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
  • Third Parties Providing Services on Our Behalf
  • Sweepstakes, Contests, and Promotions
  • Administrative and Legal Reasons
  • Business Transfers
• THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES
• "DO NOT TRACK" AND GLOBAL PRIVACY CONTROL SIGNALS
• CHANGING YOUR INFORMATION
• YOUR CHOICES
• THIRD PARTY CONTENT, SITES, & DEVICES
• SECURITY
• CONSENT TO TRANSFER
• CHANGES TO THE PRIVACY POLICY
• OTHER PRIVACY RIGHTS
  • Notice to Nevada Residents
  • Notice to Connecticut Residents
  • Notice to California Residents

THE INFORMATION WE COLLECT

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.

Information You Provide Us

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.

Information We Collect Automatically

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.

Information Third Parties Provide About You and Social Media Interactions

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.

OUR USE OF INFORMATION COLLECTED THROUGH THE SITES

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.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

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.

Parent, Subsidiaries, and Affiliates

Home Partners may share Personal Information with its parent, or its subsidiaries and affiliates, primarily for business and operational purposes.

For Direct Marketing Purposes and When You Direct That We Share Your Information

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.

Third Parties Providing Services on Our Behalf

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.

Sweepstakes, Contests, and Promotions

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.

Administrative and Legal Reasons

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.

Business Transfers

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.

THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES

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.

"DO NOT TRACK" AND GLOBAL PRIVACY CONTROL SIGNALS

Do Not Track. Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. When you choose to turn on the “Do Not Track” settings in your browser, your browser will send a signal to websites, analytics providers, advertisements networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

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.

CHANGING YOUR INFORMATION

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.

YOUR CHOICES

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 Cookie Preference 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".

THIRD PARTY CONTENT, SITES, & DEVICES

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.

SECURITY

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.

CONSENT TO TRANSFER

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.

CHANGES TO THE PRIVACY POLICY

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.

OTHER PRIVACY RIGHTS

NOTICE TO NEVADA RESIDENTS

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.

NOTICE TO CONNECTICUT RESIDENTS

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.

NOTICE TO CALIFORNIA RESIDENTS

California Residents

California residents have certain rights regarding their Personal Information. Please review the California Privacy Notice.

Other California Privacy Rights

California Civil Code Section 1798.83 permits residents of California to request certain details about how their Personal Information has been shared during the prior calendar year with third parties for those third parties' own direct marketing purposes. This information includes the categories of Personal Information and types of services provided to the individual, as well as a list containing the names and addresses of all third parties to which the visitor information was disclosed.

If you are a California resident and you would like to receive this information, please write us at

  Attention: Legal Department
  Home Partners Holdings LLC,
  120 S. Riverside Plaza, Suite 2000
  Chicago, IL 60606
  [email protected]

You must put the statement "Your California Privacy Rights" in the subject field of your email or in the address line of your envelope. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.