HOMEGAUGE PRIVACY POLICY

Last Effective Date: March 23, 2022

INTRODUCTION

This Privacy Policy addresses information collected by SHGI Corporation a/k/a HomeGauge (collectively, “HomeGauge”; “we”; “us”; or “our”) when you visit the website, http://www.homegauge.com and the pages under such website, including all mobile and PC applications (collectively, our “Website”) or register on the Website and our practices for preserving the privacy and security of such information. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use the Website. By accessing or using this Website, you agree to this Privacy Policy.

DEFINITIONS

The terms defined in the Introduction have their assigned meanings, and each of the following terms has the meaning assigned to it:

• “Agent” means a real estate agent or broker who retains an Inspector to perform an inspection
• “Customer” means an individual homebuyer, home seller, or investor who retains an Inspector to perform a home inspection.
• “Inspector” means an entity or individual providing home inspection services.

INFORMATION COLLECTION

Our Website (HomeGauge.com) collects information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). HomeGauge collects the following categories of personal information and has collected the following categories of personal information from its Customers within the last twelve (12) months, for the following categories of purposes and from the following categories of sources, and HomeGauge shares personal information with the following categories of third parties:

Cookies and Tracking

Browsing Information is automatically collected through various means such as cookies and pixels on this Website or in our emails. “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, tags, etc…) on our Website to customize your visit, to analyze how you use our Website and for other purposes to make your visit more convenient or to enable us to enhance our services. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge, but may be used to store your login credentials. We may use both first- and third-party cookies. First-party cookies are those set by us. Third-party cookies (like those used by Google Analytics described below or social media platforms) are cookies that are set by a domain and party other than us.

We may use Google Analytics, which is a web analytics service provided by Google, Inc. Google and similar services collect certain information relating to your use of the Website. Such services may use cookies to help the Website analyze how users use the Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).

Based on your web browser, you have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the services. Further information on cookies is available at www.allaboutcookies.org.

HOW WE USE YOUR INFORMATION

We use information that we collect from you or a third party that has been authorized to establish or access your HomeGauge account (such as an Inspector, Customer, or Agent with whom you are working):

• To present our Website and its contents to you;
• To provide you with notices about our Website and your account;
• To provide you with information, products, or services that you request from us;
• To market our projects and services to Inspectors;
• To market the products and services of our vetted affiliates and select third parties to Customers;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

DATA RETENTION

We will retain your information for as long as your account is active or as needed for us to manage and provide our services and for our business needs. Even if we delete some or all of your personal information, we may continue to retain and use de-identified or aggregate data previously collected.

DISCLOSURE OF YOUR INFORMATION

HomeGauge may share personal information (such as name, telephone number and email) of Customers with our vetted partners and affiliates for marketing purposes, such as contacting them about additional products and services. We only share Customer personal information after receiving express consent. Customers may opt out of HomeGauge sharing this information with such third parties at any time

Additionally, we may disclose your information:

• To our services providers, contractors, and third parties we use to support our business, such as those providing IT security, analysis of usage data, and other services to provide our products and services. However, such parties are only authorized to use the information as directed;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HomeGauge’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by HomeGauge about our Website users is among the assets transferred;
• To our affiliated companies within the American Family Enterprise to improve their products and services;
• To comply with any court order, law, or legal process, including to respond to any lawful government or regulatory request;
• To enforce or apply our policies or investigate fraud; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of HomeGauge, our users, Customers, or others.

INTEREST-BASED ADVERTISING

We believe that advertising is more effective and relevant when it is targeted to your interests and behaviors. Therefore, we may work with third parties who collect information on our Website and elsewhere through the use of cookies and similar methods in order to serve you with relevant advertisements on other services or to determine that you have seen our advertisements on other services.

You do have the ability to control certain advertising practices. We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA). You can learn more about interest-based advertising and opt out of targeted advertising from certain providers with whom we work by visiting the DAA’s consumer choice page. The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms automatically transmitted by web browsers for which we are cannot evaluate your choice.

For targeted advertisements delivered through mobile Apps, you can install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices or “Opt out of Ads Personalization” on Android devices).

LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other websites that we think may be of interest to you, such as social media platforms, and review sites suggested by the Inspector or in programs in which you participate. We do not endorse any other websites and services by providing such links, and our privacy policy applies only to your use of our Website. We are not responsible for the privacy policies of any websites and services we link to on our Website, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.

If you have a previous relationship with a third party, such as a social media platform, then they may recognize you and combine information collected through this Website with information they already possess about you. As described in this Privacy Policy, we may work with social media platforms or other advertising platforms to target advertisements to you based on the services HomeGauge provides.

CALIFORNIA PRIVACY RIGHTS

Right to Know About Personal Information Collected, Disclosed or Sold

If you are a resident of California, you have the right to request us to disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Data Subject Rights), and subject to certain limitations that we describe below, we will disclose such information to you.

You have the right to request any or all of the following:

• The categories of personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you; and
• The categories of information that we sell or discloses to third parties

Right to Request Deletion

If you are a resident of California, you have the right to request us to delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Data Subject Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated.

Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to perform certain actions, such as detecting security incidents and protecting us from illegal activity.

Right to Opt Out of the Sale or Sharing of Personal Information

We may sell your personal information. If you are a resident of California, you have the right to direct us to not sell your personal information at any time (see Exercising Data Subject Rights). Our ‘sales’ are generally sharing the personal information with our affiliates and advertising partners as described above for purposes that we believe are complementary to HomeGauge. However, you may choose to opt in to a program that may involve selling your personal information. You can always later opt out, but we are not able to retrieve your information from third parties who were previously provided with your information.

“Shine The Light” Law

California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us regarding the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt out of having your personal information disclosed to third parties for their direct marketing purposes, please complete our Do Not Sell My Personal Information Form and provide your contact information to be added to our suppression list.

Notice of Financial Incentive

From time-to-time, HomeGauge offers select qualified Inspectors the opportunity to build their inspection business at a discounted rate (“Promotional Offers”). Promotional Offers provide the HomeGauge reporting platform at discounted rate of $1 for a year (12 months from sign up). With these Promotional Offers, we hope to share the value of our state-of-the-art reporting platform to a broad new market of Inspectors.

If you are new to HomeGauge and interested in qualifying for Promotional Offers, you can opt in.

Privacy rules and regulations may consider these Promotional Offers as financial incentives provided in exchange for contact information. It is our reasonable estimate that based on our operating costs and the consideration exchanged, the value Inspectors receive from Promotional Offers is reasonably greater than or equal to the value HomeGauge receives. HomeGauge uses the contact information to offer the option of receiving additional information about discounted products, and only after recipients explicitly choose to opt in.

These are optional offers, and you can withdraw at any time. To opt out of Promotional Offers, please email us at privacy@homegauge.com, or call us toll-free at 1-(877) 274-4299. If you withdraw from a Promotional Offer, we will be unable to offer you the HomeGauge reporting platform at the discounted rate.

Exercising Data Subject Rights

To exercise the access, deletion and opt out rights described above, please submit a request to us by either:

• Visiting:
  • https://resources.homegauge.com/california-consumer-privacy-rights/ (opt-out)
  • https://www.homegauge.com/ccpa.htmls (access and delete)

• Calling us at 1-(800) 503-8766.

The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information. If you use an authorized agent to make request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us. To protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. You have the right not to receive discriminatory treatment for exercising any of your privacy rights.

NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. If you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by emailing us at privacy@homegauge.com or calling us toll-free at 1-(800) 503-8766. Please provide sufficient information for us to verify your identify, such as information your HomeGauge account number.

EUROPEAN UNION / UNITED KINGDOM PRIVACY RIGHTS

This section only applies to individuals in the European Union (EU), United Kingdom and Switzerland:

If you are situated in such locations, and the General Data Protection Regulation or its national equivalent (GDPR) applies, as a data subject, you have the following rights:

• Right to access — This right allows individuals to obtain confirmation as to whether or not personal data concerning them is being processed and provide access to such personal data It also allows individuals to request details of the processing of their personal data including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
• Right to rectify — This right allows individuals to rectify any inaccurate personal data about them.
• Right to restrict processing — This right allows individuals to block or suppress processing of personal data under certain circumstances.
• Right to be forgotten — This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
• Right of data portability — This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
• Right to object to processing — This right allows individuals to object to certain types of processing, including direct marketing, profiling, and providing for purposes of scientific or historical research and statistics.

We shall only process your personal data pursuant to a lawful basis, which will usually be with your consent, when we have a legitimate interest, or to perform a contract to which we are subject. Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To exercise your rights under the GDPR, please contact us at privacy@homegauge.com. Please note that for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. To verify your identity, we may need to gather more personal data from you than we currently have.

If you are situated in the EU/UK/Switzerland and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.

SECURITY

We take the security of our data and information seriously. We take what we believe are reasonable precautions to protect against unauthorized access to our systems and to prevent data from being disclosed to unauthorized parties. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Payment Security

When you place orders or make payments on our Website, all of your order information, including your credit card number, is transmitted through the internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our websites from capturing and viewing your personal information.

While we use industry standard means to protect our Website and your information, the Internet is not 100% secure. The measures we use are appropriate for the type of information we collect. We cannot promise that your use of our Website will be completely safe. We encourage you to use caution when using the Internet. Online access to your personal information is protected with a password you select. We strongly recommend that you do not share your password and that you use unique passwords for all of your online accounts.

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy at our discretion at any time. If we do make any changes, such change will appear on this page of our Website. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of the Website following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. We do not knowingly collect personally identifiable information from children under 16. 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 believe we might have any personal information from or about a child under 13, please contact us at privacy@homegauge.com.

CROSS BORDER DATA TRANSFERS

Our Website is maintained in the United States of America (USA). By using the Website, you authorize the export of personally identifiable information to the USA and its storage and use as specified in this Privacy Policy. We transfer personally identifiable information from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Information stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at privacy@homegauge.com.