Privacy Policy

HomeGuard Management LLC ("HomeGuard," "we," "us," or "our") is committed to protecting the privacy and personal information of property owners, tenants, applicants, website visitors, and all individuals who interact with our services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in connection with our property management services and our website at homeguardmanagement.com.

By using our website, submitting an application, signing a lease, or otherwise engaging with our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please discontinue use of our services and website.

HomeGuard Management LLC is headquartered at 2110 Willey Avenue, Cleveland, Ohio and operates in compliance with all applicable federal, state, and local privacy laws, including but not limited to the Ohio Consumer Sales Practices Act (ORC Chapter 1345), the Fair Credit Reporting Act (FCRA), the Fair Housing Act, and the Gramm-Leach-Bliley Act (GLBA) where applicable.

We collect the following categories of personal information:

a. Tenant and Applicant Information - Full legal name, date of birth, and Social Security Number (for background and credit checks) - Current and previous addresses, rental history, and landlord references - Employment information, income verification, and pay stubs - Government-issued identification (driver's license, state ID, or passport) - Emergency contact information - Vehicle information (make, model, license plate) where required - Housing Choice Voucher (Section 8) documentation, voucher size, and Housing Authority contact information

b. Property Owner and Investor Information - Full legal name and business entity information - Tax identification numbers (EIN or SSN) for 1099 reporting - Bank account information for direct deposit of rental proceeds - Property addresses, deed information, and insurance documentation - W-9 forms and tax-related documentation

c. Website and Digital Information - IP address, browser type, device information, and operating system - Pages visited, time spent on pages, and referring URLs - Cookies and similar tracking technologies (see Section 9) - Information submitted through contact forms, applications, and inquiries - Job application data including resumes, cover letters, and employment history

d. Communication Records - Phone call recordings (see Section 6) - Email correspondence - Text messages and SMS communications - Chat and messaging platform communications - Maintenance request submissions and work order communications

We use personal information for the following purposes:

• Tenant Screening: Conducting background checks, credit checks, eviction history searches, and employment/income verification through authorized third-party screening services in compliance with the Fair Credit Reporting Act (FCRA)
• Lease Administration: Preparing, executing, and managing lease agreements; processing rent payments; handling security deposits; and managing lease renewals or terminations
• Property Management Operations: Coordinating maintenance and repairs; scheduling inspections; managing vendor relationships; and ensuring property compliance with housing codes
• Financial Management: Processing owner distributions; preparing monthly financial statements; managing accounts payable and receivable; and generating year-end tax documentation (1099s)
• Section 8 / Housing Choice Voucher Compliance: Coordinating with local Housing Authorities; managing Housing Assistance Payment (HAP) contracts; facilitating property inspections; and ensuring compliance with HUD regulations
• Legal Compliance: Fulfilling obligations under Ohio Landlord-Tenant Law (ORC Chapter 5321), fair housing laws, tax reporting requirements, and court proceedings including evictions
• Communication: Responding to inquiries, sending notices, providing maintenance updates, and delivering important property-related information
• Quality Assurance and Training: Reviewing recorded calls and communications to improve service quality and train personnel
• AI-Assisted Operations: Utilizing artificial intelligence systems to improve operational efficiency (see Section 7)
• Website Improvement: Analyzing website usage patterns to improve functionality, content, and user experience

We may share your personal information with the following parties and under the following circumstances:

• Property Owners and Investors: Tenant information relevant to their property, financial reports, and occupancy data
• Tenant Screening Services: Credit bureaus and background check providers (TransUnion, Experian, Equifax, or similar services) for applicant screening
• Housing Authorities: Tenant and property information required for Housing Choice Voucher (Section 8) program administration, inspections, and HAP contract compliance
• Government Agencies: Information required by law, including tax authorities (IRS, Ohio Department of Taxation), housing code enforcement, building inspectors, health departments, and law enforcement agencies
• Legal Proceedings: Information necessary for court proceedings, including eviction filings, collections, disputes, and compliance with lawful subpoenas or court orders
• Service Providers and Vendors: Maintenance contractors, attorneys, accountants, insurance companies, and technology service providers who assist in our operations, subject to confidentiality obligations
• Financial Institutions: Bank account information for processing payments and direct deposits
• Emergency Services: Information necessary to protect the health and safety of tenants, property, or the public

We do not sell personal information to third parties for marketing purposes.

HomeGuard Management LLC conducts tenant screening through authorized consumer reporting agencies in strict compliance with the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq.

Screening may include: - Credit reports and credit scores - Criminal background checks (subject to HUD guidance on criminal records and fair housing) - Eviction history searches - Employment and income verification - Rental history and landlord reference checks - Sex offender registry checks

Your Rights Under the FCRA: - You have the right to know if information in a consumer report has been used against you - You have the right to know what is in your file at any consumer reporting agency - You have the right to dispute incomplete or inaccurate information - Consumer reporting agencies must correct or delete inaccurate, incomplete, or unverifiable information - You may seek damages from violators in court

If an adverse action is taken based in whole or in part on information obtained from a consumer report (including denial of a rental application), you will be provided with an Adverse Action Notice identifying the consumer reporting agency that supplied the report, along with your rights to obtain a free copy of the report and to dispute its accuracy.

HomeGuard Management LLC records and monitors telephone calls to and from our office for the following purposes:

• Quality assurance and service improvement
• Staff training and performance evaluation
• Dispute resolution and documentation of verbal agreements
• Compliance verification and regulatory purposes
• Safety and security

Legal Basis: Ohio is a one-party-consent state under ORC §2933.52, meaning that recording is permitted when at least one party to the conversation consents. By calling HomeGuard Management LLC or receiving calls from us, you are informed that calls may be recorded. Continued participation in the call constitutes acknowledgment of this practice.

Retention: Call recordings are retained for a minimum of two (2) years or as otherwise required by applicable law, legal proceedings, or regulatory requirements. Recordings are stored securely and access is limited to authorized personnel.

Your Rights: You may request to not have your call recorded, in which case you may be directed to communicate via email or written correspondence.

HomeGuard Management LLC utilizes artificial intelligence (AI) and automated technologies to enhance the efficiency and quality of our property management services. These technologies may be used in the following areas:

• Communication Assistance: AI may assist in drafting, summarizing, or responding to communications including emails, maintenance requests, and tenant inquiries. All AI-assisted communications are reviewed and approved by HomeGuard personnel before being sent
• Data Analysis: AI tools may be used to analyze financial data, market trends, property performance metrics, and operational data to provide property owners with insights and recommendations
• Maintenance Scheduling: Automated systems may assist in prioritizing and scheduling maintenance requests based on urgency, availability, and property needs
• Document Processing: AI may be used to extract, organize, and process information from documents including lease agreements, applications, invoices, and financial statements
• Website Chatbot and Virtual Assistance: Our website may employ AI-powered chatbots to provide immediate responses to common inquiries

Important Disclosures: - AI systems do not make final decisions regarding tenant applications, lease approvals or denials, eviction proceedings, or security deposit dispositions. All such decisions are made by qualified HomeGuard personnel - AI-generated content or analysis is subject to human review and oversight - We do not use AI for automated decision-making that produces legal effects or similarly significant effects on individuals without human intervention - Our AI vendors are subject to confidentiality and data protection requirements

If you have questions about our use of AI technology, please contact us at leasing@homeguardmanagement.com.

HomeGuard Management LLC implements administrative, technical, and physical security measures to protect personal information, including:

• Encryption of sensitive data in transit (TLS/SSL) and at rest
• Access controls limiting data access to authorized personnel on a need-to-know basis
• Secure password policies and multi-factor authentication for staff accounts
• Regular security assessments and monitoring of systems
• Secure document storage and disposal procedures (shredding for physical documents)
• Vendor security requirements and data processing agreements
• Employee training on data privacy and security best practices

While we take reasonable precautions to protect your information, no method of electronic transmission or storage is 100% secure. In the event of a data breach affecting your personal information, we will notify you in accordance with Ohio data breach notification requirements (ORC §1349.19) and applicable federal law.

Our website uses cookies and similar technologies to:

• Enable essential website functionality (session management, security)
• Remember your preferences and settings
• Analyze website traffic and usage patterns (via analytics services)
• Improve website performance and user experience

Types of Cookies Used: - Essential Cookies: Required for basic website functionality; cannot be disabled - Analytics Cookies: Help us understand how visitors interact with our website - Functional Cookies: Remember your preferences for a better experience

You may control cookies through your browser settings. Disabling certain cookies may affect website functionality. We do not use cookies for targeted advertising.

We retain personal information for the following periods:

• Tenant Records: For the duration of the tenancy plus seven (7) years after lease termination, or as required by law
• Rental Applications (Approved): For the duration of the tenancy plus seven (7) years
• Rental Applications (Denied): For a minimum of five (5) years in compliance with fair housing documentation requirements
• Property Owner Records: For the duration of the management agreement plus seven (7) years
• Financial Records: Seven (7) years in compliance with IRS record retention requirements
• Call Recordings: Minimum of two (2) years
• Website Data: As needed for analytics purposes, generally up to twenty-six (26) months
• Job Applications: Two (2) years from the date of application or last activity
• Section 8 / HCV Records: As required by HUD and the applicable Housing Authority, generally five (5) years after the end of participation

After the applicable retention period, records are securely deleted or destroyed.

Depending on applicable law, you may have the following rights:

• Right to Access: You may request a copy of the personal information we hold about you
• Right to Correction: You may request correction of inaccurate or incomplete personal information
• Right to Deletion: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs
• Right to Opt-Out of Communications: You may opt out of non-essential communications at any time
• Right to Dispute: Under the FCRA, you have the right to dispute information in your consumer report
• Right to File a Complaint: You may file a complaint with the Ohio Attorney General’s Office, the Consumer Financial Protection Bureau (CFPB), HUD, or other applicable regulatory agencies

To exercise any of these rights, please contact us using the information provided in Section 14.

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will take steps to delete such information.

HomeGuard Management LLC reserves the right to update or modify this Privacy Policy at any time. Changes will be effective upon posting to our website with an updated "Last Modified" date. We encourage you to review this Privacy Policy periodically. For material changes affecting current tenants or property owners, we will provide notice via email or written correspondence.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

HomeGuard Management LLC 2110 Willey Avenue Cleveland, OH 44113 United States of America

Email: leasing@homeguardmanagement.com Phone: +1 (216) 364-8008 Business Hours: Every day, 8:00 AM – 5:00 PM EST

For fair housing concerns, you may also contact: - HUD Fair Housing Hotline: 1-800-669-9777 - Ohio Civil Rights Commission: 1-888-278-7101