PRIVACY POLICY FOR TWEENER HOMES

 PRIVACY POLICY 

TweenerHomes.com connects individuals looking to rent property (“Tenants”), property owners (“Owners”), and Service Providers (Tenants, Owners and Service Providers are collectively referred to as “Users” or “you”) in order to book a rental agreement and to identify service providers who provide services related to such booking (“Services”). 

This Privacy Policy governs the manner in which Tweener Homes, Inc. (“Tweener Homes” or “we” or “us” or “our”) and TweenerHomes.com collects, uses, maintains and discloses information collected from Users of TweenerHomes.com (“Personal Information”), including any subdomains thereof, and any Sites through which Tweener Homes makes its services available (the “Site”). This Privacy Policy applies to the entire Site and any promotions offered by Tweener Homes, Inc. 

1. Information we collect. 

We ask for and collect the following Personal Information about you when you use the Site. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. 

• Account Information. When you sign up for an account, we require certain information such as your first name, last name, and email address. 

• Profile and Listing Information. To use certain features of the Site (such as booking or creating a listing), we may ask you to provide additional information, which may include your physical address, phone number, mobile phone number, social media accounts, and a profile picture. 

• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of a government issued ID or driving license, as permitted by applicable laws) or other authentication information. 

• Payment Information. To use certain features of the Site (such as booking or creating a listing), we may require you to provide certain financial information (like your bank account, debit card, or credit card information) in order to facilitate the processing of payments. If you are an Owner then we may require identity verification information (defined above) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, to provide the payment services to you, and to comply with applicable law. 

• Communications with Tweener Homes and other Users. When you communicate with Tweener Homes or use the Site to communicate with other Users, we collect information about your communication and any information you choose to provide. 

• Information you choose to give us. You may choose to provide us with additional Personal Information in order to obtain a better user experience when using the Site. This additional information will be processed based on your consent. 

• Testimonials. Tenants and Owners may choose to submit a review. If you post a review, we will ask for your email address. Your email address will be kept private. Also, any personally identifiable information that you submit as part of the review can be read or used by other visitors to the Site. We are not responsible for any personally identifiable information that you choose to submit as part of your review. We believe you can post a helpful review without disclosing any Personal Information. 

• Log files. We may collect information about you whenever you interact with our Site. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We may use this information to analyze trends, administer the Sites, track your movement in the aggregate, and gather broad demographic information for aggregate use. 

• Cookies. We may use “cookies” to enhance User experience. Users’ web browsers place cookies on the users’ hard drives for record-keeping purposes and sometimes to track information about them. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, some parts of the Site may not function properly. 

2. How we use collected information. 

We may collect and use your Personal Information for the following purposes: 

• To enable access to the Site; 

• To deliver our services to you; 

• To provide and improve customer service; 

• To provide a personalized user experience; 

• To provide, improve, and develop our Site; 

• To enable us to communicate with you; 

• To enable you to communicate with other Users; 

• To process and receive payments; 

• To create and maintain a trusted and safer environment; 

• To comply with our legal obligations; 

• To verify and authenticate information or identification provided by you; 

• To resolve disputes between Users; 

• To enforce our Terms of Service; 

• To detect and prevent fraud, spam, abuse, security incidents or other harmful activity; and 

• To send you email updates and other communications, including support messages, security alerts, account notifications, promotional messages and advertisements that we believe may be of interest to you. 

3. Children’s Privacy Statement. 

We do not knowingly collect any Personal Information from any children under 18. If you are a parent or guardian of any children under the age of 18, please do not submit any of their Personal Information to us. If you are under the age of 18, please do not submit any Personal Information to us, and rely on a parent or guardian to assist you. If we become aware that we have inadvertently received personally identifiable information from a user under the age of 18 through the Services, we will delete such information from our records. 

4. Security. 

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information, username, password, transaction information and data stored on the Site. Sensitive and private data exchanged between you and the Site happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Access to your Personal Information is restricted. Only employees who need access to your Personal Information to perform a specific job are granted access to your Personal Information. While we use industry-standard precautions to safeguard your Personal Information, we cannot guarantee complete security. 100% complete security does not presently exist anywhere online or offline. 

5. Google Maps/Earth. 

Parts of the Site use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy. 

6. Sharing Personal Information 

• With your consent. Where you have provided consent, we may share your information, including Personal Information, as described at the time of consent, such as when you authorize a third party application or websites to access your Account. 

• To secure booking. We may share your Personal Information to help facilitate bookings or other interactions between Users, including Personal Information, as it is necessary to secure the booking. 

• To secure services. We may share your Personal Information with third party Service Providers to help the third party Service Providers perform their service. 

• To comply with the Law, Respond to Legal Requests, Preventing Harm and Protection of our Rights. Tweener Homes and the Site may disclose your information, including Personal Information, to courts, law enforcement or governmental authorities, industry regulators, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Tweener Homers or TweenerHomes.com, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our Users to legal liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Tweener Homes and the Site, its employees, its Users, or Owners of the public. 

Where appropriate, we may notify you about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law or regulation, or (ii) we believe that providing notice would be futile, ineffective, create a risk of 

injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Tweener Homes, Inc.’s property, its Users and the Site. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify you about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so. 

• Aggregated data. We may also share aggregated information (information about you and other Site visitors that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes. WE DO NOT SELL, TRADE, OR RENT YOUR PERSONAL IDENTIFICATION INFORMATION TO OTHERS. 

• Third Party Partners and Integration. The Site may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Tweener Homes doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Tweener Homes, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit. When you link to Third Party Partners, you are no longer on this Site, and this privacy statement will not apply to those sites. 

7. Managing Your Personal Information. 

Reviewing, Correcting and Removing Your Personal Information. Upon request, we will advise you regarding whether TweenerHomes.com holds any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information: 

• To review the user information that you have supplied to us. 

• To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us. 

• To request that your user information not be used to contact you. 

• To request that your user information be removed from any solicitation list that we use. 

• To request that your user information be deleted from our records relating to transaction which are not pending or have not been completed unless otherwise required by law or regulation. 

• To opt out of being solicited by Tweener Homes or third parties. 

• To exercise any of these rights, please contact us as described in Section 13 “Contact Us” below. 

Anti-Spam Policy. We will not send you unsolicited commercial email in violation of applicable laws. Every email we send for marketing purposes will include a mechanism to opt out of further such communications. 

To Unsubscribe From Communications. You may opt out from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by contacting us as described in Section 13 “Contact Us” below. We cannot unsubscribe you from marketing communications from other Users or Third Party Partners. You can unsubscribe from other User’s and Third Party Partners’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly. 

Once you opt out, we will honor your choice until you inform us otherwise. All requests to update or delete any Personal Information shall be responded to within a reasonable period not to exceed 30 days. 

Under all circumstances, the sender of any communications to Tweener Homes, or TweenerHomes.com is responsible for the content and information contained therein, including its accuracy and truthfulness, and you agree that you will not knowingly provide to Tweener Homes or TweenerHomes.com any information which is inaccurate or which you do not have the legal right to provide. 

Users cannot opt out of receiving transactional emails related to their account with us or the Service. 

8. Retention. 

Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use Personal Information for a period of time consistent with the original purpose for which it was provided or collected (e.g., as needed to provide you the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, and for a reasonable period of time thereafter). If you wish to cancel your account or if you wish to request that we no longer use the Personal Information you have supplied in order to provide you the Services, please contact us as described in Section 13 “Contact Us” below. Personal Information no longer retained will be disposed of or destroyed in a reasonable manner intended to prevent loss, theft, misuse, or unauthorized access. 

9. General Data Protection Regulation (GDPR) (European Union). 

Your Individual Rights Under the GDPR. 

If you are an individual data subject entitled to the protections of the EU General Data Protection Regulation (GDPR), the following information describes additional rights you have with regard to your Personal Information, subject to certain exceptions: 

• The right to be informed regarding the collection and use of your Personal Information. This Privacy Policy serves that purpose. You should also review the Privacy Policies of any data controllers – including other Users of the Site – to which you may have provided your Personal Information. 

• The right of access. You have the right to access the Personal Information which has been collected concerning you, and to exercise that right easily and at reasonable intervals, in order to be aware of, and verify, the lawfulness of the processing. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• The right to rectification. You have the right to obtain from the data controller (which may be other Users of TweenerHomes.com) and without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• The right to erasure (“right to be forgotten”). In certain circumstances, you may have a broader right to erasure of Personal Information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• The right to restrict processing. You may have the right to request that we restrict processing of your Personal Information in certain circumstances (for example, where you believe that the Personal Information we hold about you is inaccurate or unlawfully held). To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• The right to data portability. In certain circumstances, you may have the right to be provided with your Personal Information in a structured, machine readable and commonly used format and to request that we transfer the Personal Information to another data controller without hindrance. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• The right to object to processing. You may have the right to request that Tweener Homes and TweenerHomes.com stop processing your Personal Information and/or to stop sending you marketing communications. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

• Rights in relation to automated decision-making and profiling. You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

If you are an individual who interacts with our Users of our Services and wish to inquire or exercise your rights with regard to your Personal Information, please contact the User directly. If you believe Tweener Homes or TweenerHomes.com is processing your Personal Information, you may contact us as described in Section 14 “Contacting Us” below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request. Please identify the User which may be acting as a data controller with regard to your Personal Information. In that case, we will refer your inquiry to the User and assist them, to the extent possible, in responding to your request to exercise your rights with regard to your Personal Information. 

• Legal Bases for Processing. We will collect or process your Personal Information only where we have a legal basis for doing so. We will normally collect, process and/or use your Personal Information only where: 

• It is supplied to us by you, or by one of our Users acting as a data controller, and you have consented to the processing of your Personal Information for one or more specific purposes. Note that where your Personal Information is contained within the data sent to us for processing by our User, you will normally already have provided your consent to that User. 

• It is necessary in order to provide and operate our Services, including providing support and personalized features, or to protect the safety and security of our Services or Users and their data. 

• It is necessary in the context of performing our obligations under a contract, e.g., to provide our Services to a User. 

• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as research and development, marketing and promotion of our Services, fraud prevention and to protect our or our Users’ legal rights and interests. 

• You provide us or other Users with your consent to do so for a specific purpose. 

• It is necessary for compliance with a legal obligation to which our User (as the data controller) is subject. 

If you have consented to our, or our User’s, use of your Personal Information for a specific purpose, you have the right to change your mind at any time and object to that use, but this will not affect any processing that has already taken place. This may mean, however, that you may no longer be able to use or benefit from our Services or those provided by our User, as applicable. To exercise this right, contact us as described in Section 13 “Contact Us” below. 

10. California Privacy Rights. 

California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those third parties. See Section 13 “Contact Us” for where to send such requests. Tweener Homes and TweenerHomes.com do not share Personal Information with third parties for their own direct marketing purposes without your prior consent, except as required or permitted by your state’s law. Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent. 

11. Canada Anti-Spam Law. 

Tweener Homes, Inc. and the Site comply with the Canada Anti-Spam Law. Users who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages. 

12. Changes to this Privacy Policy. 

Tweener Homes, Inc. and the Site have the discretion to update this Privacy Policy at any time without notice. When we do, we will revise the updated date at the bottom of this and all pages. We encourage Users to frequently check this page and other pages for any changes to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. 

13. Contact Us. 

If you have any questions about this Privacy Policy, the practices of the Site, or your dealings or interactions with the Site, please contact us at: 

Tweener Homes, Inc. 

Att: President 

Phone: (833) 893-3637 

Email: support@tweenerhomes.com 

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