FINDTRUEOWNER.COM Privacy Policy

Date: June 19th , 2023

1. Introduction.

Thank you for viewing the FindTrueOwner.com privacy policy. We take the privacy and security of the personal information we hold seriously. We have written this privacy policy to explain the kinds of personal information we collect, save, and process, how we use it, with whom we share it, how we protect it, and how we allow individuals to exercise choices about it.

We refer to FindTrueOwner.com as “we,” “us,” “our,” or “the Company” in this privacy policy. This policy covers the use of our website (“Website”) and of our social media accounts on platforms that currently include Facebook, Instagram, Twitter, TikTok, YouTube, and LinkedIn.

The purpose for our Company’s service is to allow our clients conveniently gain access to, as accurate as possible, personal contact information of real estate property owners in volumes/bulk or one by one. The personal contact information may include (to the extent available) name, phone numbers, email addresses, and post addresses along with property description information. We provide this information in response to individual queries made on our website. Customers can either utilize the filters available on the search/advanced search feature of our website building a list of property owners owning certain type of real estate in a specific location to receive that list filled with the property owners’ personal contact information and the property description information, or they can submit their own list of property owners with certain information such as subject property full address, owner full name, and full mailing address linked to subject property for taxes, and we will enrich their list with personal contact information of the property owners. Additionally, Customers can conduct individual searches by subject property address via filters available on the search/advanced search feature.

We receive and pass along to our customers contact information of real property owners. We refer to this information as “Property Owner Personal Information.” Real property owners may own single family homes, apartment complexes, retail or office spaces/buildings, mixed-use buildings, warehouses, special use properties, or even undeveloped land. If an individual owns real estate, the contact information we provide is about that individual. If a business or other organization owns the real property asked about, we provide information about the individuals representing that business or organization. For properties held in a trust, we provide the contact information of the trustee managing the trust to the extent it is available.

Also, we collect personal information from website visitors whether they complete a webform to communicate with us or not. Finally, we collect information from individual customers, vendors, business partners, and, where any of them are businesses or

organizations, their representatives (“Representatives”). We may also communicate with current and prospective customers, vendors, and business partners using our social media accounts. Finally, we collect personal information automatically from customers (registered users) that use our website to use our service.

2. Personal Information We Collect.

a. Property Owner Personal Information.

Our service provides our customers the following types of Property Owner Personal Information for living individual property owner:

· Full name (first name and last name)

· Email address

· All phone numbers available for a contact (which could be business, mobile, or home numbers)

· Postal address tied to particular real property, which may in some cases be a home address, an office address, or a PO box

Also, our service may have contact information of a deceased person if that person remains, at least for the present, the owner of record or representative of the owner of record for a given property. Nonetheless, since that person is deceased, the owner’s contact information is no longer “personal information.”

We have trusted data providers who give us access to Property Owner Personal Information. As customers query our service for Property Owner Personal Information, our systems seek the requested information from our data providers and immediately pass it along to our customers.

b. Customers (Registered Users).

When we establish an account for a customer, we collect business contact information, payment information, and other information relating to maintenance of their accounts. Customers with an established account are registered users of the service.

We automatically collect certain information from registered users of our service that are logged into our website. Specifically, we collect:

· Information from cookies (see Section 3 below)

· Browser type

· Your behavior while using the website, including clicking, scrolling, using the mouse, opening a new page, and typing or submitting data to the website

· Date and time of access to a webpage on the website

· IP address of the registered user

· Geolocation of the registered user

· Your full name

· Your phone number

· Your email address

· Your payment information via Stripe, Inc.

· Billing address

c. Website Visitors

We do collect data from website visitors that are not registered users of our service logged into their accounts. Moreover, we have a webform on our website that collects contact information from website visitors who wish to communicate with us. We also collect any personal information contained in the information provided by website visitors completing a webform or chat box.

d. Other Individuals Interacting Us.

We may collect information that you provide us in face-to-face meetings, trade shows, and your telephone and electronic communications with us, for instance by telephone calls, email, text, and social media messages and posts, including if you are a Representative of a potential customer, a vendor, or business partner.

If you post information on our social media pages, we will be able to view your username and whatever personal information you place in the post.

3. Cookie Policy.

Cookies may be automatically used to collect specific information from a computer or mobile device that accesses and navigates through our website over time. Information collected by cookies may include information to help improve and customize the content or layout of the website.

A cookie is a small text file that websites save on a computer’s storage device when a website is visited. Cookies cannot be used to run programs or deliver viruses to the computer or mobile device accessing our website. Users can establish or change their browser settings to refuse cookies. However, refusing cookies may interfere with the full functionality of the website and limit the user experience.

We use a web analytics service, Google Analytics, to evaluate how users view and use our website. Google Analytics tells us about when and how you use or website, the website from which you navigated to our website, information about your system, and your location.

For more information about Google Analytics, please visit: http://www.google.com/policies/privacy/partners/.

You can opt out to prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout.

4. Personal Information of Children.

Our service is for the use of adults 18 years of age or older. We do not market or sell services to minors or knowingly collect personal information from children under age 13. If you believe that we have inadvertently gathered personal information about a minor, please contact us using the contact information in Section 11 for us to delete it.

5. Uses of Personal Information.

We use Property Owner Personal Information to provide our service to our customers. Specifically, our customers send us queries or submit lists so that they can receive Property Owner Personal Information.

We use personal information collected from customers to establish a relationship with them, register and manage their accounts, obtain payments from them for our service, and provide our service to them. We also communicate with our customers to send updates about our services, account administration messages, and marketing information about our service.

We use information collected automatically from registered and logged-in users to:

· Improve the performance and reliability of our website

· Understand your preferences and interests

· Enhance your experience in using our website

· Assist us in developing and providing you more relevant content

If you complete a webform to communicate with us, we will use the contact information in your webform to communicate with you. We use other personal information in your webform to respond to your requests or communications.

We use personal information collected from Representatives of our business partners and vendors to establish, maintain, and manage our business relationships with these partners and vendors. For instance, we use their contact information to communicate with them.

We use personal information collected from our social media accounts and pages to understand our use community’s preferences and interests, improve our service, and communicate our marketing messages.

6. Sharing or Disclosing Personal Information.

We may share your personal information with vendors or outsource service providers that help us provide service to our customers, or that assist with support functions such as marketing, billing, payment card processing, and data analysis. For instance, we use a cloud services

provider to host our service. We will require any such vendors or service providers to manage your personal information with privacy and security safeguards consistent with this privacy policy.

From time to time, we may be required to respond to a subpoena, court order, search warrant, administrative or judicial process, requests by law enforcement agencies, or other requests that we must respond to under applicable law. We may disclose your personal information in response to any of these requirements. Also, we may disclose your personal information to preserve the security of our website or social media accounts, resolve disputes, or to assess any possible wrongdoing.

We also may share aggregate or anonymous information collected about website or social media usage, as long as the information does not identify any specific individuals.

We may share or transfer personal information about you in connection with a merger, acquisition, reorganization, or sale of assets of our business, in the event of bankruptcy, or during the negotiations leading to such an event. We will seek assurances from any buyer that your personal information will be used, shared, maintained, and disclosed consistent with the terms of this privacy policy.

Our service provides Property Owner Personal Information to our customers. And this section describes other circumstances in which may disclose your personal information. Otherwise, we will not sell, distribute, transfer, or lease your personal information to third parties.

7. Information Security.

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access or disclosure, we have put in place industry standard administrative, physical, and technical safeguards to secure the personal information we collect using our website or social media accounts.

8. Retention of Personal Information.

Our policies regarding the length of time in which we will retain your personal information are as follows:

· We do not store a copy of Property Owner Personal Information we provide to customers in a master Company database. However, when a customer receives Property Owner Personal Information from us in response to a query or in an enriched list of contacts, such results are stored in each customer’s account. We will retain these search results containing Property Owner Personal Information for so long as the customer’s account is active. If the account is terminated, we will delete all such search results and the Property Owner Personal Information contained in them.

· Personal information of customers used for account management is retained so long as the customer’s account is active. If the account is terminated, we will delete all customer personal information associated with the account.

· Personal information of customers collected automatically when they are logged in is retained as long as the customer’s account is active. However, if a customer’s account is not active for two years, we will delete the information automatically collected from that customer.

· We will retain the personal information of vendors, business partners, and others who communicate with us for as long as our relationship with them continues or we otherwise have a business purpose for preserving the personal information. Factors relevant to when we no longer need to preserve such personal information include:

o Whether we may continue a business relationship in the future.

o Whether our customers have a need to contact such vendors or business partners.

o The need to preserve transactional records for accounting and record keeping purposes.

o Whether our business contacts might benefit from contacting our current or past vendors or business partners.

In addition to the above, we will preserve personal information to the extent required by applicable law or rules, for instance if it is needed for legal proceedings.

9. Links to Other Websites.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy policy applicable to the website in question.

10. Choices About Your Personal Information.

You may choose to restrict the collection or use of your personal information in the following ways:

· If you would like access to the personal information about you that we may have in our possession, please contact us using the contact information in Section 11 below.

· You may also contact us using the contact information in Section 11 to correct or update personal information about you in our possession. Please keep in mind that we may have a legal right or obligation to preserve personal information as it currently exists.

· If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by telling us using the contact information below.

Any email communications from us contain instructions on opting out of further email communications, although we will still send you emails relating to the support, administration, and security of our service.

We will use reasonable and appropriate procedures to verify your identity before acting on any such request.

11. Contacting Us About Privacy.

Please direct all questions or complaints about our privacy practices to our privacy team using the following contact information:

· Email: support@findtrueowner.com

· Phone: Toll Free: (866) 348-8585, local not toll free: (650) 365-7776

If you have a complaint, please provide information relevant to your complaint. Our privacy team will evaluate your complaint based on the information you provide and send you a response. We may need to ask you for additional information to evaluate your complaint. We will promptly investigate and respond to your communications about a complaint. You may have other rights under law and the right to contact the privacy regulator in your jurisdiction about your complaint.

12. Amendments to this Privacy Policy.

We may change this policy from time to time. We will make changes by posting a revised copy of this policy to our website or, if we deem it necessary, by email notice to you. Your continued use of our website, social media accounts, or our service after a revised version of this policy appears on the website or linked to our social media accounts will constitute your approval of the amended version. If you are a user and do not agree with amendments to this policy, you may opt out of amendments by canceling your account.

NOTICE TO CALIFORNIA RESIDENTS

1. California Privacy Laws.

This notice applies to individuals who reside in the State of California, USA whose personal information is accessible to us. This notice provides information about California privacy laws that may apply to you, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). The CPRA amends and supplements the CCPA.

2. Personal Information Collected.

We have created a table that summarizes the categories of personal information collected and their purposes of use. The table below lists the categories of personal information we may have collected from you within the last 12 months. The table also includes the business or commercial purposes for which personal information will be used or disclosed to third parties. We have sold Property Owner Personal Information of property owners within the last 12 months.

If you have created an account with us, you provided a username and password to control access to your account. Usernames and their associated passwords are considered “sensitive personal information” under the CPRA.

3. CCPA/CPRA Individual Rights.

CCPA and CPRA give individual rights to California residents, which are described below. Our obligation to afford you these rights or provide notifications to you, however, are subject to any contrary laws, rules, or law enforcement demands.

4. Right of Access and Data Portability.

In response to a request from a California resident, we will disclose to that resident the categories and specific pieces of personal information we have collected about the resident in the previous 12 months and, we will disclose to the California resident:

The categories of personal information we have collected about that California resident.

The categories of sources from which the personal information is collected.

The business or commercial purpose for collecting that California resident’s personal information.

The categories of third parties with whom we share personal information.

The specific pieces of personal information we have collected about that California resident.

The identity of the California resident must be verified before we can disclose the personal information requested. See the “Identity Verification” section below.

5. Right of Deletion.

California residents have the right to request that we delete any personal information that we collected from that California resident and retained by us, subject to certain conditions and exceptions under the law. For instance, we have the right to retain personal information needed to:

Complete the transaction for which the personal information was collected, provide a good or service requested by the California resident, or reasonably anticipated within the context of our ongoing business relationship with the California resident, or otherwise perform a contract between our business and the California resident.

Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.

Enable solely internal uses that are reasonably aligned with the expectations of the California resident based on the California resident’s relationship with us.

Comply with a legal obligation.

The identity of any person making such a request must be verified before we can delete the personal information as requested. See the “Identity Verification” section below

6. Right of Correction.

California residents have the right to request that we correct any inaccurate personal information about them, taking into account the nature of the personal information and purposes of using it. Please be aware, however, we may have a legal obligation or right to maintain personal information as currently recorded in our records.

The identity of any person making such a request must be verified before we can correct the personal information as requested. See the “Identity Verification” section below.

7. Right to Know What Personal Information is Sold and to Whom.

The purpose of our service is to sell Property Owner Personal Information to our customers. We do not sell any other Personal Information in the ordinary course of business. Accordingly, property owners who reside in California have the right to request that we disclose to them:

· The categories of personal information collected from property owners.

· The categories of personal information sold and the categories of third parties to whom the personal information was sold.

· The categories of personal information that we disclosed about property owners for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The identity of any person making such a request must be verified before we can correct the personal information as requested. See the “Identity Verification” section below.

8. Property Owners’ Right to Opt Out of Sale of Personal Information.

California resident property owners have the right, at any time, to direct us not to sell the property owner’s personal information. These property owners may exercise this right by following the procedures in Section 10 below or by clicking on the link entitled “Do Not Sell My Personal Information” on our website and following the instructions displayed.

9. Right to Restrict Usage and Disclosure of Sensitive Personal Information.

California residents have the right to request that we restrict usage and disclosure of what is defined as “sensitive personal information” under California law. The only sensitive personal information we collect and use is account information – usernames and passwords. Nonetheless, by policy, we never disclose usernames and passwords to third parties, and we only use them for authenticating you when you try to access your account on our website. Accordingly, no such request is necessary to restrict usage and disclosure of your username and password.

10. How to Exercise Your Individual Rights Under the CCPA or CPRA.

If you wish to exercise any of the rights of California residents set out above, please contact us (see Section 11 above). We will use the procedures in the Identity Verification section below to verify the identity of the California resident or any authorized agent acting on behalf of a California resident.

11. Identity Verification.

As noted above, exercising some of the individual rights requires that we verify the identity of the person making the request. We will identify individual California residents exercising their own rights by checking two items of personal information already on file in our records or, in the case of a request for specific items of personal information, three items. An authorized agent or conservator seeking to exercise individual rights on behalf of a California resident will have to show proof of authority, such as using a durable power of attorney or letters of conservatorship.

We will not provide or delete information as requested if we are unable to verify the identity of the requestor as required above, if an agent cannot prove authority to act on behalf of an individual, or we have reason to believe that the request is fraudulent. We may ask for additional verification if we suspect fraud, such as a copy of an identification credential from the requestor, or an additional identification credential if we have already obtained a copy of one credential. We will use any such additional information strictly for identity verification purposes, and it will be deleted following the completion of the verification process. The information you provide us for identity verification will not be further disclosed, retained longer than needed for verification purposes, or used for unrelated purposes.

12. Policy Against Discrimination.

The Company will not discriminate against individual California residents for exercising any of their rights under the CCPA or CPRA, including by:

· Denying goods or services to the California resident.

· Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

· Providing a different level or quality of goods or services.

· Suggesting that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services.

13. Retention of Personal Information.

See Section 8 of the Privacy Policy above.

14. Notice About “Do Not Track” Settings.

Under California law, online service providers must say in their privacy policies how they respond to “do not track” settings that users can set in their browser software. Currently, there is no standard governing what, if anything, a website operator should do when receiving a “do not track” signal. Consequently, we do not currently take action in response to a “do not track” browser setting. We will revisit and revise this policy accordingly if an industry standard regarding such settings emerges.