The Residences at The Dallas EDITION

1. Introduction and Scope

Welcome to the website Privacy Policy (“Privacy Policy”) of The Residences at The Dallas EDITION ("we," "us," or "our"). We are committed to protecting the privacy and security of your personal information (defined below). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website located at https://editionresidencesdallas.com/ (the "Website") and submit information through our data-collection form.

This Privacy Policy applies to all visitors and users of the Website who are residents of Texas and is specifically designed to comply with the Texas Data Privacy and Security Act ("TDPSA"), Tex. Bus. & Com. Code §§ 541.001 et seq., as well as all other applicable Texas and federal privacy laws.

"Controller" means the legal entity that determines the purposes and means of processing personal data. Chalk Hill Development Partners, LLC acts as the controller for all personal data collected through this Website.

"Personal Data" means information that identifies, relates to, describes, or could reasonably be linked with an individual, including information that would allow reasonable inference or linkage to identify you. Personal data includes:

Identifiers and Contact Information:

Full name, first name, last name, nickname
Email address (personal or professional)
Postal address, street address, city, state, zip code
Telephone number (home, mobile, or business)
Account number or username

Online Identifiers:

Internet Protocol (IP) address
Device identifiers (UDID, IMEI, Android ID)
Cookie identifiers and similar tracking technology identifiers
Mobile advertising identifiers
Hashed or encrypted identifiers

"Personal Data" DOES NOT include:

De-Identified Information: Information that has been irreversibly de-identified through:

Removal or suppression of identifying elements that would directly identify you
Application of cryptographic techniques that make re-identification infeasible using publicly available means
Aggregation with other personal data such that you cannot be identified from the aggregated data

"Processor" or "Service Provider" means a legal entity that processes personal data on our behalf and according to our documented instructions and this Privacy Policy.

"Sensitive Personal Data" means a subset of personal data that includes:

Racial or ethnic origin
Religious or philosophical beliefs
Trade union membership
Genetic data
Biometric data processed for identification purposes
Health data
Data concerning sex life or sexual orientation
Precise geolocation data (within 1,850 feet)
Data of children under 13 years of age
Criminal convictions or offense data
Financial account data with access credentials

"Processing" means any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, transmission, erasure, or destruction.

By submitting your personal information through our Website, you acknowledge that you have read and understood this Privacy Policy.

2. Controller Information

For purposes of the TDPSA, we are the "controller" of your personal data, meaning we determine the purposes and means by which your personal data is processed. Our contact information is as follows:

Business Name: Chalk Hill Development Partners, LLC

Mailing Address: 2601 Olive Street, Suite 1420, Dallas, Texas 75201

Email Address: PRIVACY@KAIZENDP.COM

Phone Number: (214) 414-3810

Website: editionresidencesdallas.com

3. Personal Data We Collect

When you complete and submit our online form, we collect the following categories of personal data:

Full Name — first name, middle name (if provided), and last name;
Mailing Address — street address, city, state, zip code, and country;
Phone Number — home, mobile, or business telephone number; and
Email Address — personal or business email address.

We collect only personal data that is adequate, relevant, and reasonably necessary for the purposes described in this Privacy Policy, consistent with our obligations under TDPSA § 541.101(a)(1). We do not knowingly collect sensitive data (as defined by the TDPSA) through the website or your emails, including but not limited to precise geolocation data, racial or ethnic origin, religious beliefs, mental or physical health diagnoses, sexual orientation, citizenship or immigration status, genetic or biometric data, or personal data of a child under 13 years of age.

We do not collect personal data from individuals we know to be under the age of 18. If you believe we have inadvertently collected personal data from a minor, please contact us immediately using the contact information in Section 2 so that we can promptly delete such information.

4. Purposes for Which We Use Your Personal Data

We process your personal data only for the following disclosed purposes:

To respond to your inquiry, request, or submission made via email or through the Website form;
To communicate with you regarding products, services, or information you have requested;
To send administrative notices, confirmations, or updates related to your interaction with us;
To maintain and improve the quality of our Website and services;
To comply with applicable legal obligations, court orders, or regulatory requirements; and
To protect the rights, property, or safety of our business, our users, or others.

We will not process your personal data for purposes that are not disclosed herein without first obtaining your consent, as required by TDPSA § 541.101(a)(3).

4.1 How We Obtain Your Consent

Purpose Limitation Principle

We process your personal data only for the purposes disclosed in Section 4 of this Privacy Policy. If we want to use your personal data for a purpose not previously disclosed, we will first obtain your affirmative consent. For purposes of this Policy, "consent" means your affirmative, voluntary, and informed agreement to our processing of your personal data for a specific, disclosed purpose.

When you send an inquiry to us by email or submit our online form, you consent to us processing your personal data for the purposes listed in Section 4:

□ To respond to your inquiry or request
□ To communicate about products/services you've requested
□ To send administrative notices or confirmations
□ To maintain and improve Website quality
□ To comply with legal obligations
□ To protect rights, property, and safety

By submitting the email or form, you affirmatively consent to these primary purposes. Your submission constitutes explicit opt-in consent.

5. How We Share Your Personal Data

We do not sell your personal data to third parties. We may share your personal data with the following categories of recipients in limited circumstances:

5.1 Service Providers (Processors)

We may share your personal information with trusted third-party service providers ("processors") who assist us in operating the Website and delivering our services, including but not limited to email delivery services, customer relationship management (CRM) platforms, and IT support vendors. Processor Obligations

We maintain written contracts with each processor that explicitly require them to:

(a) Process Limitations

(b) Data Restrictions

Not sell your personal data (as defined by TDPSA § 541.001(2))
Not retain your personal data longer than necessary to perform contracted services
Not combine your personal data with information from other sources without our prior written authorization
Not disclose your personal data to sub-processors without our prior authorization

(c) Security and Confidentiality

(d) Data Subject Rights

Assist us in fulfilling your TDPSA rights requests (access, correction, deletion, portability, opt-out)
Return or delete your personal data within 30 days following termination of our contract or upon your written deletion request
Not claim independent rights to your personal data

(e) Compliance and Oversight

Current Processors

We currently use processors in the following categories:

Service Category | Typical Processor Functions |
Email/Communications | Sending transactional and informational emails |
CRM Platform | Storing and organizing contact information |
Web Hosting | Hosting the Website infrastructure |
Analytics | Analyzing Website usage and performance |
IT Support | Providing technical support and system maintenance |

We will update this list as our processor relationships change. For details about a specific processor or the data they access, contact our Privacy Office at privacy@kaizendp.com.

5.2 Legal and Regulatory Disclosures

We may disclose your personal data if required by law, regulation, court order, subpoena, or other legal process, or if we believe disclosure is necessary to protect our legal rights or the rights of others, prevent fraud, or comply with a judicial proceeding.

5.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transaction, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. We will notify you of any such change and your options, as required by applicable law.

We do not share your personal data for targeted advertising or profiling purposes without your prior consent.

6. Your Rights Under the Texas Data Privacy and Security Act

As a Texas resident, you have the following rights regarding your personal data under TDPSA § 541.051:

6.1 Right to Know / Right of Access

You have the right to confirm whether we are processing your personal data and to access that personal data.

6.2 Right to Correction

You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and the purposes for which it is processed.

6.3 Right to Deletion

You have the right to request that we delete personal data you have provided to us or that we have collected about you, subject to certain exceptions provided by law.

6.4 Right to Data Portability

You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity.

6.5 Right to Opt Out of Targeted Advertising, Sale, and Profiling

You have the right to opt out of the processing of your personal data for the purposes of: (a) targeted advertising; (b) the sale of personal data; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As noted above, we do not currently engage in these activities.

6.6 Right to Appeal

If we decline to act on your rights request, you have the right to appeal our decision. The appeal process is described in Section 7.3 below.

6.7 Automated Decision-Making and Profiling (TDPSA § 541.101(a)(6))

What Is Automated Decision-Making?

"Automated decision-making" means:

Using algorithms, artificial intelligence, or machine learning to process your personal data
Making a decision about you based solely on automated processing
That decision has legal effects (affects your rights/access to services) or similarly significant effects (affects your opportunities/benefits)

Controller does not use automated decision-making processes that produce legal effects or similarly significant effects concerning you. We do not:

✗ Use AI, algorithms, or machine learning to deny services
✗ Use scoring/profiling systems to make final decisions about you
✗ Make consequential decisions based solely on automated processing
✗ Use automated systems to determine eligibility or access

Our Website operates based on human review and individual assessment of your requests.

7. How to Exercise Your Rights

7.1 Submitting a Request

To exercise any of the rights described in Section 6, you may submit an authenticated request using one of the following methods:

Email: Send a written request to privacy@kaizendp.com with the subject line "Texas Privacy Rights Request";
Mail: Send a written request to Chalk Hill Development Partners, LLC, Attn: Privacy Officer, 2601 Olive Street, Suite 1420, Dallas, Texas 75201; or
Online Form: Complete the rights-request form available at https://www.dallaseditionresidences.com/consumer-rights.

To protect your privacy and security, we may need to verify your identity before fulfilling your request using commercially reasonable efforts. We will not require you to create an account with us solely to submit a rights request.

7.2 Response Timeline

We will respond to your authenticated request without undue delay and no later than 45 calendar days after receipt, consistent with TDPSA § 541.051(c). If reasonably necessary, we may extend this period by an additional 45 days, in which case we will notify you of the extension and the reason for the delay within the initial 45-day period. We will respond to each consumer's request free of charge at least twice per calendar year.

7.3 Appeals Process

If we decline to take action on your rights request, we will inform you of our decision and the reason for denial within the applicable response period. You may appeal our decision by submitting a written appeal to privacy@kaizendp.com with the subject line "TDPSA Rights Appeal." We will respond to your appeal within 60 calendar days of receipt. If we deny your appeal, we will provide you with an online method or written instructions to contact the Texas Attorney General to submit a complaint, as required by TDPSA § 541.053.

7.4 Authorized Agent

As of January 1, 2025, you may designate an authorized agent to submit requests on your behalf. An authorized agent may use a global opt-out technology, such as a universal opt-out mechanism (e.g., Global Privacy Control), on your behalf. We will process such signals in accordance with TDPSA § 541.055(e).

8. Data Security

We maintain reasonable and appropriate administrative, technical, and physical safeguards designed to protect your personal data from unauthorized access, disclosure, alteration, loss, or destruction, in accordance with TDPSA § 541.101(a)(2). These measures are proportionate to the volume and nature of the personal data we collect.

Our security practices include, but are not limited to:

Encryption of data in transit using industry-standard Transport Layer Security (TLS);
Access controls limiting personal data access to authorized personnel on a need-to-know basis;
Regular review of our data security practices and procedures; and
Contractual requirements imposed on third-party processors to maintain appropriate security safeguards.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

9. Data Minimization Commitment

Controller is committed to the principle of data minimization under the Texas Data Privacy and Security Act (TDPSA). We collect personal data only to the extent necessary and reasonable to accomplish the specific, identified purposes disclosed in Section 4 of this Privacy Policy. We retain personal data only for the duration necessary to fulfill those purposes and will securely delete or de-identify personal data that is no longer necessary.

No Indefinite Retention

We do not retain personal data indefinitely for:

Marketing purposes
Future contact without your renewed consent
Building customer profiles or behavioral data
Data sharing or aggregation with third parties
Any purpose beyond those explicitly listed above

If you do not engage with Controller for more than 180 days, we will delete your personal data unless you maintain an active service relationship with us.

Your Right to Deletion

You have the right to request deletion of your personal data at any time. To submit a deletion request:

Contact Information:

Email: privacy@kaizendp.com
Phone: (214) 414-3810
Mailing Address: 2601 Olive Street, Suite 1420, Dallas, Texas 75201

No Sale or Sharing of Personal Data

Controller does not sell, share, or disclose personal data to third parties for any purpose, including marketing, data brokerage, or targeted advertising. Your personal data is used solely to fulfill the purpose for which you provided itFactors we consider in determining retention periods include the nature and sensitivity of the data, the purposes for which it is processed, applicable legal requirements, and the potential risk of harm from unauthorized use or disclosure.

10. Non-Discrimination

We will not discriminate against you for exercising any of your rights under the TDPSA. We will not deny you goods or services, charge you different prices or rates, provide you with a different level or quality of goods or services, or suggest that you will receive any of the foregoing, solely because you exercised your privacy rights.

11. Cookies and Tracking Technologies

Our Website may use cookies, web beacons, pixels, or similar tracking technologies to enhance your browsing experience and to analyze Website usage. These technologies may collect certain information about your device and browsing behavior. You may control the use of cookies through your browser settings. Please note that disabling certain cookies may limit the functionality of our Website.

We do not use tracking technologies to process your personal data for targeted advertising or cross-context behavioral advertising without your consent.

12. Links to Third-Party Websites

Our Website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party websites you visit. This Privacy Policy applies solely to personal data collected by our Website.

13. Children's Privacy

Our Website is not directed to children under the age of 18. We do not knowingly collect personal data from individuals under the age of 13 without verifiable parental or legal guardian consent, in accordance with the Children's Online Privacy Protection Act (COPPA) and TDPSA § 541.101(a)(4). If you are a parent or guardian and believe we have collected personal data from a minor, please contact us immediately and we will promptly delete such information.

14. Updates to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where required, provide you with additional notice (such as a prominent notice on our Website or an email notification). We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Your continued use of the Website and submission of personal data after any changes to this Privacy Policy constitutes your acknowledgment of the revised Policy.

15. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your rights under the TDPSA, please contact us at:

Privacy Officer: General Counsel

Company: Chalk Hill Development Partners, LLC

Address: 2601 Olive Street, Suite 1420, Dallas, Texas 75201

Email: privacy@kaizendp.com

Phone: (214) 414-3810

We are committed to working with you to resolve any concerns about your privacy. If you are not satisfied with our response, you may file a complaint with the Texas Attorney General’s Consumer Protection Division at: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.