Privacy Policy

Categories of Sources of Personal Information

We collect Personal Information about you from the following categories of sources:

You

When you provide such information directly to us.

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.  

When you use the Services and such information is collected automatically.

• Through Cookies(defined in the “Tracking Tools and Opt-Out” section below).
• If you use a location-enabled browser, we may receive information about your location.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.

Public Records

• ‍‍From the government or other sources.

Business Partners

• ‍Securitize
• ‍Banking partners
• ‍Loan Servicers
• ‍Originators

Third Parties

‍Vendors

• For example, we may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

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Our Commercial or Business Purposes for Collecting Personal Information

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving theServices, including testing, research, internal analytics and product development.
• Personalizing theServices, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Homium or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Homium or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

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How We Disclose Your Personal Information

We disclose your Personal Information to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your PersonalInformation. For more information, please refer to the state-specific sectionsbelow.

Service Providers.

These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.  
• Document service providers.
• Direct marketing service providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors.
• Title, closing, and escrow service provider.‍

Analytics Partners.

These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.  
• Companies that track how users interact with the Services.

Business Partners.

These parties partner with us in offering various services. They include:

• Businesses that you have or may develop a relationship with, such as  
• Securitize, whose privacy policy you can find https://securitize.io/privacy-policy
• Originators, such as Guild Mortgage whose privacy notice you can find https://www.guildmortgage.com/privacy-notice/

Parties You Authorize, Access or Authenticate

Third parties you access through the services.

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Affiliates

We may share Personal Information we collect with our affiliates, including our investors, Homium Mutual Benefit Corporation and Homium Asset Corporation, in connection with our Services and our business.

Legal Obligations

We may share any Personal Information that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the“Our Commercial or Business Purposes for Collecting Personal Information”section above.

Business Transfers

All of your Personal Information that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Information

We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.  

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Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use ourServices, analyze trends, learn about our user base and operate and improve ourServices. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our useof Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time. As of now, we only place necessary or essential cookieson our website. These cookies are necessary for our website to function.

Generally, you can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as(depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or“options” section of your browser’s menu. To find out more information aboutCookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

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Data Security

We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

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Data Retention

We retain Personal Information about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Information. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Information, why we collected the Personal Information, and the sensitivity of the Personal Information. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain your profile information and credentials for as long as you have an account with us.
• We retain your payment data for as long as we need to process your investment, loan, or software subscription.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
• We maintain records as required by applicable law.  

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Personal Information of Children

As noted in the Terms of Use, we do not knowingly collect or solicitPersonal Information about children under 16  years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected PersonalInformation from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Information to us, please contact us at hello@homium.io.

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California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@homium.io.

Access

You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:

• The categories of PersonalInformation that we have collected about you.
• The categories of sources from which that Personal Information was collected.
• The business or commercial purpose for collecting or selling your Personal Information.
• The categories of third parties with whom we have shared your Personal Information.
• The specific pieces of PersonalInformation that we have collected about you.

If we have disclosed your Personal Information to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Information shared with each category of third party recipient. If we have sold your Personal Information over the past 12 months, we will identify the categories of Personal Information sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Information that we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Information involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Information we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Information, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Processing of Sensitive Personal Information Opt-Out

If you are a California resident, please note that we only collect your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process such information with the purpose of inferring any characteristics about California residents.

Personal Information Sales and Sharing

We will not “sell” or “share” your Personal Information (as such terms are defined under the CCPA) and have not done so over the last 12 months. To our knowledge, we do not sell or share the Personal Information of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.

Exercising Your Rights under the CCPA

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, specifically: your name and email address, or if you have used SecuritizeID to login to Homium, your SecuritizeID username, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your ValidRequest warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: support@homium.io
• Send a request in writing to: Homium Inc., c/o Privacy, 15260 Ventura Blvd, Suite 1040, Sherman Oaks, CA 91403

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Other State Law Privacy Rights

California Resident Rights

UnderCalifornia Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at hello@homium.io.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at hello@homium.io with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• hello@homium.io
• Homium, Inc. c/o Privacy, 15260 Ventura Blvd, Suite 1040, Sherman Oaks, CA 91403