Virtuo Inc. (“we”, “us”, “our”, and similar expressions) values your privacy and we want you to understand how we handle your personal information when you visit www.virtuo.com and related subdomains or websites owned or operated by us (our “Website”), use our applications (“Apps”), buy products or services through us, sign up for an account with us (an “Account”) (the foregoing collectively, the “Services”) and otherwise interact with us. By using our Website or any of our Services, you are agreeing to the terms of this Privacy Policy.

This Privacy Policy describes what we do with personal information that we collect and otherwise handle for our own purposes. This Privacy Policy does not apply to, and Virtuo is in no way responsible for, third parties that handle personal information for their own purposes.

“Personal information” is generally any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a natural person.

There are several types of information we collect about you:

·      Contact information. We collect personal details that allow us to identify and communicate with you. This includes your name, email address, phone number, mailing address, and any links to your social network profiles you choose to provide (including for authentication purposes).

·      Account information. When you create an account, we collect information such as your username and password. You may also provide optional profile details, including avatars or profile images.

·      Information you upload. Any information you upload to our Services may be collected by us. This normally includes information about your home. We encourage you to avoid uploading other personal information to our Services where it isn’t necessary for your use of them.

·      Payment and transaction information. If you make a purchase or financial transaction through our Services, we collect billing details, credit card or other payment card information, account and authentication data, and information related to your transactions. 

·      Communication Content. We collect personal information contained in your communications with us. This includes information shared via SMS, RCS (text) messages, emails, form submissions, phone calls, mail, and any content you post on public areas of our Services.

·      Technical and Usage Information. When you use our Website, App, or Services, we collect technical data such as your IP address, geographic location, browser type and settings, device details (including operating system), other browsing activity (e.g. the site you were on before you visited our Website) log data, date and time of visits, language preferences, and information about your interactions with our Services. We collect this information through cookies and similar tracking technologies. For more details, please refer to our Cookies Policy.

·      Marketing and Preference Information. We collect information related to your marketing preferences and any data you provide when participating in surveys, contests, or promotions.

·      Jurisdiction and Legal Compliance Information. We may collect information about your jurisdiction and other details required for contractual or legal compliance, such as tax-related information.

We collect most personal information from you directly and through your use of our Services. We also receive personal information from partners including referral partners, advertising platforms, channel partners (such as homebuilders or property managers), and identity verification services. We may also collect information from third-party providers that provide you services through the App. This information helps us deliver services, support marketing initiatives, and verify your identity.

We use information that we collect about you or that you provide to us, including any personal information for several purposes:

·      To provide our Services. We use your personal information to provide the Services to you. We also use it to personalize our Services, process payments, and to respond to your requests.

·      To communicate with you. We use your personal information to communicate with you, including to send you emails about the Services and your relationship with us. Please note, whether communicating with us or HomieAI, please do not provide any personal details that aren’t necessary.

·      To market and promote our business to you. We use your personal information to market our Services and business to you, including through surveys, and promotions. We may use your information to send you tailored marketing communications about products, services, offers, programs, and promotions of ours and those of our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on what we think may interest you based on other information we hold about you. We may also use your information to help us improve and measure the effectiveness of our advertising.

·      To customize your experience. We use your personal information to provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering your preferences.

·      To improve our Services and customer experience. We use your personal information to analyze and learn about how the Services are accessed and used and to evaluate and improve our Services (including by developing new products and services and managing our communications), and to monitor and measure the effectiveness of our advertising. This includes improving HomieAI based on how you interact with it. We usually do this based on information that we have anonymized, pseudonymized, or aggregated. For example, if we learn that most people using our Services in a location or for a particular purpose tend to use a specific integration or feature, we might wish to expand on that integration or feature.

·      To protect you and us. We use your personal information to keep our Services secure, such as when we use your personal information to verify your identity and access credentials. We may also use your information to investigate incidents and potential wrongdoing, and to protect against fraud, spam, or misuse.

·      To manage our third-party relationships. We use your personal information to manage our vendor and partner relationships.

·      To enforce our rights and to meet our obligations. We use your personal information to carry out our obligations and enforce our rights under contracts, including our Terms of Service, billing, or to comply with legal requirements. We may also use your personal information to protect our and others’ interests, rights, and property.

·      To comply with the law. We use your personal information to comply with applicable legal requirements, such as tax and other government regulations, contracts, and law enforcement requests. We will also use your personal information to give you notices about your relationship with us.

·      To fulfill the purposes that you provided the information to us. We use your personal information when you give it to us for a specific purpose or for reasons that were described when it was collected, or any other purpose for which you provide it, including for any other reason described in this Privacy Policy.

In addition to other scenarios we have discussed in this Privacy Policy, we may share your personal information with the following third parties:

·      Business partners. We may share your personal information with business partners, such as builders and developers, when our Services integrate with theirs. We may tell them if you appear to be at potential risk of not closing on your home purchase. We may also provide these partners with aggregated reporting on usage of our Services and information for industry benchmarking.

·      Referral partners. In some cases, we may share your information with third parties whose services you can view or access through our App (such as trades, home insurance providers or realtors). We may provide these third parties with your information to facilitate the referral and your receipt of services from them, and to manage our relationship with the referral partner.

·      Industry partners. We provide aggregated information, usually in the form of insights or reports, to other organizations who may use it for industry benchmarking, business and marketing decisions, or other informational purposes.  For example, we may correlate home purchasing behaviour and certain demographic data, such as approximate age and income level, and provide market insights to homebuilders and developers to assist them in developing their products, marketing their business, and improving their sales and service models.

·      Advertising partners. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your actual or pseudonymized email address with a third-party social media platform on which we advertise to avoid serving ads to people who already use our Services.

·      Affiliates. We share personal information with our affiliates to help provide the Services to you or analyze and improve the services we or they provide. 

·      Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf, process payments, or assist with data storage. We also use a variety of service providers in connection with the Services. For example, we may share your personal information with movers, utility companies, and others as part of our offering to you and facilitated through the App. We only share your personal information when you have been informed or would otherwise expect such sharing.

·      Other third parties to protect you and us. We may disclose your personal information in response to a request from law enforcement that we determine to be legitimate. We may also disclose your information in order to comply with legal requirements or protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or to prevent fraud or abuse.

·      Parties involved in a business transaction. If we’re involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals.

Depending on your jurisdiction, you can request to access, update, change or delete your personal information.

·      Access and update. You can access, update, or change personal information either directly in your Account or by contacting us at privacy@virtuo.com to request the required changes. You can exercise your other rights (including deleting your Account and personal information) by contacting us at the same email address. Please note that we may need to verify your identity in connection with your requests.

·      Delete. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

·      Disclose. You may have the right to request that we disclose the information you provide us to a third party.

You may also have a right to complain to the appropriate privacy regulator or data protection authority.

You can exercise privacy choices with us in a number of ways.

·      Unsubscribe. Like many other companies, we may send you emails and other electronic messages. If you no longer wish to receive those messages, you can opt-out by following the unsubscribe link in the messages or by contacting us. In certain circumstances, we may still be required to send you some kinds of non-promotional messages.

·      Withdraw consent. Depending on the circumstances, you can withdraw consent to our handling of your personal information, you can withdraw  at any time and free of charge. However, depending on the circumstances, this may mean that we can no longer provide part or all of our Services to you.

·      Manage cookies. Our Cookie Policy explains how you can manage cookies and similar technologies with us.

·      Ask us. If there’s another privacy-related choice you would like to make, feel free to reach out using the information under “Contact us” below.

This Section is only applicable to you if you are a resident of the state of California in the United States (“California Residents”) and only applies to personal information for which we are a “Business” (as defined in the California Consumer Protection Act, or “CCPA”), but does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to personal information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person).

California law requires us to disclose certain information regarding the categories of personal information we collect. The following is a list of all categories of personal information which we collect, or have collected, from California Residents, in the twelve (12) months prior to the effective date of this Privacy Policy (each, a “Category”), together with, for each Category: (1) the categories of sources from which such Category is collected; and (2) the categories of third parties with whom we share such Category.

(i) “Personal information” under California Civil Code section 1798.80: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners, service providers and payment processors; and (2) third parties: business partners, service providers and payment processors.

(ii) Identifiers: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners, service providers and payment processors; and (2) third parties: business partners, service providers and payment processors.

(iii) Protected classifications (for example, race, gender, and other demographic and socioeconomic information): (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners and service providers; and (2) third parties: business partners, service providers and payment processors.

(iv) Commercial information: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners and service providers; and (2) third parties: business partners, service providers and payment processors.

(v) Biometric information (for example, fingerprints used for verifying your identity when accessing the App or Services): (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners and service providers; and (2) third parties: business partners, service providers and payment processors.

(vi) Financial, professional, or employment-related data: (1) sources: you (either directly or through a Third Party Provider), business partners and payment processors; and (2) third parties: business partners, service providers and payment processors.

(vii) Internet or other network or device activity: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners, service providers and payment processors; and (2) third parties: business partners, service providers and payment processors.

(viii) Location information: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners and service providers; and (2) third parties: business partners, service providers and payment processors.

(ix) Sensory information: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners and service providers; and (2) third parties: business partners, service providers and payment processors.

(x) Other information that identifies or can be reasonably associated with you by inference or otherwise: (1) sources: you (either directly or through a Third Party Provider), collected by the Services, business partners, service providers and payment processors; and (2) third parties: business partners, service providers and payment processors.

Each Category is collected for the following business purposes: (i) providing the Services (including without limitation maintaining your Account, processing and fulfilling orders, and administering surveys and contests); (ii) providing customer support for the Services; (iii) operating the Services (including without limitation managing third party relationships and enabling usage of our service providers); (iv) communicating with you; (v) customizing the Services; (vi) securing and protecting the Services (including without limitation auditing the Services, bug and fraud detection, debugging and repair of errors and the detection, protection and prosecution of security incidents or illegal activity); (vii) enforcing our terms and policies; (viii) complying with law; (ix) verifying your identity; and (x) other business purposes about which we may notify you from time to time.

Each Category is collected for uses that advance our commercial or economic interests such as: (i) promoting surveys and contests; (ii) promoting and advertising the Services; (iii) customizing the Services; (iv) improving our Services; (v) communicating with you about relevant offers from third parties; and (vi) other commercial purposes about which we may notify you from time to time.

Subject to certain exceptions and restrictions, the CCPA provides California Residents the right to submit requests to a business which has collected their personal information: (i) to provide them with access to the specific pieces and categories of personal information collected by the business about such California Resident, the categories of sources for such information, the business or commercial purposes for collecting such information, and the categories of third parties with which such information was shared; and (ii) to delete such personal information (each, a “California Request”). We need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.

If you are a California Resident, please follow the instructions in the “Your rights and choices” section above to submit California Requests and please make sure you note that you are a California Resident when you do so. California Residents may designate an authorized agent to make California Requests on their behalf. In order to designate an authorized agent to make a California Request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification and the authorized agent’s valid government issued identification.

We do not sell your personal information, as that term is defined based on our understanding of the CCPA and its implementing regulations. We have not sold any personal information to third parties for a business or commercial purpose in the 12 months prior to the effective date of this Privacy Policy. We do share personal information with third parties for the business and commercial purposes described in this Section, including without limitation advertising and marketing based on online activities over time and across different sites, services and devices.

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. We do not discriminate against California Residents for exercising their rights.

You may be able to post or make public communications on certain areas of our Website or Services, such as comments and questions fields, in-App communication functions, and other public discussion mechanisms. These kinds of communications are made at your own risk. Although we may monitor or even control these types of public posts, we are under no obligation to do so. We also cannot control the actions of other users of the Website, including how they will use your public posts and any personal information you include in them. We cannot and do not guarantee that unauthorized persons will not view your public posts or respect your privacy.

We are based out of Canada, but we may process, store, and transfer personal information in Canada or elsewhere, such as the United States. For example, we could use third-party service providers, such as managed hosting providers, credit card processors, customer relationship management (CRM) systems, and technology partners to provide the necessary software, networking, infrastructure and other services that we use to operate the Website and Services. These third-party providers may process, or store, personal information on servers outside of Canada.

Locations other than Canada may have different privacy laws, which may be more or less protective. If we move personal information to a location other than Canada, the governments, courts, law enforcement, or regulatory agencies of that country may have access to your personal information through their laws.

We use a variety of physical, technical, and organizational safeguards to protect your information based on its sensitivity.

No method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your personal information.

In general, we keep your personal information throughout your relationship with us. However, this can be a long relationship. We’re here to help you throughout your homeowner journey. One of the ways we help is by being a place to store and manage information about your home. This may mean that you might not need to use our Services for an extended period of time, but still want us to hold on to your information. If you want us to delete your information, just ask us using the information below under “Contact us.”

Once you terminate your relationship with us, we will continue to store archived copies of your personal information for legitimate business purposes, like defending a contractual claim or for audit purposes and to comply with the law. We will continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to improve our Services.

We use machine learning algorithms and forms of automated decision-making with our Website, the App, and the Services. For example, we use automated decision-making to prevent risk and fraud, to personalize your experience and make it more efficient, and to determine eligibility for certain services or features we offer on our Services. We may also use such technologies to improve our Services and how we deliver them to you.

Our Services are not meant for children under 13 years of age. See our Website Terms of Use for more details. If you are under 13 years old, please do not give us your personal information. If you are the parent or guardian of someone under 13 years of age, please do not give us personal information of that person.

If you have a question or a concern about our Privacy Policy or your personal information, please get in touch with us. Our Privacy Officer can be reached at privacy@virtuo.com.

We may update this Privacy Policy from time to time to reflect, for example, changes to our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will give you notice of such changes by posting the revised policy on our Website, and where appropriate, by other means. By continuing to use the Website or other Services after these changes are posted, you agree to the revised policy.