This notice supplements the Agent Portal Privacy Policy of Home Partners
Holdings LLC (together
with its
subsidiaries and affiliates, “Home Partners”) and applies only to California residents with whom
we have a direct
business or potential business relationship with through the Agent Portal. Terms (including defined capitalized
terms)
used in this California Privacy Notice have the same meanings given in the California Consumer Privacy Act, the
California Privacy Rights Act of 2023, and any implementing regulations adopted thereunder (collectively, the
“CPRA”),
unless otherwise defined.
EXERCISING YOUR CALIFORNIA RIGHTS
California Consumers have the right to request: (1) that we disclose to you what Personal Information we collect,
use,
disclose, and sell, including the right to request that we provide to you the categories and specific pieces of
Personal
Information we have collected about you (“Right to Know”); (2) that we delete the Personal
Information we have
collected
from you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about
you “Right to
Correct”),
(4) to opt-out from the sharing of your Personal Information to a third party for cross-context behavioral
advertising
(i.e., targeted advertising) (“Right to Opt-Out of Sharing”), and (5) the right to opt-out from
the sale of
Personal
Information (“Right to Opt-Out of Sale”), all subject to meanings and exceptions set forth in the
CPRA. More
information
on each of these rights is below.
In your request, you must provide enough information to allow us to verify you are the person about whom we
collected
personal information, or their authorized representative. You must also describe your request with enough detail
so that
we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity.
Making
such a request does not require you to create an account with us, and we will only use the information you provide
in a
request to verify your identity.
Verifying Your Requests
We will take reasonable steps to verify your identity based upon the information you provide and the type of
request you are making.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us
with
information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to
verify that the individual submitting the request is the same individual about whom we have collected information
(or
someone authorized by that individual to act on their behalf), we will not be able to process the request.
Agents
If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable
request
per the instructions below. We will follow up to request a signed, written permission signed by the individual who
is
the subject of the request authorizing you to make the request on their behalf. The written permission must state
your
full legal name, the full legal name of the individual who is the subject of the request, and needs to be clear
about
the permission granted.
Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either
case,
please also indicate in your email the nature of your request. The Consumer’s identity, in addition to your own,
will
need to be independently verified in order for us to be able to fulfill your request. We may also ask the Consumer
to
directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do
not
receive adequate proof that you are authorized to act on the user’s behalf, we may deny the request.
Right to Know
California Consumers have the right to know what information we have collected about you (the categories and the
specific pieces of information).
If you are a California Consumer and would like to exercise your Right to Know, please submit your request through
the
form or by calling us toll-free at 1-855-921-0222.
In order to have us provide specific pieces of information, we may require a signed declaration under penalty of
perjury
that you are the Consumer whose Personal Information is the subject of the request.
Right to Delete
California Consumers have the right to request that we delete any of the personal information we have collected
from
you. If you are a California Consumer and would like to exercise your Right to Delete, please submit your request
through the form or by calling us toll-free at 1-855-921-0222.
Please note that as part of the verification process, once you submit a request to delete, we may follow up and
require
you to confirm that you want your information deleted.
Right to Correct Inaccurate Information
California Consumers have the right to request that we correct inaccurate information we hold about you. If you
are a
California Consumer and would like to exercise your Right to Correct, please submit your request through the form
or by calling us toll-free at 1-855-921-0222.
Right to Limit the Use and Disclosure of Sensitive Personal Information
Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive
Personal
Information when Sensitive Personal Information is collected or processed for the purpose of inferring
characteristics
about a Consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Home Partner’s
use
and disclosure of Sensitive Personal Information is not used for such purpose and/or falls within the statutory
exceptions, and we therefore do not offer this right at this time.
Do Not Sell My Personal Information or Share for Cross Contextual Behavioral Advertising
Right to Opt-Out of Sale and Right to Opt-Out Of Sharing for Cross Contextual Behavioral Advertising
California Consumers have the right to opt-out of the sale of your Personal Information (note that Home Partners
does
not sell Personal Information for monetary compensation. California Consumers have the right to opt-out of the
sharing
of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted
advertising),
whether or not for monetary or other valuable consideration. If you are a California Consumer and would like to
exercise
your Right to Opt-Out of Sale of Personal Information or Sharing for Cross Contextual Behavioral Advertising,
please
submit your request through the form.
Cookie Based Opt-Outs for Do Not Sell My Personal Information or Share for Cross Context Behavioral Advertising
Home Partners engages in online advertising practices (and certain analytics or similar activities), which may be
considered a “sale” or “share” for cross-context behavioral advertising under the CPRA. To opt out of cookies set
by 3rd
parties that may be considered "sales" or “sharing” under the CPRA, click here.
In addition, the Digital Advertising Alliance also offers tools for California Consumers to send requests under
the CPRA
to opt out of the sale of personal information by some or all of the participating companies(https://www.privacyrights.info).
Data Retention
We will retain all categories of personal information described in this California Privacy Notice for as long as
it is
reasonably necessary for the purposes set out in this California Privacy Notice, considering the time period
reasonably
necessary to: provide the Portal to you; exercise the choices and rights you have requested; comply with our
contractual
obligations; enforce our terms of the Portal; and, comply with legal and regulatory requirements. Except as noted
differently on specific pages or apps, we retain your personal information while you have an account with us, or
while you
are using our Portal.
USERS YOUNGER THAN 18
Home Partners does not knowingly Sell or Share Personal Information of minors younger than 18 years of age.
RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHTS
California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will
not
discriminate against you for exercising your CPRA rights.
PERSONAL INFORMATION HOME PARTNERS OF AMERICA COLLECTS
The Personal Information we collect about you will depend upon how you use our Portal or otherwise interact with
us.
Accordingly, we may not collect all of the below information about you.
In addition to the below, we may also collect and/or use additional types of information, and will do so after
providing
notice to you and obtaining your consent to the extent such notice and consent is required by the CPRA.
Category of Personal Information Collected | Categories of Sources from which Information is Collected | Business or Commercial Purpose(s) for which Information is Collected
| CCategories of Third Parties with whom this type of Information is
Shared/Disclosed for a Business Purpose
| Categories of Third Parties to Whom this Type of Information is Sold or
Shared for Cross Context
Behavioral Advertising |
---|
IdentifiersThis category includes information such as name, contact information, and online or device identifiers.
| We may collect this type of information from:
- Consumer,
- Tracking Technologies,
- Third party business partners, such as data analytics providers, advertising networks, or joint
marketing partners,
| We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Recognizing you across devices to improve your experience with us and on the Portal,
- Providing customer service,
- Providing you with our newsletter and/or other marketing materials or other communication,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
|
We may disclose this type of information to:
- Service Providers,
- Third parties who deliver our communications,
- Third party advertising and analytics companies,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition,
- Third parties or affiliated companies when you agree to or direct that we share your information with
them,
- Other third parties (including government agencies) as required by law or in connection with court
proceedings (such as
pursuant to subpoenas or court orders).
| Third party analytics, advertising, and similar marketing business partners may have access to this data,
and this may
be considered a “sale” or "share” under CPRA under certain circumstances. We may share information with third parties with whom we have a relationship, such as through a referral
program, and
some of this sharing may be considered a sale under CPRA. |
Any categories of personal information described in subdivision (e) of Section 1798.80This category includes name, address, and phone number, information about your employment or education,
and other
categories of information classified as “personal” under this California law. | We may collect this type of information from:
- Consumer,
- Tracking Technologies,
- Third party business partners, such as joint marketing partners,
- Third party data resellers.
|
We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Providing customer service,
- Providing you with our newsletter and/or other marketing materials or other communications,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
|
We may disclose this type of information to:
- Service Providers,
- Third parties who deliver our communications,
- Third party advertising and analytics companies,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition,
- Third parties or affiliated companies when you agree to or request that we share your information with
them,
- Other third parties (including government agencies) as required by law or in connection with court
proceedings (such as
pursuant to subpoenas or court orders).
| Third party advertising, analytics, and similar business partners may have access to this data, and this
may be
considered a “sale” or "share” under CPRA under certain circumstances. |
Characteristics of protected classifications under California or federal lawThis category includes information such as age, sex (including gender), and marital status. | We may collect this type of information from:
- Consumer,
- Third party business partners.
| We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
| We may disclose this type of information to:
- Service Providers,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition
- Third parties or affiliated companies when you agree to or request that we share your information with
them,
- Other third parties (including government agencies) as required by law or in connection with court
proceedings (such as
pursuant to subpoenas or court orders).
| Such characteristics are not sold or shared. |
Commercial informationThis category includes, for example, payment information you provide for goods, services, customer
service records, and
information about the products you have purchased. | We may collect this type of information from:
- Consumer,
- Third party business partners.
| We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Providing customer service,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
| We may disclose this type of information to:
- Service Providers, such as those who help us process transactions and deliver our communications,
- Third party advertising and analytics companies,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition,
- Third parties or affiliated companies when you agree to or request that we share your information with
them,
- Other third parties (including government agencies) as required by law or in connection with court
proceedings (such as
pursuant to subpoenas or court orders).
| We may share information with third parties with whom we have a relationship, such as through a referral
program, and
some of this sharing may be considered a “sale” or "share” under CPRA. |
Internet or other electronic network activity informationThis category includes information about the web browser and operating system you are using, the website
or ad that
referred you to our Portal, areas of the Portal that you visited, and terms entered into a search engine
that led you to
the Portal. | We may collect this type of information from:
- Consumer,
- Cookies and Tracking Technologies,
- Third party social media companies,
- Third party business partners, such as data analytics providers, advertising networks, or joint
marketing partners,
- Third party data resellers.
| We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Providing customer service,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
| We may disclose this type of information to:
- Service Providers,
- Third party advertising and analytics companies,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition,
- Third parties or affiliated companies when you agree to or request that we share your information with
them,
- Other third parties (including government agencies) as required by law (such as pursuant to subpoenas
or court orders).
|
Third party advertising, analytics, and similar business partners may have access to this data, and this
may be
considered a “sale” or "share” under CPRA under certain circumstances.
|
Audio, electronic, visual, thermal, olfactory, or similar informationThis category includes, for example, images, video, or audio recordings. | We may collect this type of information from:
| We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Providing customer service,
- Accomplishing our business purposes as described in detail in our privacy policy.
| We may disclose this type of information to:
- Service Providers,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition.
| Audio, electronic, visual, thermal, olfactory, or similar information is not sold or shared. |
Inferences drawn from any of the information identified above to create a profile about a ConsumerThese inferences may relate to your perceived interests, preferences, characteristics, or behavior. |
We may collect this type of information from:
- Consumer,
- Cookies and Tracking Technologies,
- Third party social media companies,
- Third party business partners, such as data analytics providers, advertising networks, or joint
marketing partners,
- Third party data resellers.
|
We may use this type of information for:
- Providing the functionality of the Portal and fulfilling your requests,
- Providing customer service,
- Analytics for business reporting and providing personalized services,
- Accomplishing our business purposes as described in detail in our privacy
policy.
|
We may disclose this type of information to:
- Service Providers,
- Third party advertising and analytics companies,
- Third parties who may acquire your information as a result of a merger, acquisition or other ownership
transition.
- Other third parties (including government agencies) as required by law or in connection with court
proceedings (such as
pursuant to subpoenas or court orders).
| Third party advertising, analytics, and similar business partners may have access to this data, and this
may be
considered a “sale” or "share” under CPRA under certain circumstances. |
QUESTIONS AND CONTACT INFORMATION
You can contact us for more information by emailing [email protected]