Privacy Policy

1. Introduction

Rhome Exchange Inc. ("Rhome," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, mobile applications, and services (collectively, the "Services"). Rhome is a Delaware corporation.

This Privacy Policy applies to all personal information collected through our Services, as well as any related services, sales, marketing, or events. By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

We use your personal data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect several types of information from and about users of our Services, including:

2.1 Personal Information

• Account Registration Information: Full name, email address, password, phone number, date of birth, address, and any other information you provide during the account creation process.
• Profile Information: Profile picture, bio, social media handles, and other information you choose to provide in your user profile.
• Identity Verification Information: Government-issued identification numbers, passport numbers, driver's license information, Social Security number (or equivalent), utility bills, proof of address, and credit history for identity verification purposes.
• Financial Information: Bank account details, credit/debit card information, income information, tax identification numbers, employment information, credit scores, and other payment-related information necessary for property transactions and co-ownership arrangements.
• Transaction Information: Details about properties you browse, own, co-own, or express interest in, including purchase history, property co-ownership details, mortgage information, and any other information related to your transactions on our platform.
• Communication Data: Content of emails, messages, forum posts, and customer service interactions, including call recordings where permitted by law.
• Property Information: Information about properties listed or managed through our platform, including address, value, condition, amenities, and occupancy status.
• Co-ownership Information: Details about your co-ownership arrangements, including ownership percentages, usage schedules, and shared expenses.

2.2 Non-Personal Information

• Usage Data: Information about how you use our Services, including pages viewed, features used, search queries, clickstream data, referring/exit pages, date/time stamps, and other interaction data.
• Device Information: IP address, browser type and version, operating system, device type, device identifiers, and other technical information about the devices you use to access our Services.
• Location Information: General location derived from IP address or more precise location if you enable such features, including GPS data from mobile devices.
• Log Data: Server logs, which may include information such as your device's Internet Protocol (IP) address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Business partners, such as real estate agents, property managers, and financial institutions.
• Identity verification services.
• Credit reporting agencies (with your consent where required by law).
• Social media platforms, if you choose to link your Rhome account to your social media accounts.
• Public databases and other publicly available sources.

3. How We Use Your Information

We use your information for various purposes, including to:

• Provide, maintain, and improve our Services
• Process transactions and send transaction notifications
• Verify your identity and prevent fraud
• Facilitate property co-ownership arrangements
• Communicate with you about our Services, including sending administrative messages, updates, support messages, and marketing communications
• Personalize your experience and deliver content and product offerings relevant to your interests
• Analyze trends, usage, and activities in connection with our Services
• Conduct research and development to improve our Services and develop new features
• Comply with legal obligations and enforce our legal rights
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• Evaluate and improve our business operations
• Protect the rights, property, and safety of Rhome, our users, and others
• Facilitate dispute resolution between co-owners or users
• Provide customer support and respond to your inquiries
• Conduct internal research and development
• Carry out any other purpose described to you at the time the information was collected

4. How We Share Your Information

We may share your information in the following circumstances:

• With Other Users: Certain information may be visible to other users as necessary for the functioning of the platform (e.g., your profile information, property listings). If you are a co-owner, certain information may be shared with other co-owners of the same property.
• With Service Providers: We share information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf. These may include payment processors, data analytics providers, customer service providers, email delivery services, and marketing partners.
• With Lenders and Financial Institutions: We may share certain financial information with lenders and financial institutions to facilitate mortgage applications, offer you competitive rates for mortgages or other financial products related to property co-ownership, and process transactions. This sharing is always done with your consent and for your benefit.
• With Real Estate Professionals: We may share information with real estate agents, property managers, and other professionals involved in property transactions or management, as necessary to facilitate your use of our Services.
• For Legal Reasons: We may disclose your information if we believe it is necessary to:
  • Comply with any applicable law, regulation, legal process, or governmental request
  • Enforce our Terms of Service, including investigation of potential violations
  • Detect, prevent, or otherwise address fraud, security, or technical issues
  • Protect against harm to the rights, property, or safety of Rhome, our users, or the public as required or permitted by law
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred as part of such a transaction as permitted by law and/or contract.
• With Your Consent: We may share your information for any other purpose disclosed to you at the time we collect the information or with your consent.
• Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for various purposes, including data analytics, research, and marketing.

We do not sell your personal information to third parties for their direct marketing purposes.

5. Cookies and Tracking Technologies

We and our third-party service providers use cookies, web beacons, and other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Services. They help us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns
• Store information about your preferences, allowing us to customize our Services according to your individual interests
• Speed up your searches
• Recognize you when you return to our Services

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

We use the following types of cookies:

• Essential Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems.
• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
• Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization.
• Targeting Cookies: These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

We also use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use our Services. The information generated by the cookie about your use of the Services will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Services, compiling reports on website activity, and providing other services relating to website activity and internet usage.

6. Your Choices and Rights

Depending on your location, you may have certain rights regarding your personal information, including:

• The right to access personal information we hold about you
• The right to request correction or deletion of your personal information
• The right to object to or restrict certain processing of your information
• The right to data portability
• The right to withdraw consent at any time for processing based on consent
• The right to lodge a complaint with a supervisory authority

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We may need to verify your identity before responding to your request.

Additionally, you may have the following options regarding your information:

• Account Information: You may review and change your account information by logging into your account settings at any time.
• Marketing Communications: You can opt-out of receiving promotional emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
• Mobile Push Notifications: You can opt-out of receiving push notifications through your device settings.
• Cookies: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies.

Please note that some data may be necessary to provide you with our Services, and deleting or restricting the use of certain information may impact our ability to provide the Services to you.

7. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

Our security measures include:

• Encryption of personal data both in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Regular security training for employees
• Physical security measures for our data centers and offices
• Incident response plans and regular security drills

We regularly review and update our security practices to enhance the protection of your personal information.

8. Data Retention

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. International Data Transfers

Our Services are primarily operated and managed on servers located and operated within the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to, and processed, stored, and used in the United States and other countries where we or our third-party service providers operate.

If you are located in the European Economic Area, United Kingdom, or Switzerland, please note that the United States may not have data protection laws as comprehensive or protective as those in your country of residence. However, we take steps to ensure that your privacy is protected and that your information is treated securely. By using the Services, you agree to the transfer of your information to the United States and other countries where we and our third-party service providers operate.

Where required by law, we may implement data transfer mechanisms, such as Standard Contractual Clauses approved by the European Commission, to ensure that your personal information is protected when transferred out of your home country.

10. Children's Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Your continued use of our Services after the effective date of any update to the Privacy Policy will constitute your acceptance of the updated policy.

12. Third-Party Links and Services

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

13. Contact Us

If you have questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your data protection rights, please contact us at:

Rhome Exchange Inc. Email: privacy@rhome.com

14. Additional Information for Specific Jurisdictions

14.1 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and other state privacy laws. These include:

• The right to know what personal information we collect about you and how we use and share it
• The right to request deletion of your personal information, subject to certain exceptions
• The right to opt-out of the sale of your personal information
• The right to non-discrimination for exercising your CCPA rights

To exercise your California privacy rights, please contact us using the information in the "Contact Us" section. We will verify your request using information associated with your account, including email address. Government identification may be required.

We do not sell personal information as defined by the CCPA. However, we do share certain information as described in the "How We Share Your Information" section above.

In the past 12 months, we have collected the following categories of personal information from consumers:

• Identifiers (such as name, email address, IP address)
• Personal information categories listed in the California Customer Records statute
• Protected classification characteristics under California or federal law
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Professional or employment-related information
• Inferences drawn from other personal information

For more details about the personal information we collect and how we collect, use, and share it, please see the sections above titled "Information We Collect" and "How We Share Your Information."

14.2 European Economic Area (EEA), UK, and Swiss Residents

If you are in the EEA, UK, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws

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