Privacy Policy

Last updated: June 15, 2025

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Kairoi Residential (“Kairoi Residential”, “Kairoi”, “we”, “us”, or “our”) collects, uses, shares, and safeguards information that may be used to reasonably identify, directly or indirectly, an individual or household (“Personal Data”) when you access or use our website at www.kairoi.com, and any other websites (“Site(s)”), applications, or services that link to this Privacy Policy (collectively, the “Services”).

Depending on the jurisdiction in which you reside, including certain countries and states in the US, you may have additional rights regarding your Personal Data. Please see the Your Privacy Rights section below for more information.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@kairoi.com or see the Contacting Us section below for more information.

Personal Data We Collect and How We Collect It

Personal Data You Provide to Us

The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Information that is not considered Personal Data includes deidentified data and publicly available information.

The Personal Data we collect may include the following:

Name(s)
Phone number(s)
Email address(es)
Job title(s)
Username
Contact and/or authentication information
Contact preferences
The “Sensitive Personal Data” (as defined below) we collect may include the following:
- Contents of emails, phone calls, and/or text messages or other communications you share with us when not directed at Kairoi.
- Social Security Number
- Driver’s License

Sensitive Personal Data is a subset of Personal Data and is subject to heightened scrutiny and protection.

Examples of interactions with our Services that may lead to the collection of the types of Personal Data listed above include:

Online Leasing. When you submit an online leasing application, we collect Personal Data necessary to process your application. This may include, among other things, employment-related data, family-related data, your driver’s license and Social Security Number. Please note, providing this information is required to rent at any of our communities.
Account Registration. When you create an account, such as when you access Kairoi Residential’s Investor Portal or other restricted areas of the Services, we collect your name, email address, phone number, general location, and your Social Security Number and account information.
Newsletter Sign Up. If you choose to sign-up to receive our newsletters, we will collect your name and email address.
Form Submissions and Other Communications. We collect Personal Data when you communicate with us, such as when you request additional information about our company and our products and services, contact us about career opportunities, or submit other inquiries using our contact form. Examples of such Personal Data include your name, contact data, the date and time of your communications, and the content of your correspondence.
Job Applications. If you apply for a job posting, or become an employee, we collect Personal Data necessary to process your application or to retain you as an employee. This may include, among other things, employment-related data, education-related data, and your Social Security Number. Please note, providing this Personal Data is required for employment.
Website Chatbots. If you engage with our virtual AI-powered chatbots, we may collect the information you provide during the chat, including transcripts of your conversation with the chatbot. For more information on our use of AI technologies, please see the How We Use Artificial Intelligence Technologies section below.

Data We Collect Automatically

We collect certain data that cannot be used to identify you and cannot be linked to you (“Deidentified Data”) when you visit, use, or navigate the Services.

The Deidentified Data we collect automatically is anonymized statistical data (for example the number of visitors to a Site and the time spent on a Site). It helps us to improve our Services and to deliver a better and more personalized experience, including, but not limited to, by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize and improve our Services.
Speed up your searches.
Recognize you when you return to our Website.

Cookies

We and our service providers use “Cookies” to collect certain Personal Data when you interact with our Site. Cookies are small files that a website sends to your computer’s hard drive through your web browser that enables the website to recognize your browser and capture and remember certain information. Most web browsers allow you to reject or delete Cookies through their settings preferences. Please note that if you choose to remove or reject certain Cookies, this could affect the availability and functionality of our Services. When you first visit our site, you will be asked to consent to the use of Cookies. You can manage your Cookies preferences at any time through our website.

We use the Personal Data collected through Cookies for several reasons, including to:

Ensure our Services operate properly and efficiently.
Improve our Services.
Understand and save your preferences for future visits.
Help us analyze the use and performance of our Services, including traffic and Site interaction so that we can offer better experiences and tools in the future.
Monitor our networks and the visitors to our Services for security purposes, including detecting and preventing fraud.

Global Privacy Control and Opt-Out Preference Signals

Certain browsers or browser extensions enable you to instruct websites not to share your Personal Data for cross-contextual behavioral advertising via the “Global Privacy Control” or other opt-out preference signals. If you have activated Global Privacy Control or an opt-out preference signal in your browser or extension, we will honor those requests that our Sites can recognize by disabling targeting cookies and similar technologies. Please be aware that we may not always be able to link an opt-out preference signal to other user data, such as your email address.

Personal Data We Obtain From Other Sources

We may also receive Personal Data about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check where permitted by law.

Some of the Personal Data we receive from third parties may be collected with the use of artificial intelligence (“AI”). For more information see the How We Use Artificial Intelligence Technologies section below.

Third-Party Analytics

We may use third-party analytics services on our Services to monitor and analyze the use of our Services. For example, we utilize Google Analytics, a web analysis service provided by Google, to collect certain Personal Data, such as how often users visit the Services or what pages they visit. To learn more about how Google collects and processes Personal Data, please visit https://policies.google.com/technologies/partner-sites. For more information about how to opt out of having your Personal Data used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Summary of Our Personal Data Collection Practices (past 12 months)

Category	Examples
Identifiers	Name(s), phone number(s), email address(es), job title(s), username, contact data, Internet Protocol (IP) address
Contact Information	Name, contact data, education, employment history, financial data (e.g., Social Security Number, driver’s license)
Protected classification characteristics	Gender, age, date of birth, race and ethnicity, national origin, marital status
Commercial data	Transaction data, purchase history, payment information
Biometric data	Fingerprints, voiceprints
Internet or similar network activity	Browsing history, search history, online behavior, IP address, interactions with websites and advertisements
Geolocation data	General device location
Audio, electronic, sensory, or similar data	Audio or video recordings, images, call recordings
Professional or employment-related data	Business contact details, work history, job title, and professional qualifications (for job applicants)
Education data	Student records, directory data
Inferences drawn from collected data	Inferences drawn from Personal Data to create profiles (e.g., user preferences, characteristics)
Sensitive Personal Data	Social Security Number, driver’s license, financial data (including account access details), citizenship status, contents of emails or text messages when not directed at Kairoi
Personal Data obtained from other sources	Personal Data from third-party partners, Personal Data from public databases, Personal Data obtained through artificial intelligence (AI) processing

How We Use Personal Data

In addition to the purposes and uses described elsewhere in this Privacy Policy, we may collect and process Personal Data in order to:

Administer, maintain, evaluate, and improve our Services and website offerings.
Facilitate account creation and authentication and otherwise manage user accounts.
Deliver and facilitate delivery of services to the user.
Respond to user inquiries.
Send administrative information.
Send marketing and promotional communications.
Detect and protect against malicious, deceptive, fraudulent, or illegal activity.
Debug, identify, and repair errors.
Identify usage trends.
Make decisions about recruitment.
Comply with our legal or regulatory obligations.
Operate and improve upon our lawful business activities.

We may also collect and process Personal Data for such other purposes as you may consent (from time to time).

We may disclose your Personal Data with the following categories of third parties to support our business operations and Services:

Sales & Marketing Tools
Communication & Collaboration Tools
Data Analytics Services
AI Platforms
Government Entities

In addition to the parties enumerated above and the parties/situations discussed elsewhere in this Policy, we may also disclose your Personal Data in the following situations and/or with the following parties:

Affiliates. We may disclose Personal Data to our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
Service Providers. We may disclose Personal Data to third parties that perform services to support our business and internal operations, including data storage and website hosting service providers. Among other things service providers may help us to host and operate our Services, provide technical support, send communications, or assist with the other activities described in this Policy. We may disclose your Personal Data with our service providers pursuant to a written contract between us and each service provider.
Legal Requirements and Protection. We may disclose your Personal Data in response to subpoenas, warrants, court orders, government inquiries or investigations, or in connection with any other legal process, or to comply with relevant laws and regulations. We may also disclose your Personal Data to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
Business Transactions. If another company acquires, or plans to acquire, our company, business, or our assets, or in the event of a merger, we will also disclose your Personal Data to that company, and we may disclose your Personal Data at the negotiation stage.
Other Disclosures with Your Consent. If necessary, we may seek your explicit consent to disclose Personal Data to additional third-parties not otherwise covered in this policy.

We have not sold any Personal Data to third parties for a business or commercial purpose in the preceding twelve (12) months.

How We Protect Personal Data

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, we cannot guarantee the security of your Personal Data.

How Long We Retain Personal Data

We will retain your Personal Data only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law (such as for tax, accounting, or other legal obligations). For more information on the purposes for our collection of certain types of Personal Data, please see the Summary of Our Personal Data Collection Practices section above.

Factors that determine our retention periods include:

The duration of our ongoing relationship with you and the services we provide to you;
Any legal obligations we must comply with (e.g., certain laws may require us to retain records of your transactions for a specific period before we can delete them); and
Whether retention is advisable based on our legal position (such as statutes of limitations, ongoing litigation, or regulatory investigations).

When we no longer have a legitimate business purpose to process your Personal Data, we will either delete it or, if deletion is not possible (for instance, because your Personal Data is stored in backup archives), we will securely store and isolate it from further processing until deletion becomes possible.

How We Use Artificial Intelligence Technologies

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. We use artificial intelligence technologies to enhance our Services and provide you with a better user experience. These AI technologies may be used to collect and process your Personal Data in various ways, including but not limited to, personalizing content, providing communications, and improving our Services.

Our AI Products are designed for the following functions:

User interaction
Natural language processing
Voice call monitoring
AI insights

The terms in this Privacy Policy govern your use of the AI Products within our Services. When you begin an interaction with any of our Services that utilize artificial intelligence technologies, you will be provided with an appropriate notice informing you of the nature of the interaction.

By engaging with our AI-powered Services, you acknowledge that you are interacting with a third-party artificial intelligence bot, that any Personal Data you provide in your conversation may be collected and used to generate analytics or otherwise improve our Services, that you have the right to discontinue the interaction at any time, and that you consent to the terms of this Privacy Policy.

Scope of AI Usage

Website Chatbots. Several of our property websites employ AI-powered chatbots to provide instant responses to your inquiries. These chatbots assist with finding property information, scheduling viewings, and answering general questions about our services.
Email and Text Responses. We use AI to automate and streamline our email and text communications. This includes responding to your inquiries, sending property alerts, and providing updates on your transactions with us.
Call Monitoring. To ensure the highest quality of service, we utilize AI technologies to answer, monitor, and analyze phone calls. This helps us improve customer service, ensure compliance with our policies, and train our staff.

How We Process Your Personal Data Using AI

Any user Personal Data processed using our AI Products is handled in line with our Privacy Policy and our agreements with third parties. We strive to achieve a high level of security and safeguard your Personal Data throughout the process.

Segmentation and Automated Decision Making. We do not use segmentation or automated decision-making without human intervention, including profiling.

Your Privacy Rights

Depending on your state (US) of residence, you may have rights that allow you greater access to and control over your Personal Data. You may review, change, or terminate your account at any time, depending on your state of residence.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section Contacting Us below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For more information, see the “Global Privacy Control and Opt-Out Preference Signals” section above.

Your Rights

Depending on your jurisdiction, you may exercise the following privacy rights. These rights are not absolute and are subject to exceptions, and we may be legally required or allowed to deny your request. We cannot process a request unless we verify the request. Your request must be accompanied with enough detail for us to address it.

Right to Access. You have the right to request access to the Personal Data we hold about you.
Right to Correction. You have the right to request that we correct any inaccuracies in your Personal Data.
Right to Deletion. You have the right to request that we delete your Personal Data, subject to certain exceptions.
Right to Data Portability. You have the right to request that we transfer your Personal Data to another entity, in a structured, commonly used, and machine-readable format.
Right to Opt-Out of Targeted Advertising. You have the right to opt out of the processing of your Personal Data for the purposes of targeted advertising.
Right to Opt-Out of the Sale of Your Personal Data. You have the right to opt out of the sale of your Personal Data to third parties.
Right to Opt-Out of the Sharing of Your Personal Data. You have the right to opt out of the sharing of your Personal Data with third parties for cross contextual behavioral advertising.
Right to Opt-Out of Profiling. You have the right to opt out of the processing of your Personal Data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Non-Discrimination. You have the right to non-discrimination.
Right to Revoke Consent. You have the right revoke consent.
Right to Appeal. You have the right to appeal any decision we make regarding your privacy rights.

Other Jurisdictions

We recognize that there may be other jurisdictions with applicable data privacy and security laws and regulations (“Data Protection Laws”). If you reside in a jurisdiction not specifically mentioned above, you may still have rights regarding your Personal Data. Please contact us to inquire about your specific rights and choices based on your jurisdiction. For more information, see the “Contacting Us” section below.

How To Exercise Your Rights

To exercise your rights, you can contact us by emailing privacy@kairoi.com, or by referring to the contact details at the bottom of this document.
If we decline to take action in any request that you submit in connection with the rights described in this section or elsewhere in this Privacy Policy, you may ask that we reconsider our response by sending an email to privacy@kairoi.com. You must ask us to reconsider our decision within 45 days after we send you our decision. We will respond to your appeal in accordance with the timeline set forth under applicable Data Protection Laws.

Children’s Privacy

Our Services are not intended for or directed to individuals under the age of 18 and we do not knowingly collect Personal Data from individuals under the age of 18. If you are under 18, please do not use online leasing, job application and contact form submissions or send any personally identifiable information to us. If we learn that we have collected Personal Data from anyone under age 18, we will delete that data as quickly as possible. If you believe that anyone under 18 may have provided Personal Data to us, please contact us at privacy@kairoi.com.

Third-Party Links

For your convenience, we may provide links to websites and other third-party content that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what Personal Data is collected and how it is used and/or shared. For more information on the types of third parties to whom we may disclose Personal Data, please see the How We Disclose Personal Data section above.

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable Data Protection Laws. Our Privacy Policy includes an “effective” date. The effective date refers to the date that the current version took effect.

Contacting Us

If you have any questions or concerns about this Privacy Policy, our data practices, or you would like to submit a request or appeal, please contact us at privacy@kairoi.com or contact us by post at 711 Navarro St No. 400, San Antonio, TX 78205. By continuing to use this website, you agree to our Privacy Policy.

Last Updated: June 15, 2025

Effective Date: June 15, 2025

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