Effective Date: August 17th, 2026

This California Personnel Privacy Notice (“Notice”) describes how Vivmark and its affiliates, subsidiaries, and related entities (collectively, “Company,” “we,” “our,” or “us”) processes Personal Information of Company job applicants, employees, former employees, and independent contractors (“Personnel”) in various human resources contexts, including through our job application process. If you are not interacting with Company as Personnel, please see our Privacy Notice for disclosures relating to our consumer-facing website(s) and other services. This California Personnel Privacy Notice is provided pursuant to the California Consumer Privacy Act (the “CCPA”).

For purposes of this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available, deidentified, or aggregated information. Capitalized terms used but not defined in this Notice shall have the meanings given to them under the CCPA.

If you provide information about other individuals, such as emergency contacts, dependents or beneficiaries, to Company, you are responsible for obtaining their consent, as appropriate, and providing them with a copy of this Notice.

In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to Personnel who are California residents, unless stated otherwise.

We may update this Notice from time to time, as indicated by the “Effective Date” date at the top of this Notice. Any changes to this Notice will be effective as of the Effective Date at the top of this page, unless otherwise expressly indicated. We encourage you to review this Notice whenever you visit our careers site.

Unless otherwise stated, the description of our data practices in this Notice covers our current practices and our practices in the twelve (12) months prior to the Effective Date.

Contents

1. Collection of Personal Information


2. Use of Personal Information


3. Disclosure of Personal Information


4. Retention of Personal Information


5. California Personnel Rights


6. Contact Us

1. Collection of Personal Information

We may collect your Personal Information directly from you, such as when you apply for a position, from our careers websites with which you may interact, from our service providers who operate on our behalf, from other businesses or individuals (e.g., references), or from public sources of data, such as government databases or your public profiles.

We collect the following categories of Personal Information about Personnel. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all the examples below.

• • Identifiers, including real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.


• • Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, physical characteristics or description, Social Security number, address, telephone number, passport number, driver's license or state identification card number, financial information, education, employment, and employment history.


• • Characteristics of Protected Classifications Under California or Federal Law, including age, sex, sexual orientation, gender identity, marital status, military or veteran status, nationality, race, ethnic origin, citizenship or immigration status, familial status, medical condition, disability, age and date of birth, or religion or creed. We abide by the legal requirements imposed under applicable law when processing such Personal Information.


• • Commercial Information, records of products or services purchased or obtained in the human resources context, such as benefits you have signed up for or reimbursements for expenses.


• • Internet or Other Electronic Network Activity Information, including device identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, information regarding interactions with the careers site, browsing history, search history, and other information regarding your interaction with our systems or other sites, applications, including employee-provided applications, or content.


• • Geolocation Data, including approximate location of the device or equipment you are using or the location from which you are accessing our systems. If you use Company-owned equipment or devices or employee-provided applications, we may track the precise location of such equipment or devices.


• • Sensory Data, including video and audio recordings of interviews, photographs, security videos, and other electronic, visual, or similar information.


• • Professional or Employment Information, including:


• ° Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;


• ° Answers to behavioral or other screening questions in an application or interview;


• ° Information contained in any personal webpages or documents you choose to share with us;


• ° Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;


• ° Information relating to membership in civic organizations; and


• ° Human resources data for benefits and related administrative services.


• • Non-Public Education Information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education.


• • Inferences drawn from other Personal Information we process to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


• • Sensitive Personal Information, including social security, driver's license, state identification card, or passport number; account log-in in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; Personal Information that reveals your racial or ethnic origin, religious or philosophical beliefs, citizenship or immigration status, or union membership; Personal Information collected and analyzed concerning your health (i.e., drug-screening information); and Personal Information collected and analyzed concerning your sex life or sexual orientation.

As permitted by applicable law, we may convert your Personal Information into deidentified data or aggregate your information. We will not attempt to reidentify data that we maintain as deidentified.

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2. Use of Personal Information

We or our vendors may use the Personal Information described above for the following purposes:

• • Recruitment, including to open and maintain your application records, assess your eligibility for employment, and otherwise manage the recruitment process.


• • Managing Employment, including running background checks; performing employee intake, onboarding, and off-boarding; maintaining Personnel records; providing payroll and reimbursements; managing timekeeping; booking Personnel travel; administering benefits; managing employee activation initiatives and communications; facilitating diversity and inclusion programs; administering training and education programs; managing employee performance; compliance; and facilitating mandated reporting obligations.


• • Communicate With You, including regarding your application and the recruitment process.


• • Operate Our Business, including to facilitate your use of our careers website.


• • Maintain Security and Integrity (including electronic and on premises), including protecting our website from cyber risks; authenticating users; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other liabilities; enforcing our policies and terms; protecting our rights; fulfilling our legal obligations; and generally providing you with a secure experience when participating in the recruitment process.


• • Perform Quality, Safety, and Internal Research, including to improve our website, set default options, and provide you with a better recruitment experience.


• • For Legal and Compliance Purposes, including complying with applicable law, court order, governmental regulations, or other legal obligations; assisting in an investigation, regulatory requests, litigation, or arbitration; protecting and defending our rights and property, or the rights or safety of parties; enforcing our terms, policies, or any agreements with parties; complying with health and safety obligations; and preventing crime.


• • With your consent.

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3. Disclosure of Personal Information

We may disclose Personal Information for the purposes described above to the following parties:

• • Our group of companies, including our affiliates, subsidiaries, locations, and brands.


• • Agents, vendors, consultants, and other service providers so that they may provide their services to us, including for recruitment and hiring activities; payroll and other benefits; legal compliance; information technology and software support; background checks, drug testing, and other screening; record processing and data storage; and other business operations support.


• • Other parties at your direction or through your action.


• • Government or private parties, including to comply with law or legal process; respond to requests from public and government authorities; enforce our terms and conditions and other agreements; protect our operations and our rights, privacy, safety, and property or that of you or others; and allow us to pursue available remedies or limit the damages that we may sustain.


• • Our insurers, auditors, consultants, legal counsel, and other professional advisors, including to manage risk, exercise or defend against legal claims, and otherwise obtain professional advice.


• • Third Parties as part of or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other transaction where another party assumes control over all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

When job applicants visit our websites to apply for a job, we may Sell or Share Personal Information for Cross-context Behavioral Advertising for certain analytics, marketing, and advertising activities, including to show you relevant ads while you browse the internet or use social media. We do not Sell Personal Information in exchange for money, but some of the ways in which we Share Personal Information may be considered “Sales” under the CCPA.

• • We Share for purposes of Cross-context Behavioral Advertising the following categories of Personal Information: Identifiers; Personal Information described in Cal. Civ. Code § 1798.80(e); Internet or Other Electronic Network Activity Information; Geolocation Data (where permitted); and Inferences.


• • We have Shared for Cross-context Behavioral Advertising Personal Information to the following categories of third parties: advertising and marketing vendors and partners; analytics companies; social networks; third-party digital businesses; and other marketing and advertising services that we utilize on our Services.


• • We do not have actual knowledge that we Sell or Share for Cross-context Behavioral Advertising the Personal Information of Consumers under 18 years of age.


• • For information about opting out of Sales and Sharing for Cross-context Behavioral Advertising, please see our California Personnel Rights Section below.

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4. Retention of Personal Information

We retain Personal Information for as long as necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• • Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Information;


• • Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;


• • Personal Information is reasonably required to protect or defend our rights or property; or


• • Personal Information may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

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5. California Personnel Rights

(a)Exercising Your Rights

To submit a request to exercise your privacy rights, or to submit a request as an authorized agent, legacy-Equity Residential Personnel should use our HR and B2B Privacy Rights Request Form or call us at 1-866-869-5413 and/or legacy-AvalonBay Personnel should use our Privacy Web Form or call us at 1-833-605-4293 between the hours of 9 AM and 5 PM ET, Monday through Friday, and respond to any follow-up inquiries we make.

If you submit certain requests, we may request additional information to verify your identity, which may require you to log into your account or to provide 2-3 pieces of Personal Information that we will match against our records.

You may be able to designate an authorized agent to make certain privacy rights requests on your behalf. Such privacy rights requests may have to undergo our verification process, which includes verifying the identity of the agent and their authorization to make the request. An authorized agent may submit a request on your behalf using the form or toll-free number listed above.

If you need special accommodation, please let us know by contacting us through the information in our Contact Us Section below. Please be aware that we do not accept or process requests through other means (e.g., fax, chats, social media).

We will not discriminate or retaliate against you for your exercise of your privacy rights.

(b)Personnel Rights

As a California resident, you have the following rights related to your Personal Information:

• • Right to Know: You may have the right to know:


• ° The categories of Personal Information we have collected about you.


• ° The categories of sources from which we collected your Personal Information.


• ° The Business Purposes or Commercial Purposes for our collecting, or Selling, Sharing, or disclosing your Personal Information.


• ° The categories of third parties to whom we have Sold, Shared, or disclosed your Personal Information.


• ° The categories of Personal Information that we Sold or Shared, and for each category identified, the categories of Third Parties to which we Sold or Shared that particular category of Personal Information.


• ° The categories of Personal Information that we disclosed for a Business Purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.


• ° The specific pieces of Personal Information we have collected about you.


• • Right to Correct: You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate.


• • Right to Deletion: You may request that we delete your Personal Information.


• • Right to Opt Out of Sales and Sharing for Cross-Context Behavioral Advertising: If you are a job applicant and want to opt out of the Sale or Sharing of your Personal Information for Cross-Context Behavioral Advertising, please use our Cookie preference center by clicking the “Your Privacy Choices” link in the footer of the Services or in your App settings. Alternatively, you may use the Global Privacy Control browser signal to opt out of Cookie-based Sales and Sharing for Cross-Context Behavioral Advertising. Other than limited Personal Information that may be Sold or Shared for Cross-Context Behavioral Advertising when you visit our careers webpage online, we do not disclose Personnel Personal Information in a way that constitutes a Sale or Sharing of your Personal Information for Cross-Context Behavioral Advertising.


• • Rights related to Automated Decisionmaking Technology: We do not process Personal Information using automated decision-making technology to make significant decisions about you, so we do not provide a way to exercise these rights.


• • Right To Limit the Use and Disclose of Sensitive Personal Information: We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA, so we do not provide a way to exercise this right.

6. Contact Us

If you have any questions, comments, or concerns about our HR privacy practices, please contact us by email at [email protected] or [email protected].

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