HomeAbroad Privacy and Information Security Policy

Effective date: Aug. 30, 2023 

This Privacy and Information Security Policy applies to your access and use of all products and services that are made available by HomeAbroad Inc. through our websites, including but not limited to www.homeabroadinc.com and our downloadable mobile applications (collectively, the “Site”). 

At HomeAbroad, we are committed to protecting your privacy and creating a safe and secure online environment for anyone who visits or uses our site. All information is confidential and is never sold, rented, or otherwise shared with another business other than to help us provide the Services listed on our website and as provided herein. By visiting HomeAbroadInc.com or otherwise using our Services, you are accepting the practices described in this Privacy Policy.

Most of our data collection, use, and sharing practices are governed by the Gramm-Leach-Bliley Act.  

I. Information We Collect 

A. INFORMATION WE COLLECT DIRECTLY FROM YOU 

We may collect information directly from you when you use our Services — for example, when you submit your inquiry to get connected with a real estate agent, a mortgage lender or access to other financial products. In such cases, we may ask you to provide us with one or more of the following pieces of information: 

• Name. 
• Email address. 
• Phone number. 
• Information about your real estate or financial product needs.  
• Other demographic information when such information is relevant to a particular financial product or service you have requested  

• When you communicate with us, either by email, phone, or other means of communication, we may also collect the content of these communications, including but not limited to recordings of phone calls where permitted by law. 

B. INFORMATION AUTOMATICALLY COLLECTED  

1. Information Collected 

When you visit the Site, use the Services, or open an email from HomeAbroad, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation: 

• IP address or other device address or ID. 
• Web browser and/or device type. 
• Geolocation data, including if you use the Site on a mobile device. 
• Hardware and software settings and configurations. 
• Web pages or sites that you visit just before or just after visiting the Site. 

• Pages you view on the Site. 
• Your actions on the Site, including the electronic path you take to our Site, through our Site and when exiting our Site, as well as your usage and activity on our Site, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”). 
• Dates and times that you visit, access, or use the Services. 
   

2. Cookie Information  

When you use the Services, we may send one or more Cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device.  We may use both Session Cookies and Persistent Cookies.  A Session Cookie disappears after you close your browser. A Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent Cookies can be removed.  Please review your web browser “Help” file to learn the proper way to modify your Cookie settings. If you delete, or choose not to accept, Cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. 

3. Third-Party Web Beacons and Third-Party Buttons 

We may implement third-party advertising or other content on the Site that may use clear GIFs or other forms of web beacons, which allow the third-party content provider to read and write Cookies to your web browser in connection with your viewing of the third-party content on the Site. Additionally, we may implement third-party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser Cookies, even when you do not interact with the button. 

We also engage third-party partners and vendors like Google Analytics, Hotjar and others, who provide analytics and advertising services, to assist us in providing you the Site and our Services. We allow these third parties, including nonaffiliated business partners, advertising networks, analytics providers, and other advertising service providers, to automatically collect Clickstream Data and other information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. For example, we may use third-party analytics tools to help us understand and record the electronic path you take to our Site, through our Site and when exiting our Site, as well as your usage and activity on our Site, such as the links and objects you view, click or otherwise interact with. We use this data for our own analytics and advertising purposes, as well as to facilitate partner relationships and your interactions with other third parties. In addition, certain of our third-party partners may use this information to display online advertisements tailored to your interests and preferences across your browsers and devices, to conduct ad campaign measurement and website analytics, to detect, prevent and report fraud, or to carry out their own business and commercial purposes. 

Where information collected through web beacons, buttons, and similar technologies is collected directly by third parties, their collection and use of information is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative or the Digital Advertising Alliance and participate in the industry’s opt out, available at http://optout.aboutads.info/#!/ or at http://optout.networkadvertising.org/#!/. Additionally, you may opt out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout. 

Due to differences between using websites and apps on mobile devices, you may need to take additional steps to opt out on both platforms.  Many mobile devices allow you to opt out of interest-based advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our app using the standard uninstall process available on your mobile device or app marketplace. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out. 

C. INFORMATION FROM OTHER SOURCES  

We may also obtain information about you from third-party sources, such as our business partners, referral partners or advertisers. If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Policy, the Terms, and applicable law. 

II. How We Use Your Information 

Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. We use the information you provide, for example: 

A. To provide you the Services you request and enable non-affiliated third parties to provide additional services to you. 
 

B. To operate, maintain and improve the Services and create new features and functionality. 
 

C. To understand and analyze usage trends and preferences of our users across different devices. 
 

D. For fraud detection and information security. 
 

E. We may use your e-mail address or other personal information (a) to contact you for administrative purposes such as customer service, (b) to address intellectual property, right of privacy or defamation issues related to content you have posted on the Services, and/or (c) to send you promotional materials, offers, and/or messages related to the Services and the activities of third parties we work with. Generally, you can opt out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Services, or by contacting us directly at [email protected]. 

F. We may use Cookie Information and Automatically Collected Information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) pre-fill forms; (c) provide customized advertisements, content, and information across your devices; (d) monitor and analyze the effectiveness of Services and third-party marketing activities; (e) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (f) track your entries, submissions, and status in any promotions or other activities. 

III. How We Share Your Information 

A. We may disclose your information in connection with providing the Services and the operation of our business. For example, we may share personal information, such as name, email, phone number and other identifying information, with nonaffiliated third-party service providers to verify your identity in connection with your use of certain aspects of the Services.  
 

B. Affiliated Entities – We may share your personal information to our subsidiaries and corporate affiliates, including future subsidiaries and affiliates of HomeAbroad to use your information consistent with this Policy.
 

C. We may share automatically collected information such as IP address and Clickstream Data as well as de-identified information with nonaffiliated third-party in regard to your inquiry. 
 

D. We may share your information with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure. For example: 

1. For website, application development, hosting, data storage, maintenance, and other services for us. 

2. For internal marketing, delivery of emails, including promotional, marketing and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising. 

3. For fraud prevention and security purposes. 
 

E. When you choose to share your own information on a publicly accessible area of the Site, such as a public profile page or any section where you can publicly submit questions to us or our third-party partners, that information will be available to anyone who is able to access that content, including other Site users. Additionally, questions you submit, and answers provided by third parties may be posted on our Site and viewable by other users and the public. 
 

F. We may share de-identified and/or aggregate analytics with third-party partners about how users interact with our Services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service. 
 

G. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity. 
 

H. By submitting a request through our Services, you consent to the disclosure of your information to third parties in order for us to carry out your request. The collection and use of your information by third parties is subject to each third party’s specific privacy policy and terms of use. HomeAbroad has no control over the means by which third parties further use or disclose your information. 
 

I. If you submit a request through our Services, a third-party service provider may directly contact you with quotes or information via telephone, auto-dialed prerecorded calls, SMS, fax, and/or email. You may also receive telemarketing calls (HomeAbroad Phone Numbers and Partners) as a result of submitting the request, even if you are on the National Do Not Call Registry or any other similar registry, based on your express written consent to be contacted in regard to your inquiry. 
 

J. Do not submit a request for information or services if you do not want your personal information shared as described above. Once you have submitted a request through the Services and we have shared your information as described above, the terms of the third party’s privacy policy will apply to that party’s use of your information. 
 

K. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services. 
 

L. You have the option to refuse any free consultations or offers for services provided after you submit a request to a third party through the Services. 

M. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiations of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership. 

IV. Unsubscribing from our communication 

A. How to Unsubscribe From Email Communications 

If you do not wish to receive email offers or newsletters from us, you can opt out of receiving emails from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. 

B. How to Unsubscribe from SMS Communications 

If you do not wish to receive SMS form us in regard to your inquiry, you may reply STOP to any message you receive from us. Upon receipt of your STOP message, we will send you a SMS message to confirm that you have been unsubscribed. At that point, you will no longer receive any further SMS messages from us. If you need any assistance, you can reply HELP to any message you receive from us. Upon receipt of your HELP message, we will respond with STOP instructions and a link to relevant Terms of Service and Privacy Policy. 

V. Our Commitment to Data and Information Security 

We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services or store on the Site, and you do so at your own risk. 

VI. Nevada Privacy Rights 

Although we do not currently conduct sales of personal information, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future. To exercise this right, email us at [email protected] with the subject line:  “Nevada:  Request to Opt-Out.” 

VII. California Privacy Rights 

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to that law.  Most of our data collection, use, and sharing practices are governed by our Gramm-Leach-Bliley Privacy Policy. However, if you are a California resident, the CCPA may apply to our Services as they relate to business products featured on our site.  

VIII. International Visitors 

The Service is hosted in the United States and the third-party products and services featured are tailored for the United States market only.  You agree that if you choose to use the Services from outside the United States, you will be transferring your information outside of those regions to the United States for storage and processing regarding meeting your inquiry.  

GDPR Privacy Policy 

Legal Basis for Processing Personal Data under GDPR 

We may process Personal Data under the following conditions: 

• Consent: You have given your consent for processing Personal Data for one or more specific purposes in order to utilize our services.  
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof. 

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject. 
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person. 
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company. 
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company. 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Your Rights under the GDPR 

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. 

You have the right under this Privacy Policy, and by law if You are within the EU, to: 

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data by contacting us at [email protected]. This also enables You to receive a copy of the Personal Data We hold about You. 
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. 

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. 
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. 
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. 
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service. 

Exercising of Your GDPR Data Protection Rights 

You may exercise Your rights of access, rectification, cancellation and opposition by contacting us at [email protected]. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. 

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA. 

IX. In the Event of Merger or Sale 

HomeAbroad reserves the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. 

X. Changes and Updates to This Privacy Policy 

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Services. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms. Immaterial modifications are effective upon posting of the updated Privacy Policy or Terms of Service on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose. 

XI. Our Contact Information 

Please contact us with any questions or comments about this Privacy Policy, your personally identifiable information, our use and disclosure practices, or your consent choices by e-mail at [email protected]. You can also fine more options to contact us on this page.

Thank you for reviewing our Privacy and Information Security Policy.