CINCH PRIVACY POLICY

This privacy notice for Cinch Home Services, Inc. and/or California Cinch Home Services,  Inc. (doing business as Cinch or Cinch Home Services or California Cinch Home  Services) ("we," "us," or "our"), describes how and why we might collect, store, use,  and/or share ("process") your information when you use our services ("Services"), such  as when you:  

• Visit our website at http://www.cinchhomeservices.com, or any website of ours that  links to this privacy notice (together the “Website”); 

• Engage with us in other related ways, including any sales, marketing, or events. 

Questions or concerns? Reading this privacy notice will help you understand your  privacy rights and choices. If you do not agree with our policies and practices, please do  not use our Services. If you still have any questions or concerns, please contact us at  erelations@cinchhs.com. If you have an unresolved privacy or data use concern that we  have not addressed satisfactorily, please contact our U.S.-based third party dispute  resolution provider (free of charge) at https://feedbackform.truste.com/watchdog/request. 

SUMMARY OF KEY POINTS  

This summary provides key points from our privacy notice, but you can find out more  details about any of these topics by clicking the link following each key point or by using  our Table of Contents below to find the section you are looking for.  

What personal information do we process? When you visit, use, or navigate our  Services, we may process personal information depending on how you interact with us  and the Services, the choices you make, and the products and features you use. Learn  more about personal information you disclose to us. 

Do we process any sensitive personal information? We do not process sensitive  personal information.  

Do we receive any information from third parties? We may receive information from  public databases, marketing partners, social media platforms, and other outside sources.  Learn more about information collected from other sources. 

How do we process your information? We process your information to provide,  improve, and administer our Services, communicate with you, for security and fraud  prevention, and to comply with law. We may also process your information for other  purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.  

In what situations and with which parties do we share personal information? We  may share information in specific situations and with specific third parties. Learn more  about when and with whom we share your personal information.  

How do we keep your information safe? We have organizational and technical  processes and procedures in place to protect your personal information. However, no  electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,  cybercriminals, or other unauthorized third parties will not be able to defeat our security  and improperly collect, access, steal, or modify your information. Learn more about how  we keep your information safe. 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. 

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at privacy@cinchhs.com. We will consider and act upon any request in  accordance with applicable data protection laws. 

Want to learn more about what we do with any information we collect? Review the privacy  notice in full. 

TABLE OF CONTENTS 

1. WHAT INFORMATION DO WE COLLECT? 

2. HOW DO WE PROCESS YOUR INFORMATION? 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 5. HOW LONG DO WE KEEP YOUR INFORMATION? 

6. HOW DO WE KEEP YOUR INFORMATION SAFE? 

7. DO WE COLLECT INFORMATION FROM MINORS? 

8. WHAT ARE YOUR PRIVACY RIGHTS? 

9. CONTROLS FOR DO-NOT-TRACK FEATURES 

10.DO UNITED STATES RESIDENTS HAVE STATE SPECIFIC PRIVACY  RIGHTS? 

a. California Residents 

b. Colorado Residents 

c. Connecticut Residents 

d. Utah Residents 

e. Virginia Residents 

11.DO WE MAKE UPDATES TO THIS NOTICE? 

12.HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 

13.HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

1. WHAT INFORMATION DO WE COLLECT? 

Personal information you disclose to us 

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you register on  the Services, express an interest in obtaining information about us or our products and  Services, when you participate in activities on the Services, or otherwise when you  contact us. 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may  include the following: 

• names 

• phone numbers 

• email addresses 

• mailing addresses 

• contact preferences 

• billing addresses 

• debit/credit card numbers 

• contact or authentication data 

Sensitive Information. We do not process sensitive information. 

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated  with your payment instrument.  

All personal information that you provide to us must be true, complete, and accurate, and  you must notify us of any changes to such personal information. 

Information automatically collected 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser  and device characteristics — is collected automatically when you visit our Services. 

We automatically collect certain information when you visit, use, or navigate the Services.  This information does not reveal your specific identity (like your name or contact  information) but may include device and usage information, such as your IP address,  browser and device characteristics, operating system, language preferences, referring  URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain  the security and operation of our Services, and for our internal analytics and reporting  purposes. 

Like many businesses, we also collect information through cookies and similar technologies. You can control the use of cookies at the individual browser level. If you  reject cookies, you may still use our site, but your ability to use some features or areas of  our site may be limited. 

The information we collect includes: 

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage,  and performance information our servers automatically collect when you access or  use our Services and which we record in log files. Depending on how you interact  with us, this log data may include your IP address, device information, browser  type, and settings and information about your activity in the Services (such as the  date/time stamps associated with your usage, pages and files viewed, searches,  and other actions you take such as which features you use), device event  information (such as system activity, error reports (sometimes called "crash  dumps"), and hardware settings). 

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the  device used, this device data may include information such as your IP address (or  proxy server), device and application identification numbers, location, browser  type, hardware model, Internet service provider and/or mobile carrier, operating  system, and system configuration information. 

• Location Data. We collect location data such as information about your device's  location, which can be either precise or imprecise. How much information we  collect depends on the type and settings of the device you use to access the  Services. For example, we may use GPS and other technologies to collect  geolocation data that tells us your current location (based on your IP address). You  can opt out of allowing us to collect this information either by refusing access to  the information or by disabling your Location setting on your device. However, if  you choose to opt out, you may not be able to use certain aspects of the Services. 

Information collected from other sources 

In Short: We may collect limited data from public databases, marketing partners, social  media platforms, and other outside sources. 

To enhance our ability to provide relevant marketing, offers, and services to you and  update our records, we may obtain information about you from other sources, such as  public databases, joint marketing partners, affiliate programs, data providers, social  media platforms, and from other third parties. This information includes mailing 

addresses, email addresses, phone numbers, intent data (or user behavior data), Internet  Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles,  for purposes of targeted advertising. 

Social Media 

If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name,  email address, and gender. Any personal information that we collect from your social  media account depends on your social media account's privacy settings. 

2. HOW DO WE PROCESS YOUR INFORMATION? 

In Short: We process your information to provide, improve, and administer our Services,  communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. 

We process your personal information for a variety of reasons, depending on how you  interact with our Services, including: 

• To facilitate account creation and authentication and otherwise manage user  accounts. We may process your information so you can create and login to your  account, as well as keep your account in working order. 

• To deliver and facilitate delivery of services to the user. We may process your  information to provide you with the requested service. 

• To respond to user inquiries/offer support to users. We may process your  information to respond to your inquiries and solve any potential issues you might  have with the requested service. 

• To send administrative information to you. We may process your information  to send you details about our products and services, changes to our terms and  policies, and other similar information. 

Types of email communication we send you: 

• Service-related announcements 

We will send you service-related announcements on rare occasions when it is  necessary to do so. For instance, if our service is temporarily suspended for  maintenance, we might send you an email. 

We may also send you email to communicate with you about servicing a home  warranty claim. If you request access codes to the Appliance Buyline service as a benefit of your warranty plan, those codes will be emailed to you. 

Generally, you may not opt-out of these communications, which are not  promotional in nature. If you do not wish to receive them, you have the option to  deactivate your account. Please contact our customer service team at (877) 248- 6683 for information on deactivating your account. 

• Renewal notifications 

We may also send you email to notify you when it is time to renew your warranty.  You may opt out of renewal notifications by following the Unsubscribe or Opt-out  instructions found in the email message. 

• Homeowner tips 

On occasion, as a benefit of your home warranty membership, we may also send  you emails containing tips for maintaining your appliances and home systems.  You may opt out of these notifications by following the Unsubscribe or Opt-out  instructions found in the email message. 

• To fulfill and manage your claims/orders. We may process your information to  fulfill and manage your claims/orders, payments, returns, and exchanges made  through the Services. 

• To request feedback. We may process your information when necessary to  request feedback and to contact you about your use of our Services. 

• To send you marketing and promotional communications. We may process  the personal information you send to us for our marketing purposes if this is in  accordance with your marketing preferences. You can opt out of our marketing  emails at any time. For more information, see "What Are Your Privacy Rights?"  below. 

• To deliver targeted advertising to you. We may process your information to  develop and display personalized content and advertising tailored to your interests,  location, and more.  

• To protect our Services. We may process your information as part of our efforts  to keep our Services safe and secure, including fraud monitoring and prevention. 

• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to  identify usage trends, determine the effectiveness of our promotional campaigns,  and to evaluate and improve our Services, products, marketing, and your  experience.

• To identify usage trends. We may process information about how you use our  Services to better understand how they are being used so we can improve them. 

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide  marketing and promotional campaigns that are most relevant to you. 

• To comply with our legal obligations. We may process your information to  comply with our legal obligations, respond to legal requests, and exercise,  establish, or defend our legal rights. 

3. WHEN AND WITH WHOM DO WE SHARE YOUR  PERSONAL INFORMATION?  

In Short: We may share information in specific situations described in this section and/or  with the following categories of third parties. 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your  data with third-party vendors, service providers, contractors, or agents ("third parties")  who perform services for us or on our behalf and require access to such information to  do that work. We have contracts in place with our third parties, which are designed to  help safeguard your personal information. This means that they cannot do anything with 

your personal information unless we have instructed them to do it. They will also not share  your personal information with any organization apart from us. They also commit to  protect the data they hold on our behalf and to retain it for the period we instruct. 

We also may need to share your personal information in the following situations: 

• Business Transfers. We may share or transfer your information in connection  with, or during negotiations of, any merger, sale of company assets, financing, or  acquisition of all or a portion of our business to another company. 

• When we use Google Analytics. We may share your information with Google  Analytics to track and analyze the use of the Services. The Google Analytics  Advertising Features that we may use include: Remarketing with Google Analytics,  Google Display Network Impressions Reporting and Google Analytics  Demographics and Interests Reporting. To opt out of being tracked by Google  Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You  can opt out of Google Analytics Advertising Features through Ads Settings and Ad  Settings for mobile apps. Other opt out means include  http://optout.networkadvertising.org/ and 

http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page. 

Affiliates. We may share your information with our affiliates, in which case we will require  those affiliates to honor this privacy notice. Affiliates include our parent company and any  subsidiaries, joint venture partners, or other companies that we control or that are under  common control with us. 

Customer testimonials, comments and reviews 

We post customer testimonials/comments/reviews on our Website which may contain  personal information. We do obtain the customer's consent via email prior to posting the  testimonial to post their name along with their testimonial. To request removal of your personal information from testimonials or comments please contact us at  erelations@cinchhs.com. 

Referrals 

If you choose to use our referral service to refer a contractor to us, we will ask you for the  contractor's name, email address and phone number, as well as additional information  about the contractor. We will use this information to recruit the provider into our Service  Network. We store this information for the sole purpose of recruitment initiatives. The  contractor may contact us at (800) 531-3466 to request that we remove this information  from our database. 

We may also collect, from you, personal information about your contacts such as first and  last name when you provide an additional customer. When you provide us with personal  information about your contacts, we will only use this information for the specific reason  for which it is provided. 

If you believe that one of your contacts has provided us with your personal information  and you would like to request that it be removed from our database, please contact us at  the contact information below. 

Links to other websites 

Our site includes links to other Websites whose privacy practices may differ. If you submit  personal information to any of those sites, your information is governed by their privacy  policies. We encourage you to carefully read the privacy policy of any website you visit. 

4. DO WE USE COOKIES AND OTHER TRACKING  TECHNOLOGIES? 

In Short: We may use cookies and other tracking technologies to collect and store your information. 

We may use cookies and similar tracking technologies (like web beacons and pixels) to  access or store information.  

Behavioral targeting/re-targeting 

We partner with a third-party ad network to either display advertising on our Web site or  to manage our advertising on other sites. Our ad network partner uses cookies and Web  beacons to collect non-personally identifiable information about your activities on this and  other Web sites to provide you targeted advertising based upon your interests. If you  wish to not have this information used for the purpose of serving you targeted ads, you  may opt-out by clicking here. Please note this does not opt you out of being served  advertising. You will continue to receive generic ads. 

5. HOW LONG DO WE KEEP YOUR INFORMATION? 

In Short: We keep your information for as long as necessary to fulfill the purposes  outlined in this privacy notice unless otherwise required by law. 

We will only keep your personal information for as long as it is necessary for the purposes  set out in this privacy notice, unless a longer retention period is required or permitted by  law (such as tax, accounting, or other legal requirements).  

When we have no ongoing legitimate business need to process your personal  information, we will either delete or anonymize such information, or, if this is not possible  (for example, because your personal information has been stored in backup archives),  then we will securely store your personal information and isolate it from any further  processing until deletion is possible. 

6. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational  and technical security measures.  

We have implemented appropriate and reasonable technical and organizational security  measures designed to protect the security of any personal information we process.  However, despite our safeguards and efforts to secure your information, no electronic  transmission over the Internet or information storage technology can be guaranteed to be  100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other  unauthorized third parties will not be able to defeat our security and improperly collect,  access, steal, or modify your information. Although we will do our best to protect your  personal information, transmission of personal information to and from our Services is at  your own risk. You should only access the Services within a secure environment. 

7. DO WE COLLECT INFORMATION FROM MINORS? 

In Short: We do not knowingly collect data from or market to children under 18 years of age. 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If  we learn that personal information from users less than 18 years of age has been  collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have  collected from children under age 18, please contact us at erelations@cinchhs.com. 

8. WHAT ARE YOUR PRIVACY RIGHTS? 

In Short: You may review, change, or terminate your account at any time. 

Withdrawing your consent: If we are relying on your consent to process your personal  information, which may be express and/or implied consent depending on the applicable  law, you have the right to withdraw your consent at any time. You can withdraw your  consent at any time by contacting us by using the contact details provided in the section  "How Can You Contact Us About This Notice?" below. 

However, please note that this will not affect the lawfulness of the processing before its  withdrawal nor, when applicable law allows, will it affect the processing of your personal  information conducted in reliance on lawful processing grounds other than consent. 

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the  SMS messages that we send, or by contacting us using the details provided in the section  "How Can You Contact Us About This Notice?" below. You will then be removed from the  marketing lists. However, we may still communicate with you — for example, to send you  service-related messages that are necessary for the administration and use of your  account, to respond to service requests, or for other non-marketing purposes. 

Cinch My Account Information: If you would at any time like to review or change the  information in your account or terminate your account, you can: 

• Log in to your account settings and update your user account. 

Upon your request to terminate your account, we will deactivate or delete your account  and information from our active databases. However, we may retain some information in  our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce  our legal terms and/or comply with applicable legal requirements. 

Cookies and similar technologies: Most Web browsers are set to accept cookies by  default. If you prefer, you can usually choose to set your browser to remove cookies and  to reject cookies. If you choose to remove cookies or reject cookies, this could affect  certain features or services of our Services.  

If you have questions or comments about your privacy rights, you may email us at  privacy@cinchhs.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES 

Most web browsers and some mobile operating systems and mobile applications include  a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy  preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT  signals has been finalized. As such, we do not currently respond to DNT browser signals  or any other mechanism that automatically communicates your choice not to be tracked  online. If a standard for online tracking is adopted that we must follow in the future, we  will inform you about that practice in a revised version of this privacy notice. 

10. DO UNITED STATES RESIDENTS HAVE STATE  SPECIFIC PRIVACY RIGHTS? 

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you  are granted specific rights regarding access to your personal information. 

What categories of personal information do we collect? 

We have collected the following categories of personal information in the past twelve (12)  months:

Retention 

Cinch retains Personal Information for the following expected retention periods: 

• Information about you we collect to engage in transactions with you, our  suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services  period, or longer as necessary for record retention and legal compliance  purposes. 

• If you have registered for a Cinch online account (MyAccount) to access your  Cinch account online, your account information will be retained for as long as  you maintain an active account. After service termination, minimal account  information will be held for records retention purposes. 

• Contact information such as your email address or phone number collected  online on our sites, and used for our marketing and sales activities will be  retained for as long as we have an active (customer) relationship with you,  and/or as appliable by law. 

• Personal information needed to retain your opt-out preferences will be  retained for as long as necessary to comply with your request and with  applicable law. 

We may also collect other personal information outside of these categories through  instances where you interact with us in person, online, or by phone or mail in the context  of: 

• Receiving help through our customer support channels; 

• Participation in customer surveys or sweepstakes, or contests; and • Facilitation in the delivery of our Services and to respond to your inquiries. How do we use and share your personal information? 

Learn about how we use your personal information in the section, "How Do We Process  Your Information?" 

We collect and share your personal information through: 

• Targeting cookies/Marketing cookies 

• Social media cookies 

• Beacons/Pixels/Tags 

• Click redirects

Will your information be shared with anyone else? 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "When And With Whom Do We Share  Your Personal Information?" 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is  not considered to be "selling" of your personal information. 

We have disclosed the following categories of personal information to third parties for a  business or commercial purpose in the preceding twelve (12) months: 

• Category A. Identifiers 

• Category C. Characteristics of protected classifications under state or federal law • Category D. Commercial information 

• Category F. Internet or other electronic network activity information • Category G. Geolocation data 

• Category I. Professional or employment-related information 

• Category J. Education information (for employment-related purposes with us) • Category K. Inferences drawn from collected personal information 

The categories of third parties to whom we disclosed personal information for a business  or commercial purpose can be found under "When And With Whom Do we Share Your  Personal Information?"  

We have shared the following categories of personal information to third parties in the  preceding twelve (12) months: 

• Category F. Internet or other electronic network activity information • Category G. Geolocation data 

• Category K. Inferences drawn from collected personal information The categories of third parties to whom we shared personal information with are:

• Advertising, Direct Marketing, and Lead Generation

• Affiliate Marketing Programs 

• Retargeting Platforms 

• Social Media Sharing and Advertising 

• Web and Mobile Analytics 

California Residents 

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits  our users who are California residents to request and obtain from us, once a year and  free of charge, information about categories of personal information (if any) we disclosed  to third parties for direct marketing purposes and the names and addresses of all third  parties with which we shared personal information in the immediately preceding calendar  year. If you are a California resident and would like to make such a request, please submit  your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with  the Services, you have the right to request removal of unwanted data that you publicly  post on the Services. To request removal of such data, please contact us using the  contact information provided below and include the email address associated with your  account and a statement that you reside in California. We will make sure the data is not  publicly displayed on the Services, but please be aware that the data may not be  completely or comprehensively removed from all our systems (e.g., backups, etc.). 

CCPA Privacy Notice 

This section applies only to California residents. Under the California Consumer Privacy  Act (CCPA), you have the rights listed below. 

The California Code of Regulations defines a "residents" as: 

1. every individual who is in the State of California for other than a temporary or transitory purpose and 

2. every individual who is domiciled in the State of California who is outside the State  of California for a temporary or transitory purpose 

All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. 

Your rights with respect to your personal data 

Right to request deletion of the data — Request to delete 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information,  subject to certain exceptions provided by law, such as (but not limited to) the exercise by  another consumer of his or her right to free speech, our compliance requirements  resulting from a legal obligation, or any processing that may be required to protect against  illegal activities. 

Right to be informed — Request to know 

Depending on the circumstances, you have a right to know: 

• whether we collect and use your personal information; 

• the categories of personal information that we collect; 

• the purposes for which the collected personal information is used; • whether we sell or share personal information to third parties; 

• the categories of personal information that we sold, shared, or disclosed for a  business purpose; 

• the categories of third parties to whom the personal information was sold, shared,  or disclosed for a business purpose; 

• the business or commercial purpose for collecting, selling, or sharing personal  information; and 

• the specific pieces of personal information we collected about you. 

In accordance with applicable law, we are not obligated to provide or delete consumer  information that is de-identified in response to a consumer request or to re-identify  individual data to verify a consumer request. 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information. 

Verification Process 

Upon receiving your request, we will need to verify your identity to determine you are the  same person about whom we have the information in our system. These verification  efforts require us to ask you to provide information so that we can match it with information  you have previously provided us. For instance, depending on the type of request you  submit, we may ask you to provide certain information so that we can match the  information you provide with the information we already have on file, or we may contact  you through a communication method (e.g., phone or email) that you have previously  provided to us. We may also use other verification methods as the circumstances dictate. 

We will only use personal information provided in your request to verify your identity or  authority to make the request. To the extent possible, we will avoid requesting additional  information from you for the purposes of verification. However, if we cannot verify your  identity from the information already maintained by us, we may request that you provide  additional information for the purposes of verifying your identity and for security or fraud 

prevention purposes. We will delete such additionally provided information as soon as we  finish verifying you. 

Other Privacy Rights 

You may object to the processing of your personal information. 

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. 

You can designate an authorized agent to make a request under the CCPA on your  behalf. We may deny a request from an authorized agent that does not submit proof that  they have been validly authorized to act on your behalf in accordance with the CCPA. 

You can opt out from the sharing of your personal information by emailing  privacy@cinchhs.com. 

To exercise these rights, you can contact us by email at privacy@cinchhs.com, by calling toll-free at (844) 621-5165, or by referring to the contact details at the bottom of this document.  

If you have a complaint about how we handle your data, we would like to hear from you,  please contact us at privacy@cinchhs.com. If you have an unresolved privacy or data use  concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback form.truste.com/watchdog/request. 

If you are a California resident, please see our California Consumer Privacy Act (“CCPA”)  and California Privacy Rights Act of 2020 (CPRA”) Notice at Collection for more information on your privacy rights. 

Colorado Residents 

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA),  you have the rights listed below. However, these rights are not absolute, and in certain  cases, we may decline your request as permitted by law. 

• Right to be informed whether or not we are processing your personal data • Right to access your personal data 

• Right to correct inaccuracies in your personal data 

• Right to request deletion of your personal data 

• Right to obtain a copy of the personal data you previously shared with us 

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that  produce legal or similarly significant effects ("profiling") 

We do not sell personal data to third parties but do process personal data for our own  targeted advertising. You can opt out from our own targeted advertising, or profiling by  emailing privacy@cinchhs.com. 

If we decline to take action regarding your request and you wish to appeal our decision,  please email us at privacy@cinchhs.com. Within forty-five (45) days of receipt of an  appeal, we will inform you in writing of any action taken or not taken in response to the  appeal, including a written explanation of the reasons for the decisions. 

Connecticut Residents 

This section applies only to Connecticut residents. Under the Connecticut Data Privacy  Act (CTDPA), you have the rights listed below. However, these rights are not absolute,  and in certain cases, we may decline your request as permitted by law. 

• Right to be informed whether or not we are processing your personal data • Right to access your personal data 

• Right to correct inaccuracies in your personal data 

• Right to request deletion of your personal data 

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that  produce legal or similarly significant effects ("profiling") 

We do not sell personal data to third parties but do process personal data for our own  targeted advertising. You can opt out from our own targeted advertising or submit a  request to exercise any of the other rights described above, by emailing privacy@cinchhs.com. 

If we decline to take action regarding your request and you wish to appeal our decision,  please email us at privacy@cinchhs.com. Within sixty (60) days of receipt of an appeal,  we will inform you in writing of any action taken or not taken in response to the appeal,  including a written explanation of the reasons for the decisions. 

Utah Residents 

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in  certain cases, we may decline your request as permitted by law. 

• Right to be informed whether or not we are processing your personal data • Right to access your personal data 

• Right to request deletion of your personal data 

• Right to obtain a copy of the personal data you previously shared with us 

• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data 

We do not sell personal data to third parties but do process personal data for our own  targeted advertising. You can opt out from our own targeted advertising or submit a  request to exercise any of the other rights described above, by email to privacy@cinchhs.com. 

Virginia Residents 

Under the Virginia Consumer Data Protection Act (VCDPA): 

"Consumer" means a natural person who is a resident of the Commonwealth acting only  in an individual or household context. It does not include a natural person acting in a  commercial or employment context. 

"Personal data" means any information that is linked or reasonably linkable to an identified 

or identifiable natural person. "Personal data" does not include de-identified data or publicly available information. 

"Sale of personal data" means the exchange of personal data for monetary consideration. 

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data. 

Your rights with respect to your personal data 

• Right to be informed whether or not we are processing your personal data • Right to access your personal data 

• Right to correct inaccuracies in your personal data 

• Right to request deletion of your personal data 

• Right to obtain a copy of the personal data you previously shared with us 

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that  produce legal or similarly significant effects ("profiling") 

We do not sell personal data to third parties but do process personal data for our own  targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for our own targeted advertising or profiling purposes. 

Exercise your rights provided under the Virginia VCDPA 

You can opt out from own targeted advertising by email at privacy@cinchhs.com. 

If you are using an authorized agent to exercise your rights, we may deny a request if the  authorized agent does not submit proof that they have been validly authorized to act on  your behalf. 

Verification process 

We may request that you provide additional information reasonably necessary to verify  you and your consumer's request. If you submit the request through an authorized agent,  we may need to collect additional information to verify your identity before processing  your request. 

Upon receiving your request, we will respond without undue delay, but in all cases, within  forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such  extension within the initial 45-day response period, together with the reason for the  extension. 

Right to appeal 

If we decline to take action regarding your request, we will inform you of our decision and  reasoning behind it. If you wish to appeal our decision, please email us at  privacy@cinchhs.com. Within sixty (60) days of receipt of an appeal, we will inform you  in writing of any action taken or not taken in response to the appeal, including a written  explanation of the reasons for the decisions.  

11. DO WE MAKE UPDATES TO THIS NOTICE? 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and as our business practices change with regard to the distribution, sharing, or sale of  customer information. 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon  as it is accessible. If we make material changes to this privacy notice, we may notify you  either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of  how we are protecting your information. 

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 

If you have questions or comments about this notice, you may email us at privacy@cinchhs.com or contact us by mail at: 

Cinch Home Services, Inc.  

Attn: General Counsel 

4700 Exchange Ct 

Suite 300 

Boca Raton, FL 33431 

Or telephone at: (800) 778-8000 

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE  DATA WE COLLECT FROM YOU? 

Based on the applicable laws of your country, you may have the right to request access  to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email  privacy@cinchhs.com.