ONeil Interactive Privacy Policy

Last Updated: November, 2023

ONeil Interactive, Inc. (the "Company" or "we"), in the operation of the Homefiniti website, including through its software, (collectively, the "Services") is committed to protecting the privacy of its customers (collectively, "our users" or, as applicable to yourself and your organization, "you").

We believe that maintaining privacy is very important and hope you will read this Privacy Policy carefully so that you will clearly understand both our commitment to you and your privacy and how we collect, disclose and use personal information.

This Privacy Policy only applies to transactions made, and data gathered, on theServices and associated services, and does not apply to any other website or services.

By using the Services, communicating with us by email, or by otherwise submitting personal information to us, you agree to the terms of this Privacy Policy.

The term "personal information" refers to non-public information that relates to, identifies, describes, or is reasonably capable of being associated with, linked or linkable with a specific individual. As it relates to you, personal information could include your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, , credit card information, and other similar information). If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with our services, we will treat the combined information as personal information in accordance with this Privacy Policy.

Other information that may be collected on the Services may include, without limitation, website pages viewed, sites visited before using or visiting the Services, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, presentations viewed, time spent viewing pages of our website or using certain features of our website, demographic data such as server locations, clickstream data, location services, server location, cookies existing on your computer, search criteria used and results, date and time of access or visits to our website, frequency of visits to our website, connection speed, and other information.

UPDATES AND CHANGES TO PRIVACY POLICY

We may revise our Privacy Policy at any time. In the event of a change in this Privacy Policy, a revised Privacy Policy will promptly be posted to our Services, and the "Updated" date will be changed. Please revisit this page to familiarize yourself with changes to the Privacy Policy. You agree to accept posting of a revised Privacy Policy as described herein as actual notice to you of such revised Privacy Policy. Your continued use of our Services after such posting constitutes consent to the collection and use of your information as described in the then-current Privacy Policy.

HOW AND WHY WE GATHER INFORMATION

When you register for an account for use of the Services or at any later time, we collect certain personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your "User Account." From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences. If you choose to provide such information, during registration or otherwise, you are giving us permission to collect, store and use it consistent with this Privacy Policy.

We may also obtain your personal information from your transactions with us or other users through the services provided through this Services, or from third parties such as credit reporting agencies.

EMAIL COMMUNICATIONS

We regularly send email newsletters to our registered users. Registered users may subscribe or unsubscribe to an email newsletter at any time by changing their email preferences. On occasion, we may send emails to individuals such as registrants and members who have provided us with their email address, informing them of events or promotions we think might be of interest to them. We also send promotional emails, or other marketing communications, to customers and those individuals who have requested a catalog or email. Email recipients may always opt out of any email category at any time by following the unsubscribe instructions included in the email message or by emailing us at: optout@oneilinteractive.com.

Please note that opt-out requests may take up to twenty-four (24) hours to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

Emailing Us: We try to respond to email messages requiring a response in accordance with our internal policies. If you email us, your message and email address will be forwarded to the appropriate department within our business. We may choose to save this information. We are pleased to hear from you.

COOKIES AND BEACONS

When you use our Services, whether or not you register for an account, we may send one or more cookies. "Cookies" are small text files containing a string of alphanumeric characters that may be placed on your web browser. Cookies make it easier for you to navigate our Services by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you navigate between webpages on the Services and/or as you access the Services. This use of cookies for authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set or to prevent cookies from being set.

A "web beacon" is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Please note that if you decline to use cookies, you may experience reduced functionality or slower site response times. Declining to use our authentication-related cookies may prevent you from using the Services altogether. You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at: http://support.google.com/analytics/bin/answer.py?hl=en&answer=2700409.

We or our service providers may also collect web surfing data related to your use of our Services (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences). This may be accomplished by using cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you use or visit the Services. Web surfing data and similar information may be used: for administrative purposes; to assess the usage, value and performance of our online products and services; and to improve your experience with our services. For more information on our use of cookies and similar technologies please see our cookie policy.

COLLECTION OF PERSONAL INFORMATION

Categories of Personal Information.Depending on how you interact with us,we may collect the following categories of personal information (subject to applicable legal requirements and restrictions):

• Name, contact information and other identifiers: identifiers such as a name, username, account name, address, phone number, birth date, email address, and online identifier.
• Purchase Information: electronic customer records, including information about purchases, containing Personal Information.
• Device information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
• Demographic Information: including gender, age, race and disability. Certain information could include information that is considered sensitive personal information as that term is understood under certain data protection laws.
• Communications: direct communication, web forms, online polls, or interactions with our blogs and posts.
• Commercial information: including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Usage data: internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement.
• Location data: location information about a particular individual or device, general location information (for example, your IP address may indicate your more general geographic region), and information.
• Profiles and inferences: inferences drawn from any of the information identified above to create a profile reflecting a resident's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

SOURCES OF PERSONAL INFORMATION.

We may collect Personal Information about individuals:

• Directly from you: such as when you make a purchase, when you create an online account with us (the "User Account"), participate in contests and promotions we offer, register to receive marketing and other communications from us, enter a sweepstakes or promotion, register product warranties, engage with us as part of an offer or marketing initiative, or contact us for customer support purposes.
• From third parties: such as our customers that engage us to provide website hosting services, third-party providers of services to us (e.g., fraud detection, identity verification and security), internet listing services (e.g. Zillow, Trulia, etc.), marketing agencies and third parties that provide advertising services to us, consumer data resellers, social networks, and marketing partners.
• Related to your use of our Services: including information we collect automatically when you use our Services or interact with us, or information we derive about you and your preferences or interests based on the personal information we collect and our interactions with you.

We may collect personal information about you from third-party sources (which may be combined with other personal information we have collected about you), such as:

• Purchases, orders, and payments: if you make a purchase and process your payment with a third-party processor (e.g. Stripe) we may collect personal information such as your name, billing address, payment type, as well as credit card number or other payment account details.
• Social media: if you choose to link, create, or log in to your User Account with a social media service (e.g., Twitter, Facebook, Instagram, TikTok, etc.), we collect your permission to access certain information from your profile with that social media service. We include links to social media platforms, such as Facebook, TikTok, Pinterest, Instagram and Twitter. These third-party services may collect identifiers from you or information about your IP address and which page you're visiting on our Services, and they may set cookies for the purposes the third-parties have described in their privacy policies. Your interactions with those features are governed by the privacy policies of the companies that provide them, and not by this Privacy Policy. If you post or if you engage with a separate social media service or interact with us on our page with any social media service, we may collect personal information about you related to those interactions.
• Acquisition: we may collect Personal Information as a result of a corporate restructuring, or an acquisition or merger with a third party.
• Other: we may obtain personal information, such as demographic information or updated contact details, from third parties; we may also collect information from public records.

We may automatically collect or derive personal information about your use of our Services, or other interactions with us.

• Site and Applications: We and our third-party providers may use cookies, pixels, tags, log-files, and other technologies to collect information about a user from their browser or device, including, without limitation, your browser type, device type, operating system, software version, phone model, phone operating system, platform-dependent information, requested document, referring URL, date and time of your visit, clickstream data (e.g., about the pages you view, links you click and date and time stamps for your activities on our Site), and the IP address associated with your transactions in the system. The information that we collect automatically may be linked with other Personal Information we have collected.

USE OF PERSONAL INFORMATION.

We and our authorized third parties will only process your personal information for the purposes set out in this Privacy Policy or our Terms of Service. We may use personal information for a variety of purposes, including, without limitation:

Providing support and services: including to provide our Services and interact with you on our Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes.

Analyzing and improving our business: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Services; to troubleshoot problems that may arise on the Services; to improve the accuracy of our customer database; to increase our understanding of our customer database; to increase our understanding of our customers; and for other research and analytical purposes.

Personalizing content and experiences: including to tailor content we send or display on our Services and to otherwise personalize the content you receive and/or your experiences on the Services. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in, and to display the content according to your preferences.

Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to send you promotional materials when you sign up for our email list; to conduct sweepstakes, contests or other promotional offers; to contact you about our Services, products, or other information we think may interest you; and to identify potential new customers.

Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third-party, or other unauthorized activities or misconduct.

Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.

Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests.

To perform any contracts in place between us and you: where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

We use aggregated information provided by or collected from our users to understand and analyze the usage trends and preferences of our users, to improve the way our Services work and look, and to create new features and functionality. We do not and will not sell analytics that identify personal information of our users without written consent from the user.

DISCLOSURE OF PERSONAL INFORMATION

We limit disclosure of personal information outside our Company. We may disclose the personal information we collect with the following categories of third parties:

• Service providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as information management, account processing, client services, hosting providers, auditors, advisors, consultants, payment processors, customer service and/or support providers, or other data collection relevant to our business.
• Advertising and Marketing Partners: We may share personal information with third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services. These third parties may receive or access browsing and/or other data about your use of the Services, in order to help us better reach individuals with relevant ads and/or measure our ad campaigns, and/or to better understand how individuals interact with our Services over time and across devices. The third parties may also assist us with promotions, promotional offers or engagements. We may also transfer and/or sell personal information we collect and/or join together with other businesses to bring selected opportunities to customers or potential customers.
• Subsidiaries, affiliates, and business partners: We may share your personal information with affiliates, and other companies that sell products or services that complement our products and services; we may also share personal information with companies we work with to provide the Services; these affiliated companies may use such Personal Information for the purposes set out in this Policy, including for market research, sending promotional material, newsletters, and surveys.
• Legal compliance: We may be required to share personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain personal information when we believe that doing so is reasonably necessary to protect the rights, property and safety of our company and/or others.
• Business transfers: We may disclose and/or transfer personal information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law. In such cases, we will provide you notice before your personal information is transferred to and becomes subject to the Privacy Policy of a different entity.
• Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect our and our affiliates, partners, clients, customers and/or others' rights, property, or safety.
• Credit reporting or collection agencies: We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

We do not and will not sell any of your information, including non-personally identifiable or personally identifiable information, to any third party for purposes of advertising, soliciting, or telemarketing

OUR PRIVACY POLICY DOES NOT APPLY TO THIRD-PARTY ACTIVITIES OR SITES

The Services may provide links to third-party websites for your convenience and information. If you access those links, you will leave our Services. Any information submitted by you to a third party, will be controlled by that third party's Privacy Policy, which may differ from our own. This Privacy Policy does not cover the collection of information by cookies or other methods by such third party services or other third parties, such as our business partners. We do not control how these third party services or third parties collect information or by what means such third party services or third parties may use their own cookies to collect information about you. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services. We encourage you to review the privacy policy of any company before submitting your personal information.

YOUR RIGHTS

US data protection laws grant California, Colorado, Connecticut, Utah, and Virginia residents the following data rights:

Right to Know and to Access.You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. This information is disclosed in the "Collection of Personal Information" Section of this Privacy Policy.

You also have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request.

Right to Portability. You have the right to request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you through your user account with us, or via email to the email address you have provided with your request.

Right to Delete.Subject to certain exceptions, you have the right to request that we delete any of your personal information. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct.Subject to certain exceptions, you have the right to request that we correct inaccurate personal information that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the personal information and the purposes of the processing of the personal information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.

You can modify the information concerning your account by visiting your profile page and editing any information you wish to change. You can change and update your e-mail address, password, contact information, or other login information by visiting your account's settings page subject to our website policy. If you wish to delete your account or need help modifying account information, please contact us at support@oneilinteractive.com. We will require up to twenty-four (24) hours to process such requests.

Non-Discrimination.We will not discriminate against you for exercising any of your data privacy rights.

Exercising Your Rights.To make your request to know or delete, contact us toll-free at 800-285-0689, and provide the following information: first name, last name, email, mailing address, brand, request. We will verify your request by sending a response to the email or mailing address we have on file for you.You can also submit requests to exercise your rights via one of the below methods:

Contacting us via our website, https://oneilinteractive.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child.

Certain data protection laws limit the ability to make a request to know to twice within a 12-month period, and allow us to charge a reasonable fee for responding to numerous requests from the same user. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

California Residents.Right to Opt-Out of Sale or Sharing of Personal Information.If you are a California residentyou have the right to opt-out of selling or sharing your personal information with third parties, as those terms are defined under California law. Submit your request to opt out of the sale of your personal information here.

As described above, we will only share your information with our affiliates, service providers, in connection with certain business transfers, as required by law, or, in some cases, business partners that you agree to share your information with. We do not offer any financial incentives in exchange for retention or sale of personal information.

California Shine the Light Law

Under California's "Shine the Light" law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal data are entitled to request and obtain from us, free of charge, information about the personal data (if any) we have shared with third parties during the immediately preceding calendar year for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may submit a request to the contact information provided below. The request should attest to the fact that the requester is a California resident, and provide a current California address. We are only required to respond to a customer request once during any calendar year. Please be aware that not all information sharing is covered by California's "Shine the Light" law and only information sharing that is covered will be included in our response.

Virginia and Colorado Residents Rights

Right to Opt-Out. You have the right to out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Right to Appeal. If you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing [INSERT PRIVACY APPEAL EMAIL ADDRESS] with the subject line "Data Access Request Appeal." If after you complete the appeal process with us, you are still unsatisfied with our response, you may contact your Attorney General to file a complaint. Below are the contact information for the appropriate entity where you can inquire about filing an appeal:

Virginia residents:
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
Phone: (804) 786-2071
https://www.oag.state.va.us/

Colorado residents:
Office of the Attorney General
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000
https://coag.gov/

Supplemental Notice for Nevada Residents

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 support@oneilinteractive.com 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. If you have any questions, please contact us as set forth below.

OUR COMMITMENT TO CHILDREN'S PRIVACY

We do not knowingly collect personal information on or through our Services from persons under 13 years-of-age without their legal guardian's consent. If we learn that personal information has been collected from persons under 13 years-of-age through our Services without their legal guardian's consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the Services or we have received any personally identifiable information of that child without your consent, you may alert us by contacting us.

INTERNATIONAL VISITORS

Our Services may be accessed and/or used by users located outside the United States in accordance with our Terms of Use and other policies and procedures posted on the Services. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

SECURITY

We use commercially reasonable efforts to maintain the confidentiality, integrity and security of our users' personal information. We urge you to take steps to keep your personal information safe, such as choosing a strong password and logging out of your User Account and closing your web browser when finished using the Services.

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to our Company is done at your own risk.

Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. All credit card numbers submitted to the site are encrypted using "Secure Socket Layer" (SSL) encryption. SSL technology is an industry standard for protecting sensitive information as it is transmitted over the Internet. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place other appropriate physical, electronic and administrative procedures to safeguard and secure the information we collect online. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the service or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of our Services. We may post a notice on our Webpage if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

CONTACT INFORMATION
If you have any questions regarding this Privacy Policy, please contact: support@oneilinteractive.com.