LEASING CENTRAL APP PRIVACY POLICY

APARTMENT INCOME REIT CORP.

1. Scope and Applicability

This Leasing Central Mobile application is provided by AIR Communities for internal business purposes and is accessible exclusively on company-issued mobile devices. By accessing or using the Leasing Central Mobile App, employees acknowledge that the collection, use, disclosure, and retention of personal information are governed by (i) AIR Employee and Staff Privacy Notice and (ii) AIR Workplace Monitoring Policy and Authorization and (iii) if applicable, the California Employee and Staff Privacy Notice, executed during onboarding or during employment (together, referred to as the "AIR Employee Privacy Policies"). This Leasing Central Mobile App Privacy Notice supplements—and does not replace or diminish - those governing documents. In the event of a conflict, the AIR Employee Privacy Policies control.

2. Information We Collect

We may display and collect the following categories of information:

a. Account Information

• Name, work email, job title
• Property/region assignment

b. Performance & Activity Data

• Lease activity, sales performance metrics
• Commission projected value and estimated payout
• Contest participation
• Leaderboard ranking
• Badge activity and engagement behavior

c. Device & App Usage Data

• Device type, OS version, IP address
• Login timestamps

3. How We Use Your Information

The data is used for legitimate business and operational purposes, including:

• Displaying your sales metrics, commissions, and performance insights
• Ranking you on leaderboards and contest standings
• Awarding and tracking achievement badges
• Communicating important updates, alerts, and reminders
• Conducting internal analytics to improve App functionality
• Ensuring compliance with leasing and HR policies

4. Data Sharing & Disclosure

Your data may be visible to:

• Your direct manager and regional leadership
• Authorized IT and system administrators
• Other leasing consultants and team members only in aggregated or competitive contexts (e.g., Leaderboard)
• No data is sold to third parties.

5. Data Security and Device Management

We implement administrative, technical, and physical safeguards, including:

• Encrypted storage and encrypted API transmission (TLS)
• Access controls and authentication protocols
• Activity logging and audit trails
• Periodic privacy and security reviews

The Leasing Central Mobile App operates within AIR's mobile device management and application protection framework (e.g., Intune + Okta), employing industry-standard technical and organizational measures.

6. Data Retention

Personal information processed through the LC Mobile App is retained only for as long as necessary to fulfill the purposes described herein or as required by law and internal policy. Retention and disposal are governed by AIR's Records Management Policy and the Employee Privacy Policy. Aggregated or de-identified operational metrics may be retained for longer periods for analytics and service improvement.

7. Your Rights

You may request:

• Access to view your data
• Corrections to inaccurate information
• Submitting concerns or complaints regarding data handling
• Requesting to have your data removed

Requests may be submitted via IT Support lcappsupport@aircommunities.com

8. Changes to This Privacy Policy

AIR may update this Leasing Central Mobile App Privacy Notice from time to time to reflect changes in law, technology, internal practices, or otherwise.

• Effective Date: 04/15/2026
• Last Update: 04/15/2026

9. Contact Information

For questions or concerns, please contact lcappsupport@aircommunities.com