HomeKey Privacy Policy

Effective Date: March 1, 2024

This HomeKey Privacy Policy describes how we (as defined in "Who We Are" below) process information collected on our websites and applications (including mobile) or through your online interactions with us (collectively, our "Services").

In some circumstances, we may provide you with additional or supplemental privacy notices to the extent they apply to you because of the products and services you obtain from us or different laws that may apply to you. Some states may provide additional privacy rights. Please refer to the Additional Information Regarding Your State Privacy Rights section to learn more.

By using any of our Services, you acknowledge the privacy practices we describe in this HomeKey Privacy Policy. You also acknowledge that you have read this policy and other policies described.

Who We Are

When we say "HomeKey," we mean companies that are controlled by Electronic Mortgage & Housing Acquisition, Inc. and share the HomeKey name or are on the HomeKey platform. A reference to "HomeKey", "we" or "us" is a reference to the relevant HomeKey Company in the HomeKey that is involved in the processing activity. This policy does not apply to HomeKey affiliates that aren't in the HomeKey ("Affiliates"). The data practices of Affiliates are governed by their own privacy policies.

Information We Collect

Information You Provide

We collect information you provide to us. For example, we collect information from you when you create a HomeKey account, fill out a form or otherwise submit content through our Services, are referred to us via one of our third-party professional partner relationships, make a purchase, communicate with us via third-party platforms, participate in a contest, promotion or survey, request customer support or information about our Services, or otherwise communicate with us.

The specific information we collect depends on the context in which you provide it, and could include:

• Name
• Email address
• Postal address
• Phone number
• Identification
• Location and approximate value of your property
• Age and/or date of birth
• Demographic information, such as gender gathered pursuant to federal requirements
• Related loan products or services you have used in the past
• Financial information, such as income, assets and net worth
• Home ownership status and employment status
• Insurance information
• Other profile data, including your interests and preferences
• Any other information you choose to provide

Information We Automatically Collect

We automatically collect certain information about your interactions with us or our Services, including:

• Transactional Information: When you make a purchase or complete a transaction, we collect information about the transaction, such as product or service details, financial details and the date and location of the transaction.

• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as hardware model, operating system version, mobile network, IP address, unique device identifiers and device regional and language settings, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, products and services considered, and the page you visited before navigating to our Services.

• Your Content: As you allow through your device or application, we may collect information and content stored on your device, such as photos.

• Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).

• Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

Information We Collect From Other Sources

We obtain information from third-party sources in certain situations. For example, we may collect information about you from identity or other verification services, credit bureaus (including your credit report), advertising networks, mailing list providers, service providers and data brokers. Our Services also may allow or require you to integrate or connect your HomeKey account with third-party services through service providers (such as real estate developer systems or lender systems).

The information we receive from such third parties varies depending on the information made available by those entities. Examples of the types of information we receive include identifiers and information about account owners, information about account transactions, status of purchase applications or loan submissions, and employment information.

Additionally, if you create or log into your HomeKey account through a third-party platform, such as Facebook or Instagram, we'll have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or city or postal code or infer that you are looking to purchase certain products based on information you provide to us and your browsing behavior and past purchases.

How We Use Your Information

We use the information we collect to provide our Services to you.

Other Reasons to Collect Information

We also use the information we collect to:

• Fulfill or deliver the services you requested
• Provide, maintain, improve and develop new products, services and features, including debugging and repairing errors in our Services
• Personalize your experience with us
• Send you technical notices, security alerts, support messages and other transactional or relationship messages, including responding to your inquiries and comments
• Communicate with you about products, services, and events offered by HomeKey and others and provide news and information that we think will interest you. See the Your Choices section below for information about how to opt out of these communications at any time
• Monitor and analyze trends, usage, and activities in connection with our products and services
• Personalize the advertisements you see on third-party platforms and websites. For more information, see the Advertising and Analytics section below
• Show you offers for third-party services personalized to you, based on information we have collected about you
• Facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of HomeKey and others
• Comply with our legal and financial obligations
• Create de-identified, anonymized or aggregated information
• Fulfill any other purpose at your direction

How We Share Your Information

We share personal information in the following circumstances or as otherwise described in this policy.

Sharing Among HomeKey Family Of Companies

The HomeKey use and share your information with each other in accordance with this HomeKey Privacy Policy. This allows the HomeKey to manage and provide and offer you a variety of their services through a broad lifecycle of your personal and financial needs.

Sharing With Affiliates

HomeKey also shares your information with our Affiliates. For example, we share, or may share, your information:

• With Affiliates that act as vendors, service providers and consultants that access personal information to perform services for us
• With Affiliates for their own services and marketing purposes
• With Affiliates for regulatory reporting purposes and capturing performance metrics
• With Affiliates if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of HomeKey, our users, the public or others
• In connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company
• With Affiliates with your consent or at your direction

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

Sharing With Other Third Parties

HomeKey shares your information with non-affiliated third parties in the following circumstances:

• We share personal information with vendors, and service providers that access personal information to perform services for us, such as companies that assist us with web hosting, payment processing, fraud prevention, customer service, data analytics, home purchase, loan processing, technical support, marketing and advertising.
• If you submit a product review or post content in another public area of our Services, we share this information publicly on our Services.
• If you choose to use integrations we offer on our Services, such as sharing your location through our Google Maps integration, we may share certain information with the integration partners.
• We share personal information with third parties for their own services and marketing purposes, analytics, and in some cases to jointly market and provide products and services with third parties.
• When you request information about services offered by other companies, we may disclose information about you to those companies so that we or they can notify you of, and determine if you qualify for, products or services.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may share personal information if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of HomeKey, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
• We share personal information with your consent or at your direction, including but not limited to through third-party integrations you choose to enable.
• We also share aggregated or de-identified information that cannot reasonably be used to identify you.

Advertising and Analytics

Web and Mobile Apps

We share personal information to allow others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information.

This information may be used by HomeKey and others to, among other things, analyze and track data, reconstruct or observe activity relating to a session, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Interest-Based Ads" or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. Certain state privacy laws also provide their residents with rights relating to submitting a direct opt-out for the sharing of personal information for purposes of cross-contextual, or interest-based, advertising. For more information, please see the Additional Information Regarding Your State Privacy Rights section below.

Third Parties

We also share personal information to work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address or phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that third-party platforms may offer you choices about whether you see these types of customized ads.

Children's Privacy

HomeKey products are not intended for children. We don't direct our Services to children under 16, or knowingly attempt to solicit or receive information from children.

California Shine The Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you're a California resident and would like to make such a request, please email us at hello@homekey.com.ph.

Processing Of Information In The United States and Other Countries

HomeKey is headquartered in the United States, and the HomeKey offers goods and services to consumers in the United States. We have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.

Your Choices

Right to Correct Account Information

You may update and correct certain account information, or delete your account, by logging into your account or emailing us at hello@homekey.com.ph. Please note that we may retain certain information as required by law or for our legitimate business purposes. For more information, please see Additional Information Regarding Your State Privacy Rights.

Location Information

When you first launch any of our mobile apps that collect precise location information, or when you visit portions of our Services that collect precise location information, you'll be asked to consent to the collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. It is important to note that some Services may not function without precise location information. You may also stop a mobile app's collection of location information by following the standard uninstall process to remove the app from your device.

Do Not Track Signals

You may be using an Internet browser that can communicate your privacy preferences to the website, including requests not to track your usage and browsing history. Our websites are configured to recognize those browser signals. If we recognize one of these signals – which may be referred to or are labeled by your browser as “do not track” or “opt-out preference” or “global preference” signals – we give you the option of submitting a request to opt-out of sale/sharing. For more information on opting out of the sale/sharing of personal information, please see Additional Information Regarding Your State Privacy Rights, below.

Changes To This Policy

We may change this HomeKey Privacy Policy from time to time. If we make changes, we'll notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice, such as adding a statement to our website or sending you a notification. We encourage you to review this policy regularly to stay informed about our information practices and the choices available to you.

Contact Information

If you have questions regarding this HomeKey Privacy Policy, our information practices or other aspects of privacy relating to our Services, email us at hello@homekey.com.ph.

ADDITIONAL INFORMATION REGARDING YOUR STATE PRIVACY RIGHTS

Some states require that we provide additional information regarding our privacy practices and your privacy rights. States that have passed comprehensive privacy laws giving residents specific privacy rights include: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia.

Below we provide you additional notices about our privacy practices and consumer rights relating to your information. Some of the rights may depend on when the law is effective and whether you are a resident of a state with specific privacy laws, as well as other factors. Also, some of the companies within the HomeKey are financial institutions subject to other regulatory privacy frameworks, such as the Gramm Leach Bliley Act (GLBA), and the privacy disclosure and rights described in this section may not apply.

Notice of Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

Disclosure Of Personal Information

In the preceding 12 months, we've disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:

Right to Limit Processing of Sensitive Personal Information

In California, you have the right to limit our processing of your Sensitive Personal Information to only uses which are necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. When we collect your Sensitive Personal Information, we collect and use that information to perform the services or provide the goods for which that information is necessary and as reasonably expected by you.

Under other state privacy laws, we are only permitted to collect certain pieces of Sensitive Personal Information after we have obtained your consent to do so. Where required, we get your agreement to collect and use Sensitive Personal Information.

Sale Of Personal Information

State privacy laws require certain disclosures for companies that "sell" personal information pursuant to the respective state's privacy law. Each state defines the "sale" of data differently. In California, the "sale" of data means certain scenarios in which HomeKey has shared personal information with third parties or Affiliates, in exchange for valuable consideration. Other states define the "sale" of data as HomeKey exchanging personal information for monetary consideration with a non-affiliated third party. Under this definition, we do not "sell" your personal information.

Under California's definition, we "sell" personal information to enable our Affiliates and certain third parties to use your information in accordance with their privacy policies. We "sell" the following categories of personal information to the following categories of third parties:

Right to Opt-Out of Selling

You have the right to opt out of the "sales" described above at any time by visiting our Do Not Sell My Personal Information webpage. We do not knowingly sell or share personal information about consumers under the age of 16.

Right to Opt-Out of Personal Information Being Shared or Used In Targeted Advertising

California requires that we notify you if we “Share” your personal information with third parties. In California, “Sharing” means we make available or otherwise disclose your information to third parties for cross-context behavioral advertising. Further, “cross-context behavioral advertising” means targeting of advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services.

Similarly, privacy laws in other states require we notify you if we use your information for Targeted Advertising. Targeted Advertising means displaying advertisements to you where the advertisement is selected based on personal information obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests.

Accordingly, we "Share" your personal information with third parties for purposes of cross-contextual advertising, and we use your information for Targeted Advertising. Specifically, we share your identifiers and internet or other network activity with our advertising partners.

You have the right to opt out of "sharing" or Targeted Advertising by accessing our Do Not Sell My Personal Information webpage. We also honor browser “Do Not Track” signals, as noted above.

Retention of Personal Information

We will not retain your personal information for longer than is reasonably necessary to carry out the purposes we disclose in this policy.

State Consumer Data Rights

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose and sell, and to access your information, (2) request deletion of your personal information, (3) request correction of your personal information and (4) not be discriminated against for exercising these rights.

You may make these requests by emailing us at hello@homekey.com.ph. We'll verify your request by asking you to provide information related to your recent interactions with us.

If we receive your request from an authorized agent, we may ask for evidence that you've provided such agent with a power of attorney, or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you're an authorized agent seeking to make a request, please contact us as set out above.

California Financial Incentive Disclosure

California’s privacy law requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of personal information, which it defines as a “financial incentive.” We may offer you certain financial incentives that may result in different prices, rates, or quality levels (for example, contests and referral programs). Through these offerings, consumers provide us with some personal information (e.g., names, emails, phone numbers) when they opt-in to our programs. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in the program offering. We offer these programs, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We invest heavily in our marketing and brands, in part, so we can provide programs to our customers. Consumer data is valuable to our business only when it is combined with a sufficient number of other consumer data and after it is enhanced by our efforts herein described. The value to our business of any individual consumer's personal information is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to enhance the data through our efforts herein described. Our ability to create any value from the programs is heavily based on our ability to leverage said intellectual properties. We do not calculate the value of consumer data in our accounting statements.