Privacy Policy

Last Updated: February 10, 2020

Welcome to the website of BrightHome, Inc. also known as Disclosures.IO (“Disclosures.IO”, “we”, “us” and/or “our”). We have prepared this Privacy Policy to explain how we collect, use, protect and disclose information and data when you use our website (“Site”) and our services, including any software, mobile applications, products, devices or other services offered by Disclosures.IO from time to time and other services offered through third parties integrating Disclosures.IO functionality (collectively, “Services”). “You” refers to you as a user of the Site or Services, or anyone you allow to use the Site or Services on your behalf.

For purposes of this Privacy Policy, “Personal Information” means information about an identified or identifiable individual, such as their name and email address and 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.

Information We Collect

The categories of Personal Information we collect depend on whether you are a customer, real estate professional or other service provider, employee, or job applicant, and the requirements of applicable law.

  • Information You Provide. Depending on your role in the real estate transaction, we collect information that personally identifies you, such as your name, username, email address, phone number, contact information, address and characteristics of the property involved in a real estate transaction, professional and employment information, and other Personal Information when you sign up to use the Site or Services. The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services.
  • Commercial and Financial Information: In connection with your order to purchase Services through one of our payment processors, we collect credit card and other financial account information. Your Personal Information may also be collected and shared with others in connection with a loan application, the purchase or sale of property, home owners association (HOA) minutes and other documents or if you apply for a mortgage or other insurance.
  • Platform Information. We also collect Personal Information from you when you access the Services and/or other parts of the Site and elect to provide Personal Information that can be stored and accessed by the third parties described below including real estate and insurance agents, legal advisors, bankers, closing agents, home buyers and sellers and others. For example, when you use the Services, we will collect data that you upload to, or create during the course of your use of the Site and/or information that you input into your account such as your records of personal property, offer or listing information, legal disclosures, seller disclosures, inspections and HOA documents.

Automatic Collection:

  • Identifiers and Devices. We may collect certain additional information automatically, including, but not limited to, the type of device you use and your user settings, your device’s unique IDs, your IP address, your operating system, the type of Internet browsers you use, and information about the way you use the Site and Services.
  • Geolocation: We may also use your IP address (or other similar technology) to determine your general location. If you do not want to transmit your location information to us, you should turn off the location services in your browser or in your mobile phone settings and/or within the mobile application.
  • Cookies and Other Technologies. We use cookies (a small text file placed on your computer to identify your computer and browser). We may also use Web beacons (a file placed on a website that monitors usage). We also collect cookie identifiers, information about your online activities over time and across third-party websites or online services, information about the links you click, and other information about how you use the Site and Services. We, or our third-party service providers and contractors use this information to allow you to enjoy a more seamless visit, more accurately measure your behavior on the Site, and to detect and prevent fraudulent activity. At this time, we do not recognize automated browser signals regarding tracking, including “do-not-track” signals. You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser’s “help” directory. However, certain features of the Site or Services may not work if you delete or disable cookies. Some of our service providers may use their own cookies and Web beacons in connection with the services they perform on our behalf, as further explained below. Information we collect may be associated with accounts and other devices.
  • Our uses of these technologies fall into the following general categories:

    • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular Site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
    • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
    • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
    • Advertising or Targeting Related.We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party sites.
  • Usage Data and Site Activity. We automatically collect information regarding the actions you take on the Site and Services. For example, each time you use the Site we may automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. This information may be associated with your account. We may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, etc. We use this information to help us understand how people use the Site and Services and to enhance the Site and Services.
  • APIs/SDKs. We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Information for various purposes including to provide analytics services and content that is more relevant to you.

How We Use Information

We may use the information collected from you, including your Personal Information, through the Site and Service to provide the Site and Service and related functionality and services for which we have been engaged. Such information may be used to perform a variety of purposes, including to:

  • Provide, operate, maintain and improve the Site and Services;
  • Enable you to access and use the Site and Services, including uploading, downloading, collaborating on and sharing Usage Data and sending emails on your behalf;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Verify your identity, provide and deliver the Services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • Respond to your comments, questions, and requests and provide customer service and support;
  • Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners such as multiple listing services or environmental service companies;
  • Process and deliver contest or sweepstakes entries and rewards;
  • Monitor and analyze trends, usage, and activities in connection with the Site and Services, develop new products and services and for marketing or advertising purposes;
  • Detect bugs and other software issues and ensure internal quality control;
  • Investigate and prevent fraudulent activities, transactions, unauthorized access to the Site and Services, and other illegal activities;
  • Personalize and improve the Site and Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Site and Services;
  • Send you push notifications from time-to-time in order to update you about events or activities related to the Site and Services. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we collect certain information about your device such as operating system and user identification information;
  • Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
  • Enable you to communicate, collaborate, and share files with users you designate and/or have granted access rights to use the Services; and
  • For other purposes about which we notify you or when you provide your consent.

How We Disclose Your Information to Third Parties

Third Party Services and Applications

Through the Site or Services, you may access certain integrated third-party services and applications, such as social media networks like Facebook, Twitter, Instagram, and LinkedIn, and third-party services such as Docusign, Google Drive, Dropbox, Box, multiple listing services, and environmental service companies. When you do so, you may be able to import information from those other services and applications and share content with those services. For example, the Site and Services are integrated with Google Drive and will allow you to access and share documents and files directly from your Google Drive account with the Site and Services. Some of those third-party services may also provide us with information from your accounts, which may enable us to enhance and personalize your use of the Site and Services. The information shared with such third-party services and applications will be subject to their privacy policies and your privacy settings and other users, who may change the privacy settings and/or share or publicly post your Personal Information, documents and files. These third parties may collect Personal Information about your online activities over time and across different websites when you use the Site or Services. We are not responsible for the privacy practices or content of such other third-party services or applications.

Business Partners

We may provide Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Affiliates

We may share Personal Information with our affiliated companies

Disclosure of Information Obtained by the Site and/or Services

We may disclose information you provide to us and information automatically collected from you when you use the Site and the Services: (a) as required by law, such as to comply with a subpoena, or similar legal process; (b) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud; (c) with our third-party services providers and contractors who work on our behalf, for the purpose of providing our Services, and for no other purpose; and (d) with your consent and at your direction.

Analytics

We may work with analytics companies such as Google Analytics and other service providers to help us understand how the Site and Services are being used, such as visitor behavior, demographics and the frequency and duration of usage. Our third-party service providers and contractors use some of the information collected by the Site and Services to assist us in providing the Site and Services. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information about Google Analytics, please visit www.google.com/policies/ privacy/partners/. Please contact us below if you have any questions.

Information You Make Available to Others

By using the Site or Services, including creation of a profile on the Site or submission of information in response to public queries, you may make your Personal Information available to others, such as your name, your username, and your picture. This information may be accessed by users who use the Site or Services and may be accessed by commercial search engines, including, but not limited to, Google, Yahoo!, and Bing to the extent that such engines are permitted to access the Site or Services.

Advertising

We partner with third-party ad networks to display advertising on our website and to manage advertising on other sites. Our ad network partners use cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at https://youradchoices.ca/choices/, www.networkadvertising.org/managing/opt_out.asp, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice. You must separately opt out in each browser and on each device. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Also, please note that any information you provide to any advertiser is provided directly to that advertiser and is subject to that advertiser’s privacy policy and not our Privacy Policy.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be shared, sold, or transferred in connection with or during negotiations of such a transaction, as permitted by law and/or contract.

Managing Your Information Preferences and Your Privacy Rights

You can always review, correct, or update your Personal Information by changing the relevant settings in your Disclosures.IO account. You can opt out of receiving certain emails, except for transactional emails generated and transmitted in the course of your use of the Site and Services, by changing the notification settings on the Site or in our applications, clicking the unsubscribe link provided in an email, or by emailing us at [email protected]

European Residents

If you are a resident of the European Economic Area and Switzerland, you have certain rights and protections regarding the processing of your Personal Information.

Legal Basis for Processing

If you are a European resident, we process your Personal Information when:

  • We need to do so to perform our obligations under a contract with you (e.g., processing payments)
  • We have a legitimate interest in processing your Personal Information. For example, we may process your Personal Information in order to provide, secure, improve, and market our Services.
  • We need to do so to comply with a legal obligation to which we are subject.
  • We need to do so to protect your vital interests or those of others.
  • We have your consent to do so, which you may withdraw at any time by contacting us at [email protected]

Data Subject Requests

In accordance with applicable law, if you are a European resident you may have the right to:

  • Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Information transferred to another party.
  • Request correction of your Personal Information where it is inaccurate or incomplete.  In some cases, we may provide self-service tools that enable you to update Personal Information stored for your account, or for data we do not control, we may refer you to the third party who is able to make the correction.
  • Request deletion of your Personal Information, subject to certain exceptions prescribed by law.
  • Request restriction of or object to processing of your Personal Information, including the right to opt in or opt out of the sale of your Personal Information to third parties, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

California Residents

If you are a resident of California, California law requires us to disclose the following information with respect to our collection, use, and disclosure of Personal Information.

Notice of Collection

Although the information we collect is described in greater detail in the “Information We Collect” section above, the categories of Personal Information that we have collected – as described by the California Consumer Privacy Act (CCPA) – including in the past 12 months are:

  • Identifiers – including name, email address, IP address, and mobile device ID.
  • Other individual customer records – including phone number, billing address, payment card information, real estate license information, and signature. This category includes personal information protected under pre-existing California law (Cal. Civ. Code § 1798.80(e)), and overlaps with other categories listed here.
  • Commercial information – including subscriptions, purchasing information, and engagement with our Services.
  • Internet activity – including referring and exiting pages and your interactions with our Services.
  • Geolocation data – including location-enabled services such as WiFi and GPS.
  • Professional information– including your company name and job title.
  • Sensory information – including photos.
  • Inferences– including information about your interests and preferences.

Business or Commercial Purpose for Collecting and Using Data:

We collect each category of Personal Information listed above for the business or commercial purposes described in the “How We Use Information” section above.

Categories of Sources of Personal Data:

We collect each category of Personal Information listed above 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.

Categories of Personal Data Disclosed:

In the preceding 12 months, we have disclosed each category of Personal Information listed above in the circumstances described in the “How We Disclose Your Information to Third Parties” section above.

Categories of Third Parties With Whom We Share Personal Data:

We may share each category of Personal Information listed above with the third parties described in the “How We Disclose Your Information to Third Parties” section above.

Right to Know:

California residents may request disclosure of the specific pieces and/or categories of personal data that we have collected about them, the categories of sources for that Personal Information, the business or commercial purposes for collecting the information, the categories of Personal Information that we have disclosed, and the categories of third parties with which the information was shared.

Right to Opt-Out:

Disclosures.IO does not sell Personal Information to third parties for monetary value. However, the term “sale” is defined broadly in the CCPA. To the extent that “sale” under the CCPA is interpreted to include interest-based advertising or other data uses described in the “How We Use Information” section above, California residents are entitled to opt-out of the “sale” of data at any time.

Deletion:

You may request that we delete the Personal Information we have collected about you (subject to certain exceptions). Please be aware that we may keep certain information as required or permitted by applicable law. To exercise this right, please contact us at [email protected] or using our contact information below.

Authorized Agent:

You may designate an authorized agent to make a request on your behalf. To do so, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. To verify the request, we may contact you directly.

Right to Non-Discrimination:

Limiting use of, or deleting, your Personal Information may affect features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.

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]

Be Careful When You Share Information with Others

Please be aware that whenever you share information on a publicly available web page or any other public forum on the Site or Services, others may access that information. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Security

We maintain technical and procedural safeguards 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 Site or Services, we cannot and do not guarantee absolute security.

Links and Third-Party Sites

Our Site and Services may contain links or integrate with third-party websites and online services, or allow others to send you such links. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. Disclosures.IO is not responsible for the privacy practices or the content of these other websites. We encourage you to review the privacy policy statements of these other web sites to understand their policies, before providing any Personal Information to or through them. If you access a linked site, you may be disclosing your private information.

Children’s Privacy

We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, please contact us at [email protected]

Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using our Site or Services, you agree that the applicable laws in the United States will govern the collection, use, transfer, and disclosure of your Personal Information and communications.

Supervisory Authority

If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law. However, we invite you to contact us with any concern, as we would be happy to try to resolve it directly.

Data Retention

We store the Personal Information we receive as described in this Privacy Policy for as long as you use our Site and Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Changes

From time to time, we may change this Privacy Policy. If we change this Privacy Policy, we will give you notice by posting the revised Privacy Policy on the Site. Those changes will go into effect on the date shown in the revised Privacy Policy. By continuing to use the Site or Services after any change to the Privacy Policy, you consent to the revised Privacy Policy.

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 as detailed in this Privacy Policy, please contact us at: [email protected] or write to us at:

Disclosures.IO - 1640 Stockton Street Unit 330568, San Francisco, CA 94133

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOU RECORDS, AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES TO THIS PRIVACY POLICY.