This Privacy Policy describes our practices regarding the collection, use, disclosure, storage, and other
processing
of
information collected by Home Partners Holdings LLC (together with its subsidiaries and affiliates,
"Home Partners")
through our web sites, applications, and other online services that post or include a link to this Privacy Policy
(collectively, the "Sites"). Please review this Privacy Policy carefully. In addition, please
review the
Terms and Conditions of Use which govern your use of the Sites.
TABLE OF CONTENTS
- THE INFORMATION WE COLLECT
- Information You Provide Us
- Information We Collect Automatically
- Information Third Parties Provide About You and Social
Media Interactions
- OUR USE OF INFORMATION COLLECTED THROUGH THE SITES
- DISCLOSURE OF INFORMATION TO THIRD PARTIES
- For Direct Marketing Purposes and When You Request That We
Share Your Information
- Parent, Subsidiaries, and Affiliates
- Third Parties Providing Services on Our Behalf
- Sweepstakes, Contests, and Promotions
- Administrative and Legal Reasons
- Business Transfers
- THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES
- "GLOBAL PRIVACY CONTROL" SIGNALS
- CHANGING YOUR INFORMATION
- YOUR CHOICES
- THIRD PARTY CONTENT, SITES, & DEVICES
- SECURITY
- CONSENT TO TRANSFER
- CHANGES TO THE PRIVACY POLICY
- CONTACT US
- STATE SPECIFIC PRIVACY RIGHTS
- Notice to Nevada Residents
- Notice to Texas Residents
- Notice to Connecticut Residents
- Notice to California Residents
We collect information from you directly, automatically when you visit the Sites, and sometimes from third
parties.
Some
of this information may be considered “personal information” or “personal data,” and some of which may be
considered
“sensitive,” under various applicable laws. We consider information that identifies you as a specific, identified
individual to be personal information (such as your name, phone number, e-mail address), and we treat additional
information, including IP addresses and cookie identifiers, as “personal information” where required by applicable
law.
And, if we combine information we consider to be non-personal with personal information, we will treat that
combined
information as personal information under this Privacy Policy and as required by law. Note that we may de-identify
or
pseudonymize personal information so that it is non-personal, such as by aggregating it or converting it to a
code,
sometimes using a function commonly known as a “hash.” We maintain and use de-identified data without attempting to
re-identify it, except where permitted by applicable law, such as to determine whether our de-identification
processes
satisfy legal requirements. We will treat de-identified and pseudonymized information as non-personal to the
fullest
extent allowed by applicable law.
We may ask you to provide information directly, such as contact information (your name, phone number, or e-mail
address), banking and other financial information, and other information about you, including demographic
information
(for example, your gender, age, or similar information). Certain features may also collect information about your
preferences and interests.
The Sites are not intended for use by anyone younger than the age of 18 and we do not knowingly collect personal
information from users younger than age 18. If we learn that we have inadvertently collected personal information
from a
user who is younger than age 18, we will delete the information from our active databases.
We and third-party business partners (including service providers and third-party advertising and analytics and
similar
companies) may use a variety of technologies that automatically or passively collect certain information whenever
you
visit any Site or otherwise interact with us or our content ("Usage Information"). Usage
Information may include
the
hardware model, browser, and operating system you are using, the URL or advertisement that referred you to the
Site
you
are visiting, all the areas within the Sites that you visit, your time zone, approximate location information, and
mobile network (if applicable), among other information. In addition, we automatically collect your IP address or
other
unique identifier ("Device Identifier") for any computer, mobile phone or other device you use to
access our
Sites.
Usage Information is generally non-identifying, but if Home Partners associates it with you as a specific and
identifiable person, Home Partners treats it as personal information.
We use the following types of tracking technologies (collectively referred to as “Tracking Technologies”) to
automatically collect information when you interact with us online:
Cookies and Local Storage are small text files stored locally on your device that help store user
preferences.
These
technologies are able to store a unique identifier for a device that allows us to recognize the device whenever it
is
used to visit our Sites. These technologies may be used for many purposes by us, our service providers, and our
third-party business partners, such as automatically collecting Usage Information, enabling features, serving
advertisements to you online, and remembering your preferences. We may use cookies and other technologies to help
keep
your use of the Sites more secure, to study traffic patterns on the Sites, to study the effectiveness of our
customer
communications, to maintain the integrity of the Sites, to measure crash analytics and other maintenance related
information, to manage and measure the performance of advertisements displayed on or delivered by or through the
Sites,
and to personalize your experience through the Sites, such as to recognize you when you return to the Sites. The
information we store includes internet protocol (IP) addresses, browser type, Internet service provider (ISP),
referring/exit pages, operating system, date/time stamp, and clickstream data. If you do not want to accept
cookies,
you
can block them by adjusting the settings on your Internet browser, or depending on your location, via settings we
make
available on our Sites. You can find more information about cookies and how they work at www.allaboutcookies.org.
Web beacons (also known as clear GIFs and pixel tags) are small pieces of code used to collect
usage analytics.
They
help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When you ask
us to
send you information on a promotion or a newsletter, we may use web beacons to establish when an email is opened.
Embedded scripts are programming code designed to collect information about your interactions
with our Sites, such
as
the links you click on. The code is temporarily used by our server or a third-party service provider or business
partner
while you browse or interact with our Sites and is deactivated or deleted when you disconnect from our Services.
Software Development Kits (SDKs) are a software package that contains a set of tools that can be
used to help
build
applications and implement new features in existing apps. These tools can be used to create and operate features
that
collect information from your device.
Data Collection from Mobile Devices. We use embedded scripts and the tools provided in SDKs to
collect information
from
mobile devices such as the hardware model, operating system and version, identification numbers assigned to your
mobile
device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile
network information, and website usage behavior. In addition, we may use a variety of other technologies that
collect
similar information for security, fraud detection, and maintenance purposes.
Home Partners may capture session interactions with user interfaces for website analytics purposes, solely for our
internal business purposes, to improve the Sites and our products and services.
Chat Boxes
When you participate in any chat feature Home Partners may provide, Home Partners can record and use your
communications
and the information you provide in order to assist you during the chat session, and provide customer support, to
improve
our products and services.
Home Partners may receive information about you from third parties, including business partners and data
providers.
You
may also have the opportunity to interact with a third-party application or feature available through a Site, such
as
features that allow you to log-in through, access, or otherwise connect your account on a third party service
(e.g.,
Facebook). You may also be able to utilize third party services to transfer banking and other financial
information
to
your Home Partners account. If you choose to utilize such a third-party service, we will receive information about
you
from that third party service (which may include Personal Information) and they may receive information about your
use
of the Sites. Through these features, third parties may collect your IP address or other Device Identifier, which
page
you are visiting on a Site, and may set cookies to enable the third-party feature to function properly. If you
choose to
post information to a third-party platform, that information may be public.
We may combine the information we receive from those other sources with information we collect through the Sites.
In
those cases, we will apply this Privacy Policy to the combined information. The information collected and stored
by
the
third party is subject solely to the third party's privacy practices.
Home Partners may use information collected through the Sites, including Usage Information and Personal
Information,
to:
(1) allow you to participate in features we offer or to provide related customer service; (2) recognize you across
the
Sites and across devices; (3) tailor content recommendations and offers we display to you, both on the Sites and
elsewhere online; (4) process your transactions; (5) provide you with information, products, or services that you
have
requested or that we think may interest you; (6) investigate and prevent fraudulent transactions and other illegal
activities or activities that violate our policies; (7) process your registration, including verifying your
information
is active and valid; (8) improve the Sites or our services and for internal business purposes; (9) contact you
with
regard to your use of the Sites or any Home Partners service and, in our discretion, changes to the Sites'
policies;
and
(10) for purposes disclosed at the time you provide your Personal Information or otherwise with your consent.
We may also use and share non-personal information in our discretion, and we may use non-personal information,
including
information that has been de-identified or pseudonymized, to make inferences about you and offers and content you
may be
interested in, to serve you with relevant advertising, and to allow others to do so, as permitted by law.
To the fullest extent allowed by law, Home Partners may share certain information with third parties in our
discretion,
including non-personal information, such as information that has been hashed or de-identified or pseudonymized,
including aggregated user statistics, with third parties in our discretion and as permitted by law, including for
targeted advertising purposes.
We may share the information we have collected about you, including personal information as disclosed at the time
you
provide your information or otherwise with your consent, and as described below or elsewhere in this Privacy
Policy.
Home Partners may share Personal Information with its parent, or its subsidiaries and affiliates, primarily for
business
and operational purposes.
We may share certain personal information, such as contact or similar information, with third parties for those
third
parties' own direct marketing purposes. In addition, we may share information when you direct that we do so. For
example, you may have the opportunity to share your information with real estate agents or brokers to conduct
transactions. In addition, you may be presented with an opportunity to receive information and/or marketing offers
from
one or more third parties. If you agree at that time to have your personal information shared, your personal
information
will be disclosed to that third party (or parties) and will be subject to their privacy practices. Or, you may
choose to
interact with a third-party application or feature, through which information about you is shared. Please note
that
we
are not responsible for the privacy practices of third parties. If you later decide that you no longer want to
receive
communications from a third party, you will need to contact that third party directly.
We may share information about you, including personal information, with third party vendors to enable them to
perform
services on our behalf. Additionally, we may share various information relating to our users and fraudulent or
potentially fraudulent activities with our fraud prevention and similar vendors, and they will use this
information
to
help us and their other clients prevent fraudulent and illegal transactions.
We may offer sweepstakes, contests, and other promotions (any, a "Promotion") that may require
registration. By
participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the
Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the
sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or
marketing
materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the
public
in
connection with the administration of such Promotion, including, without limitation, as required by law or
permitted
by
the Promotion's official rules, such as on a winners list.
We may also transfer and disclose user information, including personal information, to third parties: (i) in the
event
we are required to comply with a legal obligation, such as respond to subpoenas or other legal process or if we
believe
in good faith such disclosure is required by law; (ii) at the request of governmental authorities conducting an
investigation; (iii) to protect and/or defend the Terms and Conditions of Use or other
policies
applicable to a
Site
or
our services; (iv) or to protect the personal safety, rights, property or security of Home Partners, our
customers,
or a
third party. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in
cooperation
with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our
discretion.
Home Partners reserves the right to disclose and transfer all information related to Sites, including Personal
Information: (i) to a subsequent owner, co-owner or operator of a Site or applicable database; or (ii) in
connection
with a corporate merger, consolidation, restructuring, bankruptcy, the sale of certain of Home Partners' ownership
interests, assets, or both, or other company change, including, without limitation, during the course of any due
diligence process. By providing your information, you understand and agree that we may transfer such information
to
the
acquiring entity without your further consent.
Home Partners works with third party business partners (such as network advertisers, ad agencies and other
advertising
partners) to serve Home Partners ads online. We also use analytics providers to provide us with information
regarding
the use of the Sites and the effectiveness of our advertisements. You may also see ads on the Sites and those ads
may be
served by a third party. These third parties may set and access their own tracking technologies on your device
(including cookies, and web beacons), and they may otherwise collect or have access to information about you,
including
Usage Information, some of which may be personal information or personal data under various state laws. Some of
these
parties may collect personal information over time when you visit the Sites or other online websites and services.
We
may share non-personal information, including information that has been hashed (including hashed email addresses)
or
otherwise de-identified, pseudonymized, Usage Information, and location information, with third party advertising
companies, analytics providers and other third parties, including for the purpose of serving you more relevant
ads.
We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about
use of
the Sites and report on activities and trends. This service may also collect information regarding the use of
other
websites, apps, and online resources. You can learn about Google's practices by going to
www.google.com/policies/privacy/partners/ and opt
out of them by downloading the Google Analytics opt-out browser
add-on, available at https://tools.google.com/dlpage/gaoptout.
We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network
Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online
Behavioral
Advertising and you may want to visit the following webpages, which provide "opt-out" mechanisms for participating
companies: http://networkadvertising.org/managing/opt_out.asp; http://www.aboutads.info/choices/. You
may also be
able
to opt-out from interest-based advertising on your mobile device through your mobile device settings. You may also
opt-out from receiving targeted ads while on Sites through your account settings as further described below in
"Your Choices".
Please note opting out through these mechanisms does not opt you out of being served advertising. You will
continue
to
receive non-targeted ads while online or on you Device. Please see our sections for residents of California below
for
additional rights you may have.
Global Privacy Control. Global Privacy Control (“GPC”) is a technical specification in your browser settings that
you can use to automatically inform websites of your privacy preferences with regard to third party online
tracking.
To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact
information
provided as part of registration. Certain Sites allow you to update certain personal information you have provided
and
to change your subscriptions or preferences regarding marketing information you receive from Home Partners. For
example,
you may visit https://www.homepartners.com/profile/dashboard to modify certain
Personal Information,
subscriptions,
and
marketing preferences. You may also contact us at [email protected] or 1-312-780-1952
if you have
questions
about or wish to modify certain information that we have collected from or about you. Note that when you modify
your
personal information or change your preferences on a Site, information that you remove may persist internally for
Home
Partners' administrative purposes or within backup media. If you have made any public postings on a Site, these
communications cannot generally be removed.
Home Partners offers you the following choices with regard to the information it collects through the Sites:
Targeted Advertising. To manage your cookie preferences, visit our Center.
You
may also opt-out from certain third parties who serve online advertising, including some who serve Home Partners
ads
elsewhere online, by visiting http://www.networkadvertising.org/managing/opt_out.asp or
http://www.aboutads.info/choices/. Opting out does
not mean you will not see any ads when browsing Sites, but the
ads
you see from participating third parties will no longer be customized to you based on your profile or interactions
with
Home Partners.
Marketing Emails and Mobile Messages. You may opt out of receiving marketing e-mails by following
the opt-out
instructions provided to you in those e-mails. Please note that we reserve the right to send you certain
communications
relating to your account or use of the Sites or Home Partners services, such as administrative and services
announcements. These transactional account messages may be unaffected if you choose to opt out from marketing
e-mails.
If you sign up to receive SMS or MMS or RCS messages from Home Partners, you may unsubscribe from any SMS or MMS
or
RCS
messages received by replying "STOP".
The Sites may contain content that is served by someone else or links to third party content or web sites that
Home
Partners does not control. This includes links from advertisers, sponsors and partners that may use our logo(s) as
part
of a co-branding relationship. You may also be able to access the Sites through third party devices and platforms,
such
as a set-top box, internet-connected TV, or similar device. The third-party operators and content providers may
send
their own cookies to your device, they may independently collect data or solicit Personal Information, and may
have
their own published privacy policies. Home Partners is not responsible for the privacy practices employed by any
third
party.
Home Partners takes commercially reasonable steps to protect and secure personal information. However, no data
transmission over the Internet, by wireless transmission or any electronic storage of information can be
guaranteed
to
be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect, and you
use
the
Sites and our services and provide us with your information at your own risk.
Home Partners is based in the United States and the information we collect is governed by United States law. By
accessing or using the Sites or providing us with any information, you consent to the transfer, processing, and
storage
of your information in and to the United States and other countries, jurisdictions in which the privacy laws may
not
be
as comprehensive as those in the country where you reside and/or are a citizen. Personal information processed or
stored
in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in
accordance
with the laws of that jurisdiction.
To the extent permitted by applicable law, Home Partners reserves the right to change this Privacy Policy at any
time
without prior notice and will notify you of material changes by posting the changed or modified Privacy Policy on
the
Sites. We may also provide notice to you in other ways in our discretion, such as through contact information you
have
provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless
otherwise
specified and your continued use of any of the Sites after the effective date of the revised Privacy Policy will
constitute your consent to those changes to the extent allowed by applicable law. However, Home Partners will not
make
material changes to how it treats previously collected personal information about you without providing notice and
giving you the chance to consent (opt-in or opt-out), as required. Note, however, that you may need to consent to
our
new policies in order to continue to use the Sites and our services.
You may contact us by emailing [email protected].
The information you provide is used to respond directly to your questions or comments. We may also file your comments
and share them with our consumer care team to improve our services in the future.
Residents of certain states may be provided additional rights with respect to personal data as defined in each state’s
privacy laws. At this time, we are only subject to the privacy laws in the below noted states. Please contact us at
[email protected] with any questions about your privacy rights.
Home Partners does not currently sell your covered information as those terms are defined under applicable Nevada
law.
However, you may still submit an opt-out request and we will honor that request as required by Nevada law if Home
Partners were to ever engage in such a sale in the future. If you are a Nevada resident and would like to opt-out
of
future sales of your covered information, please submit your request to [email protected]. Your
request
must include your full name, street address, city, state, zip code, and an email address so that we can contact if
needed regarding this request. You may also be required to take reasonable steps as we determine from time to time
in
order to verify your identity and/or the authenticity of the request. Home Partners will respond to your request
within
sixty (60) days either confirming that your request has been processed or indicating that we need an additional
thirty
(30) days to complete the request.
We set forth above the categories of personal data we process, the purpose for processing personal data, the
categories of personal data shared, and the categories of third parties with whom personal data is shared, Residents
of Texas have certain privacy rights with respect to this data, as described below.
If you are a resident of Texas (as defined by its privacy law) and would like to exercise your applicable rights,
please submit a request at this
form.
- Access Your Personal Data/Data Portability – to confirm whether we are processing your personal data and request
to access such data, please following the instructions above. This includes to obtain a copy of the personal data
we hold about you and, to the extent feasible and permitted by applicable law, in a readily usable format to allow
data portability.
- Delete Your Personal Data – request to delete your personal data.
- Correct Your Personal Data – request to correct the personal data we hold about you.
- Opt-Out of Sales/Targeted Advertising – Home Partners may sell your data as defined by Texas (noting that we do not
sell your information for monetary compensation) and engages in online advertising practices (and certain analytics or
similar activities) that may be considered “targeted advertising” under the Texas privacy law. To disable sharing
through tracking technologies, such as cookies, set by third parties that may be considered targeted advertising under
such laws, manage cookie preferences by clicking “Cookie Preferences” in the footer of our website. To opt out of sales,
follow the instructions noted above.
- Right to Appeal – If, for any reason, you would like to appeal our decision relating to your request, you have the right
to submit an appeal and can do so by following the instructions noted above. Please include your full name, the basis for
your appeal, and any additional information to consider.
- Sensitive Data – We will obtain your consent to the processing of any Sensitive Data (as defined in Texas).
Home Partners is committed to maintaining the confidentiality of the Social Security numbers it collects during
the
regular course of business. Accordingly, Home Partners has established policies to safeguard and restrict access,
disclosure and use of the Social Security numbers it has collected.
Home Partners collects the Social Security numbers of employees, customers, realtors, and contractors only for
legitimate business purposes. Home Partners restricts access to the Social Security numbers it collects to only
Home
Partners’ employees and certain third parties who have a legitimate business need to access this
information. Authorized
third parties that are granted access to this information are contractually obligated to maintain its
confidentiality.
Home Partners prohibits the disclosure and use of Social Security numbers unless such disclosure and use complies
with
this policy and applicable law. Social Security numbers shall not be displayed on identification cards or badges,
bulletin boards, or any similar materials that are publicly displayed. Home Partners safeguards the
confidentiality
of
the Social Security numbers it collects in accordance with its internal policies and procedures governing the
protection
of Personal Information. Such policies and procedures address the physical, technical and administrative
safeguards
Home
Partners has adopted and implemented to protect Social Security numbers and other Personal Information.
California Residents
California residents have certain rights regarding their Personal Information. Please review the California
Privacy Notice.
