TRUEPARITY PRIVACY POLICY

Effective Date: July 7, 2022

This Privacy Policy describes how TrueParity handles personal information that we collect through our website, application, and any other sites or services that link to this Privacy Policy (collectively, the “Services”).TrueParity’s mission is to connect homeowners and real estate agents in order facilitate property sales. This Policy applies to all visitors and users of the Services, including real estate agents bidding for the opportunity to list a property (“Agents”), and property owners (or trust lawyers or trust executors working on such individuals’ behalf) looking to sell a property (“Owners”).

Personal information we collectInformation users submit to us:
Contact and account information
, such as your first and last name, phone number, email address, password, profile photos, and account biographies. This information may be part of your public profile page and may be publicly visible.

Payment information, such as your credit card or bank account number and billing address. This information is processed by our payment service provider, Stripe, and we do not have access to your payment information.

Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

Usage information, such as information about how you use the Services and interact with us and other users, including information associated with any content you upload to the Services or otherwise submit, and information you provide when you use any interactive features of the Services.

Marketing information, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.

Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Additional information Agents provide to us:

License information,
such as your Agent License Number and Broker License Number.

Real estate experience, such as your years of experience, the name and logo of your brokerage, the number of properties you have sold in the past 12 months, and the dollar amount of the properties you have sold in the past 12 months.

Additional information Owners provide to us:
Property information, such the property address, description, and pictures and videos of the property.

Information we obtain from third parties:
Publicly available property information.
We will use the property address Owners provide to us to collect information about the property from public sources, such as county records and online databases. This may include information such as the number of beds, bathrooms, square footage, lot size, property type, and property description.

Social media information. We may maintain pages on social media platforms, such as Facebook, TikTok, Instagram, LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information such as your biographical, educational, and professional experience, and we will treat such information in accordance with this Privacy Policy.

Third-party login information. When you link, connect, or login to the Services with a third party service (e.g. Google, Facebook, or Apple), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Automatic data collection.
We, our service providers, and advertising partners may automatically log information about you, your computer or mobile device, and your interactions over time with our Services, our communications and other online services, such as:

Device data, ****such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies
, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal informationTo operate our Services:
Provide, operate, maintain, secure and improve our Services;Verify Agents’ credentials with their state’s real estate licensing agencies;Obtain information regarding Owners’ properties from public sources;Enable Agents and Owners to connect, interact, schedule in-person meetings, and facilitate the listing and sale of a property;Provide our users with customer service;Fulfill payments;Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages;Understand your needs and interests, and personalize your experience with our Services and our communications; andRespond to your requests, questions and feedback.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:

Direct marketing. We or our advertising partners may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.Interest-based advertising. We or our advertising partners, including third party advertising companies and social media companies, may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms.

Compliance and protection.
We may use personal information to:Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);Audit our internal processes for compliance with legal and contractual requirements and internal policies;Enforce the terms and conditions that govern our website and Services; andPrevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal informationReal estate licensing agencies. We will share Agent License Numbers and Broker License Numbers with the California Department of Real Estate or other applicable agencies in order to verify that Agents are licensed in their respective states.

Escrow partners. When homes are sold, we may share information regarding the sale, the property, and information regarding Owners with an escrow partner in order to facilitate the transaction.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, hosting, analytics, email delivery, marketing, and database management).

Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

How users share their personal informationOur goal is to allow Agents and Owners to find each other and interact – both on our Services and in-person. In these interactions, Agents and Owners will share information with each other. We facilitate that sharing, so when you use our Services, you direct us to share information about yourself. Depending on how you use the Services, you may share personal data with:

Other users, such as Agents and Owners. By using the Services, Agents and Owners may elect to have in-person meetings or communicate via email, telephone, or other methods outside the context of the Services.

The public, through profiles and other details that are visible to others on the platform; this information may become publicly available and can be collected, viewed and used by anyone.

Your choices
Access or update your information.
Users may themselves update their personal information in their accounts by logging in and editing their information.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our Services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.Google analytics. We use Google Analytics to collect and summarize information about how individuals engage with the Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.****

Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
Facebook
Google
LinkedIn
Twitter

Third Party Pixels and Cookies: When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Advertising industry opt out tools
. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:Digital Advertising Alliance for Websites: http://outout.aboutads.infoDigital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoicesNetwork Advertising Initiative: http://optout.networkadvertising.org/?c=1Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Personal information rights requests. We offer you choices that affect how we handle the personal information that we control. You may request the following in relation to your personal information:

Information about how we collect and use your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

Access and portability. You may request copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, and readily usable format.

Correction of personal information that is inaccurate or out of date.

Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.

Opt out of the sale or sharing of your personal information and opt out of the processing of your personal information for targeted advertising. We don’t sell personal information in the traditional sense. Like many businesses, we use services that display interest-based ads to users around the web. To exercise these rights, follow the instructions in the “Online tracking opt-out” section above, which explain how to modify the use of advertising cookies on your device. You may also click the link at the bottom of our website that reads: “Do Not Sell or Share My Personal Information.”You are entitled to exercise the rights described above free from discrimination.Please note that the law of your state may limit these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

To make a request, you may do one of the following:
Visiting trueparity.com to submit a request
Calling 424-588-5700

Identity verification. We will need to confirm your identity to process your requests to exercise your data subject rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

Sensitive personal information We ask that you not provide us with any sensitive personal information (e.g., government identifiers such as Social Security Numbers or driver’s license numbers, information related to racial or ethnic origin, religious or philosophical beliefs, union membership, sex life, sexual orientation, citizenship or immigration status, biometrics or genetics, mental or physical health, or specific geolocation data) on or through the Services, or otherwise to us. If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

StripePayments on our Services are handled by Stripe, and the information you provide to Stripe is handled in accordance with its terms and privacy policies. Your payment data is stored by Stripe.For more information, please read Stripe’s Services Agreement here and Privacy Statement here.

Other sites, mobile applications and servicesOur Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children
Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.
How to contact us
Please direct any questions or comments about this Policy or our privacy practices to [email protected].

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