Common Ownership Disclosure

You understand and acknowledge that in the course of providing services to you, we, CAMCO Management may presently or in the future, and at our sole and complete discretion, engage or utilize the services of vendors under common ownership or control with us. CAMCO Management and/or its affiliates may receive financial remuneration as a result of the engagement of any vendors under common ownership or control with it, in connection with any services it provides to you. We understand that such arrangements could potentially lead to a conflict of interest without adequate policies in place to allay such a possibility. To mitigate this, we have internal policies and procedures designed to ensure that any engagement of such vendors or contractors is in the best interest of our customers and does not compromise the quality or value-effectiveness of the services we provide. To see a listing of brands that may be under common ownership or control with us, please visit www.continuum-companies.com

CAMCO Management is an affiliate of Continuum Companies Inc.

Continuum Privacy Policy

Effective Date: January 15, 2024

Introduction:

Continuum (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy (this “Policy”) outlines how we collect, use, and disclose your personal information. Please read this Policy carefully to understand our practices regarding your data. By using our services,visiting our offices, or accessing our websites and mobile applications (collectively, the “Sites”), you agree to the terms of this Policy.

This Policy does not cover personal information collected from employees, independent contractors, or job applicants.

Definition of Personal Information:

For the purposes of this Policy, “personal information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It does not include publicly available personal information.

Notice at Collection: Personal Information We May Collect About You:

This section describes the categories of personal information we collect, including new categories as of January 15, 2024:

● Personal Identifiers:

  • Name, physical address, email address, phone numbers, and other contact
  • IP

● Professional Information:

  • Job title, name, and contact information of the employer or entity you
  • Status as a board member of your homeowner’s association or residential
  • Name and location of the homeowner’s association or residential community you
  • Association Tax ID, Bank Information, Bank Account Balances

● Audio and Visual Information:

  • CCTV recordings in public
  • Voice recordings of calls made to our customer service

● Internet or Other Electronic Network Activity:

  • Information regarding your browsing history, interactions with our Sites, and device

● Owner Information:

  • Lease information, Vehicle information, Owner balances, Homeowner Association Information, Engineering Reports, etc

● Tenant Information:

  • Lease Application Information, Lease information, vehicle information, pet information, Insurance policies, claims matters, legal collections matters, delinquency reports, etc.

Notice at Collection: Purpose for the Collection of Personal Information:

For each category of personal information, we collect and use data for the following purposes:

Provide Services on Behalf of Our Clients:

  • Management of facilities, public grounds, and common
  • Responding to requests and
  • Facilitating sales, leasing/rentals, and processing
  • Operating call-in
  • Compliance with applicable

Provide Additional Services:

  • Marketing and improving our
  • Compliance with applicable

Security and Fraud Prevention:

  • Fraud prevention and
  • Protecting our company, affiliates, clients, or

Compliance with Laws and Protection:

  • Legal and compliance
  • Responding to court orders or

Marketing and Recruiting:

  • Informing you about the Company and
  • Providing information about career

Communications:

  • Communicating about your account or our
  • Contacting you about your use of our

Debugging and Identifying Errors:

  • Debugging and identifying and repairing

Statistical Analysis and Research:

  • Statistical analysis and research

Use of Community Information:

  • Anonymized use of community information for data sales (opt-out available).

Notice at Collection: Categories of Personal Information We Sell or Share or Use for Targeted Advertising:

When engaging in digital advertising, we may sell or share the following categories of personal information or use them for targeted advertising:

Personal Identifiers:

  • IP

Internet or Other Electronic Activity Information:

  • Information used for cross-context behavioral

Information provided for Additional Service Packages to Vendors:

  • Data that may be included in service packages, and potentially sold, encompasses details related to in-unit services or homeowner associations. Service providers, including but not limited to management companies or contractors, may have access to this information as part of the service offerings.

To opt-out of such sales/sharing/targeted advertising, please click this link.

We do not sell or share other categories of personal information for targeted advertising.

Retention Periods:

We retain personal information for the duration necessary to provide services and comply with legal obligations.

Sources of Collection:

We collect personal information directly from individuals, employers, entities represented, or third- party references.

Use or Disclosure of Sensitive Personal Information:

We do not use or disclose sensitive personal information for profiling or purposes other than providing services.

No Profiling for Decisions with Legal Effects:

We do not engage in automated processing of personal information for decisions with legal or significant effects.

Disclosure of Personal Information For Business Purposes in the Past 12 Months:

In the last 12 months, we may have disclosed personal information to the following categories of third parties for business purposes:

● Personal Identifiers:

  • Service providers for CRM, IT, legal, and accounting

● Professional Information:

  • Service providers for CRM, legal, and accounting

● Internet or Other Electronic Network Activity Information:

  • Service providers for CRM, IT, and marketing

● Audio or Visual Information:

  • Service providers for CRM and legal

Business Purposes for Such Disclosures:

We disclose personal information to manage customer accounts, process payments, engage in advertising and marketing, operate IT systems, and obtain professional advice.

Additional Information About How We May Disclose Personal Information:

We may disclose personal information to comply with legal obligations, respond to court orders, protect against fraud, or in connection with business transfers.

Cookies and Other Tracking Technologies:

We use cookies and similar tracking technologies. Third parties may also set cookies for analytics, advertising, or other purposes. Refer to our “Cookies and Other Tracking Technologies” section for more details.

Personal Information of Minors:

Continuum’s services are not intended for individuals under the age of 13, and we do not knowingly collect personally identifiable information from anyone in this age group. If you are a parent or guardian and become aware that your child has provided personal data to Continuum, please contact us immediately. In the event that we discover that personal data has been collected from an individual under the age of 13 without proper parental consent verification, we will take prompt steps to remove that information from our systems.

In cases where we depend on consent as the legal foundation for processing personal information, and if your country requires parental consent, we may seek approval from your parent before

collecting and utilizing such information. Additionally, it’s important to mention that data related to minors might be provided during the property application process, but it will be promptly erased from our records. In specific situations, photo identification for minors, such as pool pass cards, may be generated; however, it’s crucial to note that this information is not stored.

Do Not Track:

Do Not Track (DNT) is a privacy preference that you can set in your web browser to inform websites that you do not want your online activities tracked. Our website currently does not respond to Do Not Track signals. For more information on Do Not Track, and how to enable this preference, you can visit donottrack.us.”

Security:

At Continuum, safeguarding the security of your personal data is our top priority. We employ reasonable security practices, encompassing both technical and physical safeguards, to protect your personal data from unauthorized access, misuse, and disclosure. However, it’s important to acknowledge that despite these security measures, it’s impossible to completely eliminate all risks of loss, misuse, alteration, or unauthorized access or disclosure of personal data. As such, we cannot provide an absolute guarantee of security.

Third Party Sites / Social Media Buttons:

Third-party services advertised on our Sites may have different privacy policies. We do not endorse or guarantee third-party services. Your interactions with third-party websites are governed by their respective privacy policies.

US State Data Privacy Rights:

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. This section provides information to those persons as a supplement to the information generally provided in this privacy notice.

In connection with your state rights, you should know that we do not “sell” or “share” personal information as defined by applicable state laws. We also do not create profiles using your personal information or use profiling in furtherance of decisions that produce legal or similarly significant effects.

California consumers may have the following rights under the California Consumer Privacy Act (CCPA):

  • To request that we disclose what information we collect, use, or disclose about
  • To know the specific pieces of information we hold about
  • To request the deletion of your personal information, with some

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal
  • Access and delete certain personal
  • Data

Colorado, Connecticut, and Virginia also provide their state residents with right to correct inaccuracies in their personal information.

The below list shows you where to find details about the information to which you may be entitled under the CCPA:

  • Categories of personal information collected: see “Types of Data Collected”; “Tracking Technologies & Cookies”
  • Categories of sources from which we collected personal information: see “Types of Data Collected”; “Tracking Technologies & Cookies”
  • The business purpose for which we collected your personal information: see “Use of Your Personal Data”; “Tracking Technologies & Cookies”
  • Categories of information shared or disclosed to third parties, and the categories of third parties to which we shared or disclosed that information: see “Use of Your Personal Data”; “Tracking Technologies & Cookies.”

To exercise any of these rights, please contact us using the details below in “Contact Us.”

Access & Choice

We acknowledge that you have the right to access Your Personal Data. Upon request, Continuum will provide individuals the opportunity to, under certain circumstances, correct, amend, update, or delete that information or limit the uses and disclosures of that information. A request may be

denied under certain circumstances, such as where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of the persons other than the individual would be violated. For requests to access, correct, modify, delete, or limit uses or disclosures of Your Personal data, please contact us using the information in the “Contact Us” section below. Requests will be addressed within a reasonable timeframe.

Accessibility Policy:

Continuum is committed to ensuring accessibility for people with disabilities. For accessibility- related requests or reporting barriers, contact us at Info@continuum-companies.com.

Contact Us:

If you have questions about this Privacy Policy or wish to request a copy in another format, contact us at: Privacy@continuum-companies.com.

Conflict of Interest Policy and Statement

of CONTINUUM Companies, Inc. and Affiliated Brands

Article I – Purpose

  1. CONTINUUM Companies, Inc. (CONTINUUM) is committed to maintaining integrity and transparency in its business operations, especially regarding the engagement of vendors or contractors under common ownership or control. In line with that commitment, this is an internal conflict of interest and competitive pricing policy to address and mitigate potential conflicts of interest and ensure that our pricing practices are competitive and This policy outlines the procedures and guidelines to ensure transparency and fairness in our dealings with customers.
  2. The purpose of this policy is to govern disclosures of potential conflicts of interest that may arise within CONTINUUM and its portfolio companies when engaging Affiliated Brands that are part of CONTINUUM’s corporate structure or under the direct or indirect control of CONTINUUM or its executives.

Article II – Definitions

  1. Affiliated Brands. Any company that is under common ownership by CONTINUUM (intermittently phrased as affiliated companies, affiliated entities, or portfolio companies).
  2. Material Any relationship between CONTINUUM and its portfolio companies or between CONTINUUM and external entities or individuals that could influence business decisions. This includes relationships that involve common ownership, financial interests, or family ties.
  3. Market-Based Pricing. The pricing of services or goods that is consistent with the current market value as determined by regular analysis of what other businesses charge for similar services or goods within the same industry and geographic region.
  4. Competitive Bidding. A procurement process where several vendors or contractors are invited to submit bids for the opportunity to fulfill a contract for services or goods. The process is initiated to ensure that CONTINUUM obtains the best possible price by fostering
  5. Conflict of Interest. A situation in which an individual or entity has competing interests or loyalties. A conflict of interest arises when individuals within CONTINUUM or its Affiliated Brands face a situation where personal and/or corporate interests, personal and/or corporate relationships, or financial gains could potentially conflict with fiduciary duties to the company or duties to its customers. This includes but it expressly not limited to scenarios where a CONTINUUM-owned property management company may choose to hire a maintenance or service company that is also under the umbrella of CONTINUUM-owned
  6. Authorized Individuals or a group within CONTINUUM or an Affiliated Brand who are given the power or authorized to make decisions on behalf of CONTINUUM or an Affiliated Brand. This typically includes officers, members of the board of directors, or any committee members vested with decision-making authority by CONTINUUM’S board or CEO.
  7. Formal Written Action. A documented decision or policy change that is recorded in writing and requires approval or ratification by authorized persons within CONTINUUM.
  8. Officer or Executive. A person holding a position of authority within CONTINUUM, such as a President, Vice President, Chief Executive Officer, Chief Financial Officer, Chief Investment Officer, Treasurer, Secretary or any other position designated as an officer of the company by the board of directors.

Article III – Disclosure and Transparency

  1. CONTINUUM is dedicated to upholding transparency and fostering trust with our As part of our commitment to this principle, CONTINUUM will provide notice of potential material connections with affiliated companies. This notice will not only be accessible through a disclosure on CONTINUUM’s official website but may also be included in an annual notice to our customers. This annual notice can be enclosed with periodic invoicing, proposals, management reports, website updates, and/or management contracts ensuring that all customers are generally well-informed about the relationships between CONTINUUM and its affiliated entities. Through this dual approach, we aim to provide our customers with easy access to relevant information, thus enabling them to make informed decisions regarding our services.

Article IV – Scope

  1. This policy applies to all transactions and arrangements entered into by CONTINUUM or its portfolio companies, particularly those involving vendors or contractors under common ownership or control with CONTINUUM or its executives.
  2. This policy applies to all employees, officers, and directors of CONTINUUM, and its Affiliated Brands encompassing all transactions, especially those involving vendor selection and customer
  3. This policy is intended to supplement, but not replace, any applicable state and federal laws governing conflicts of interest and competitive

Article V – Conflicts of Interest

  1. The Commitment. To safeguard the integrity of CONTINUUM’s operations and maintain the trust of our customers by preventing collusion, price fixing, and any actions that may mislead or confuse customers or misrepresent costs and services.
  2. Disclosure Policy. In connection with any actual or possible conflict of interest, any CONTINUUM employee or agent should disclose verbally or in writing to an Authorized Person the existence of the potential conflict and, specifically, indicate whether the conflict:
  3. amounts to misrepresentation, b. is likely to cause customer confusion, or c. affects a public interest.
  4. Further Actions: In the event that a conflict of interest is either undisclosed or materially mismanaged, CONTINUUM will evaluate the applicability of corrective measures as outlined in the employee manual guidelines, which are to be followed in the ordinary course of

Article VI – Vendor Selection and Pricing

  1. Vendor Selection. All vendor selection decisions will adhere to objective criteria, ensuring that the chosen vendors display standards of quality, offer value-based solutions, possess the necessary expertise, and align with the commercially reasonable needs of our customers. This approach applies equally to all vendors, including those with potential common ownership or affiliations with CONTINUUM or its For vendors that share common ownership or are controlled by CONTINUUM, its affiliates, or employees, a thorough evaluation process will be enacted. This process mandates that such vendors present appropriate licensing (where applicable) and insurance coverage. Additionally, their selection will be contingent upon a demonstrated capacity to fulfill the requirements of the specific project or service, assessed without preferential treatment based on the existing relationship. We aim to eliminate unnecessary partiality in vendor relationships and to ensure that every decision is predicated upon merit and the value offered to our customers. Through this policy, CONTINUUM assures that all vendor engagements are conducted with professionalism and ethical consideration, reflecting our commitment to upholding the interests of our customers and stakeholders.
  2. Market Pricing. CONTINUUM is committed to ensuring that pricing by CONTINUUM and its Affiliated Brands is aligned with the commercially reasonable range of market standards and reflects the current range of market Regular market analysis will be a cornerstone of our pricing strategy to maintain transparency and fairness in our pricing. This ongoing process will ensure that our fees for services are consistently within a commercially reasonable range compared to prevailing market rates. Our focus on market analysis is central to our commitment to providing fair and competitive pricing to our customers.
  3. Competitive Bidding. Competitive bidding processes may be utilized at the sole discretion of CONTINUUM and its Affiliated Brands, which may include careful assessments of project scopes, taking into account factors like the scale of the project or its strategic value, available customer bidding policies, when such a process is considered essential to be considered to provide services or products. This process reinforces our commitment to accountability and transparency in our pricing strategies.

Article VII – Enforcement

  1. In the event that a conflict of interest is identified per Article II Section 5 of this policy, an officer or executive of the Affiliated Brand may draft a detailed written explanation of the deviation to the customer. This document may articulate the nature of the transaction, explain the reasons for the deviation, and provide a brief summary of the contemplated transaction arrangement for the customer’s review and ratification; provided that, such a summary may be in the form of an invoice, email, or purchase order form.

Article VIII – Policy Review and Update

  1. This policy is dynamic and will be reviewed periodically at the sole discretion of CONTINUUM to reflect changes in business practices, legal requirements, or market conditions. Any amendments to the policy will be communicated promptly to all relevant parties.

Article IX – Policy Implementation

  1. CONTINUUM will ensure that all applicable employees and affiliates are trained on this policy and understand the importance of its Those designated as Authorized Persons will oversee the implementation of this policy.