Privacy Policy

Updated: April 2022

Introduction

Your privacy is important to us. This privacy policy (“Privacy Policy”) applies to the use of the Sites (as defined below), including by both consumers and Professionals. This Privacy Policy explains what personal data we collect from you and how we use it. We encourage you to read the summary below.

Contacting Us

If you have concerns about this Privacy Policy or our privacy practices in general, contact us at:

Legal Department, House Method

c/o Three Ships

1122 Oberlin Road

Raleigh, NC 27605

legal@housemethod.com

“Professional(s)” means individuals, companies and other organizations or persons engaged in a business relevant to the Sites, including, without limitation, homebuilders, real estate professionals, re-modelers, seniors-related housing, product or service providers, home service professionals and other service professionals.

“Consumer” (or “consumer”) has its ordinary meaning but generally includes any visitor to or user of the Sites other than Professionals.

Except as otherwise indicated, Professionals, consumers and other persons using the Sites are individually and collectively referred to as “you,” and House Method, together with its affiliates, is referred to as, “House Method”, “we”, “us” and “our.”

We use the Sites to provide you with information, resources, tools, products and services specific to the home products and services industry and related markets, and to provide you with information about us and our advertisers, and our respective products and services.

Our website, and mobile apps, mobile-optimized websites and other applications and/or electronic media (such as emails that House Method sends), linking to or bearing this Privacy Policy and operated by or on behalf of House Method (collectively, the “Sites,” and each, a “Site”) are committed to implementing policies and procedures designed to provide for privacy and security and deliver the best possible online experience.

To that end, we want you to understand what kinds of information we gather about you, how this information, particularly Personal Information (defined below), is used and safeguarded, and how you can control its use.

In conjunction with this Privacy Policy, you should also review our Terms of Use for a more complete understanding of the rules governing our Sites.

What Information is Collected From Me?

Information You Give Us:

Information collected from you will vary, depending on how you access, visit, use or otherwise take advantage of the Sites and what information you may choose to provide to us (whether through email or otherwise). It may be possible to browse various sections of the Sites without submitting any Personal Information.

“Personal Information” means individually identifiable information about you that we collect online or otherwise through the Sites, including, but not limited to, your full name, a username and password, email address, phone number, physical address, or and for certain e-commerce transactions your credit card information.

Information in a form that is aggregated with other information so as not to be reasonably identifiable with you, and information in a form that otherwise is detached, combined, organized, segmented, modified or processed so as not to be reasonably capable of being associated with you, will not be considered Personal Information, and will not be restricted by this Privacy Policy as to use, sharing or otherwise.

If you access, visit, use or otherwise take advantage of certain of our products and/or services, or certain of our tools, Sites or Site functionality, we may receive or you may be asked to provide Personal Information. Whenever we ask for Personal Information, we strive to provide a link to this Privacy Policy to help you understand how Personal Information will be used before you decide whether to disclose it. You can choose not to provide us with Personal Information, but then you may not be able to fully take advantage of certain features of our Sites and we may not be able to provide you with certain requested information, products and/or services.

Automatic Collection of Information: Like many websites or media on or using the Internet, we automatically track certain information about you as you access, visit, use or otherwise take advantage of our Sites; this is for various reasons, including to help us (i) better understand, offer, operate, improve and modify the Sites, (ii) better understand how the Sites are used and experienced and (iii) enhance, or better understand how we can enhance, your or others’ overall experience on one or more of the Sites, including providing advertising and other information that is relevant to you.

This tracked or automatically gathered information may include, among other things, your computer’s (as used in this Privacy Policy, meaning a computer, tablet, smartphone or other relevant device) IP address (Internet Protocol address), identification number or location, the URLs and Site pages you’ve visited, sections of or content on Site pages on which you click or in which you are interested, the number of times you visit each Site page, what downloads and/or search queries you have made, when emails are opened or links are clicked, how long you spent on particular sections of each Site and on each Site generally, and information about your computer, browser or operating system type.

This automatically gathered data includes information provided through the use of “cookies” (which is described in more detail below) and other technology or methods and may also include information gathered in connection with your use of third-party Web sites and media (for example, through the use of “web beacons,” “clear GIFs” or “pixels”). Although not restricted by this Privacy Policy, we may also gather and use information, generated our self or obtained from others, derived from or based on information you have provided or that is obtained by way of the collection means referred to in this Privacy Policy (e.g., automatically).

Information from Cookies: Cookies are small files that we or others send to and store on or with your computer so that your computer, browser, mobile app or other application can be recognized as unique the next time you access, visit, use or otherwise take advantage of the Sites or other media. Cookies may also reflect demographic data pertaining to you or other data linked to information you submit. One use or consequence of cookies is to enable you to receive customized ads, alerts, content, services or information.

You are always free to decline any cookies we use by adjusting the settings of your browser, as your browser may permit; however, some products, services or features might not be available or operate properly if cookies are not enabled. Some of our advertisers and third-party service providers may also utilize their own cookies.

In addition, we, our service providers and others sometimes use “web beacons” or “clear GIFs.” These perform statistical and administrative functions, such as ascertaining and measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or I.P. address) and positioning images, and typically do so without detracting from your online experience. Web beacons and clear GIFs are not necessarily designed to collect Personal Information. In addition, if you have provided your email address, we might use a non-human unreadable form (or “hash”) of your email address to deliver, or facilitate delivery of, relevant advertisements and information to you on or by way of the Sites or on or by way of other Web sites or media, including, for example, popular social media sites and features.

Information Sharing Disclosure – How Is Information About Me Used and Shared?

The use of information about you depends on the context in which it is collected. Therefore, pay special attention to the categories below that relate to the features of the Sites that you wish to utilize.

Personal Information

We may share the Personal Information we collect from you with your consent or under the following circumstances or understandings.

User-Requested Services and Information: Certain features, products or services on or of our Sites may seek or obtain Personal Information from or about you, which may be used in the following ways:

The information you submit is used by us to provide the information, features, product or service you’ve requested. For example, we might try to show you ads or stories that we think you’ll find interesting based on your activities on our site.

We may also share this information with others to fulfill your request or to facilitate your use of the information, features, products or services, or as otherwise outlined in this Privacy Policy.

When sharing Personal Information in such a manner, we may also share your computer’s Internet Protocol (IP) address, identification number or location. In addition, we may use and share any registration information that you submit as set forth in the “Registration Information” section below.

• We may use other companies and individuals (1) to perform supporting functions for the various tools, functionality, information, products and services offered through our Sites on our behalf, (2) to perform or support various tasks or initiatives instrumental to the business of, or related to operating or improving, the Sites or (3) to assist us in testing, maintaining or improving the features, content or effectiveness of the Sites or in performing research or development. These service providers may be permitted to receive from us and use information collected from you but will not be authorized by us to use Personal Information for any other purpose other than in connection with performing the support functions for House Method or such other tasks, initiatives or assistance for or expressly permitted by House Method.
• For information, features, products and services marketed or offered to you jointly or on a coordinated basis by us and a third party, Personal Information may be shared with or independently gathered by the third party. In these situations, House Method will be free to use Personal Information to facilitate such information, features, products and services (or information about them) being made available to you and as otherwise outlined in this Privacy Policy, and you understand the third party may use the information in different ways. Although not always the case, you often can tell when information, features, products or services are marketed or offered jointly or in coordination with a third party because a page or area of the Sites often will be “co-branded” in such cases, will display the third party’s logo and/or name (whether or not along with our own), will describe or reference the relationship between House Method and the third party or will be set up so that you can contact or be linked to the third party or its Web site to initiate, complete or learn more about the transaction. Please be aware that each company we do business with (including, without limitation, Professionals and Providers, each as defined herein) has its own policies regarding its use, sharing and protection of information about you and that such policies may differ from those outlined in this Privacy Policy. If you submit your personal information on the site to learn more about a product, service or partner provided on the site’s content, House Method and/or third party service provider partners may contact you via email, telephone calls, texts or autodialed calls to provide information that might interest you, using the contact information you provide. Your consent is not a condition of purchase.

User-Initiated Communication: From time to time, portions of the Sites may enable you to send email and other types of messages to us or to third parties and to participate in bulletin boards and discussion groups. All such emails and messages, and all such postings to bulletin boards and discussion groups, become our property once you submit them. Your computer’s Internet Protocol (IP) address may be included in any email that you send, whether to us or to third parties. Whenever you choose to initiate these kinds of communication with us, or anyone else, you may be contacted in return. Also, remember that our bulletin boards and discussion groups are open to the public, and, therefore, your postings can be seen by anyone and are not protected by us or any other entity. Please use your own discretion when deciding whether and what to post and whom to contact. We reserve the right, in our sole discretion, to edit or delete postings from our bulletin boards and discussion groups. This reservation of rights shall not under any circumstances obligate us to conduct such edits or deletions, nor shall it cause us to be liable for any such edits or deletions.

Leads and Referrals. If you participate in or inquire about any lead, referral or similar service we may offer:

• We may use the information you submit, as well as other data we might have or obtain ourselves or from other sources (for example, from cookies), to determine which of our participating Professional(s) may be willing, able and/or compatible to serve your needs or possible interests and to assist them or others in doing so.
• We may forward or share information relating to you, which may include such information as well as Personal Information obtained through our sign-up form or otherwise, to certain Professional(s), which may sometimes include multiple Professionals (such as in cases where a given Professional has a marketing or business relationship with one or more other Professionals and designates them to receive such information, or in cases where the nature of a product, service or feature offered on or through a Site is designed to involve participation by multiple Professionals). Those Professionals or their affiliates, contractors, advertisers, agents or other designees may use such information and contact you regarding your needs or possible interests, as may we ourselves. We always endeavor to make clear when your information is being shared with other Professionals. In the EU, one of these professionals is Leads 2 Trade.
• The following paragraph applies only to Professionals; others may not infer any commitments or assurances from such following paragraph.
  • This paragraph applies only to Professionals, but does not apply to a Professional to the extent modified in a separate written agreement signed by an authorized officer of House Method, which agreements may be entered into by House Method in its sole discretion and without notice to others. Professionals might receive information from, or originating from, consumers seeking the Professional’s products or services or related information. These information submissions or related inquiries or leads might include, without limitation, Personal Information. Because protecting personal privacy is important, we require that Professionals treat data received from House Method consumers as if it was still on the Sites and in accordance with this Privacy Policy. Professionals may use the information sent to the Professionals via our Sites only for the purposes of providing the consumer products and/or services about which the consumer inquired or such purpose(s), if any, specified by us in connection with such information being made available to you. We require that Professionals not make any other use of any such data and that Professionals otherwise not share or transmit this information with or to any third party without the consumer’s consent.

Protection of rights: We will release Personal Information or other information we collect from you if we believe that such action is appropriate to: (1) comply with legal process or requirements, including the GDPR; (2) enforce the Terms of Use agreement for the applicable Site; (3) identify, contact or bring legal action against persons or entities who are or we believe have caused or might cause injury to us or a third party, (4) defend or respond to claims brought or threatened against House Method, its employees, directors, suppliers or service providers, Site users or others or (5) otherwise protect or assert the rights, property, interests or personal safety of House Method, its employees, directors, suppliers or service providers, Site users or others. Any such release decisions may be made by us in our sole discretion.

Asset transfers: We continue to develop our business and in doing so might choose to buy or sell, or expand or otherwise restructure (e.g., by way of joint ventures) with respect to, businesses or assets. Personal Information and other information we collect from you is generally one of the assets acquired, transferred otherwise shared or affected in connection with such transactions.

Registration Information: The Personal Information you provide when you become a registered user or customer of one of the Sites is used primarily to help us customize or enhance your or others’ online experience, increase the convenience of accessing new or existing tools, products and services, and, if applicable, provide the information, features, products and/or services you purchase or request. This Personal Information may also be shared among the Sites to make use of the Sites more convenient by, for example, limiting the number of times you have to register with us. Your email address serves as a unique identifier in our record system, and together with your password is designed to help us prevent unauthorized access to information you choose to store on the Sites. The data you give us about your personal preferences and demographics (e.g., your age, ZIP code, occupation or the like), as well as other information we might have or obtain ourselves or from other sources (for example, based on or related to such data), may be used to help us offer content, advertisements, products, and services that we believe will be of interest to you. In addition, we may share this information, in aggregate or other protected form (see “Information You Give Us,” above) or under confidentiality terms, with our current and potential advertisers and service providers so that they, or we, can present and deliver advertisements more effectively.

• Consumers: Unless you specify that you would prefer not to hear from us, we may use the email address and other information (including Personal Information) you provide at the time of registration to contact you for promotional or other purposes. You may have promotional email communications terminated at any time by opting out through your member profile on the applicable Site, or by clicking on any “unsubscribe” link contained in a promotional email. Please be aware that opting out on one of our Sites, does not opt you out from any of our other Sites unless that option is specifically provided. If you would like to request to opt out with respect to all of the Sites please email legal@housemethod.comwith your requests. The following paragraph applies only to Professionals; others may not infer any commitments or assurances from such following paragraph.
• Professionals: This paragraph applies only to Professionals, but does not apply to a Professional to the extent modified in a separate written agreement signed by an authorized officer of House Method, which agreements may be entered into by House Method in its sole discretion and without notice to others. We may offer a newsletter, electronic flyer or similar material to keep Professionals abreast of the products and services on the Sites or other professional products and services. Information such as a Professional’s license number or personal financial information will not be shared with third parties except to complete a transaction or as outlined in this Privacy Policy. Additionally, information provided by Professionals for the purposes of offering the Professional’s products and services to others via one or more of the Sites will be shared with others, including consumers accessing or using one or more of the Sites. To the extent such information is necessary to offer such products and services it typically will be posted on the applicable Site(s). This may include, without limitation, the Professional’s full name, email address, license number, state of license, address, phone number, graphic images and any other data intended to help consumers identify or contact the Professional or related to the Professional’s products or services.

Special Messaging Consent

By submitting a request or inquiry about (or a request or inquiry for information about), or a request or authorization to be contacted about, real estate-, moving-, neighborhood-, mortgage-, credit-, care- or home-related products, services, offerings, procedures, details or matters you are providing to House Method’s associated advertisers, lead customers (e.g., lead or referral service customers), subscribers and Professionals (each, a “Provider”), and to House Method, your consent to be contacted for marketing, informational and related purposes in connection with such request, authorization or inquiry by one or more Providers and by House Method by telephone device (including, but not limited to, being contacted on a recorded line and potentially by use of automated dialing systems and artificial or prerecorded voice messaging), email, mail or otherwise, based on the phone number, email address and/or other data you have provided. This consent applies even if your phone number, email address or other data is on a corporate, federal, State, local or other do-not-contact type of list or directory (such as the U.S. National Do Not Call Registry). You are not required to consent to receiving autodialer calls, or to otherwise provide this consent, as a condition of purchasing any products or services from Providers or House Method. You agree that your submitted request, authorization or inquiry (as described above) acts as your electronic signature for this consent. You acknowledge that for text, SMS, calls and other electronic messages that message and data rates (for example, from your network provider) may apply. We endeavor to obtain your express consent. If you ever prefer to opt-out, email legal@housemethod.com.

When sharing Personal Information in accordance with this Privacy Policy, we may also share your computer’s Internet Protocol (IP) address, identification number or location.

You (whether you are a consumer, a Professional, a Provider or otherwise) consent to House Method (including any designee of House Method) contacting you in any manner consistent with information (including Personal Information) you have provided or we otherwise have pertaining to you or consistent with other instructions, requests, inquiries or consents that have been given by you or on your behalf (whether by way of this Privacy Policy or otherwise).  If for a particular contact we determine we need consent from you we currently do not have (or are not sure we have), House Method (including any designee of House Method) may contact you by any available communication means to seek such consent.

Non-personal Information

Automatically Gathered Information: Information that is automatically, electronically or otherwise gathered, including through the use of cookies and other technology, may be shared among the Sites. It may also be shared with other third parties, including listing providers, advertisers, service providers and others, so that we may better understand how the Sites are used, to enhance the overall experience on the Sites and otherwise in connection with our operation of the Sites and conducting related business. But when so shared with third parties, any Personal Information will be included for such purpose(s) only if first put in aggregated, de-identified or other protected form (see “Information You Give Us,” above) or the third party will be contractually or otherwise restricted as to the use of such Personal Information (for example, restricted to use only in connection with the purpose for which it was shared by House Method).

Children’s Privacy: Our Sites are general audience Web sites and media. If you are under the age of 16 you should not register or provide information on our Sites. We do not collect Personal Information from any person we actually know is a child under the age of 16. If you have knowledge that a child under the age of 16 has submitted Personal Information to us, please email legal@housemethod.com.

How Can I Access and Change Personal Information?

If you would like us to no longer use or share with our affiliates, partners or other service providers, Personal Information we may gather from you to market information to you, please send a request to legal@housemethod.com. We will take reasonable steps to comply with your instructions. We are not responsible for the acts or omissions of our affiliates, partners or other service providers.

How Is Personal Information Protected?

Whenever Personal Information is stored on our computers, that information is protected from unauthorized access or use by way of passwords or other industry-acknowledged means. In addition, servers of ours that store this information are located behind a firewall. Since your Personal Information is especially sensitive, we take special care to keep it secure. We will only electronically transmit or ask for this information over secure Internet connections using precautions such as SSL (Secure Sockets Layer) encryption (an accepted standard for online security), security keys and password authentication from any third parties receiving this information.

Of course, we appreciate your help in safeguarding the integrity of your own and others’ privacy. We hope you’ll use common sense whenever you disclose Personal Information over the Internet. Just as importantly, we encourage you to let us know immediately if you suspect that Personal Information you share with us is being used in any way contrary to this Privacy Policy. Finally, unfortunately no data transmission over the Internet nor any storage of information on servers or other media can be guaranteed or made to be 100% secure; and while we strive to protect Personal Information, as outlined in this Privacy Policy, we cannot promise, guarantee or warrant the complete security of information. To contact us, please send an email to: legal@housemethod.com

Scope of this Privacy Policy: Outside Links

Be aware that our Sites link to other Web sites and media that may collect Personal Information. This Privacy Policy applies only to the Sites, and we are not responsible for the privacy practices, nor the content, associated with any linked Web sites. You should refer to the privacy policies and statements of other Web sites or contact the respective Webmasters of those Web sites to obtain information regarding their information collection, security, use and disclosure policies.

Online Behavioral Advertising (OBA) – Information

Sometimes ads might appear on the Sites that are delivered to you based on OBA methods. (Please see the definition of “OBA” below.) If such ads are displayed to you, the purpose typically is to deliver ads to you that are expected to be of greater relevance to you (because they tend to relate to topics of interest to you as indicated by such collected data), and thus more helpful to you while potentially being more effective for advertisers as well. Such ad-delivery and data-collection normally is performed by third parties not affiliated with us. However, if you prefer not to receive ads delivered to you on this Site based on OBA, then you can click About Ads and you will be presented with a Web site offering the opportunity to eliminate or reduce the receipt of ads on this Site delivered to you based on OBA, or information on how you may do so. Similarly, you can also click Opt Out with respect to ads by advertisers who cooperate with the Network Advertising Initiative (“NAI”) and its self-regulatory online behavioral advertising principles, and opt out of an NAI member’s behavioral advertising program. With respect to the Sites, we endeavor to comply with OBA-related guidelines known as the Self-Regulatory Principles for Online Behavioral Advertising as published in July, 2009, by a consortium of leading advertising associations including the Council of Better Business Bureaus and others (including the AAAA, ANA, DMA and IAB). Note that when we refer here to “you” or “your” in connection with OBA, this oftentimes means a computer, IP address (Internet protocol address) or other device that presumably you use, or is associated with you, in connection with use of the World Wide Web. Accordingly, by “Online Behavioral Advertising” (or, “OBA”), we mean the collection of data online from a particular computer or device regarding Web viewing behaviors over time and across non-affiliate Web sites (meaning, Web sites other than this Site or other of the Sites) and for the purpose of using such data to predict user preferences or interests to deliver advertising to that computer or device based on the preferences or interests inferred from such Web viewing behaviors. Certain things that are not included as OBA (some of which have been addressed elsewhere in this Privacy Policy) are: collection on one or more of the Sites of viewing behavior on such Site(s) solely for use on or in connection with one or more of the Sites (including the delivery of ads on the Sites); the logging or reporting of ad performance or other ad metrics such as page views or the number and type of advertisements delivered (such reporting may include, for example, reporting by us to one of our service providers or customers, or vice versa); the activity itself of causing ads or advertising-related services to be delivered (apart from whether OBA is involved); and Contextual Advertising. By “Contextual Advertising,” we mean the delivery of advertisements based on (i) the content of one or more of a Site’s Web pages, (ii) a search query on one of the Sites or (iii) a user’s behavior on one or more of the Sites during the same online session during which the ad is delivered.

Additional EU Disclosures:

Legal Basis:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where you have consented to a certain use of your personal data
• Where we need to comply with a legal or regulatory obligation
• To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.

Data controller:

We are the data controller of all personal data collected through our Site. To contact us, please see the section titled “Contact Us”. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager at legal@housemethod.com.

Provision of personal data and failure to provide personal data:

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.

Collection of Personal Information from third party sources:

We also collect personal data about you from various third parties and public sources.

Withdrawing your consent:

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at legal@housemethod.com.

Data Transfer:

We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.

Use of your personal data for marketing purposes:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

• Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of Three Ships and its related businesses for marketing purposes.
• To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.

Data Subject Rights:

If you are a situated in the EU, under GDPR, as a data subject, you have the following rights:

• Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
• Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
• Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
• Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
• Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
• Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
• To exercise your rights under the GDPR, please contact us at legal@housemethod.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data.  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

Additional Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

CATEGORY	EXAMPLE	COLLECTED
A. Identifiers.	A real name, Internet Protocol address, email address, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability 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 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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

• Complete the transaction for which we collected the personal information, provide a good or 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.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer 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.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message.

We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.

Effective Date and Modifications

This Privacy Policy is effective as of the date first written above (the “Recited Date”) and may be updated and modified from time to time by us in our sole discretion. If we choose to update or modify this Privacy Policy, such updated or modified policy shall become effective on the date that is five (5) days after its posting on the applicable Site(s) (the “Modification Effective Date”); this is true even if it were to happen that the Recited Date (as also modified) is a date earlier than the Modification Effective Date, in which case this Privacy Policy, as updated or modified, is effective as of the Modification Effective Date.  We encourage you, therefore, to periodically review this Privacy Policy and the Sites in order to keep apprised of our current privacy practices. If you do not agree to any provision of this Privacy Policy, or any update or modification of it, please do not use the Sites.