Homestead Privacy Policy 

We at Homestead America, Ltd, ("Homestead,” "our,” "we," or "us") value our users' privacy as we know that you care about how your personal information is collected, used, safeguarded, shared, and we take that seriously. Kindly read the following terms to learn more about your privacy as this Privacy Policy ("Policy") will help you understand how we collect and use personal information from those who use access and make use of our Site and the services that we offer.

This privacy policy also helps you understand the rights and choices that you have with respect to your personal information.

By accessing or using the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

1. Changes to this Privacy Policy

We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time Homestead decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be promptly notified by email. Users at that time shall have the option as to whether to permit the use of their information in this separate manner.

2. What does this privacy policy cover?

This Policy applies to Homestead, and it governs any and all data collection and usage by us in compliance with applicable regulations. Through the use of these Services, you are consenting to the data collection procedures expressed in this Policy.

We gather various types of information from our users, as explained in more detail below, and we use this information internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to make payments, communicate with you, and to analyze how you use the Services. In certain cases, we may also share some information with third parties, but only as described below.

Please note that this Policy does not govern the collection and use of information by companies that Homestead does not control, nor by individuals not employed or managed by us. If you visit a website that is made available via the service or link, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand how such websites garner, make use of and share the information collected.

3. Information we collect

When you make use of our Services, we may collect and process a variety of personal information about you from various sources which may include but are not limited to the following as described below:

a. Information you provide:

i. “Account and Personal Information" means any information which, either alone or in combination with other information we hold about you, identifies you as an individual or as an organization, including, for example, your contact information such as your name, email address, telephone, birth date, social security number (“SSN”), government-issued ID, location information, demographic information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data which you may be required to provide when using the Service.

We may also collect information when you sign-up for the Service through our third party partners, engage our interactive services, provide feedback and survey responses, request customer support or otherwise communicate with us.

ii. "Anonymous/Aggregated Data" means data that is not associated with or linked to your Personal Information; Anonymous Data does not, by itself, permit the identification of individual persons. We collect, use and share Anonymous Data such as statistical or demographic data for any purpose. Anonymous Data may be derived from your personal information but is not considered personal information in law as such data does not directly or indirectly reveal your identity. For instance, Homestead may aggregate or anonymize your usage data to calculate the percentage of users accessing a specific Service feature. However, if Homestead combines or connects Aggregated Data with your personal information so that it can directly or indirectly identify you, Homestead treats the combined data as personal information which will be used in accordance with this privacy notice.

Please note that you can choose not to provide us with certain information, but this may limit the features of the Services you can use.

b. Information we collect automatically:

We may collect certain information (which does not identify you as an individual) about your use of the Service through the use of tracking technologies or by other passive means and other relevant statistics, including the following:

i. Usage Data: When you access and/or make use of our Services, we collect details of your visit such as traffic data, date and time of your visit to the Service, logs, location, error tracking information, and other usage data and resources that you access and use on or in the Services.

ii. Log files; device and location information: We may also collect information about your mobile, internet connection, and computer devices, such as your operating system, IP address, and browser type. For example, we make use of Google Analytics or other analytics services to track and collect these kinds of information. We may also collect location information through the use of geolocation technology.

iii. Cookies: When you access and/or make use of our Services, we may send one or more cookies (small text files containing a string of characters) to your device that

uniquely identifies your browser. We use cookies to improve the quality of the software and service by storing user preferences and tracking user trends. You can refuse to accept browser cookies on your computer by activating the relevant browser setting, and you may have the same capabilities on your mobile device under the choices for your operating system or browser. If you choose this option, you may be unable to access or utilize certain features of our Services. Unless you have configured your browser or operating system to reject cookies, our system will send cookies when you visit our website.

iv. Links: The Service or contents made available on the Service may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our services and design.

v. Beacons: Beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Service and to recognize users by accessing our cookies. We may employ beacons to facilitate Service administration and navigation, track the actions of users of the Service, compile aggregated statistics about Service usage and response rates, and provide an enhanced online experience for visitors to the Services.

vi. Analytics services: We may use third-party analytics services ("Analytics Services"), such as Google Analytics to help collect, monitor, visualize, report, integrate and analyze how users use our Services. Google Analytics also make use of cookies, which are text files placed on your computer, to help our Services analyze how users use the Services. You can find out more about how Google uses data when you visit our Services by visiting "How Google uses information from sites or apps that use our services" (located at https://policies.google.com/technologies/partner-sites).

Furthermore, the information generated through cookies or other technologies about your use of the Homestead Service (the "Analytics Information") may be transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Service's ability to use and share Analytics Information is restricted by such Analytics Service's terms of use and privacy policy.

vii. Payment transaction information: Through the use of a third-party payment processor, certain financial information used by you for payment transactions on our Services may be collected. Payment amount, date and time of the transaction, payment instrument expiration date and billing postcode, user’s address and other details related to the transaction may be collected as well.

c. Information automatically collected by third parties about you

Some embedded content on the Service may be served by third-party service providers. Please note that these companies may also use cookies or other similar technologies to collect data about you, both on the Homestead Services and throughout the Internet. Data collection and use by those third parties is subject to the privacy policies of those third-parties

Please rest assured that this site will only collect personal information that you knowingly and willingly provide to us by way of surveys, completed forms, and emails. Homestead intends to use personal information only for the purpose for which it was requested, and for any additional uses specifically provided for on this Policy.

4. What we use your personal information for

Homestead uses the information collected from you to provide, improve, and develop the software and services we provide to you, serve you offers that we think might be of interest to you, communicate with you, offer you a better service, and protect us and our users. When you interact with or make use of the Homestead service, we use a variety of technologies to collect information about you for various reasons.

a. To make available and provide the service to you and to enable certain functionalities for your use on our Services.

b. For your safety and security. To validate your identity and ensure the security of our users -e.g., by sending an email or SMS to confirm that you are the owner of the email address or phone number linked to your account.

c. To personalize the content and information that we may send or display to you, personalized help and instructions, and otherwise personalize your experiences while using our website and/or our services, such as developing and offering you new features to the services we are providing you.

d. We use the information we collect about you to develop new and improve existing products and services by conducting research and analysis to help develop relevant and helpful features.

e. For communication purposes: We may send emails, product updates and related emails to the email address you provide to us and text messages to any cellphone number you provided to us, and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes. We use personal information that we gather from you to communicate with you in relation to your use of the Homestead Service via different channels (e.g., by email and phone).

f. For promotions and marketing purposes: We also make use of the information we have about you to promote our services, products and other offerings to you. For instance, we may use certain information, like your email address to send information or Homestead content to you that we think may be of interest to you by email, or other means and send you marketing communications relating to our business and the services that we offer. We use this information to promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences.

g. Fraud detection and prevention: Increase and maintain the safety and security of our products and services, community and prevent misuse. We use personal information to detect and prevent fraud and abuse in order to protect us and ensure the safety of our users, Homestead, and others. We also use collected information to protect against, identify theft and prevent fraud and other criminal activity, claims and other liabilities.

h. Provide, troubleshoot, and improve Homestead Services: We use your personal information to understand, diagnose, troubleshoot, and fix issues with the Homestead Services. We also use such information to operate, evaluate, develop, manage and

improve our Services (including operating, administering, analyzing and improving our products and services; developing new features and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions).

i. Comply with and enforce applicable legal requirements: In certain cases, we collect your personal information to stay in compliance with laws and relevant industry standards and policies, including this Privacy Policy and our Terms and Conditions of use.

5. Personal Information that we share

Except as described below, we do not sell, rent, trade, or otherwise share personal information collected through the Service because we are committed to maintaining your trust:

a. Service providers: We may provide collected data about you to certain service providers such as Entrata to help provide the service to you, keep our services running or support our website. Such service providers may also include our payment processor/partners that we may make use of from time to time for payment processing when you make a payment on our website. They may use your data to perform services for us and may have access to, store, and process your personal data to provide services on our behalf. Such services may also include marketing service providers, verifying your identity, preventing, detecting and protecting against fraudulent activity or abuse of our services, conducting internal research and analytical assessments, processing your transactions and providing you with customer support services. We may share personal information or any information collected through the Service with these third parties for the purpose of enabling them to provide these services and they may have controlled and limited access to the database of user information.

b. Subsidiaries, business partners and affiliates: We may share personal information or any information collected through your use of the Service with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes. We may share your Personal Information with our business partners. Some of these business partners may use your personal information to facilitate the offering of services or products that may be of interest to you. We may also share your Personal Information as otherwise described to you at the time of collection.

c. Public forums: Our Services may provide publicly accessible blogs, message boards or community forums. You understand that if you directly disclose any information through our blogs, public message boards, or forums (including profile information associated with the account you use to post the information) it may be seen, read, collected and used by any member of the public who accesses these websites. Your posts and certain profile information may remain accessible even after you terminate your account with us. So, we hereby urge you to consider the sensitivity of any information you decide to disclose in this way. We may delete or edit any information you have posted on the websites if you so request, as described herein this policy. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

d. Analytics Partners: When you provide your personal information to us, we may make certain personal information available to certain third parties for analytics purposes, including but not limited to leveraging third-party tools and services to host, track, integrate, manage user's interests, usage pattern, and/or functionality available through our Services. We will only share your personal information with analytics partners for the improvement of our own service and/or to deliver the Homestead services to you. We do not in any way sell your personal information to advertisers.

e. Merger and acquisition: We may disclose or transfer personal information or any information collected through your usage of our Service to third parties who acquire all or a portion of Homestead’s business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

f. Compliance with laws: We may disclose personal information or any information collected through your usage of the Homestead Service if we are required to do so by law or pursuant to legal process, in response to a request from government officials, law enforcement authorities or a valid subpoena, or as necessary or appropriate in connection with an investigation of illegal activity, including without limitation to prevent, investigate, detect or prosecute any criminal offense or attack.

g. Consent: We may share personal information in accordance with any consent you provide.

h. Aggregate Information: We share aggregate statistical data for the improvement of our Services. We may also share aggregated or de-identified information with third parties at our discretion.

6. Data retention and deletion

We keep your personal information only as long as necessary to provide you with the Homestead Service and for legitimate and essential business purposes, such as maintaining the performance of the Homestead Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal information for as long as you are a user of the Homestead Service.

If you request, we will delete or anonymize your personal information so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal information, including situations such as the following:

a. If there is an unresolved issue relating to your use of the service, such as an unresolved claim or dispute, we will retain the necessary personal information until the issue is resolved;

b. Where we need to retain the personal information for our legal, tax, audit, and accounting obligations, we will retain the necessary personal information for the period required by applicable law; and/or,

c. Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users and the platform.

7. Your privacy rights

General Data Protection Regulations grant you certain rights ('Information Rights') which provide you with:

a. Right of rectification or erasure: If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will/shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure. Note that we may have a legal obligation to retain some or even all personal information about you under relevant laws. We may also have the legal right to retain the information you have requested to be erased.

b. Right to restriction of processing: You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don't need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal information.

c. Right to data portability: In certain circumstances, you may have the right to request that data which you have provided to us be made available to you so that you can transfer this to another data controller.

d. Right to object: You have a right to object to our processing of your personal information where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.

e. Right to withdraw consent: You have the right to withdraw your consent for the processing of your personal information where the processing is based on consent. To withdraw consent, please specify what you wish to withdraw consent for, by emailing us at compliance@homesteadcos.com.

f. Right of complaint: If you are unhappy with the way we have used or are handling your personal information you have the right to lodge a complaint with a supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach such a Supervisory Authority. So, please contact us in the first instance by emailing us at compliance@homesteadcos.com.

8. Data security

As a matter of policy, we are committed to protecting your data and as such, Homestead takes precautions to protect your information. We adopt commercially reasonable measures to secure Personal Information by using physical and electronic measures designed to ensure the integrity and security of the Personal Information we hold. When you submit sensitive information via the Service, your information is protected. Any payment transactions will be encrypted using SSL technology. Where you have chosen a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Although we will do our best to protect the personal information that we gather about you, the transmission of information via the internet is not completely secure and as such, we cannot guarantee the absolute security of your data transmitted to the Service; any transmission is at your own risk. We have implemented various

policies including encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal information in our systems.

9. Additional privacy rights for California residents

If you are a resident of California, this section provides additional information about specific rights regarding your personal information in accordance with the California Consumer Privacy Act (“CCPA”).

Personal Information we collect

The following is a list of personal information that we collect or have collected from California residents over the past twelve months. We will update this disclosure from time to time as appropriate.

  • Unique identifiers such as your first name, last name, or similar identifier, address, or IP address;

  • Internet or other electronic network activity information, including content interaction information, such as content downloads, search history, transaction and interaction data on your use of our Service and from links in our emails sent to you; geolocation data, such as the location of your device or computer; inference data, such as information about your purchase preferences, interest, feedback, and survey responses; Other information that identifies or can be reasonably associated with you (e.g., the information you voluntarily provide as you use the Homestead services, such as additional profile information or user-generated content).

How we collect personal information

We obtain the categories of personal information listed above from the following sources:

  • Directly from our Services users when they provide the information to us.

  • Indirectly from you as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From third-party service providers.

Categories of personal information disclosed for our business purpose

The personal information that we disclosed about consumers for a business purpose over the past (12) twelve months falls into the following categories as established by the California Consumer Privacy Act:

  • Identifiers such as your name, email address, billing address, or IP address;

  • Personal information, such as a credit card number, for example, if we use a third-party payment processor;

  • Your age, age range, gender, or other protected classifications, for example, if you choose to participate in a survey distributed by us or fill the User Content form;

  • Geolocation data from your IP address

Access request rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. But only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Designated agents must submit proof that the consumer has authorized them to act on their behalf. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If you wish to do any of these things, please contact us. Once we receive and verify your request, we will disclose it to you. You may make up to two (2) requests, no more than twice in a twelve-month period for information as to:

  • The categories of personal information we collected about you or shared with our service providers for business purposes.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting that personal information.

  • The specific pieces of personal information we collected about you.

Right to deletion of personal information

You have the right under the California Consumer Privacy Act to request the deletion of your personal information. If you wish to do this, please contact us. Depending on your data choices and subject to applicable regulations, certain services may be limited or unavailable.

We may, however, deny your deletion request if retaining the information is necessary for us or our service providers(s) to:

  • Complete the purpose for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Exercise free speech; ensure another consumer's right to exercise their free speech rights or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq. or other legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

No discrimination

You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA, and Homestead will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.

10. Additional Privacy Rights for Texas Residents

If you are a resident of Texas, you have the right to request access to your personal information, request correction of inaccuracies, request deletion of personal information, and appeal denied requests under the Texas Privacy Protection Act (“TPPA”) and the Texas Data Privacy and Security Act (“TDPSA”). Under the TDPSA, you also have the right to opt out of targeted advertising and the sale of your personal information, though Homestead does not directly sell personal data. You have the right not to receive discriminatory treatment for the exercise of your rights, and Homestead will not discriminate against any consumer for exercising their rights under the TPPA or TDPSA.

11. Children under the age of 18/Age restriction

Homestead's Services are not directed to and do not knowingly collect personally identifiable information from children under the age of thirteen (13). If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps to ensure that such information is deleted from our system's database. Also, for users between the age of thirteen (13) and eighteen (18), you must have your parent’s or legal guardian's permission to use our website and the services we offer.

12. Your choices; unsubscribe or opt-out

a. Account information: You may update certain information you provide to us (such as your password, name and email address) by logging into your Homestead account or contacting us through our support channel at compliance@homesteadcos.com. Also, if you decide to delete your Homestead account, please contact us at compliance@homesteadcos.com but note that we may retain certain information where required or permitted by law. We may also retain cached or archived copies of certain information about you and your usage of the Services for a certain period of time.

b. Marketing emails: If you have subscribed to our e-mail and electronic newsletter communications, you will always have the opportunity to unsubscribe from future communications. You will also have the opportunity to "opt-out" of commercial e-mail from the applicable Homestead Service by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Homestead will continue to adhere to this Policy with respect to any personal information previously collected.

c. Advertising Preferences: We try to serve you ads that we think will be relevant to your interests. If you would like to modify the information we and our advertising partners use to select these ads, you can do so through your preferences settings on the website.

d. Do not track: Some browsers have “Do Not Track” features that let you send a request to sites to not track your online activities. We, like many other sites, do not honor those requests.

13. Links to other sites or resources

Homestead does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other third-party sites or resources. Therefore, we encourage all users and visitors to be aware when they leave our Site and to read the privacy statements o

website that collects personally identifiable information. This Privacy Policy Agreement applies only and solely to the information collected by our Site.

14. How to contact us

Feedback, comments, requests for technical support, and other communications relating to the Site and the services should be directed to us at compliance@homesteadcos.com.