PRIVACY NOTICE

This Privacy Notice applies to, and explains how, Renuity Operations, LLC and its subsidiaries and affiliates (“we” or “Company” or “us” or “our”) collect, use, and share your information. Company is part of a portfolio of national home improvement operating divisions operating across the United States.

Please note that this Privacy Notice (“Privacy Notice”) applies to:

• information collected through the website, www.renuityhome.com (the “Site”);
• information collected through the sites belonging to our subsidiaries and affiliates, and any other sites linking to this Privacy Notice (collectively, “our Sites”);
• information obtained during phone calls to us that you initiate or that we or our partners initiate with your prior consent;
• and any other information you choose to provide to us.

INTRODUCTION

This Privacy Notice discloses Personal Information we collect and how we use it, as well as the choices you can make about the way your Personal Information is collected and used. We also explain how Personal Information will be used.

Personal Information is information that identifies, relates to, describes, and is reasonably capable of being associated with a particular consumer or household. Personal Information does not include de-identified, anonymized, or aggregated consumer information.

Our Sites are intended for use by individuals in the United States. If you are outside the United States, by using any of our Sites or by providing your information to us, you are consenting to having your Personal Information transferred to and stored in the United States.

INFORMATION WE COLLECT

We and our service providers may collect Personal Information and other information from or about you in a few different ways. Specifically, we may collect or receive information: (1) from you through information you provide to us,including one of our sister companies, affiliates, subsidiaries or parent company;(2) indirectly from you by observing your actions on our Sites; and (3) from certain third parties. Each of these is discussed in more detail below.

Information You Provide to Us

You may provide information to us in a number of ways:

• If you request information from or create an account with us, you will provide your name and email address, and potentially your geographical location.
• If you purchase goods or services through us, you will provide your name, email address, physical address, telephone number and payment information.
• If you request financing for goods and/or services, we will also collect driver’s license, social security and other credit related information. Providing such information does not guaranty that financing will be made available to you.
• If you sign up for our newsletter, you will provide your name and email address.
• If you submit an inquiry through one of our Sites, we will generally collect your name, email address, telephone number, and any other information you provide.
• If you post information on our social media pages through sites such as Facebook and LinkedIn, that information may be collected and used by us (as well as other users of those sites and the public generally). Please do not post any information on any site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
• When you submit a resume or application for employment, any information you provide will be collected and we may also obtain additional information through references, former employers, background checks, and credit reports where permitted by law.
• If you contact us through some other means, such as by calling, we may collect information you provide to us.

Information Indirectly Collected from You

Cookies and Other Technologies. We automatically collect information from you using cookies and other technologies on our Sites. Cookies are small text files offered to your computer or mobile device by servers in order to keep track of your browser as you navigate our Sites. We may use cookies and similar technologies to identify who you are and may use them when you visit our site, click on our ads, or click on links in our emails. Cookies also enable us to remember your user preferences for our Sites. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, site and application development, and protecting against fraud and theft. You can block or remove cookies using your Internet browser’s settings. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. If you block or remove cookies, you may not be able to perform certain transactions, use certain functionality, and access certain content on our Sites.

We use three primary types of cookies:

• Necessary Cookies – These cookies are essential for the running of a website. Without these cookies, some features of our Sites may not work.
• Functional Cookies – These cookies support your use of our Sites and enable certain features to enhance your experience. For example, functional cookies remember your selections as you move from page to page.
• Performance Cookies – These cookies collect information needed to support our Sites and allow us to identify problems and improve our Sites– for example, performance cookies may provide us with information about how you came to our Sites and how you navigate through our Sites.

Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. Clear GIFs are embedded invisibly on web pages. We may use clear GIFs in connection with our Sites to, among other things, track the activities of visitors, help us manage content, and compile statistics about usage of our Sites. We and our third party service providers also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Some of our communications to you may contain a “click-through URL” which links to content on our Sites. When you click one of these URLs, it passes information through our web servers before you arrive at the destination webpage. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from us.

“Do Not Track” is a privacy setting that users can set in certain web browsers. If turned on, this setting requests that website not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.

Site Recordation Technology. We use site visit recordation technology to memorialize site visits, including technology provided by third parties, including Jornaya’s Lead ID or Active Prospect’s TrustedForm, as applicable. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. The LeadID and/or TrustedForm Script is embedded on our Sites and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the LeadID and/or TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser (“Data Collection Pages”). For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at https://activeprospect.com/privacy-policy/. For more information about Jornaya’s data use and collection policies and practices, please review the Jornaya Privacy Policy, located at https://www.jornaya.com/consumer-privacy-policy/.

Traffic Data. We automatically track and collect general log information when you visit our Sites, including your: (a) Internet Protocol (IP) address; (b) domain server; (c) operating system; and (d) type of web browser; and (e) the pages you visit on our Sites (collectively “Traffic Data”). We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of our Sites. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and clear GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).

Third Party Websites and Social Media Services. Our Sites may include links to third party websites or social media services where you may be able to post comments, reviews or other information. We may monitor comments and reviews regarding us that you publicly post on social media or customer review sites. In addition, please note that your use of these third party websites or social media services may result in those sites collecting information about you. We are not responsible for these third party websites or social media services and you should review their privacy policies to make sure you understand the information that may be collected, used, and shared by those sites.

Information from Third Parties

Social Media Sites. To the extent you post information on our pages on third party social media sites, we may collect such information. We may also receive Personal Information about you through certain social media sites such as Facebook, Instagram, Twitter, and LinkedIn.

Third Party Analytics Services. We may work with third party analytics services such as Google Analytics to help us understand how our Sites are being used, such as tracking the frequency and duration of use of website and social media pages. These analytics services may use cookies and other technologies to collect information about the content you view, what website you visit immediately prior to and after visiting our Sites, and your system information and geographic information. The information generated by these technologies about your use of sites may be transmitted to and stored by the applicable analytics services.

Referral Sources. We may receive information from third party referral sources.

HOW WE USE YOUR INFORMATION

We and our service providers may use Personal Information for the following purposes:

• To register an account with us.
• To contact you regarding your appointments and provide you marketing and promotional information relating to our Services, including through phone calls and text messages if you opt-in to receive those communications.
• To process and fulfill orders for products and services.
• To process requests for financing and in connection with other financing transactions with third party lenders.
• To respond to your inquiries and fulfill requests for service, quote or estimate, or provide more information about our products and services. This may include sharing your information with our third-party partners, when applicable.
• To present our Sites.
• To provide our newsletter and other promotional information, including through phone calls and text messages, depending on how you choose to hear from us.
• To improve your experience on our Sites, including using your geographic location to show information most relevant to you.
• To evaluate and make improvements to our Sites or social media presences.
• To diagnose and fix problems with our Sites.
• To secure our Sites, and to prevent or detect criminal, unlawful, or harassing actions or conduct.
• If you apply for a job, to verify previous employment and to conduct background checks (as permitted by law).
• To provide any required reporting to governmental or regulatory entities.

On other occasions where we ask you for consent, we will use the information for the purposes we provide at that time.

SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We do not sell your Personal Information. We may disclose your Personal Information as follows:

• Service Providers. We may disclose Personal Information to third party vendors, contractors or agents who perform functions on our behalf (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as providing renovation services, SMS providers, data storage and management, analytics services, marketing services, payroll services, or payment services.
• Internal Parties. We may share Personal Information with our sister companies, affiliates, subsidiaries or our parent company.
• Third Party Lenders. We may share Personal Information with third party lenders in connection with financing transactions.
• Auditors and Legal Advisors. We may disclose Personal Information to our auditors and legal advisors.
• Business Transfers. If we are acquired by, or merged with, another entity, if substantially all of our assets are transferred to another entity, or as part of a bankruptcy proceeding, or if we are evaluating or in negotiations with respect to any such transaction, we may transfer, or make available, the Personal Information we have collected from you to the other entity or resulting legal entity.
• Legal Process. We also may disclose the Personal Information we collect from you in connection with a government investigation, a judicial proceeding, a court order, or other legal process (such as in response to a subpoena), or to respond to discovery requests or present evidence in a legal proceeding in which we are involved.
• To Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe such disclosure is needed to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, suspected violations of this Privacy Notice, and suspected violations of any applicable terms and conditions.
• Aggregated and De-Identified Information. We may share aggregated or de-identified Personal Information with our service providers and/or affiliated companies for marketing, analytics, advertising, research, or similar purposes.
• Regulators. We may disclose the Personal Information we collect to comply with applicable laws and regulations, to provide required reports to regulators, and to respond to inquiries or investigations by regulators.
• Job Applications. If you apply for a job position, some of your Personal Information may be shared with third parties in order to confirm your education, work history, and references, and to obtain background checks and credit reports if permitted by law.

CHILDREN’S PRIVACY

Our Sites and our services are not directed to children under the age of 13. Further, we do not knowingly collect Personal Information from children under the age of 13. If you become aware that your child has provided personally identifiable information without your consent, please contact us at privacy@renuityhome.com . We will take commercially reasonable efforts to delete such information from our records.

YOUR PRIVACY CHOICES

You may opt-out of receiving email communications and other marketing materials from us (or any third-party email marketing service we may use) via links provided in each email (usually at the bottom of the email). You can view and manage your marketing preferences to receive savings and project ideas or to opt out of marketing communications from us (or any third-party email marketing service we may use) via links provided in each email (usually at the bottom of the email). These marketing preferences will not affect communications such as: account statements, customer service inquires and legal documents. The preferences that you have entered will be honored in accordance with our Privacy Notice. Please allow sufficient time for your request to be processed.

Data Access and Portability

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

Data Erasure

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep information for tax, legal reporting, and auditing obligations.

Information you have shared with others (e.g., reviews, forum postings) will continue to be publicly visible on our Sites. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

USER-GENERATED CONTENT

You may be able to post content on or through our social media pages, including your comments, photos, or other information. If you post such content on social media pages, all of the information or content that you post may be visible to other visitors or users. Your postings and content may become public and we cannot prevent such information from being used by others in a manner that may violate this Privacy Notice, applicable law, or your personal privacy. Please carefully consider your content before posting. Further, please note that all such content is subject to removal if we determine, in our sole discretion, that it violates any applicable law, poses a security risk, infringes the rights of someone else, or constitutes a threat, defamation, or harassment.

LINKS TO THIRD PARTY WEBSITES OR PLATFORMS

Our Sites may contain links to third party websites or platforms. These links are provided for your convenience. We are not responsible for and have no control over the content on these other websites or platforms. The inclusion of a link on our Sites is not an endorsement. Please note that when you click on one of these links, you will leave our Sites and will be subject to the policies and privacy practices of the other website or platform, which may differ significantly from our Privacy Notice. Please review such third parties’ privacy policies before providing any Personal Information to them.

SECURITY OF YOUR INFORMATION

We use commercially reasonable security safeguards to help protect Personal Information from unauthorized access, alteration, loss, or disclosure. Despite these efforts, please understand that no system is perfect and we cannot guarantee that unauthorized access, theft, or loss of data will not occur. Please exercise caution when transferring any Personal Information over the internet.

Please advise us immediately at privacy@renuityhome.com of any incident involving Personal Information in our custody or control.

CHANGES TO YOUR INFORMATION

Our customers with accounts can visit our Sites and, if applicable, log into their account with us to update or correct their information. You may also contact us at privacy@renuityhome.com.

CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice and our Sites. You should review this Privacy Notice when you visit the Site to understand our current practices. The date at the top of the page shows when this Privacy Notice was last updated.

We encourage you to refer to this Privacy Notice on an ongoing basis so that you understand our current practices. You consent to any changes we make to this Privacy Notice if you continue to use our Sites or provide information to us after receiving a notice of the change or upon our posting of the new Privacy Notice on our Sites.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may be entitled to additional rights over your personal information. For more information about these rights and how to exercise them, please email privacy@renuityhome.com.

VIRGINIA PRIVACY RIGHTS

Virginia residents can exercise the following rights by also emailing privacy@renuityhome.com:

• Request to Access My Personal Information
• Delete My Personal Information
• Correct My Personal Information
• Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising

If we decline to take action on one of your rights as a Virginia resident, you can submit an appeal by going to privacy@renuityhome.com.