Agent Portal Privacy Policy

Effective Date: May 11, 2021.

This Privacy Policy describes our practices regarding the collection, use and disclosure of information collected by Home Partners of America, Inc. (together with its subsidiaries and affiliates, "Home Partners") through the Agent Portal and your participation in the Home Partners Lease Purchase Program (and other programs Home Partners may add from time to time for licensed real estate professionals), including through any web sites, applications, or other services that post or include a link to this Privacy Policy (collectively, the "Portal").

This Privacy Policy applies only to licensed real estate professionals who register an account with Home Partners to promote the Home Partners Lease Purchase Program and other programs Home Partners may add from time to time.

Please review this Privacy Policy carefully. In addition, please review the Agent Portal Terms and Conditions of Use, which govern your use of the Portal.

THE INFORMATION WE COLLECT

We collect information from you directly, automatically when you visit the Portal, and sometimes from third parties. Some of this information may be considered “personal information” 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 personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using function commonly known as a “hash.” We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

Information You Provide Us About Yourself

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) and the company with which you work. Certain features may also collect information about your preferences and interests. And, when submitting certain documents, we may ask you to provide your e-signature.

The Portal is 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.

Information You Provide Us About Others

When participating in the Home Partners Lease Purchase Program (and other programs Home Partners may add from time to time for licensed real estate professionals) and using some of the Portal features (such as, submitting properties and inviting prospective residents to apply), you may disclose personal information related to other people, such as a property address and an owner or prospective resident’s name, email address or other contact information. You may also provide additional information, such as your lead source and anticipated rent, or you may upload documents that contain information about a property or owners of a property. When you disclose any information to us that relates to other people, you represent that you have the authority to do so, and have provided any legally required notice and obtained any legally required consent in order to provide us with the data.

Information We Collect Automatically

We and our service providers and third party business partners may use a variety of technologies that automatically or passively collect certain information whenever you visit any the Portal 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 webpage you are visiting, all of the areas within the Portal that you visit, your time zone, 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 Portal. As you use the Portal, we may also track how you interact with the content. In some cases, we may directly collect location information through your device. You may be able to turn off the collection of location information through the settings on your device.

The methods that may be used to collect Usage Information include the following:

Cookies and Local Storage

Cookies and local storage are data files placed within a browser on a device when it is used to visit a Site. Certain web browsers and browser add-ons may provide additional local data storage mechanisms. For example, a Flash cookie is a data file placed on a device via the Adobe Flash plugin. Cookies and local storage can be used for a variety of purposes, including to store a unique identifier for your device that recognizes your device as you visit the Portal or other web sites or online services and to remember your preferences. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser's settings for further information. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of a Site may not function properly.

Web Beacons

Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs"), may be included in our web pages and e-mail messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a Site, to monitor how users navigate a Site, to count how many e-mails that were sent were actually opened or to count how many particular links were actually viewed.

User Submissions

The Portal may provide you the opportunity to participate and post content through interactive features and through other communication functionality ("Content Features"). You may choose, through such features or otherwise, to submit or post questions, answers, comments, tickets, suggestions, testimonials, photographs, videos, documents, or other content (collectively, "User Content")

Note that anything you post through Content Features may be public – other users may have access to your User Content and may use it or share it with third parties. Information or other content you choose to post or make available through the Content Features may be viewed, collected and used by others. If you choose to voluntarily disclose personal information, that information will be considered public information and the protections of this Privacy Policy will not apply. Think carefully before you post and use caution before disclosing any personal information.

Information Third Parties Provide About You and Social Media Interactions

Home Partners may receive information about you from third parties, including business partners. You may also have the opportunity to interact with a third party application or feature available through the Platform. 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 and they may receive information about your use of the Portal. 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 also may supplement the information we collect with outside records from third parties, such as public databases, publicly available web pages, and third parties who enhance the information we have about you. We use this information in order to provide you with information, services or goods you have requested, to enhance our ability to serve you to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you.

We may combine the information we receive from those other sources with information we collect through the Portal. 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 PORTAL

Home Partners may use information collected through the Portal, 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 Home Partners’ sites and across devices; (3) tailor content recommendations and offers we display to you, both on Home Partners’ sites and elsewhere online; (4) process your property submissions and invitations to prospective residents; (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 Portal or our services and for internal business purposes; (9) contact you with regard to your use of the Portal or any Home Partners’ sites or services and, in our discretion, changes to the Portal’s policies; and (10) for purposes disclosed at the time you provide your personal information or otherwise with your consent.

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 de-identified, aggregated user statistics. We may also share a Home Partners identification or transaction number with third parties. California residents, please see below for additional information in the Notice to California Residents .

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.

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

We may share your personal information with third parties for those third parties' own direct marketing purposes. California Residents, please see below for additional information in the Notice to California Residents .

In addition, we may share information when you request that we do so. For example, you may have the opportunity to share your information with prospective residents 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.

Real Estate Partners

We may share your personal information with approved real estate partners with whom you work. For example, we may provide reports with information about the agents in our partners’ networks, including name and email address, as well as information about the number of applicants received and deals closed. California Residents, please see below for additional information in the Notice to California Residents .

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. 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 respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms and Conditions of Use or other policies applicable to the Portal or our services 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 may share personal information with its parent, or its subsidiaries and affiliates, primarily for business and operational purposes. Home Partners reserves the right to disclose and transfer all information related to Portal, including personal information: (i) to a subsequent owner, co-owner or operator of the Portal 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.

THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES

Home Partners works with 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 Portal and the effectiveness of our advertisements. 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 these parties may collect personal information over time when you visit the Portal or other online websites and services. We may share non-personal information, including information that has been de-identified, Usage Information, and certain location information, with third party advertising companies, analytics providers and other third parties, including to make inferences about you and offers and content you may be interested in and for the purpose of serving you more relevant ads, and to allow others to do so.

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 the Portal 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 generic ads while online.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Portal 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.

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 your Device. If you are a California resident, please see our Notice to California Residents regarding additional rights you have, including how to exercise your “Do Not Sell” right.

HOW WE RESPOND TO "DO NOT TRACK" SIGNALS

Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. Like many websites and online services, Home Partners does not alter its practices when they receive a "Do Not Track" from a visitor's browser except as specifically required by law. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

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 features of the Portal 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/agent/dashboard to modify certain personal information, subscriptions, and marketing preferences. You may also contact us at [email protected] or 1-877-234-5155 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 Portal:

Targeted Advertising. You may 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 the Portal, 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 Portal 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 messages from Home Partners, you may unsubscribe from any SMS or MMS 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.

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.

NOTICE TO CALIFORNIA, NEVADA, AND CONNECTICUT RESIDENTS

California Residents

This California Privacy Notice is effective as of May 11, 2021

This notice supplements the Agent Portal Privacy Policy and applies only to California consumers. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the California Consumer Privacy Act (“CCPA”) and the regulations of the Attorney General implementing the CCPA, unless otherwise defined. Home Partners collects personal information through the Portal from individuals acting on behalf of a business in the context of providing a service. Accordingly, Home Partners is not subject to most provisions of the CCPA. As required under the CCPA, Home Partners provides a right to users of the Agent Portal who are California consumers to request to opt-out of the sale of Personal Information. If you are a California resident and would like to opt out of the sale of your Personal Information, please submit your request by completing this form. You may also call us toll-free at 1-855-921-0222.

In addition, certain third-party analytics and advertising companies may collect data from visitors to our Sites, including to better serve you more relevant advertisements, and these may be considered “sales” under the CCPA. Click here to open our Cookie Preferences tool and opt out of certain third-party collection that may be considered “sales” under the CCPA by toggling off the switch next to “Sale of Personal Data”.

The Digital Advertising Alliance (“DAA”) offers tools for California consumers to send requests under the CCPA to opt out of the sale of personal information by some or all of the participating companies https://privacyrights.info/. You can also limit this type of tracking through industry opt-outs (http://networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/) and by limiting ad tracking on your mobile device. Note that these are cookie-based opt-outs. If you disable your cookies or upgrade your browser after opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers. You can limit this type of tracking on mobile devices by using the limiting ad tracking features within the operating system of your mobile device or using DAA’s AppChoices application, described here.

You may also be able to limit the access these third parties have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies.

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.

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.