to Provide to Us. We may collect any other information you provide to us on or through our Website or in any other way. 
3. How We Use Personal Information

We may use the personal information we collect for the following purposes: 

  • Provide and Improve Our Website, Property Management, and Other Services. To provide you with and improve our Website, property management, and other services. 
  • Communication. To communicate with you and respond to your inquiries, including inquiries received throughout our website. 
  • Marketing To send marketing emails. You may opt out of marketing emails at any time by following the instructions included therein. Please note that even if you opt out of marketing communications, we may still send you transactional or relationship messages. 
  • Analytics. To analyze and better understand how users interact with our Website, including through the use of cookies and similar tracking technologies (including third-party cookies and tracking technologies). 
  • Legal Reasons. To (i) comply with applicable laws and regulations, (ii) respond to valid legal process, including requests from law enforcement or government agencies, (iii) investigate and participate in civil discovery, litigation, or other adversarial legal proceedings, (iv) protect you, us, and others from unlawful, malicious, deceptive, abusive, or fraudulent activities, or (v) investigate potential violations of and enforce our policies. 
  • Benefits. To enroll you and designated beneficiaries in employee benefit programs. 
  • With Your Consent. We may otherwise use your personal information with your consent. 
4. To Whom We Disclose Personal Information

We may disclose personal information we collect to the following categories of third parties: 

  • Service Providers We may disclose your personal information to service providers that perform services, including payment processing, website analytics, and marketing, on our behalf. We use Google Analytics to gather statistics about the use of our Website. For information on how Google uses your personal information when you use our Website, click here
  • Affiliates. We may disclose your personal information to our affiliates for the purposes described above. 
  • Participants in Change of Control Transactions. We may disclose your information to third parties to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger, or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law (including during negotiations thereof), or who are otherwise deemed to be our successor or transferee, including as a result of insolvency, bankruptcy, or receivership. 
  • Third Parties for Legal Reasons. We may disclose your personal information to third parties if we believe such disclosure is reasonably necessary to (i) comply with applicable laws or regulations, (ii) respond to valid legal process, including requests from law enforcement or government agencies, (iii) investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, (iv) protect you, us, and others from unlawful, malicious, deceptive, abusive, or fraudulent activities, or (v) investigate potential violations of or enforce our policies. 
  • Third Parties With Your Consent. We may otherwise disclose your personal information to third parties with your consent. 
5. Retention

We will retain your personal information for as long as reasonably necessary for the purpose of collecting such personal information, taking into account the following: (i) our relationship with you, (ii) your choices regarding such personal information, (iii) our legal obligations to retain such personal information, and (iv) whether retention is advisable considering our legal position. 

6. California Resident Privacy Rights

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), we are required to notify you of (i) the categories of personal information we collect about you, (ii) the purposes for which we collect and use such personal information, (iii) whether we “sell” or “share” such personal information, and (iv) the length of time we intend to retain each category of personal information, or if that is not possible, the criteria we use to determine our retention periods, amongst other relevant information. This Privacy Policy contains such information in this section and the sections entitled Categories of Personal Information We Collect, How We Use Personal Information, How We Share Personal Information, and Retention. Please read this Privacy Policy and any other terms provided to you at or before the collection of your personal information carefully. 

The CCPA grants California residents certain rights with respect to their personal information. In particular, you may have the following rights: 

  • Right to Access. The right to access (i) the categories of personal information we have collected about you, (i) the categories of sources from which such personal information is collected, (iii) our business or commercial purposes for collecting your personal information, (iv) the categories of third parties to whom we disclose your personal information, and (v) the specific pieces of personal information we have collected about you. 
  • Right to Correct. The right to correct any inaccurate personal information that we maintain about you. 
  • Right to Delete. The right to delete any personal information we have collected from you. 
  • Right to Limit the Use and Disclosure of Sensitive Personal Information. The right to limit our use and disclosure of your sensitive personal information. Although we process information that is considered “sensitive personal information” under the CCPA, such as Social Security number, driver’s license number, and biometric information, we only process such information for the purposes of providing our services, or as otherwise permitted by the CCPA, and therefore are not required to provide this right. 
  • Right to Opt Out of the “Sale” or “Sharing” The right to opt out of the “sale” or your personal information or “sharing” of your personal information for cross-context behavioral advertising. However, we do not “sell” or “share” personal information, and therefore are not required to provide this right. 

We will not discriminate against any consumer who exercises any of the rights mentioned above. 

To exercise your rights under the CCPA, you may submit a request by either sending an email to compliance@berkshireresi.com or calling our phone number at (617) 646- 2309 Within ten business days, we will acknowledge your request, and we will respond substantively within 45 calendar days. In the event we need additional time to provide you with a substantive response, we will notify you of the extension period (up to an additional 45 calendar days) and reason therefor. 

Only you or an authorized agent may submit a request. Once we receive your request, we must verify your identity in order to respond to your request, and may do so by requiring you to log into your account, provide at least two pieces of additional information that we can compare to information already in our possession, and/or give a declaration as to your identity under penalty of perjury. For an authorized agent to be verified, you must provide the authorized agent with written permission to submit a request on your behalf or power of attorney. 

California’s Shine the Light Law allows California residents to request and obtain, annually and free of charge, information regarding the disclosure of their personal information to third parties for their direct marketing purposes in the preceding calendar year. However, we do not share personal information with third parties for such purposes. 

7. Children

Our Website is not intended for use by or directed to children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18 through our Website. 

We may collect information about children under the age of 18, such as name, age, and address, provided by parents or guardians, in connection with the application and rental of a unit, the provision of property management services, or the provision of benefits to employees. 

8. Third Party Links 

This Privacy Policy applies solely to the information we collect. This Privacy Policy does not apply to other websites that are linked on or otherwise accessible through our Website, which we do not own or control. The privacy practices of such third-party websites are governed by their own privacy policies, which we encourage you to read carefully. We are not responsible or liable for the privacy practices of such thirdparty websites. By including a link on or otherwise making a third-party website available through our Website, we do not endorse or recommend such third-party website. If you choose to visit a third-party website, you do so entirely at your own risk. 

9. Do Not Track 

“Do Not Track” is a privacy preference that users can set in certain web browsers. Our Website does not currently respond to Do Not Track or other similar browser signals. 

10. Contact

If you have any questions or concerns regarding this Privacy Policy, or have a request relating to your personal information, please contact us by email at compliance@berkshireresi.com or by telephone at (617) 646- 2309 .