Homebody Insurance Agency, LLC (collectively, “Homebody,” “we,” “us,” “our”) is a subsidiary of Entrata, Inc.  We offer insurance and financial wellness products and services, a resident rewards program, and resident experience platform (collectively, the “Services”) to consumers, including rental property residents, who purchase services through us or otherwise use our platform (“Customers”), business clients that are typically residential and commercial real estate property managers and owners (“Clients”) who use our Services to manage services to their tenants, and visitors to our websites (“Visitors”).  It is important to us that we provide transparency regarding our collection, use, and disclosure of information that can be reasonably linked with you (“Personal Information”). To help us meet this commitment to you, we have created this Privacy Notice (“Homebody Privacy Notice” or “Privacy Notice”).  This Homebody Privacy Notice governs our collection, use, and disclosure of Customers’, Clients’ and Visitors’ Personal Information in connection with the Services, including from the websites we control and that link to this Privacy Notice (“Homebody Sites”) as well as our mobile applications (“Apps”). It also describes your available rights and choices in connection with our use of Personal Information. 

Please note that while this Privacy Notice is intended to address Personal Information pertaining to Customers, Clients, and Visitors, we may process certain Customer Personal Information on behalf of our Clients, pursuant to an agreement (and/or our applicable Terms of Service).  In this case, we may direct Customers using our Services to a Homebody Client for answers to questions or concerns about the data handling practices of a Homebody Client.

Please Note: This Homebody Privacy Notice only governs our processing of Personal Information in the United States.  For information regarding our online and offline collection, use, and disclosure of Personal Information for residents of certain U.S. states, please see our Notice at Collection, linked above.

The Homebody Sites and Apps may contain links to other third-party websites.  The information practices and content of such third-party websites are governed by their own privacy notices.  We encourage you to review the privacy notices of such third-party websites to understand their information practices.     

We will update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, and other factors.  We will let you know when we update this Notice by updating the “Last Updated” legend at the top or other appropriate means.  Any changes will become effective when we post the revised Privacy Notice on the Services.‍

‍

Personal Information We Collect

We and our service providers collect Personal Information in various ways: for example, when you visit the Homebody Sites or Apps; in connection with your application for a quote; to purchase a product or enter into a transaction with us; when you use our Services; to provide you with requested Services; when you sign up for our newsletters or request other information or promotional communications; to enroll in or redeem rewards; for analytics purposes; when you contact our customer support; in connection with your inquiries and communications with us; or when you interact with us for any other purposes.

We collect the following categories of Personal Information:

• Personal Identifiers, such as name, email address, alias, account name or login credentials to our online platform, unique personal identifiers, online identifiers, IP address, government-issued identifiers (e.g., Social Security number), community or social media username, and account profile photo.
• Records Information, such as name, contact information, signature, email address, phone number, insurance information such as insured unit number, insurance policy number, policy coverage levels, lease period, and co-occupants (co-residents, co-tenants), financial information including financial account number, bank account number, credit/debit card numbers, employment information.
• Commercial Information, such as rent and utility payment information, insurance information (insured unit and policy numbers, policy coverage levels), lease period, bank account number, credit or debit card numbers, credit information, financial account information (including transactions and account balances), billing information, a record of sales, purchases, and uses.
• Internet or Network Activity Information, such as browsing history, search history, interactions with our online properties or ads.
• Audio Data, such as electronic content produced by individuals using our      systems including online interactive and voice communications such as through email, phone, or network sessions.
• Employment Information, such as employer name or company affiliation, job title, work email address, and work phone number.
• Inferences that are drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics, or behavior.

Sensitive personal information: Some Personal Information we collect is defined under certain laws as sensitive personal information.  Sensitive Personal Information we collect includes Social Security number, customer account log-in, financial account number, debit card number, and credit card number in combination with any required security or access code, password, or credentials allowing access to an account.‍

Sources of Personal Information

‍We and our service providers collect information from Customers, Clients, and Visitors when they provide it through our Services, including Homebody Sites and Apps.  We may also receive information from third-party providers, including public databases, third-party data providers, service providers, advertising sources and from our parent company, Entrata, and other companies that are owned or operated by Entrata.

How We Use Personal Information

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

To provide the Services.  This includes: 

• Administering, operating, maintaining, and securing our Services.
• Monitoring and analyzing trends, usage, and activities in connection with our Services.
• Administering Customer and Client account(s) or administering account access to our Services.
• Enforcing our Terms of Use and any other contractual terms and conditions that govern the relationship between Homebody and our Customers and Clients.

Marketing. This includes:

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
• Informing you about our various Services     .
• Re-engaging you if you have expressed an interest in our Services.
• Contacting you to set up a demo.

Improving, customizing, and personalizing our Services. This includes:

• Analyzing and improving the safety and security of our Services.
• Carrying out machine learning, data extracting, and loading data in data warehouses, to support Homebody enterprise software, data access, modifications, and operations.
• Educating and training our workforce in data protection and customer support.
• Conducting research and surveys to develop new features and services.

Operations and general business purposes (to keep the Services updated and relevant and to develop our organization). This includes:

• Processing and completing transactions, and sending you related information, including alerts and notifications about your service, events, purchase confirmations, and invoices.
• Data analysis, for example, to improve the efficiency of the Services.
• Audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
• Fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• Promoting the safety and security of the Services, our users, and other parties.  For example, we may use information to authenticate users, facilitate secure payments, respond to legal requests or claims, investigate, and protect against fraud, malicious or unauthorized access, and other illegal activities, and to demonstrate and verify compliance with our internal policies and procedures and applicable data and privacy security laws and regulations.
• Identifying performance trends with respect to specific products or services in the Homebody Services, including performance metrics and other indicators of basic product understanding trends and other metrics program metrics to identify user experience issues with Homebody Services.
• Operating and expanding the Homebody Services.
• Accounting, recordkeeping, backup, and administrative purposes.

Communicating with you. This includes:

• Providing and improving our customer support.
• Facilitating communications generally in the context of our business activities.
• Tracking and responding to Customer and Client inquiries, reviews, or correspondence regarding the Services.
• Sending administrative information to Customers and Clients, such as changes to our terms, conditions, and policies.
• Responding to inquiries, for example, when prospective Customers and Clients send us questions, suggestions, compliments, or complaints, or request further information about our Services.
• Customizing and improving the content of our communications, websites, and social media accounts.

Anonymizing, or de-identifying Personal Information.  “De-identified” means information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer.  We deidentify Personal Information to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.  Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

Who We Disclose Personal Information To

‍We may disclose Personal Information that we collect from you to:

• Our Affiliates.  We may disclose Personal Information to our parent company Entrata, Inc. and any subsidiaries and affiliates within the Entrata corporate group in connection with the Services.
• Clients.  We may disclose Personal Information to a Client who has purchased a Homebody product or service, including to facilitate the administration of a product or service you have purchased.
• Service Providers.  We disclose Personal Information to our service providers who perform certain services necessary to run our business (for example, insurance companies, insurance agents, underwriters, data hosting and development, data analysis, customer support, auditing, information technology, payments, sales, marketing, research and surveys, and other services).
• Third-Party Business Partners and Marketing Partners.  For example, we may disclose Personal Information to third parties to permit them to send you marketing, consistent with your choices.
• Credit Bureaus.  In connection with certain Homebody products, we may report information about your account to credit bureaus.  Late payments, missed payments, or other defaults on your account may be reflected in your credit report.
• Law Enforcement, Regulators, and Other Parties for Legal Reasons.  We may disclose Personal Information to comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
• Third Parties in Connection with a Business Transaction.  We may disclose Personal Information to a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Homebody’s assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which Personal Information held by Homebody or Entrata are among the assets to be transferred.
• Third parties to enforce our or others’ rights.  We may disclose Personal Information to external parties to the extent necessary to enforce or protect our or others’ rights, privacy, safety, or property, including enforcing our Terms of Use and any other agreements, or to investigate fraud or to protect the security or integrity of our Homebody Sites or any Services.

Children

‍Our Services are not intended for children.  We do not knowingly collect Personal Information from children under the age of sixteen without authorization by a parent or guardian.  If you believe that we may have collected Personal Information from or about a child under the age of sixteen, please send an email to [email protected] with the subject line “Personal Data of a Minor.”‍

Other Information

‍“Other Information” is information that does not reveal your specific identity or directly relate to an identifiable individual.  We and our service providers may collect and use Other Information in a variety of ways, including:

• Your browser or device.  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version.  We use this information to ensure that the Services function properly.
• Your use of our Apps.  When you download and use our Apps, we and our service providers may track and collect usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.  We use this information to understand how the app is used and improve it.
• Cookies.  Cookies are pieces of information stored directly on your computer.  Cookies allow us to collect such information as browser type, time spent on the Services, pages visited, language preferences, and traffic data.  We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  If you do not want information collected using cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
• Pixel tags and other similar technologies.  We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about use of the Services and response rates.
• Analytics.  We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps, and online services.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Advertising.  We may use third-party advertising companies to serve advertisements that may be of interest to you when you access and use our online services and other websites or online services.  You may receive advertisements on any of your devices, based on information relating to your access to and use of our Services and other websites or online services, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser, including through the use of pixel tags.  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to limit cross-app data sharing.

“Do Not Track” Notice: “Do Not Track” is a preference that you can set in your browser to let websites you visit know that you do not want them collecting certain information about you.  Homebody does not currently respond to, or honor, Do Not Track signals or requests from your browser.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Homebody Privacy Notice.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information.

‍How We Protect Your Personal Information‍

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  You are responsible for keeping your username and password to access the Services confidential.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the How to Contact Us section below.

Your Privacy Rights and Choices

‍You may have various privacy rights under U.S. federal and state laws depending on where you live.  Requests should be submitted to us directly as described below.  Where we process your Personal Information on behalf of our Clients, we may refer you to our Clients to fulfill your request.

You may also opt out from receiving marketing-related emails from us.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the “unsubscribe” option contained in any such email.      

Subject to applicable law, you may make the following requests:

1. Right to know and access your Personal Information.  You may request the specific pieces of Personal Information we have collected about you and to know:

• the categories of Personal Information we’ve collected or “shared”;
• the categories of sources from which we collected such Personal Information;
• the business or commercial purpose for collecting or “sharing” such Personal Information;
• the categories of third parties to whom we disclosed or “shared” such Personal Information.

2. Right to correct inaccuracies in your Personal Information.  You may request we correct any inaccurate information we have about you.  We may request that you provide documentation to support your request.

3. Right to deletion of your Personal Information.  You may request deletion of Personal Information collected from you, subject to certain exceptions including that we need the Personal Information to:

• complete a transaction or provide a service you requested, service your account, or take actions reasonably anticipated within the context of our ongoing business relationship;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• comply with a legal obligation; or
• otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

4. Non-discrimination right.  We will not discriminate against you if you exercise any of the privacy rights described in this Privacy Notice.  

Submitting a request: To make a request, please contact Homebody by sending an email to [email protected], by filling out this form or by calling 1-877-577-0850. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies.  We may need to request appropriate identification, depending on the sensitivity of the information requested, to verify your identity and protect against fraudulent requests.  

Requests from authorized agents may be submitted via the same methods listed above.  Not all kinds of requests can be made by authorized agents in all states.  We may request proof of status as an authorized agent or require the consumer to directly verify their identity with us.

Appeals process: Subject to applicable law, you may appeal a denial of your request within a reasonable period after you have received notice of the denial.  You may file an appeal by contacting us at [email protected] or calling us toll-free at 1-877-577-0850.

Certain state laws provide the right to opt out of targeted advertising, including the “sharing” of your information for cross-context behavioral advertising.  To request to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising, or any future processing for purposes of targeted advertising, complete this form. You may also opt-out by enabling a universal tool that automatically communicates your opt-out preferences through browser settings such as the Global Privacy Control.  For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. 

Keeping Your Information Updated

‍Where you have set up an account on one of our Services, it is your responsibility to keep your Personal Information up to date.  You can update your Personal Information by logging in to your Homebody account.

Retaining Your Personal Information‍

We retain Personal Information for the duration of your relationships with us, and where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations).  Retention periods may be extended if we are required to preserve your Personal Information because of litigation, investigations and other similar proceedings, or if a longer retention period is required or permitted by applicable law.

Customer Payment Information‍

When you initiate a payment through the Services, your payment information may be processed by third-party payment processors, as per their respective terms and policies.  We collect your complete payment details temporarily for the sole purpose of facilitating the transaction with our payment processors, which you consent to by making a payment through the Services.  It’s important to note that we do not store your payment information.