Privacy Notice

for Employees and Candidates for Employment

As required under the privacy notice and disclosure regulations promulgated by applicable data privacy laws and regulations, Jamestown, L.P. (“Jamestown”, “us” or “we”) is providing this notice to prospective and current employees in order to inform you of our privacy policies and practices with respect to your personal information, which is information that identifies, relates to, describes, or is capable of being associated with you or that could reasonably be linked to you (“Personal Information”).

By applying for employment or becoming an employee, you are permitting us to collect and process the Personal Information that you provide to us in the application and onboarding documentation, or that you otherwise provide to us, in accordance with this Privacy Notice in connection with your employment. Your use of other services or products offered by us may be subject to other terms and conditions. For example, if you invest in a Jamestown fund or register for our property-specific mobile apps or Wi-Fi network, we may collect other information in connection with such relationship. For purposes of this Privacy Notice, processing means and includes any operation or set of operations that are performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, erasure or destruction.

Personal Information Collection and Use

In connection with recruitment, screening, onboarding, and employment, we may collect and maintain certain Personal Information about our candidates and employees, such as:

• Identifiers (including your name, address, email address, date of birth, social security number, driver’s license number, passport number, permanent resident “green card” number, visa number, employee identification number, IP address, or other similar identifiers);
• Other information (including your signature, telephone number, copies of government issued identification, insurance policy number, bank account number, or any other financial information, and medical information or health insurance information as required to administer employment benefits);
• Characteristics of protected classifications under state or federal law (including race, color, citizenship status, national origin, ancestry, sex, sexual orientation, age, religion, creed, physical or mental disability, physical handicap, medical condition, marital status, veteran status, genetic information) if you chose to provide such information and/or the collection of such information is otherwise required by law or regulation;
• Commercial information (including records of personal property, such as information on your vehicle for onsite parking registration at our properties);
• Biometric information (including finger or hand prints or exercise data);
• Internet or other electronic network activity information (including browsing history, search history, your activity on Jamestown computer systems, IP addresses, email correspondence and instant messaging, and access control records);
• Geolocation data (including your physical location or movements, such as those shown by access control records);
• Audio, electronic, visual, or similar information (including security camera recordings at our properties and office locations, photographs, and audio/video recordings of meetings or calls);
• Professional and employment related information (including employment history, references, salary, hire and termination dates, job title and location, offer letters, performance evaluations and disciplinary information, training records, and separation agreements);
• Education information (if you include it in your resume or otherwise provide it to us);
• Marital status and information about your beneficiaries and emergency contacts (including names, social security numbers, phone numbers);
• Bank account number or other financial information (including payroll records and tax status information);
• Benefit elections and other health insurance information;
• Other information that may be collected in the course of job-related activities throughout your employment, such as securities transactions, outside business activities, social media activity, gift reports and political contributions disclosed by you and travel records for expense reimbursement; and
• Inferences drawn from any of the foregoing information to create a profile (reflecting your characteristics, psychological trends, intelligence, abilities, and aptitudes) with the exception of sensitive personal information.

We may collect Personal Information from the following sources:

• From you on your resume, in your employment application, your onboarding documentation (including federal and state tax forms, employee information form, direct deposit form), your benefit enrollment materials, and other forms and disclosures you complete in connection with your employment, or that you otherwise submit to us;
• Public searches (background checks, criminal records, bankruptcy searches, social media searches, etc.);
• Meetings and telephone conversations with you;
• Your supervisor, your prior employer, references, or other parties which become a part of your employment record;
• Activity logs for access control software and computer networks, systems or applications;
• Video recordings from onsite security cameras; and
• Your participation in wellness program activities.

We collect and process Personal Information for the following purposes:

• Recruitment and vetting of candidates for employment;
• Background checks;
• Onboarding and decisions about your continued employment or engagement;
• Developing and conducting training;
• Payroll and compensation;
• Travel and expense reimbursement;
• Administration of employment benefits;
• Responding to employment verification inquiries;
• Maintaining anonymized company diversity metrics;
• Reporting to appropriate government entities, including tax authorities and other governmental and regulatory agencies;
• Acting in compliance with our legal obligations, rights, and interests;
• Sending marketing or promotional communications relating to our business, products or services to you;
• Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and physical locations; and
• Preventing fraud, responding to legal process and government inquires, and complying with federal, state, and local laws, as well as regulatory requirements.

Personal Information Sharing and Disclosure

We may disclose such Personal Information to our affiliates and nonaffiliated third parties as permitted by law and in accordance with the agreements governing your employment, including:

• Accounting, legal, and tax preparation service providers;
• Benefit brokers and carriers, payroll processing services, recruiting and hiring services, and background screening service providers;
• Marketing, advertising, communications, training, infrastructure, and information technology service providers;
• Prospective employers, lenders or other parties that you may direct to contact us for employment verification; and
• For purposes of preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws.

If one of the foregoing service providers needs to access Personal Information to perform services on our and your behalf, they are only authorized to collect, use, disclose, and store the Personal Information as described in our contract with them, including requirements to maintain reasonable security procedures.

We do not sell your Personal Information to third parties, and we do not rent, or share your Personal Information with third parties for such third parties’ direct marketing.

Security

To protect your Personal Information from unauthorized access and use, we use security measures that comply with applicable law and industry standards. These measures include computer safeguards and secured files and buildings. We restrict access to Personal Information to those employees, affiliates, and agents who have a need to know the information to perform a business purpose. We maintain physical, electronic, and procedural safeguards reasonably designed to protect your Personal Information while it is within our control.

Retention and Disposal

The Personal Information may be stored in our technology systems or those of our service providers or in paper files. We will delete the Personal Information of candidates for employment one (1) year after the position has been filled. We will delete the Personal Information of employees ten (10) years after the date of separation or when you withdraw your consent or request erasure, unless we are legally required or otherwise permitted to continue to hold such information (for example, if necessary to assert or defend a legal claim or to comply with a legal or contractual obligation). Since we maintain our applications and systems to protect against accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or made unusable where deletion is not possible.

How to Access and Control Your Personal Information

Where appropriate and where required by applicable law, we will provide individuals with the right to access such individual’s Personal Information, the right to correct inaccurate Personal Information, the right to delete Personal Information, the right to know what Personal Information is being collected, the right to restrict the use of such individual’s Personal Information, the right to opt out of the sale of Personal Information, the right to limit the use of sensitive Personal Information as defined in section 1798.140 of the California Privacy Rights Act (“CPRA”), and the right of no retaliation following opt-out or exercise of other right.

You can exercise your rights with respect to your Personal Information by using the Online Web Form, contacting [email protected], or by calling +1 (888) 914-9661 and entering PIN: 773 067. To the extent we are processing the Personal Information based on your consent, you may withdraw such consent at any time, provided that such Personal Information is not required in connection with your employment. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.

If you do not wish to provide us with the Personal Information as required by the application and onboarding documents and applicable legal obligations and requirements, we could be prevented from complying with our legal obligations and therefore we may not be able to employ you.

Changes to This Privacy Notice

We may periodically modify this Privacy Notice and will promptly provide such updates to you via email or by otherwise distributing this to you as part of updates to our policies and procedures. We will keep prior versions of this policy which you may request via email to [email protected].

Contact Us

Your information is controlled by Jamestown, L.P. If you have any questions about this Privacy Notice, please direct your inquiry to Jamestown, L.P., 675 Ponce de Leon Avenue NE, 7^th Floor, Atlanta, Georgia, Attention: General Counsel, or via email to [email protected].

Last Updated: January 22, 2024