Privacy Policy

Last Updated: November 11, 2025

This Privacy Policy describes the data privacy practices of AP Block 4001 Venture Urban Renewal LLC and its affiliated entities, including without limitation Starfield Management Inc., and its affiliated entities (collectively, “Company,” “We,” “Us, or “Our”) for the personal information collected when you (“You” or “Your”) visit Our website – https://www.surfhouseasburypark.com – or its component webpages and/or any other website made available by Us (collectively, the “Website”).

We value and respect Your right to privacy and Your right to understand how certain information that relates to You is being collected and used. This Privacy Policy describes the personal information We collect, how that information is used, when and why that information is shared, and what Your rights are regarding Your personal information.

We may share Your personal information internally with Our affiliated entities so that We can personalize Our interactions with You and provide You with the information and/or offers tailored to Your interests. We may also share Your personal information with Our third-party marketing partners.

By providing Your personal information to the Company, You consent and agree to the terms of this Privacy Policy, as well as the collection, use, and disclosure of information as set forth in this Privacy Policy.

IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS PRIVACY POLICY (INCLUDING ANY MODIFICATIONS THERETO), YOU SHOULD NOT PROVIDE ANY PERSONAL INFORMATION TO US AND SHOULD EXIT THE WEBSITE. HOWEVER, THIS PRIVACY POLICY WILL APPLY TO ALL OF YOUR INFORMATION AND ACTIONS PRIOR TO EXITING THE WEBSITE.

COLLECTION AND USE OF PERSONAL INFORMATION

What information do We collect?

We may collect and use the following categories of personal information:

• Individual identifiers and contact information – such as information that You provide for the purpose of registering with the Website or filling out a contact form (e.g., Your real name, email, address, telephone number, other contact information, username and password, and mobile phone number);
• Computer, internet and network activity information – such as information We obtain from Your use of the Website (e.g., server log information, queries or searches, browsing history, internet protocol address, unique device identifiers, and mobile network information);
• Other electronic information – such as information from communications with Us and other user-generated content submitted by You to Us through e-mail, chat, telephone, and social media channels; and
• Marketing and promotional information – such as information You provide for the purpose of enrolling or participating in any programs, promotions or contests, or rewards programs offered by the Company.

From whom and how do We collect personal information?

The Company and its authorized service providers, contractors, and third parties obtain these categories of personal information from the following sources:

• Directly from You. For example, the information You provide directly to Us or to Our authorized service providers and contractors (e.g., payment processors, property managers, leasing agents, etc.);
• Indirectly from You. For example, the information from devices You use to access the Website; or information that is automatically collected about You by Us and Our authorized service providers as a result of Your use of Our Website, including digital tracking tools such as cookies and similar technology; and
• Information obtained by third parties. For example, information obtained by third parties as a result of the use of Our Website and other websites.

For what purposes do We collect and use personal information?

The Company, on its own or through authorized service providers, contractors and third parties, may use Your personal information that You provide to Us or that is collected about You for various business or commercial purposes, including to:

• administer the Website and present the Website and its contents to You, as well as to facilitate and improve Your experience on the Website;
• process Your registration and manage Your online account;
• personalize the Website for You;
• enable Your access to use the Website and its services;
• send You advertising, promotional and marketing communications, including email;
• contact You or communicate with You;
• create analytic reports; and
• perform internal systems diagnostics, analysis, monitoring, debugging, and troubleshooting.

In addition, We may disclose Your personal information to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise, or defend Our legal rights. We may also disclose Your personal information in connection with negotiations for or any actual sale, acquisition, or transfer of all or a portion of Our business or assets.

Please note that if You voluntarily submit any personal information for posting on Our Website or any other website (including without limitation any social media website), the information may become publicly available and can be accessed and used by Us and by others. Therefore, You should use care before posting any personal information online.

We do not sell or share Your personal information in exchange for money. We may share Your personal information with Our third-party marketing partners for marketing, advertising and related purposes.

OTHER INFORMATION COLLECTED
The Company, on its own or through authorized service providers, contractors and third parties, may also collect and use other information from and about users of the Website that does not specifically identify the user individually. Without limitation, this may include:

• preferences information (including marketing and communication preferences);
• information from Your internet browser whenever You visit or use the Website (sometimes called “Log Data” or “Log Files”);
• device information and usage data;
• internet service provider;
• referring and exiting websites and pages;
• operating system;
• which pages You visit on Our Website;
• time zone settings;
• language preferences; and
• the time and date of Your visit and use of Website pages.

SENSITIVE PERSONAL INFORMATION – NOT COLLECTED
We do not collect, request, or require that You provide any sensitive personal information (e.g., social security number, driver’s license number, state identification card, passport number, information related to racial or ethnic origin, political opinions, religious, philosophical, or other beliefs, information related to sex life or sexual orientation, health data, biometric or genetic characteristics, criminal convictions and offenses, trade union membership, or specific geolocation), and You should not send Us or disclose to Us any sensitive personal information on or through the Website or otherwise.

USING NON-PERSONAL INFORMATION
Because non-personal information does not identify You individually, We may collect, use, and disclose non-personal information for any lawful purpose in Our sole discretion.

SMS / TEXT MESSAGING
The Company and its service providers may use SMS / Text Messaging to communicate with You and provide promotional materials. To receive SMS, MMS, or other text messages from the Company, You must provide a mobile phone number and consent to agree to these terms and conditions. By affirming Your choice to receive text communications, You acknowledge and agree that (i) We will send text communications to the number You provide and anyone with access to that mobile phone or carrier account will be able to see any such text communications; and (ii) You are the subscriber for the number You provide and will inform Us if You are no longer the subscriber. You can opt out of receiving text communications at any time by texting “STOP” to the number You receive in text communications. You will receive one final message confirming You are unsubscribed.

By using the SMS / Text Messaging Service, you agree to the terms of this Privacy Policy. The Company reserves the right to modify or change this Privacy Policy at any time with or without prior notice to you. The date of the last update will be posted at the top of this Privacy Policy for your convenience. This Privacy Policy, and any changes, are effective as soon as posted and supersede any prior Privacy Policies. Your continued use of this website and SMS / Text Messaging services following the posting of any changes to the Privacy Policy constitutes your full acceptance of those changes.

COOKIES, BEACONS, AND OPTING OUT
The Company, its authorized service providers, and certain authorized third parties use digital tracking tools such as cookies and similar technology (such as web beacons and single-pixel GIF files) when You use the Website. Cookies are small files that are transferred to Your device’s hard drive through Your internet browser that enables the Website’s or authorized service providers’ or third parties’ systems to recognize Your browser and capture and remember certain information. This helps Us to improve Your access to Our Website, identify repeat visitors, ensure the authenticity of registered users, target advertising, and enable Website traffic monitoring.

We use session-based cookies and persistent cookies. Session-based cookies will last only as long as Your web browser is open, and are deleted when You close Your browser. A persistent cookie will last until it expires or until You delete it. At times, the Company administers the use of cookies (called first-party cookies) and tracking technologies, and at times We rely upon authorized service providers and third parties to do so (called third-party cookies). These service providers and third parties may also use cookies, pixels and other identifiers to collect information that indicates how users interact with the Website and across other websites (e.g., Google Analytics, social media sites).

Using cookies helps Us do a number of things to enhance Your experience as a customer or potential customer of the Company, including to:

• identify users and visitors to the Website, including new visitors and returning customers;
• process and save Your preferences for future visits;
• ensure You do not need to login multiple times through user identification tracking;
• compile analytics, statistics and reports on Our Website and web traffic activity;
• track and target Your interests to enhance Your experience on Our Website, including searches and web traffic adjacent to activity on the Website;
• allow for integration with social media;
• offer products and advertising that may be aligned with Your interests; and
• provide other services related to the Website.

You can read more about how Google uses Your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

INTEREST-BASED ADVERTISING AND OTHER TARGETED ADVERTISING

We collect data about Your activities on Our Website for use in providing tailored advertising to You while using Our Website as well as through e-mails and other direct marketing channels that We utilize.

We also have partnered with certain third parties, including social media sites, that may use their own digital tracking tools, such as cookies and pixels, to track Your online activities over time and across Our Website and other websites by collecting information through automated means. These third parties will provide You with ads based upon Your interests, activities, and preferences. As a result, You may see certain ads for the Company on other websites based on prior activities on Our Website. You may be able to disable these digital tracking tools by changing the settings for cookies on the browser for each device You use to access the Website. In addition, You may be able to opt-out of their digital tracking tools by changing Your preferences on each social media platform.

These third parties may allow consumers to opt-out of receiving advertisements through the Digital Advertising Alliance – https://youradchoices.com/control or the Network Advertising Initiative – https://optout.networkadvertising.org/?c=1.

If You receive promotional materials or newsletters from Us, You may unsubscribe from these communications at any time by following the instructions contained in the emails or text messages You receive.

CONSUMER REQUESTS
As a voluntary service to You and upon Your written request, we will provide a copy of the personal information We maintain about You, update or correct that information, or delete that information from our future marketing activities. Please contact us by sending your written request to the address in the “Contacting Us” section below.

OTHER WEBSITES
The Website contains links to other sites (including Rent Café) and social media sites that are not owned or controlled by the Company. The Company is not responsible for the content, actions, privacy policies or information privacy and security practices of any other sites and We encourage You to review the privacy policies of those sites. The Company is not responsible for the content of linked sites, Your use of any linked sites, or any information (including Your personal information) collected, posted, used, or displayed by operators of any linked sites. In addition, the Company is not responsible for any third party, or their affiliates or agents, failure to use Your personal information in accordance with such third party’s privacy policy, or any contractual or other legal obligations to which such third party, their affiliates, or agents, may be subject.

You can review Rent Café’s privacy policy here: https://resources.yardi.com/legal/rentcafeprivacy-policy/.

INTENDED WEBSITE AUDIENCE AND NOTICE REGARDING CHILDREN’S PRIVACY
This Website is intended for use only by individuals 18 years old or older. We do not knowingly collect or store any personal information from children under the age of 18, and We request that minors do not provide any personal information to Us through the Website. If a parent or guardian becomes aware that his or her child under 18 has provided Us with information without his or her consent, he or she should contact Us as set forth in the “Contacting Us” section below.

VISITORS FROM OUTSIDE THE UNITED STATES – CROSS-BORDER TRANSFER
The Website is hosted in the United States and is intended for use only by individuals in the United States who are 18 years or older. If You are visiting the Website from outside the United States, Your information may be transferred to, stored and processed in the United States or other countries. The data protection and other applicable laws of the Unites States may not be as comprehensive as those laws or regulations in other countries or may otherwise differ from the data protection or consumer protection laws in other countries.

By using the Website and/or providing personal information to the Company, You consent to the transfer and use of Your personal information by the Company as set forth and described in this Privacy Policy.

DATA SECURITY
The security of Your personal information is very important to Us. We follow generally accepted industry standards to protect the personal information submitted to Us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while We strive to use commercially reasonable means to protect Your personal information, We cannot guarantee the absolute security of the personal information provided by You or collected by Us through use of the Site.

RETENTION AND STORAGE OF PERSONAL INFORMATION
We store all categories of the personal information that We collect – (i.e., individual identifiers and contact information, computer, internet and network activity information, other electronic information, and marketing and promotional information) – for as long as You have an account with Us or the period of time necessary for the purpose for which it was collected, or as required by or permitted by applicable law. To determine the appropriate duration of the retention of personal information, We consider a variety of factors, including the following:

• The amount, nature, and sensitivity of the personal information;
• The potential risks of harm to consumers;
• Our recordkeeping and legal compliance requirements;
• The need to protect the rights or safety of You, Us or others, including the resolution of inquiries or complaints;
• The need to exercise or defend legal claims; and
• The need to prevent fraud, protect assets and promote data security.

UPDATES TO THIS PRIVACY POLICY
We may update Our Privacy Policy from time to time and use of the information We collect now is subject to the Privacy Policy in effect at the time of use. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised, and We encourage You to check Our Privacy Policy periodically. Any changes will become effective when We post the revised Privacy Policy on Our Website. Your use of the Website, and/or Your purchase of a product or service following these changes means that You accept the revised Privacy Policy.

CONTACTING US
If You have any questions about this Privacy Policy, would like more information, or would like to submit a consumer request, You may contact via this link or by mail at 1089 Ocean Ave., Asbury Park, NJ 07078.