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 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.

TABLE OF CONTENTS

• THE INFORMATION WE COLLECT
  • Information You Provide Us About Yourself
  • Information We Collect Automatically
  • Information Third Parties Provide About You and Social Media Interactions
• OUR USE OF INFORMATION COLLECTED THROUGH THE PORTAL
• DISCLOSURE OF INFORMATION TO THIRD PARTIES
  • 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
• "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
• STATE-SPECIFIC 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 Portal, 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 function commonly known as a “hash.” We maintain and use de-identified and pseudonymized 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 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 third party business partners (including our service providers and third party advertising and analytics companies) 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, 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 Portal. As you use the Portal, we may also track how you interact with the content. Usage Information is generally non-identifying, but if Home Partners associates it with you as a specific and identifiable person, we treat it as personal information.

We use the following 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 helps to store user preferences. These technologies are able to store a unique identifier for a device that allow us to recognize your device as you visit the Portal. 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 Portal more secure, to study traffic patterns on the Portal, to study the effectiveness of our customer communications, to maintain the integrity of the Portal, 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 Portal, and to personalize your experience through the Portal, such as to recognize you when you return to the Portal. 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. You can find more information about cookies and how they work at 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 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 newsletter, we may use web beacons to establish when an email is opened.

Home Partners may capture session interactions with user interfaces for website analytics purposes, solely for our internal business purposes, to improve the Portal and our products and services.

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"). Your submissions are subject to the Terms for the Portal.

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 in accordance with applicable law, including non-personal information, such as information that has been hashed, de-identified, or pseudonymized, including aggregated user statistics. 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 Direct That We Share Your Information

We may share your personal information, such as contact 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 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.

Parent, Subsidiaries, and Affiliates

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

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. 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 respond to comply with a legal obligation, such as responding 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 the Portal or our services; or (iv) 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 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. By providing your information, you understand and agree that we may transfer such information to the acquiring entity without your further consent, except whether otherwise required by law.

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 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 which may be personal information under various state laws. 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 hashed or otherwise de-identified, pseudonymized, Usage Information, and certain non-precise 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.

"DO NOT TRACK" AND “GLOBAL PRIVACY CONTROL” SIGNALS

Do Not Track. Note that your browser 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, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about and to set up "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 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. To manage your cookie preferences, visit our cookie management tool. 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 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, MMS or RCS messages received by replying "STOP".

If you are a California resident, please see our Notice to California Residents for more information on additional rights you have regarding your information.

THIRD PARTY CONTENT, SITES & DEVICES

The Portal 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 Portal 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 Portal 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 Portal 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 Portal. 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 Portal 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 Portal and our services.

STATE-SPECIFIC 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 have certain rights regarding their Personal Information. Please review the California Privacy Notice.