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Privacy Policy

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Last Updated: May 19, 2026

 

Carteret Management Corporation (“Carteret,” “we,” “us,” or “our”) is committed to protecting the privacy and security of personal information belonging to our tenants, applicants, prospective tenants, and other individuals who interact with us. This privacy policy (“Privacy Policy”) describes how we collect, use, disclose, retain, and protect personal information in connection with our property management operations, including our use of technology platforms and third-party service providers.

 

This Privacy Policy applies to Personal Information we collect through all channels, including in-person interactions at our managed communities, paper applications, our property management systems, when you visit our website https://www.carteretmanagement.com/ (the “Website”), through automated communication platforms such as the Elise A.I. Technologies Corp. artificial intelligence leasing and resident assistant services (“EliseAI”), our mobile applications (“Apps”) and any other ways you interact with us (collectively, the “Services”). This Privacy Policy does not apply to third-party websites, applications, or services that you may access through links we provide or that are otherwise connected to our operations. We encourage you to review the privacy policies of any third party before providing your Personal Information to them.

 

When we use the EliseAI platform to process your personal information, that processing is governed by a Data Processing Addendum between Carteret and EliseAI (the “DPA”), available at https://eliseai.com/dpa. The DPA requires EliseAI to protect your personal data in accordance with applicable data protection laws and limits how EliseAI may use the information it processes on our behalf.

 

BY USING THE SERVICES, YOU AGREE YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY IN ITS ENTIRETY. IF YOU DO NOT AGREE, DO NOT USE THE SERVICES.

 

As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you or your household, as that term is defined under applicable data protection laws. “Sensitive Personal Information” is a subset of Personal Information that is more sensitive in nature, and includes, but is not limited to, Social Security numbers, driver’s license numbers, financial account information, citizenship or immigration status, race, ethnicity, and biometric information. 

 

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We may collect the following categories of Personal Information from tenants, applicants, prospective tenants, household members, and other individuals in connection with our property management activities:
 

  • Personal Identifiers. We collect your full name, date of birth, Social Security number, driver’s license or state identification number, postal address (including current and previous residences), email address, telephone number, and signature.

  • Financial and Credit Information. We collect income and employment information, pay stubs, tax returns, bank statements, credit history and credit reports, records of rent payments and payment history, and information regarding any defaults or past-due balances.

  • Employment and Professional Information. We collect the name of your employer, job title, professional contact information, and employment history, which may be verified through third-party services in connection with your application.

  • Household and Demographic Information. We collect information about household composition, including the number and ages of household members, marital and family status, disability status, race, ethnicity, veteran status, and citizenship or immigration status. Certain categories of this information are collected as required by federal, state, and local affordable housing program requirements, including those administered by the U.S. Department of Housing and Urban Development (“HUD”) and applicable state housing finance agencies.

  • Criminal and Housing History. We may collect criminal background information and housing court records, which may be obtained from third-party screening and verification providers in connection with your application.

  • Residential History. We collect information about your previous residences, rental history, and prior landlord references.

  • Communications and Interactions. We collect the content of communications between you and our staff or automated systems, including emails, text messages, telephone calls (including calls handled by artificial intelligence voice technology), web chat messages, and in-person communications documented in your file. When you interact with our AI-powered leasing or resident assistant platforms, those communications are recorded and may be used to provide and improve services.

  • Internet and Electronic Activity Information. When you interact with our Website, online platforms, or the EliseAI services, we or our service providers may collect device information, IP addresses, cookie data, browsing and search activity, and other usage data.

  • Geolocation Data. We or our service providers may collect general geolocation data (such as the city where your device is located) based on your interactions with our platforms. Precise geolocation data may be collected if you use certain mobile applications, such as the EliseAI Maintenance App.

  • Audio, Visual, and Electronic Information. We may collect voice recordings from telephone calls handled through our AI voice technology or customer service interactions, photographs from government-issued identification documents provided in connection with your application or identity verifications, and video or photographic information captured in connection with self-guided tours at certain communities.

  • Biometric Information. In connection with certain services, such as identity verification or self-guided tours, our service providers (including EliseAI and its third-party vendors) may process biometric information, including photographs of your face, which may be used to uniquely identify you. Biometric identifiers are stored, transmitted, and protected using reasonable care and in a manner that is the same as or more protective than the manner in which other confidential information is stored, transmitted, and protected. Biometric identifiers are destroyed within a reasonable time following capture but no later than one year after the purposes of collection have expired, to the extent required by applicable law.

  • Education Information. We may collect education information that is not publicly available, such as enrollment or school records, financial aid and scholarship records, or student identification numbers, where relevant to affordable housing eligibility determinations or application processing.

  • . We or our service providers may draw inferences from Personal Information collected about you to create a profile of your preferences, characteristics, or behavior for purposes of communications, marketing on behalf of Carteret, or services delivery.

  • Sensitive Personal Information. Certain Personal Information we collect is considered sensitive under applicable law, including Social Security numbers, driver’s license numbers, financial account information, precise geolocation, citizenship or immigration status, race, ethnicity, disability status, and biometric information. We use Sensitive Personal Information only as reasonably necessary to provide our property management services, comply with applicable housing program requirements, process applications, prevent fraud, and ensure the safety and security of our communities.
     

2. SOURCES OF PERSONAL INFORMATION

We collect Personal Information from the following sources:
 

  • Directly from you, such as when you submit a rental application, sign a lease, submit a maintenance request, communicate with our staff or AI-powered platforms, make a rent payment, or otherwise interact with us by mail, email, phone, text message, web chat, or in person.

  • From our property management systems, including our RealPage OneSite property management software, which stores and processes tenant and applicant records.

  • From our AI-powered communication platforms, including EliseAI, which collects information from prospective and current residents through email, text message, phone call, web chat, and other means when communicating on our behalf regarding leasing, maintenance, renewals, and rent-related matters.

  • From third-party service providers, including tenant screening companies, consumer reporting agencies, credit bureaus, employment and income verification services, criminal background check providers, and other vendors to assist with the application and qualification process.

  • From government and public records, including publicly available information used to determine eligibility for affordable housing programs, such as area median income data.

  • From property owners, investors, and syndicators who may provide information relevant to the management and compliance of their communities.
     

3. COOKIES

We use cookies and similar technologies on our Website to ensure functionality, maintain security, and to understand how visitors interact with our Services. Cookies are small text files placed on your device when you visit a website, allowing it to recognize your device and store information about your preferences or past actions. We also use local and session storage, which store data locally on your device for security and functionality purposes.

 

Cookies We Use:

  • Strictly Necessary Cookies: These cookies are essential for the Website to function and cannot be disabled. They include session identifiers, security tokens that protect against cross-site request forgery, cookies that support Website rendering and performance measurement, and cookies that support load balancing and content delivery. Some of these are set by third-party providers, including Amazon Web Services and SiteWit, solely for infrastructure and functionality purposes. Strictly necessary cookies are generally session-based, though certain infrastructure cookies may persist for up to one week.   

  • Performance Cookies: These cookies help us understand how visitors interact with the Website by collecting information about traffic sources, user sessions, and browsing behavior. We use this data to analyze Website usage and improve performance.

  • Functionality Cookies: These cookies enable enhanced functionality and personalization, such as maintaining session consistency and remembering your preferences across visits.

  • Targeting Cookies: We use a targeting cookie to identify unique visitors and track sessions over time. This is a first-party cookie with a duration of approximately one year and one month.  

In some states, the use of cookies and tracking technologies may be considered “sharing” of Personal Information under applicable privacy law. For more information on your rights with respect to such sharing, please see Section 11.  

 

Third-Party Cookies.

Certain cookies are set by third-party service providers that assist us in operating and securing our Website, including Amazon Web Services (load balancing and firewall functions) and SiteWit (session management and content delivery). These providers may access information collected by their cookies in accordance with their own privacy policies. 

 

Managing Your Cookie Preferences.

You can manage or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may affect Website functionality. For more information about cookies, visit www.allaboutcookies.org.

 

Do Not Track Signals. Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Our Services do not respond to Do Not Track signals at this time.

 

4. HOW WE USE PERSONAL INFORMATION

We use Personal Information for the following purposes:

 

  • Property Management Operations. We use your Personal Information to process rental applications; conduct tenant screening (including credit, criminal background, employment, income, and rental history verification); execute and administer leases; manage rent collection and payment processing; coordinate maintenance and repair requests; manage lease renewals; communicate with you about your tenancy; and otherwise operate and manage our communities.

  • Regulatory and Program Compliance. We use your Personal Information to comply with federal, state, and local affordable housing program requirements, including those administered by HUD, state housing finance agencies, and other governmental authorities. This includes determining and verifying eligibility for affordable housing programs, completing required certifications and recertifications, submitting required reports for regulatory agencies, and conducting audits.

  • Affirmative Fair Housing Marketing. We use certain demographic and household information, including race and ethnicity, to develop and implement Affirmative Fair Housing Marketing Plans as required by HUD and applicable program requirements. This information is collected on a voluntary basis and is used solely for fair housing compliance and outreach purposes.

  • AI-Assisted Leasing and Resident Services. We use the EliseAI platform to communicate with prospective and current residents through automated email, text message, phone call (including AI voice technology) and web chat. These AI-powered services handle leasing inquiries, schedule appointments, follow up with prospective tenants, manage maintenance requests, facilitate lease renewals, and communicate with residents about rent payments. Information collected through these interactions is used to improve our Services. EliseAI may also use Personal Information to market and advertise properties to you on our behalf, including through profiling, which involves the automatic processing of your Personal Information to identify your preferences and interests.

  • EliseCollect Rent Communications. Our EliseCollect service uses email, text message, or voice calls to communicate with residents about rent payments, including sending rent statements or invoices, reminders of upcoming or past-due rent payments, instructions on how to make rent payments, and responding to resident inquiries about rent payments or rent statements. EliseCollect is a communication service only and does not include any activity to collect or attempt to collect any debt, directly or indirectly. EliseCollect does not include communications related to legal notices (including notices of default, demand, cure, termination, quit, or eviction), threats of legal action or dispossession or eviction, or legal interpretation or advice regarding the lease, rent payments, or rent statements. EliseCollect does not apply to residents who are in default on their rent or under their lease, residents against whom debt collection has commenced, residents who have refused to make rent payments, residents who are represented by an attorney with respect to rent payments, or residents who have withdrawn consent for or opted out of email, text message, or voice communications.

  • Debt Collection. We may share Personal Information with collection agencies to pursue the recovery of outstanding balances owed under your lease.

  • Legal and Compliance Purposes. We use Personal Information to comply with applicable laws and regulations; respond to legal process, subpoenas, and governmental requests; investigate and resolve disputes; exercise and defend legal claims; and protect our rights, property, and the safety of our residents and communities.

  • Service Improvement and Analytics. Our AI service providers may use Personal Information in aggregated and deidentified form to improve the functionality and performance of their services and technology.

 

5. THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

We may share your Personal Information with the following categories of third parties:
 

  • AI Leasing and Resident Assistant Provider. We share Personal Information with EliseAI, our AI-powered communication platform provider, which processes tenant and applicant data on our behalf in connection with leasing, maintenance, renewals, and rent-related communications. EliseAI collects and processes data from prospective and current residents through email, text message, telephone, and web chat. EliseAI may use Personal Information in aggregated and deidentified form for its own business purposes, including marketing and promotional activities, in accordance with the terms of our agreement and applicable law. To learn more about EliseAI’s privacy practices, please view their privacy policy.

  • Third-Party Compliance Vendors. We may share Personal Information with compliance service providers who assist us in meeting affordable housing program requirements, including eligibility verification, income certification, and regulatory reporting.

  • Tenant Screening Companies and Consumer Reporting Agencies. We may share Personal Information with screening companies and credit bureaus to conduct background checks, credit checks, employment verification, income verification, and rental history verification in connection with rental applications.

  • Collection Agencies. We may share Personal Information with collection agencies retained to recover outstanding debts owed under tenant leases.

  • Property Owners, Investors, and Syndicators. As a property management company, we manage communities on behalf of property owners. We share Personal Information with the owners, investors, and syndicators of the communities we manage as necessary for property oversight, reporting, financing, and compliance purposes. EliseAI may also share Personal Information with applicable property owners.

  • . We may share rent payment data with Esusu, a financial technology company, to facilitate rent reporting to credit bureaus and support residents’ credit-building opportunities. To learn more about Esusu’s privacy practices, please view their privacy policy.

  • Government Agencies and Regulatory Bodies. We share Personal Information with HUD, state housing finance agencies, and other governmental authorities as required by applicable affordable housing program regulations, including in connection with compliance audits, inspections, and required reporting.

  • . We share Personal Information with internal and external auditors who review our operations and compliance with applicable housing program requirements and financial reporting obligations.

  • Legal and Professional Service Providers. We may share Personal Information with attorneys, accountants, consultants, and other professional advisors as needed for legal, accounting, and advisory purposes.

  • Parties for Legal Purposes. We may disclose Personal Information to governmental authorities, law enforcement, or other third parties in response to legal process, subpoenas, court orders, or governmental investigations, or as necessary to protect our rights, property, or the safety of our residents, communities, or the public.

  • Parties You Access, Authorize, or Authenticate. When you access third-party services through our Services or through EliseAI’s platform (such as identity verification providers, employment or criminal history verification vendors, or payment processing services), your Personal Information may be shared with those third parties. Information provided to such third parties is subject to those third parties’ own privacy policies, and we encourage you to review the applicable third party’s privacy policy before providing information.

  • Parties in Connection with Business Transactions. In the event of a merger, acquisition, sales, financing, or other transfer of all or part of our business or assets, your Personal Information may be shared with or transferred to the acquiring or successor entity.

 

6. SALE AND SHARING OF PERSONAL INFORMATION

We do not sell your Personal Information in exchange for money or other valuable consideration. We do not share your Personal Information with third parties for those third parties’ direct marketing, cross-context behavioral advertising, or targeted advertising purposes.

 

7. RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide our property management services, comply with applicable legal and regulatory requirements, resolve disputes, enforce our agreements, and as directed by property owners. Applicable affordable housing program regulations may require that certain tenant records be retained for specified periods following the end of a tenancy or the conclusion of a compliance period. Upon the termination of our relationship with a service provider, we may request the deletion of Personal Information in accordance with our contractual rights.

 

8. DATA SECURITY

We implement reasonable administrative, physical, and technical safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration or destruction. Our service providers, including EliseAI, are contractually required to maintain information security programs consistent with prevailing industry standards and applicable laws, including the use of encryption for sensitive and private data.

 

Despite our safeguards and efforts to secure your information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee that unauthorized third parties will never be able to defeat our security measures or misuse your information. Transmission of Personal Information to and from our Services is at your own risk. If we become aware of a data breach affecting personal information, we will investigate and provide notifications to individuals and/or regulators as required by applicable law.

 

If we determine or reasonably suspect a security incident affecting the Website or Services, including unauthorized access, acquisition, or disclosure of personal information, we will investigate, contain, remediate, and where appropriate or required by law, report the incident and notify affected individuals and applicable authorities without undue delay. We will cooperate with law enforcement and may provide notice by email and/or on the Website, as permitted by law.

 

9. USE OF ARTIFICIAL INTELLIGENCE

Certain portions of our Services are powered by artificial intelligence and machine learning technologies provided by EliseAI. When you communicate with us by email, text message, telephone, or web chat, you may interact with an AI-powered virtual assistant rather than a human representative. These AI services are used to respond to leasing inquiries, schedule appointments, follow up with prospective tenants, communicate about maintenance requests, manage lease renewals, and communicate about rent payments. AI voice technology may be used on telephone calls, and such calls may be recorded. AI-assisted telephone calls will include a notification at the outset of the call advising the call may be recorded. By continuing the call after receiving this notification, you consent to the recording of the conversation. If you do not wish to be recorded, you may disconnect the call and contact our leasing office directly. Communications made through these AI platforms are collected and may be used to provide, improve, and train the underlying technology.

 

Consent for Automated Communications. By providing your telephone number, email address, or other contact information in connection with your lease, rental application, maintenance request, or other interaction with us, you consent to receiving automated communications from EliseAI on our behalf via email, text message, and voice call (including calls made using an artificial and/or AI voice and which may be sent using an automatic telephone dialing system) in connection with leasing, EliseCollect rent communications, maintenance (including via the Maintenance App, subject to the Maintenance App Terms and Conditions), and lease renewals. You may opt out of receiving such automated communications at any time by following the opt-out instructions provided in such communications or by contacting us at info@carteretmgmt.com.

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10. CHILDREN’S PRIVACY

Our Website and Services are intended for adults and are not directed at children under the age of 16. We do not knowingly collect Personal Information directly from children under 16. If we learn that we have collected Personal Information directly from a child under 16, we will take reasonable steps to delete that information promptly. If you believe that a child under 16 has provided Personal Information to us, please contact us at info@carteretmgmt.com with “Minor Data Collected Notification” in the subject line.

 

In the ordinary course of our property management and leasing operations, we collect information about minor children who are members of a tenant’s or applicant’s household. This information is provided to us by the child’s parent, legal guardian, or other adult household members and may include the child’s name, date of birth, age, Social Security number, and other information required for household composition verification, occupancy determinations, and compliance with applicable affordable housing program requirements administered by HUD and state housing finance agencies. The collection and use of this information about minor household members is necessary to administer leases, determine unit size eligibility, and fulfill regulatory obligations, and is not subject to the restrictions described in the preceding paragraph.

 

11. YOUR PRIVACY RIGHTS

Depending on your state of residence, you may have certain rights with respect to your Personal Information under applicable law, including:

 

  • Right to Know. You may have the right to request information about specific pieces of Personal Information we have collected about you, the sources from which we collect it, the purposes for which we use it, and the categories of third parties with whom we share it.

  • Right to Access. You may have the right to request a copy of the Personal Information we hold about you. 

  • Right to Correction. You may have the right to request that we correct inaccurate Personal Information.

  • Right to Deletion. You may have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions, including where retention is required by law or for compliance with affordable housing program requirements.

  • Right to Opt Out of Sale or Sharing. As stated in this Privacy Policy, we do not sell your Personal Information or share it for cross-context behavioral advertising purposes.

  • Right to Non-Discrimination. We will never discriminate against you for exercising any of your privacy rights.

Communication Opt-Out. You may opt out of receiving automated text messages, emails, or phone calls from our AI-powered communication platform by following the opt-out instructions provided in such communications or by emailing us at info@carteretmgmt.com. Please note that opting out of automated communications may affect our ability to communicate with you about time-sensitive matters related to your tenancy.

 

California Privacy Rights. California residents have the additional right to:

  • Know the categories of Personal Information we have collected, the categories of sources, the business or commercial purposes for collection or sharing, the categories of third parties to whom we disclose personal information, and the specific pieces of Personal Information we maintain about you;

  • Opt-out of the “sale” or “sharing” of Personal Information for cross-context behavioral advertising;

  • Limit the use and disclosure of Sensitive Personal Information to what is necessary to provide requested services (if applicable);

  • Have us honor GPC signals as a valid opt-out request; or

  • Receive information about financial incentives, if offered (we do not offer financial incentives at this time; if this changes, we will provide a Financial Incentive Notice describing the material terms and how to opt in).

 

Notice at Collection (California and similar laws).

We collect the following categories of personal information: Identifiers (e.g., name, email, IP address), Commercial Information (e.g., payment details, credit card information, and purchase or transaction history), Internet/Network Activity, General Geolocation Data, Biometric Information, Education Information, and Inferences. We collect these categories from you, your devices, our service providers, third parties, and affiliate partners for the purposes described in Section 4. We may disclose these categories to service providers and contractors for business purposes. We do not sell your Personal Information or share it with third parties for cross-context behavioral advertising or targeted advertising purposes. In some states, the use of cookies and tracking may be considered “sharing” of Personal Information under applicable privacy law; for more information see Section 3 above. We retain Personal Information for the periods described in Section 7.

 

“Shine the Light.” California Civil Code § 1798.83 permits California residents to request, once per year and free of charge, information about the categories of Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the prior calendar year and the names and addresses of those third parties. To submit such a request, contact us using the information in Section 16.

 

California Minors’ Content Removal. If you are a California resident under 16 and have an account on the Services, you may request removal of content you publicly posted by contacting us using the information in Section 16 and identifying the content. We will make the content no longer publicly visible on the Services, but complete removal (e.g., from caches or archives) may not be possible.

 

Financial Incentives. We do not offer financial incentives, price or service differences, or loyalty programs in exchange for personal information. If this changes, we will provide a Financial Incentive Notice describing the material terms, categories of Personal Information implicated, and how to opt in.

 

12. HOW TO REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

Under applicable law, you or someone legally authorized to act on your behalf (your “”), may make a request to access, correct or delete your personal information. You may, under applicable law, also make a request to know or delete Personal Information on behalf of your child (however, please note, we do not knowingly collect any Personal Information of anyone under the age of 16). Requests or exercise of your right(s) can be made by emailing us at info@carteretmgmt.com.

 

13. GOVERNING LAW

This Privacy Policy, and your access to and use of the Services, as well as any dispute, claim, or controversy arising out of or relating to them, will be governed by and construed in accordance with the laws of the State of Florida, without regard to conflict-of-law rules or principles (whether of Florida or any other jurisdiction) that would result in the application of the laws of any other jurisdiction. Any dispute between the parties that is not subject to arbitration or that cannot be heard in small claims court will be resolved exclusively in the state or federal courts located in Pinellas County, Florida and users of the Services consent to the personal jurisdiction and venue of those courts.

 

14. ​SEVERABILITY

If any part of this Privacy Policy is deemed unlawful and/or unenforceable, all other provisions contained herein will remain in full force and effect.

 

15. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy from time to time. The updated version will be indicated by the “Last Updated” date at the top of this Privacy Policy. Such updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. If the changes materially affect your rights, we will provide additional notice and, where required, obtain your consent.

 

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?​

 

We welcome your comments and questions regarding our privacy policy. If you have any questions about this Privacy Policy, or if you need this Privacy Policy in an alternative format due to a disability, please contact us at:

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Carteret Management Corporation

180 Fountain Parkway N., Suite 100

St. Petersburg, FL 33716

info@carteretmgmt.com

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