For the 12 months preceding the Effective Date, we give you notice that we collected the following types of PI about California Consumers, and used and shared that PI as set forth in the following chart and in subsections 1(B) (Use of PI) and 2 (Sharing of PI). The following chart explains the categories of PI collected and the categories of recipients with which we shared each category of PI.

Category of PI	PI Examples	Categories of Recipients with which PI is Shared, if Shared
Identifiers	This may include, but is not limited to: your name, postal address, Internet Protocol address, email address, username, Social Security number, driver's license number, passport number, or other similar identifiers.	Business Purpose Disclosure: (1) Service Providers, such as financial institutions and technology service providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: No Sale
Personal Records	This may include information such as: signature, telephone number, insurance policy number, bank account number, or other financial information.	Business Purpose Disclosure: (1) Service Providers, such as financial institutions and technology service providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: No Sale
Personal Characteristics or Traits	This may include, but is not limited to: sex, marital status, veteran status, familial status, race, or gender identity.	Business Purpose Disclosure: (1) Service Providers, such as financial institutions and technology service providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: No Sale
Customer Account Details / Commercial Information	This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Business Purpose Disclosure: (1) Service Providers, such as financial institutions, technology service providers, and marketing partners; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: Marketing partners.
Internet Usage Information	This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.	Business Purpose Disclosure: (1) Service Providers, such as technology service providers, analytics providers, and marketing partners; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: Marketing partners.
Geolocation Data	This may include, but is not limited to: precise physical location or movements and travel patterns.	Business Purpose Disclosure: (1) Service Providers, such as technology service providers, analytics providers, and marketing partners; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: Marketing partners.
Sensory Data	This may include, but is not limited to: audio recordings of customer care calls.	Business Purpose Disclosure: (1) Service Providers, such as technology service providers and customer support providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: No Sale
Professional or Employment Information	This may include, but is not limited to: professional, educational, or employment-related information.	Business Purpose Disclosure: (1) Service Providers, such as employment and asset verification providers and technology service providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: No Sale
Inferences from PI Collected	This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, behavior, and attitudes.	Business Purpose Disclosure: (1) Service Providers such as technology service providers, analytics providers and marketing providers; (2) public authorities / government bodies; and (3) Third Parties as compelled or required by law. Sale: Marketing partners.

The chart above reflects the categories of PI defined by the CCPA along with the applicable recipients with which we shared each category of PI. Keep reading this Section 1 for information on our purposes for collecting and sharing PI, and our sources of collection. There may be additional information that we collected that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.

As permitted by applicable law, we do not treat deidentified data or aggregate Consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into Deidentified or Aggregate Consumer Information. We have no obligation to re-identify such information or keep it longer than we need it for our own purposes.

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1. Sources of PI
   
   We may collect your PI directly from you, your social media accounts, or from vendors and suppliers, credit reporting agencies, our affiliates, advertising networks, data providers, governmental agencies, or other individuals and businesses, as well as publicly available information.


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2. Use of PI
   
   Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures of PI, see the next section Sharing of PI.
   
   We may collect, use and share the PI we collect for one or more of the following business purposes:
   
   
   • Processing Interactions and Transactions;
     
     
   • Managing Interactions and Transactions;
     
     
   • Performing Services;
     
     
   • Research and Development;
     
     
   • Quality Assurance;
     
     
   • Security; and
     
     
   • Debugging;
     
     
   We may also share PI with third parties for one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the Consumer or other parties at the Consumer’s request, for the additional purposes explained in our Privacy Policy , and to assignees as part of a merger or asset sale (“Other Business Purposes”).
   
   Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage Service Providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.
   
   We may collect and use your PI for commercial purposes that are deemed sales under the CCPA. For more information on your do not sell rights, see the Do Not Sell subsection of the California Privacy Rights section of this Privacy Notice at Section 3.B below.
   
   In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.

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We disclose PI for Business Purposes as more fully explained in the section immediately above. For more information on your do not sell rights, see the Do Not Sell subsection of the California Privacy Rights section of this Privacy Notice atSection 3.B [LINK] below.
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The CCPA is a new law and there remain differing interpretations of it and the regulations that implement it. Accordingly, we may from time-to-time update information in our notices regarding our data practices and your rights, modify our methods for you to make and for us to respond to your requests, and/or supplement our response(s) to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. To make a request, email us here, or call us at 1-844-405-1430 and respond to any follow up inquires we may make.

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As provided by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we charge you for responding to your request.

Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your Social Security number, driver’s license number or other government-issued id number, financial account number, or an account password in response to a CCPA request.

Your California Consumer privacy rights are as follows:

1. The Right to Know:
   
   
   1. Categories:
      
      You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
      
      
      • The categories of PI we have collected about you;
        
        
      • The categories of sources from which we collected your PI;
        
        
      • The business or commercial purposes for our collecting or selling your PI;
        
        
      • The categories of third parties to whom we have shared your PI;
        
        
      • A list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred; and
        
        
      • A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.
        
        
      To make a request, email us here or call us at 1-844-405-1430.
      
      In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the Consumer we may have collected Personal Information about or a person who has been duly authorized to make the request on behalf of the Consumer. You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We are required to verify a Consumer’s request to know categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer. If you fail to do so we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
   
   
   
   2. Specific Pieces:
      
      You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. To make a request, email us here or call us at 1-844-405-1430.
      
      In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the Consumer we may have collected Personal Information about or a person who has been duly authorized to make the request on behalf of the Consumer. You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We are required to verify a Consumer’s request to know specific pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer together with a signed declaration under penalty of perjury that the requestor is the Consumer whose Personal Information is the subject of the request. If you fail to provide the data points, we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
      
      Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
      
      



2. Do Not Sell:
   
   In the future, we may sell your PI to Flyhomes partner organizations so they can offer you goods or services. For more information on how to exercise your do not sell rights, email ushereor call us at 1-844-405-1430.
   
   Additionally, the CCPA’s broad definitions of “sale” and “personal information” may deem the common flow of information in the digital analytics and advertising ecosystem to be a sale. Like most companies that operate commercial websites, we utilize online analytics to measure the ways users engage with our website. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics and facilitate online advertising, we use third parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our website and on third-party digital properties. For instance, we may request that a third-party facilitate the placement of Flyhomes ads on a particular website after a consumer has previously visited a Flyhomes website. The third parties we use for these purposes generally do this by placing a cookie on a user’s browser so it can identify if the same browser visits other websites. To exercise choice with respect to cookies and other tracking technologies, click here
   
   We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.



3. Delete:
   
   Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.
   
   To make a request, email us here or call us at 1-844-405-1430.
   
   In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the Consumer we may have collected Personal Information about or a person who has been duly authorized to make the request on behalf of the Consumer. We are required to verify a Consumer’s request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.
   
   However, you may alternatively exercise more limited control of your PI by instead adjusting your communication preferences within your Flyhomes account. You can opt out of marketing email communications by clicking “unsubscribe” at the bottom of such communications.



4. Non-Discrimination and Financial Incentive Programs:
   
   As of the Effective Date of this Notice we did not offer any programs offering you special incentives for providing us with PI and/or requiring you to limit any of your CCPA rights in connection with charging a different price or rate, or offering a different level or quality of good or service. If we do so, the CCPA requires certain program terms and notices for California Consumers. The material aspects of any such program, and the rights of California participants, will be explained and described in its program terms. Participating in any such programs will be entirely optional. We may add or change programs and/or their terms by posting notice on the program descriptions so check them regularly.



5. Authorized Agents:
   
   You may designate an agent to exercise your CCPA rights on your behalf. To exercise your rights via an agent, your agent must (1) if an entity, show proof of registration to do business in California; and (2) submit a written authorization of his or her authority to act on your behalf or a valid power of attorney authorizing the agent to make the request on your behalf. Requests by authorized agents may be submittedhere . Once such authorization is submitted, you will receive an email at your email address asking you to verify the agent’s authority to submit a Consumer Rights Request on your behalf and to verify your identity, or in the case that a power of attorney was provided we will need to verify its authenticity. Once your agent’s authority is confirmed (s)he may exercise rights on your behalf subject to the agency requirements of the CCPA.



6. Limitation of Rights:
   
   Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law. Further, to protect your privacy and security we will not provide you with access to or copies of sensitive Personal Information such as Social Security number, driver’s license number, or other government identification number, financial account numbers, passwords or answers to security questions; provided, however, that we will inform you if we maintain any such applicable types of PI. We are also not required to search for PI not maintained in a searchable or reasonably accessible format that is used for internal purposes only, or other PI where the request is excessive, repetitive, unfounded or overly burdensome. In addition, as explained above, we will reject requests to the extent we are not able to sufficiently verify your identity, or your agent’s authority. If we conclude we have a basis for not fully responding to your request, our response to you will explain the basis for the limitation, unless we are prohibited from doing so by applicable law.

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In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

1. Third Party Marketing and Your California Privacy Rights:
   
   For more information on our online practices and your California rights specific to our online services see our online Privacy Policy. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:
   
   Separate from your CCPA “Do Not Sell” rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:
   
   We may from time to time elect to share certain “personal information” (as defined by California’s “Shine the Light” law) about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the 12 months preceding the date of this Notice. To make a request, please attest to the fact that you are a California resident and provide a current California address for our response. You may make this request by contacting us here, or in writing at: Flyhomes, Inc., Privacy Requests, 500 Union St, Ste 325, Seattle, WA 98101, (Attention: Privacy Requests). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year. As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.



2. California Minors:
   
   Although our online service(s) are intended for an audience over the age of eighteen (18), any California residents under the age of 18 who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us here, detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

For more information on your California privacy rights contact us at 1-844-405-1430, email us here, or, write to us at: Flyhomes, Inc., Attn: Privacy Requests, 1201 Western Ave., Ste 100, Seattle, WA 98101.

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