ROOTS PRIVACY POLICY

This Privacy Policy is effective as of July 28, 2022.

This Privacy Policy (“Policy”) describes how Roots Homes, Inc. (“Roots”, “we, “us” and “our”) collects, uses and personal informed from users of our website at https://roots.homes (the “Site”) and the Roots Mobile App  (“App”), and the services we provide through the Site and App (collectively, with the Site and the App, the “Services”).

When you access or use our Services or otherwise submit information to us, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Policy.  

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at hello@roots.homes

Overview of Our Services

Our Services enable individuals to earn equity in the properties that they are renting.  We collect information from current and prospective customers of our Services, and current and prospective business partners.  We use this information to provide Services, for marketing our Services and for other purposes as set forth in this Policy.

The Personal Information We Collect

The type of personal information we collect will depend on your interaction with us:

· Registration: If register to use our Services through the Site and the App, we request the following information to set up your account: your name, address, email address, phone numbers, information about housing budget, personal preferences and other data necessary to perform our Services:

· Sign

· Background Check and Credit Reports: If you are interested in renting property from us or from property owner with whom we partner, we will arrange for a background check and credit report to confirm your creditworthiness and suitability as an investor and renter of the property.

· Transaction Information: We collect information to process rent and equity transactions, including your credit card information, payments made, rents amount paid, and equity earned.  You can access this information through your account profile.

· Use of the Site and Other Contacts and Communications:  If you contact us through the Site, we may ask you to provide additional information that helps us enhance your Site visit, assist you with technical support issues, or permit post-visit follow-up. For example, if you send us an information request email, we receive your email address, and any other information you provide, such as your name, telephone number, etc.

· Third-Party Sources: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you such as IP address. This helps us to qualify customers for properties, provide Services, update, expand and analyze our records, and identify new prospective customers.  For example, we use credit reporting agencies to provide credit reports and background checks for prospective customers.

· Information Collected Automatically. If you visit our Site or use our Services, we use cookies and other technologies to track the usage our Site and Services, including your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site or use our Services; your device ID; and the referring URL, or the webpage that led you to our Site.  We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information  

How Your Personal Information Is Used

We use the personal and other information we collect from you as follows:

· To provide the Services.

· To process rent and equity transactions.  

· To respond to your inquiries and provide technical support and customer service.

· To send you email and other forms of communications about our products and services and our business;

· To (a) ensure our Site and Services are working as intended,  (b) operate our business, better understand how users access and use our Site and Services, both on an aggregated and individualized basis, (c) develop, maintain, protect and improve our Services, and (d) perform research and  analytics, including to analyze and report on usage and performance of our Site and Services.

· To detect, investigate, and prevent activities on our Site that may violate our security or terms of use, could be fraudulent, violate copyright, or other rules or that may be otherwise illegal, to comply with legal requirements, to defend or exercise legal claims, to respond to law enforcement or governmental investigations or requests, and to protect our rights and the rights and safety of our users and others.

· For other purposes consistent with any consent that you have provided.

How Your Personal Information is Disclosed

We may disclose the information we receive as follows:

· Property Managers and Owners. If you are renting a property, we may need to disclose certain information to the owner and manager of that property for their use in managing the property.

· Consent.  Where you have provided consent, we share your information, including Personal Information, as described at the time of consent.

· Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personal information will be maintained by such affiliates and subsidiaries in accordance with this Policy.

· Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, such as providing storage services.

· Business Transfers. We may transfer your personal information in connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other change in corporate status in which information is transferred to one or more third parties as one of our business assets.

· In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.

· To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use or this Policy, or as evidence in litigation in which we are involved.

We do not sell your personal Information to third parties for their direct marketing or other purposes.

Data Subject Requests

You can make a request to access, correct or delete the personal information we have collected to you by emailing us at hello@roots.homes. We reserve the right to deny requests for any reason to the extent permitted by law. We may request additional information from you to verify your request.  

Do Not Track

California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

Location of Services and Personal Information

Our Services are intended for use in the United States only and we store personal information in the United States. If you access the Services from outside the Untied States, you consent to the transfer of your personal information to the United States, which may have less protections for your personal information than your jurisdiction of residence.

Retention of Personal Information

We generally retain personal information for at long as necessary to fulfill the purposes for which it was collected. However, we might retain personal information for longer periods of time, if required by our legal obligations or for historical or research and analytical purposes.  

Cookies

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services.

In addition, we, our service providers and others sometimes use data-gathering

mechanisms on the Services, including without limitation “web beacons”, “clear GIFs”, “pixels” and/or “tags”. These perform statistical and administrative functions, such as measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or IP address) and positioning images, and typically do so without detracting from your online experience.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.

Opting Out of Targeted Advertising

You an opt-out of receiving marketing email communications by using the unsubscribe mechanisms or emailing us at hello@roots.homes.

In addition, we and some of our services provider your personal information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. To opt out of receiving such targeted advertising from us, please email us at hello@roots.homes. In addition, you can opt out of certain ad network interest-based advertising by visiting the customer opt-out pages at http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services.  For more information on Google Analytics, please see

Minors and Children’s Privacy

. Our services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access our website at any time or in any manner. If we learn that personal information has been collected on site from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information.

Security of Information

No company, including ours, can fully eliminate security risks associated with consumer information.  We strive to protect your information. We follow generally accepted standards to protect the information we receive. However, no method of transmission, or method of electronic storage, is 100% secure.  Technical mistakes are possible, and if such a mistake takes place, we will take commercially reasonable steps to correct it.  We cannot guarantee absolute or warrant the security of any information you transmit to use or receive from us.

Links to Other Websites

Our Site may include links to other sites whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Update

We reserve the right to modify or update our Policy from time to time. If we modify our policy, we will indicate when such terms are effective and will also update the “last updated” date. We will post any such changes on the Site.  We may also notify our customers by emailing them at the email address in their account.   If you use the Services after updates are posted, you agree that your personal information may be used in accordance. We encourage you to review this policy periodically to stay informed about how we collect, use, and disclose your personal information.