Recruitment Privacy Policy for Heritage Hill 

Effective date: 08/11/2025

Heritage Hill (“we,” “our,” or “us”) is an investor-focused real estate and property-management company, recruiting personnel to support various operations for our core office and properties in Ohio (OH) and Missouri (MO). This policy explains how we collect, use, share, store, and protect personal information in connection with our recruitment and hiring activities, and the rights you have regarding that information. It also covers our recruitment-related texting and candidate communications.

1. SCOPE AND PURPOSE

· This policy applies to personal information we collect from job applicants, candidates, contractors, and other individuals participating in our recruitment processes.

· It covers data collected through our career pages, applicant portals, email, phone, in-person interviews, and third-party background-check providers.

· It includes recruitment communications via SMS/text messages and other direct messaging, with your consent where required.

2. DEFINITIONS

· Personal Information: Any information that identifies or could reasonably identify an individual (e.g., name, contact details, résumé, employment history, education, work authorization, screening results).

· Sensitive Personal Information: Data that requires special safeguards and consent (e.g., results from background checks, information about eligibility to work, health-related information provided for accommodations). We obtain such data only as permitted by law and with appropriate consent.

· Applicant/Candidate: An individual who applies for a position or is evaluated for potential employment.

· Processing: Any operation or set of operations performed on personal information (e.g., collection, use, storage, sharing, deletion).

3. WHAT WE COLLECT (CATEGORIES OF DATA): We may collect and process the following categories of personal information for recruitment purposes:

A. Identifiers and Contact Information

· Name, mailing and email addresses, phone numbers, date of birth, and other identifiers. B. Employment and Education Information

· Resume/CV, cover letter, work history, current and past employers, job titles, education, professional licenses, certifications, and references. C. Work Authorization and Compliance

· Eligibility to work in the United States, immigration status, tax IDs, and documents verifying eligibility to work (as permitted by law). D. Recruitment and Interview Data

· Interview notes, assessments, decision rationale, interview scheduling, and candidate communications. E. Background Screening Information

· Background check results, credit reports (where permitted and appropriate), eviction history, criminal history, and related documents obtained from authorized vendors, with your consent where required. F. Communications and Interactions

· Emails, SMS/text messages, chat transcripts, voicemail notes, and records of conversations with recruiters or hiring managers. G. Privacy and Preferences

· Preferences for how you wish to be contacted, consent for SMS text messaging, and opt-out choices. H. Other Data

· Any additional information you voluntarily provide during the recruitment process (e.g., portfolio, driving record, drug-testing results if required by policy and law).

4. HOW WE COLLECT DATA

· Direct from you: when you apply, submit forms, upload documents, or respond to recruitment inquiries.

· From third parties: background-screening providers, references, government or regulatory agencies as allowed by law.

· Automatically: via our career portals and related platforms (e.g., cookies or analytics on our recruitment sites).

· From public or semi-public sources where permitted by law (e.g., professional networks, resume databases).

5. HOW WE USE PERSONAL INFORMATION: We use personal information to:

· Evaluate and select applicants for current and future opportunities.

· Verify identity, work authorization, and qualifications; conduct background checks as permitted by law and with your consent.

· Schedule interviews, communicate with candidates, and provide status updates.

· Comply with legal and regulatory obligations (e.g., pre-employment screening disclosures and recordkeeping).

· Communicate recruitment-related information, including reminders and offer communications.

· Maintain records for equal opportunity employment reporting and compliance (to the extent permitted by law).

6. LEGAL BASES FOR PROCESSING

· Consent: Where required (e.g., consent for background checks, SMS recruitment communications, or processing sensitive data).

· Contractual necessity: Processing needed to evaluate applicants for employment.

· Legitimate interests: Recruitment-related activities, improving our hiring process, and ensuring safety and compliance.

· Compliance with law: Adherence to applicable employment, labor, and data protection laws.

· For background checks and related screenings: We comply with the Fair Credit Reporting Act (FCRA) and applicable state laws; we obtain written authorization and provide required notices and disclosures.

7. BACKGROUND CHECKS AND PRE-EMPLOYMENT SCREENING

· We may conduct background checks and screenings with your consent and in compliance with FCRA and applicable state laws (including OH and MO).

· If a background check is used to make an adverse decision, we provide a copy of the report and a copy of any required “pre-adverse action” and “adverse action” notices, and provide information on how to dispute the findings with the reporting agency.

· You may request a copy of the background report and provide a copy of any findings to you upon request.

8. SHARING AND DISCLOSURE OF PERSONAL INFORMATION: We may share your information with:

· Hiring team members and decision-makers involved in the recruitment and hiring process.

· Background-check vendors and other service providers necessary to conduct screenings (subject to confidentiality agreements and legal requirements).

· Government authorities or regulatory bodies as required by law.

· Affiliated entities and, if applicable, during corporate transactions (e.g., mergers or acquisitions) with appropriate protections.

· We do not sell candidate information to third parties.

9. INTERNATIONAL TRANSFER OF DATA

· We may transfer candidate information to service providers and affiliates in other jurisdictions as needed to conduct recruitment activities. We rely on appropriate legal safeguards (contracts, data processing agreements, or other approved transfer mechanisms) when transferring data outside the United States.

10. DATA RETENTION

· We retain recruitment data for as long as necessary to evaluate applicants and to comply with legal requirements.

· Typical retention windows:

o Applicants who are not selected: usually 12 to 24 months from last substantive contact, unless you request deletion sooner or consent to longer retention for future opportunities.

o Applicants who are hired: data becomes part of personnel records and is governed by our employee records retention policy.

· After the retention period, data is securely deleted or anonymized.

11. DATA SECURITY

· We implement reasonable and proportionate security measures to protect candidate information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

· Security measures include access controls, encryption, secure storage, vendor risk management, and employee training.

· We cannot guarantee absolute security; in the event of a breach, we will comply with applicable breach notification laws.

12. CHILDREN'S PRIVACY

· We do not knowingly collect personal information from children under applicable minimum ages. If a parent or guardian believes their child has provided us with information, they should contact us to review and delete such data.

13. YOUR PRIVACY RIGHTS AND CHOICES

· Access and correction: You may request access to your recruitment data and request corrections if incorrect.

· Deletion: You may request deletion of your personal information, subject to legal rights and exceptions.

· Right to restrict processing: You may request to limit processing in certain circumstances.

· Data portability: You may request a copy of your recruitment data in a structured, commonly used format where applicable.

· Objection and withdrawal of consent: You may object to processing or withdraw consent where consent is the legal basis.

· Recruitment communications and messaging: You may opt out of marketing or non-essential communications; for SMS recruitment messages, you may stop text messages by following the STOP instructions in messages or by contacting us.

· Text messaging: We may text candidates to coordinate interviews, share status updates, and provide recruitment information. Replies STOP or opt-out instructions should be followed; standard messaging rates may apply.

· Do-not-sell or similar rights: If applicable in your jurisdiction, you may request restrictions; follow the opt-out methods described in this policy.

14. OHIO AND MISSOURI RECRUITMENT PRIVACY RIGHTS

· You have rights under applicable Ohio and Missouri privacy and employment laws (e.g., access, deletion, correction, data portability, and opt-out rights). These rights are subject to statutory limits and exemptions. For details, contact us using the details at the end of this policy.

15. COOKIES AND TRACKING TECHNOLOGIES (RECRUITMENT PORTALS)

· Our recruitment sites and applicant portals may use cookies or similar technologies to collect usage information. You can manage cookies via your browser settings or the portal’s preferences.

16. YOUR CHOICES AND HOW TO EXERCISE THEM

· Access, correction, deletion, and data portability requests: contact us using the methods below.

· SMS opt-out: use STOP in messages or contact us to opt out of recruitment texts.

· Withdraw consent: where consent is the basis for processing, you may withdraw it; withdrawal may affect our ability to process your application.

17. HOW WE PROTECT YOUR INFORMATION

· We maintain appropriate administrative, physical, and technical safeguards to protect personal information in our recruitment processes.

· We require service providers to protect data and to process it only as instructed.

18. CHANGES TO THIS POLICY

· We may update this Recruitment Privacy Policy from time to time. We will post the updated policy with the effective date and, where appropriate, provide notice by other means. Continued use of our recruitment services after changes constitutes acceptance of the revised policy.

19. HOW TO CONTACT US

· Heritage Hill

· Address: 8837 Chapel Square Drive Unit 1A, Cincinnati, Ohio 45249

· Phone: (513) 331-7804

· Email: recruiter@heritagehill.com

20. ADDITIONAL NOTES FOR TEXTING CANDIDATES (RECRUITMENT COMMUNICATIONS)

· We may use SMS/text messages to coordinate interviews, share status updates, and provide important recruitment information to applicants.

· By providing your mobile number and opting in, you consent to receive text messages from us. Messages may include reminders, interview details, and status updates.

· You may opt out at any time by replying STOP to a message or by contacting us using the channels listed above. Standard message and data rates may apply.

· We will not solicit highly sensitive information via text messages. If sensitive information is required, use secure channels or request a secure upload method.