Last Modified: September 27, 2023

This Privacy Policy explains how HomeLight, Inc. (“HomeLight”, “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal information in connection with our websites, including https://www.homelight.com/ and other websites we own and operate that link to this Privacy Policy (the “Sites”), the HomeLight mobile application (the “App”), and the related content, platforms, services, products, and other functionality offered on or through our services (collectively, the “Services”). This Privacy Policy does not address our privacy practices relating to HomeLight job applicants, employees, and other personnel.

1. WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or household. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.

2. HOW WE COLLECT AND USE PERSONAL INFORMATION

Personal information Collected from Individuals

The categories of personal information we collect submitted to us by individuals through the Services may include:

• Contact Information, including first and last name, email address, mailing address, and phone number. We use this information to fulfill your request or transaction and to communicate with you directly.
• Account Information, including personal and/or business information that you provide when you register for an account using to use our Services. This may include your first and last name, email address, username and password, and billing and payment card information. If you are an administrator for your company, we will also collect information to create your company profile. We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. As described further below, we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
• Financial Information, such as bank, credit or debit card number, account type, routing number, bank institution name, account balances, credit history, investment activity, income or source of funds, and payment/transaction history. Please note that we use third party payment processors, including Stripe, to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. To view Stripe’s privacy policy, please click here.
• Recorded Conversations, such as information you provide about yourself during recorded calls with members of the HomeLight team. We use this information to provide our Services as well as for training and quality assurance.
• Other Inquiry and Communications Information, including information provided to one of our email addresses, or via phone calls or text messages. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
• Marketing Emails Information, including email address and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Information Collected Through the Use of the Services, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us, your communications with other users, or your use of the Services (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Services. We use the User Content to provide you with the Services.
• Feedback Information. We may also collect feedback, testimonials, and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business. By submitting such information, you grant HomeLight the right to post and publish such information at our sole discretion. With your consent we may post your testimonial along with your name.
• Commercial information, such as primary business address, secondary business address, ownership information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, home purchase information, such as the address, type of home, and price range of the home you are interested in buying or selling, records of personal property. For example, we use this information where it is requested by title agents, title companies or otherwise reasonably required in connection with settlement and closing services. This information could also be used in connection with “Buy Before You Sell” transactions.
• Professional or employment-related information, such as occupation, title, performance evaluations, and prior employment history.
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g. email, phone, address), job title, and any other information related to the performance of the agreement with us.

Personal information from Third Parties

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.

• Our Affiliates. We may receive personal information from other companies and brands owned or controlled by HomeLight, and other companies owned by or under common ownership as HomeLight.
• Your Employer / Company. If you engage in our Services through your employer or company, we may receive information from the company such as name and contact information.
• Service providers. Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, and information about your communications and related activities. We may use this information to administer and facilitate our services and our marketing activities.
• Business Partners. We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Single Sign-On. We may use single sign-on (“SSO”) to allow a user to authenticate their account using one set of login information, including through Google. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, language preference, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also send you service-related emails or messages (e.g., account verification, customer support, changes, or updates to features of the Services, technical and security notices).
• Social media. When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Other sources. In addition to third-party data providers, we may also collect personal information about individuals that we do not otherwise have from, for example, government agencies or publicly available sources, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Other Uses of Personal information

In addition to the above, we may use personal information:

• To provide you with products or services that you request or in which you express interest;
• To provide, improve, test, update and monitor the services; or diagnose or fix technology problems;
• For training and quality and assurance purposes, such as by reviewing recordings of conversations that we have with you;
• To manage our organization and its day-to-day operations;
• To communicate with you such as via social media and to send you email messages and notifications;
• To customize the advertising and content you see;
• To respond to your emails, comments, questions, or requests for customer service;
• To market our Services to individuals, including through email and social media;
• To administer, improve and personalize our Services, including by recognizing individuals and remembering their information when they return to our Sites;
• To facilitate customer benefits and services, including customer support through our command center services;
• To identify and analyze how individuals interact with our Services;
• To conduct research and analytics on our user base and our Services;
• To improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
• To test, enhance, update and monitor the Services, or diagnose or fix technology problems;
• To help maintain the safety, security and integrity of our property and Services, technology assets and business;
• To facilitate corporate business transactions, such as a merger, acquisition, joint venture, or financing or sale of company assets, or in the event of insolvency, bankruptcy or receivership;
• To defend, protect or enforce our rights or applicable contracts and agreements;
• To prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• To comply with legal obligations; and
• For any other purpose we may describe when you provide the information.

3. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use the Services when you visit our online services, read our emails, or otherwise engage with us, such as through chat services. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use cookies and other tracking technologies to automatically collect usage and device information, such as:

• Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, mobile carrier, model and manufacturer, phone number, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our Services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Services.
• Information about how you use the Services, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Service or engage in chat features through our Services. For example, we use Hotjar in order to better understand our users' needs and to optimize our Service. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
• Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
• Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described above.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Data Collection and Online Advertising below.

For more information about your choices regarding cookies, please see the Your Choices section below.

4. OUR DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information with:

• With Affiliates: We may disclose personal information between and among HomeLight and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
• Online Advertising Partners: We may also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see the Your Choices section below.
• Business and Commercial Partners. We may share personal information with unaffiliated third parties who partner with us to deliver our services or on our commercial activities. Depending on the choices you have made and the nature of the joint activity, these third parties may contact you regarding products or services that may interest you.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Service Providers: In addition to the third parties identified above, we may share personal information with third party service providers who provide us with services, such as data analysis, online advertising, payment processing, order fulfillment, IT services, customer service, and other similar services.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement: ul li in connection with the establishment, exercise, or defense of legal claims; li to comply with laws or to respond to lawful requests and legal process; li to protect the rights and property of HomeLight, our agents, customers, and others, including to enforce our agreements, policies, and our Terms of Service; li to detect, suppress, or prevent fraud; li to reduce credit risk and collect debts owed to us; li to protect the health and safety of us, our customers, or any person; or li as otherwise required by applicable law.
• With Your Consent or At Your Direction: We may disclose personal information about you to certain other third parties, such as real estate agents and potential pre-approved cash buyers, with your consent or at your direction.

5. THIRD PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third party advertising companies to serve you targeted third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and other similar information. If permitted by your device settings, they may also collect location data through GPS, Wi-Fi or other methods. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see the Online Ads subsection of the Your Choices section below, to learn how you can opt out of interest-based advertising.

We may engage in the following:

• Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, LinkedIn, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

For more information about these practices and your choices regarding cookies, please see the Your Choices section below.

6. YOUR CHOICES

• Phone, Text and Email Communications. From time to time, we may call you, send you text messages, or send you emails regarding: updates to our Services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. p If you wish to unsubscribe from promotional phone calls, call us at 866-627-3398 to ask to be removed from our promotional calling list. p If you wish to unsubscribe from promotional text messages, reply STOP to any one of our promotional text messages. p If you wish to unsubscribe from promotional emails, simply click the “unsubscribe link” provided at the bottom of the email communication. p Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Modifying and Deleting your Information: If you have an account with us, you may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect. If you have any questions about modifying or updating any information in your account, please contact us at legal@homelight.com.
• Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.
• Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
• Cookies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online Services, as some features and services on our online Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
• Online Ads. We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at www.aboutads.info/appchoices. p Unless you have exercised your Right to Opt Out (as described in the “Your Privacy Choices” section of our U.S. Privacy Disclosures), we may “sell” or “share” your personal information to third parties for targeted or cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties. To exercise your right to opt-out of the sale or sharing of personal information as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please see the Your Privacy Choices section of our U.S. Privacy Disclosures.

7. REGION-SPECIFIC DISCLOSURES

Depending on your country, region, or state of residence, certain rights may apply to you. Please refer below for disclosures that may be applicable to you:

• Please click here for additional U.S. state-specific privacy disclosures.

8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

For your convenience, our Services may provide links to third-party websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.

9. CHILDREN’S PRIVACY

Our services are not intended for children under the age of 16. We do not knowingly solicit or collect personal information from children under the age of 16. If we learn that any personal information has been collected inadvertently from a child under 16, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 16, please contact us at privacy@homelight.com.

10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time at our sole discretion. We will notify you about material changes in the way we treat personal information by sending a notice to the primary email address specified in your HomeLight account, by updating the “Last Updated” date at the top of this Privacy Policy, and/or by placing a prominent notice on our Sites. It is your responsibility to review this Privacy Policy periodically.

11. CONTACT US

If you have any questions regarding this Privacy Policy, or any other privacy-related questions, please send an email to legal@homelight.com.

ADDITIONAL U.S. STATE PRIVACY DISCLOSURES

Last Updated: September 27, 2023

For Nevada Residents: If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at legal@homelight.com.

Depending on your state of residency, these Additional U.S. State Privacy Disclosures (“U.S. Privacy Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal information processing practices and the choices you may have with regards to the processing of your personal information. For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our Services, please visit our Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Privacy Disclosures.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect various categories and types of personal information from a variety of sources and for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use personal information, please review the How We Collect and Use Personal information and Our Disclosure of Personal information sections of our Privacy Policy to learn more.

DISCLOSURE OF PERSONAL INFORMATION

In the previous 12 months, we may have disclosed all of the categories of personal information we collect with third parties for a business purpose, as described in the Our Disclosure of Personal information section of our Privacy Policy. The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) other affiliates in our family of companies; (ii) service providers and advisors; (iii) business partners; (iv) marketing and online advertising providers; (v) analytics providers; and (vi) social networks.

SALE OF PERSONAL INFORMATION AND SHARING FOR TARGETED ADVERTISING

In the previous 12 months, we have sold or shared for targeted advertising purposes the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:

• Identifiers
• Commercial Information
• Internet/Network Information
• Inferences

Sensitive Information

The following personal information elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

• Government identifiers such as Social Security Number or Taxpayer Identification Number;
• Account name and password;
• Financial account, debit card, or credit card number in combination with any required security or access code;
• Race or ethnic origin;
• Citizenship status; and
• Precise geolocation.

We only use or disclose sensitive information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, for detecting security incidents, fraud and other illegal actions, to ensure the physical safety of natural persons, to perform services on behalf of the business, or for short term transient use. We only collect and process sensitive information without the purpose of inferring characteristics about a consumer, and we do not sell sensitive information or process or otherwise share sensitive personal information for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

How to Exercise Your Privacy Rights

To Exercise Your Privacy Rights

Please submit a request by:

• Email with the completed downloaded form attached; or
• Calling 866-627-3398.

We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and state of residency. Although we try to limit the personal information collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

To Exercise the Right to Opt Out of the Selling or Sharing of Personal information for Targeted Advertising Purposes

Unless you have exercised your Right to Opt Out, and as described in the Our Disclosure of Personal information section of the Privacy Policy, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration or “share” your personal information to third parties for cross-context behavioral advertising (targeted advertising). The third parties to whom we sell or share personal information may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.

You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

You may submit a request by calling 866-627-3398 or by filling out our online form

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at privacy@homelight.com with the subject line, “Privacy Request Appeal.”

Minors Under Age 16

We do not sell personal information of consumers we know to be less than 16 years of age unless they have opted in (“Right to Opt In”). Please contact us at privacy@homelight.com to inform us if you, or your minor child, are under the age of 16.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e. you are the child’s legal guardian or authorized representative).

California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

Personal information Collection

In the last 12 months, we may have collected the following categories of personal information:

• Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
• Personal information, as defined in the California customer records law.
• Commercial information, such as primary business address, secondary business address, ownership information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, home purchase information, such as the address, type of home, and price range of the home you are interested in buying or selling, records of personal property.
• Professional or employment-related information, such as occupation, title, performance evaluations, and prior employment history.
• Characteristics of protected classifications under California or federal law, such as age, date of birth, gender, race, color, origin, citizenship, and ethnicity.
• Geolocation data, such as city/state and zip code.
• Internet or other Electronic Network Activity information, such as log information, IP address, access times, operating system, browser type and language, Internet service provider, and website interactions and browsing history.
• Inferences drawn from the above categories of personal information reflecting your preferences, characteristics, behaviors, psychological trends, attitudes and abilities.

For more information about our collection of personal information, the sources of personal information, and how we use this information, please see the How We Collect and Use Personal information section of our Privacy Policy.

Disclosure of Personal information

As described in the Our Disclosure of Personal information section of our Privacy Policy, we disclose personal information with a variety of third parties for business purposes or we may sell or share your personal information to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see the “Your Privacy Rights” section above).

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained above, to third parties for a business purpose. In the previous 12 months, we have also sold or shared for targeted advertising or analytics purposes the following categories of personal information to third parties: Identifiers, Commercial Information, Internet/Network Information, and Inferences.

In addition, please see the Third-Party Data Collection and Online Advertising section of our Privacy Policy to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us.

Data Retention

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Therefore, we retain personal information for as long as the individual continues to use our services for the purposes explained in the How We Collect and Use Personal information section in our Privacy Policy. When an individual discontinues the use of our services, we will retain their personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain recordings of your conversations with us, the personal information supplied when joining our services, including complaints and any other personal information supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

Notice of Financial Incentives

We may offer various programs, promotions and other financial incentives that may result in differences in our prices or services offered to consumers. These incentives may include rebates for some clients that come in as a lead through our partners, provided such rebates are legally permitted in the applicable state.

To obtain access to certain of these programs and other offerings, we may collect and retain personal information as further described in the disclosures relating to the applicable program or offering. We have determined that the value of these programs and other offerings are reasonably related to the value of the personal information we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal information we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal information, as well as the expenses related to facilitating the program or offering.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information below. Participating individuals may also opt out of receiving marketing communications by emailing us at privacy@homelight.com.

“Shine the Light” Disclosures

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.

Updates to These U.S. Privacy Disclosures

We will update these U.S. Privacy Disclosures from time to time. When we make changes to these U.S. Privacy Disclosures, we will change the “Last Updated” date at the beginning of these U.S. Privacy Disclosures. If we make material changes to these U.S. Privacy Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with these U.S. Privacy Disclosures or other privacy-related matters, please send an email to legal@homelight.com.