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

1. What Is Personal Information?

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or household. It includes “personal data” as defined by the European Union’s General Data Protection Regulation and “personal information” as defined by the California Consumer Privacy Act. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.

2. How We Collect and Use Personal Information

Personal Information Collected from Individuals

The categories of personal information we collect depend on whether you are a customer, real estate professional or other service provider, and the requirements of applicable law. Depending on your role in the real estate transaction, the categories of personal information we collect submitted to us by individuals through the Services may include:

• Contact Information, including first and last name, username, email address, mailing address, phone number, and other contact information. We use this information to fulfill your request or transaction and to communicate with you directly.
• Account Information, including personal and/or business information that you provide when you register for an account to use our Services. This may include your first and last name, email address, username and password, and billing and payment card information. If you are an administrator for your company, we will also collect information to create your company profile. We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. As described further below, we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
• Financial Information, such as credit or debit card number, account type, and payment/transaction history collected in connection with your order to purchase Services. Please note that we use third-party payment processors to process card payments made to us. As such, we do not retain personally identifiable financial account information, such as full credit card numbers; rather, all such information is provided directly by you to our third-party processor, whose use of your information is governed by its own privacy notice. Your personal information may also be collected and shared with others in connection with a real estate transaction, such as a loan application, the purchase or sale of property, homeowners association (HOA) documents, or an application for a mortgage or insurance.
• Information Collected Through the Use of the Services (User Content), including any files, documents, images, data, records of personal property, offer or listing information, legal disclosures, seller disclosures, inspection reports, HOA documents, or other information you choose to upload to, create in, or transmit through the Services, your communications with us, or your communications with other users (collectively, “User Content”). User Content and any information contained in it, including personal information you may have included, is stored and collected as part of the Services. We use the User Content to provide you with the Services and enable you to store, access, collaborate on, and share it with the parties you designate, such as real estate and insurance agents, legal advisors, bankers, closing agents, and home buyers and sellers.
• Recorded Conversations, such as information you provide about yourself during recorded calls with members of our team. We use this information to provide our Services as well as for training and quality assurance.
• Other Inquiry and Communications Information, including information provided to one of our email addresses, or via phone calls or text messages, and contact information provided on our Services. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the Services we offer, and to manage and grow our organization.
• Marketing Information, including email address and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Feedback Information, such as feedback, testimonials, and ratings you provide relating to our Services. We use this information to communicate with you, conduct market research, inform our marketing activities, and improve our business.
• Commercial Information, such as subscriptions, products or services purchased, obtained, or considered, purchasing histories, engagement with our Services, and home purchase or sale information, such as the address, type, and price range of the property involved in a real estate transaction, and records of personal property.
• Professional or Employment-Related Information, such as company name, job title, and real estate license information.
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of an actual or potential agreement with us, which may include your name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement.

Personal Information from Third Parties

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

• Our Affiliates. We may receive personal information from other companies and brands owned or controlled by HomeLight, and other companies under common ownership.
• Your Employer / Company. If you engage with our Services through your employer or company, we may receive information from the company, such as name and contact information.
• Service Providers. Our service providers that perform services on our behalf, such as survey, marketing, and payment processing providers, collect personal information and often share some or all of this information with us.
• Business Partners. We may receive your information from our business partners, such as multiple listing services (MLS), environmental service companies, and companies that offer their products and/or services on our Services.
• Single Sign-On and Authentication Providers. We may use single sign-on (“SSO”) and third-party authentication providers, such as Google or Docusign, to allow you to authenticate your account. We will have access to certain information from those third parties in accordance with their authorization procedures, which may include your name, username, email address, and profile picture.
• Social Media. When you interact with our Services through social media networks, we may receive information that you permit the social network to share, depending on your privacy settings with that network.
• Other Sources. We may collect personal information from government agencies, publicly available sources, or through transactions such as mergers and acquisitions.

Other Uses of Personal Information

In addition to the above, we may use personal information: to provide you with products or services that you request or in which you express interest; to provide, improve, test, update and monitor the Services, or diagnose or fix technology problems; for training and quality assurance purposes, such as by reviewing recordings of conversations; to manage our organization and its day-to-day operations; to communicate with you and send you email messages and notifications; to respond to your emails, comments, questions, or requests for customer service; to market our Services, including through email and social media; to administer, improve and personalize our Services; to identify and analyze how individuals interact with our Services, and to conduct research and analytics on our user base; to help maintain the safety, security and integrity of our property, Services, and business; to facilitate corporate business transactions; to defend, protect or enforce our rights or applicable contracts and agreements; to prevent, investigate or provide notice of fraud or unlawful activity; to comply with legal obligations; and for any other purpose we may describe when you provide the information.

3. Cookies and Other Data Collection Technologies

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

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

• Device information, such as your IP address, browser type, Internet service provider, device type, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, device, or account.
• Usage and browsing information, such as the site from which you came and the site to which you are going when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in emails, the pages you view, the links you click, and other actions you take on the Services.
• Location information, such as general geographic location that we or our third-party providers may derive from your IP address.
• Analytics information. We may use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

Our uses of these technologies fall into the following general categories: (i) operationally necessary, to allow you access to the Services and to identify irregular Site behavior, prevent fraudulent activity, and improve security; (ii) performance related, to assess the performance of our Services, including as part of our analytic practices; (iii) functionality related, to offer you enhanced functionality, such as remembering your preferences; and (iv) advertising or targeting related, to deliver content, including ads relevant to your interests. We may also use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services, which may allow third parties, including analytics and advertising partners, to collect your personal information.

At this time, we do not recognize automated browser signals regarding tracking, including “do-not-track” signals. For more information about your choices regarding cookies, please see the “Your Choices” section below.

4. Our Disclosure of Personal Information

We may disclose your personal information with:

• Affiliates. We may disclose personal information between and among HomeLight and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
• Third-Party Services and Integrations. Through the Services, you may access certain integrated third-party services and applications, such as social media networks and services such as Docusign, Google Drive, Dropbox, Box, multiple listing services, and environmental service companies. When you do so, you may import information from, and share content with, those services. Information shared with such third-party services is subject to their privacy policies and your privacy settings. We are not responsible for the privacy practices or content of these third parties.
• Online Advertising Partners. We may share personal information with, or permit collection by, advertising networks and social network advertising providers to facilitate online advertising. For more information, including how to opt out of interest-based advertising, please see the “Your Choices” section below.
• Business and Commercial Partners. We may share personal information with unaffiliated third parties who partner with us to deliver our Services or on our commercial activities, such as business partners with whom we jointly offer products or services.
• Your Employer / Company. If you interact with our Services through your employer or company, we may disclose your information to your employer or company.
• Service Providers. We may share personal information with third-party service providers and contractors who work on our behalf and provide us with services such as data analysis, payment processing, IT services, and customer service, for the purpose of providing our Services and for no other purpose.
• Business Transaction or Reorganization. We may disclose personal information to a third party in connection with, or during negotiation of, any merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, as permitted by law and/or contract.
• Legal Obligations and Rights. We may disclose personal information to third parties, such as legal advisors and law enforcement: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process, such as a subpoena; to protect the rights and property of HomeLight, our agents, customers, and others, including to enforce our agreements, policies, and Terms of Service; to detect, suppress, or prevent fraud; or to protect the health and safety of us, our customers, or any person.
• With Your Consent or At Your Direction. We may disclose personal information about you to certain other third parties with your consent or at your direction.

By using the Services, including creating a profile or submitting information in response to public queries, you may make certain personal information available to others, such as your name, username, and picture. Please be aware that whenever you share information on a publicly available web page or public forum on the Services, others may access that information.

5. Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third-party advertising companies to collect information about your use of our online Services over time so that they may display ads on our Services, on other websites or services you may use, and on other devices you may use. This information is typically collected through tracking technologies that recognize your device and collect information such as click-stream information, browser type, the time and date you visited the Sites, and Ad ID. We may share a common account identifier, such as a hashed email address or user ID, with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests and to provide advertising-related services such as reporting, attribution, analytics, and market research.

We may engage in the following: (i) social media widgets and advertising, such as the Facebook “Like” button, LinkedIn, X (Twitter), and other widgets, whose interactions are governed by the privacy policies of those companies; (ii) social media platform advertising, displaying targeted advertising to you through social media platforms, including by sharing a unique identifier such as a hashed email address; and (iii) third-party analytics and advertising partners, such as Google Analytics, to better understand how users interact with our Services and to tailor our advertisements and content. To learn how you can opt out of interest-based advertising, please see the “Your Choices” section below.

6. Your Choices

• Phone, Text and Email Communications. From time to time, we may call you, send you text messages, or send you emails regarding updates to our Services, notices about our organization, or information about products/services we offer that we think may be of interest to you. Where required by applicable law, we obtain your prior express consent before we contact you, and we obtain your prior express written consent before sending marketing calls or texts that use an autodialer. If you wish to unsubscribe from promotional phone calls, call us at 866-627-3398. If you wish to unsubscribe from promotional text messages, reply STOP to any one of our promotional text messages. If you wish to unsubscribe from promotional emails, click the “unsubscribe” link provided at the bottom of the email. You may revoke your consent to receive calls or text messages at any time by any reasonable method that clearly expresses your wish not to receive further calls or texts. We will honor your request within a reasonable time, not to exceed ten (10) business days. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Modifying and Deleting Your Information. If you have an account with us, you may review, correct, or update your account information and adjust your account settings by logging into your Disclosures.io account. If you have any questions about modifying or updating your information, please contact us at [email protected].
• Access to Your Device Information. You may control the Services’ access to your device information, including geolocation, through the “Settings” app on your device.
• Push Notifications. You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu.
• Cookies. Most browsers will allow you to change your browser settings to notify you when you receive a cookie, disable existing cookies, or automatically reject cookies. Please note that certain features of the Services may not work if you delete or disable cookies. If you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.
• Online Ads. We support the self-regulatory principles for online behavioral advertising published by the Digital Advertising Alliance (DAA). If you want to opt out of receiving online interest-based advertisements from advertisers and third parties that participate in the DAA program, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices/. To opt out of interest-based advertisements on mobile apps, please follow the instructions at www.aboutads.info/appchoices. To exercise your right to opt out of the sale or sharing of personal information as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please see the “Your Privacy Rights” section of our U.S. Privacy Disclosures below.

7. Region-Specific Disclosures

Depending on your country, region, or state of residence, certain rights may apply to you. Please refer to the Additional U.S. State Privacy Disclosures below for U.S. state-specific privacy disclosures.

If you are a resident of the European Economic Area, the United Kingdom, or Switzerland, you have certain rights regarding the processing of your personal information, including the rights to access, correct, delete, restrict, or object to our processing of your personal information, and to data portability. Where we rely on your consent, you may withdraw it at any time. We process your personal information where we need to perform a contract with you, where we have a legitimate interest in doing so (such as to provide, secure, improve, and market our Services), where we need to comply with a legal obligation, or where we have your consent. You also have the right to lodge a complaint with a supervisory authority, although we invite you to contact us first at [email protected] so we can try to resolve your concern directly.

8. Artificial Intelligence

We may use artificial intelligence (“AI”) technologies to help operate, improve, and provide our Services. This section supplements the rest of this Privacy Policy, which continues to apply to any personal information processed using AI. We may use AI technologies to, among other things: respond to inquiries and provide customer support, including through chat features and other automated tools; transcribe, summarize, translate, and analyze communications, including recorded calls; help process, organize, and analyze documents and other User Content within the Services; generate estimates, recommendations, and other insights; and detect and prevent fraud and otherwise help maintain the safety and security of our Services. AI-generated output may not always be accurate or complete, and we maintain human oversight of AI used in connection with significant decisions. AI output should not be relied upon as legal, financial, tax, or other professional advice.

9. Links to Third-Party Websites and Services

For your convenience, our Services may provide links to, or integrate with, third-party websites or services that we do not own or operate. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with that third party. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any site or service before providing any personal information.

10. Children’s Privacy

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

11. Security

We maintain technical and procedural safeguards designed to protect the confidentiality and security of personal information transmitted to us. However, there is always some risk in transmitting information over the Internet and storing information electronically. As a result, while we strive to protect information transmitted on or through the Services, we cannot and do not guarantee absolute security.

12. Data Retention

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected, including to provide our Services, resolve disputes, establish and defend legal claims, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable legal, tax, and accounting obligations. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information and the potential risk of harm from unauthorized use or disclosure. When retention is no longer necessary, we will delete or de-identify the personal information or, if that is not possible (for example, because it has been stored in backup archives), securely store and isolate it from further processing until deletion or de-identification is possible.

13. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time at our sole discretion. We will notify you about material changes by sending a notice to the primary email address specified in your account, by updating the “Last Modified” date at the top of this Privacy Policy, and/or by placing a prominent notice on our Sites. Those changes will go into effect on the date shown in the revised Privacy Policy. By continuing to use the Services after any change to this Privacy Policy, you consent to the revised Privacy Policy. It is your responsibility to review this Privacy Policy periodically.

14. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights, please contact us at [email protected] or write to us at:

HomeLight, Inc. — HomeLight Listing Management (Disclosures.io)

100 California St, Ste 800, San Francisco, CA 94111

Please print a copy of this Privacy Policy for your records, and please check the Sites frequently for any changes to this Privacy Policy.

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

Depending on your state of residency, these Additional U.S. State Privacy Disclosures (“U.S. Privacy Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal information processing practices and the choices you may have. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Privacy Disclosures.

Collection and Use of Personal Information

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

Disclosure of Personal Information

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

Sale of Personal Information and Sharing for Targeted Advertising

Disclosures.io does not sell your personal information to third parties for monetary consideration. However, the terms “sell” and “share” are defined broadly under certain U.S. state privacy laws. To the extent that our use of cookies and other tracking technologies for analytics and interest-based advertising is considered a “sale” or a “share” for cross-context behavioral (targeted) advertising under applicable law, the categories of personal information that may be involved are: Identifiers, Commercial Information, Internet/Network Information, and Inferences. You have the right to opt out of this activity, as described in the “Your Privacy Rights” section below. We do not sell or share the personal information of consumers we know to be under 16 years of age without opt-in consent.

Sensitive Information

Certain personal information elements we collect may be classified as “sensitive” under certain privacy laws, such as financial account, debit card, or credit card number in combination with any required security or access code, and account log-in credentials. We only use or disclose sensitive information as necessary and proportionate to perform the Services you have requested, to detect security incidents and prevent fraud, to ensure physical safety, or as otherwise permitted by law. We do not use or disclose sensitive information for the purpose of inferring characteristics about a consumer, and we do not sell sensitive information or process or share it for the purpose of targeted advertising.

Deidentified Information

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

Your Privacy Rights

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

• The Right to Know / Access & Portability — the right to confirm whether we are processing personal information about you and, under California law, to obtain certain personalized details about the personal information we have collected, and to obtain a copy of that information in a portable format.
• The Right to Correction — the right to correct inaccuracies in your personal information, taking into account its nature and the purposes of the processing.
• The Right to Request Deletion — the right to request the deletion of personal information that we maintain about you, subject to certain exceptions.
• The Right to Opt Out of Sales or Sharing for Targeted Advertising — the right to direct us not to sell or share your personal information for certain targeted or cross-context behavioral advertising purposes.
• The Right to Withdraw Consent — if you have provided consent for the processing of your personal information, the right to withdraw that consent, which will not affect the lawfulness of processing before withdrawal.
• The Right to Appeal — the right to appeal a decision we make in connection with a privacy rights request. Colorado, Connecticut, and Virginia residents may contact their respective state Attorney General if an appeal is denied.

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

How to Exercise Your Privacy Rights

To exercise your privacy rights, please submit a request by emailing us at [email protected] or by calling 866-627-3398. We will need to verify your identity and confirm that you are a resident of a state that offers the requested right(s) before processing your request, which generally requires either a successful login to your account or the matching of sufficient information you provide us to the information we maintain. As a result, we require requests to include name, email address, and state of residency.

To exercise the right to opt out of the sale or sharing of personal information for targeted advertising purposes, you may submit a request by calling 866-627-3398 or by emailing [email protected]. You do not need to create an account with us to exercise your right to opt out.

Authorized Agents. You may use an authorized agent to submit requests on your behalf where we can verify the authorized agent’s authority to act for you. We generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. We may still need to separately reach out to you to confirm the authorized agent’s permission and to verify your identity.

Appealing Privacy Rights Decisions. Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request by emailing us at [email protected] with the subject line “Privacy Request Appeal.”

Minors Under Age 16. We do not sell or share the personal information of consumers we know to be less than 16 years of age unless they have opted in. Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.

California-Specific Disclosures

The following disclosures apply to residents of the State of California. In the last 12 months, we may have collected the following categories of personal information: Identifiers (such as name, email address, telephone number, address, and account username); personal information as defined in the California customer records law (such as payment card information, real estate license information, and signature); Commercial Information (such as products or services purchased and home purchase or sale information); Professional or Employment-Related Information (such as company name and job title); Geolocation data (such as general location derived from IP address); Internet or Other Electronic Network Activity Information (such as IP address, access times, browser type, and website interactions); Sensory Information (such as photos); and Inferences drawn from the above.

We collect each category for the business or commercial purposes described in the “How We Collect and Use Personal Information” section, and we collect it from the sources described in that section, including directly from you, from other Disclosures.io users, from third-party authentication providers such as Docusign or Google, from multiple listing services, and from third-party service providers. California residents have the rights described in the “Your Privacy Rights” section above, including the right to know, the right to delete, the right to correct, and the right to opt out of the “sale” or “sharing” of personal information.

“Shine the Light.” California Civil Code § 1798.83 permits 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 contact us at [email protected].

Data Retention

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected, as described in the “Data Retention” section of our Privacy Policy above, and as necessary to comply with our legal, tax, and accounting obligations, to resolve disputes, and to defend claims.

Updates to These U.S. Privacy Disclosures

We will update these U.S. Privacy Disclosures from time to time. When we make changes, we will change the “Last Updated” date at the beginning of these U.S. Privacy Disclosures. If we make material changes, we will notify you by email to your registered email address, by prominent posting on our online Services, or through other appropriate channels.

Contact Us

If you have any questions or requests in connection with these U.S. Privacy Disclosures or other privacy-related matters, please send an email to [email protected].