This Opendoor Home Loans LLC Privacy Policy (the “Policy”) explains how Opendoor Home Loans LLC (collectively “Opendoor Home Loans”, “we”, “us” or “our”) collects and uses information about you through our website www.opendoorhomeloans.com (collectively, our “Service” or “Services”). Other privacy policies may also apply in addition to the terms of this Policy, including the Opendoor Home Loans Consumer Privacy Notice posted on www.opendoorhomeloans.com

We may from time to time modify this Policy. We will promptly make any changes available at www.opendoorhomeloans.com. Changes will be effective as soon as the revised Policy is posted unless otherwise stated. In certain circumstances, we will provide a more prominent notice before the change goes into effect (including, for certain of our Services, email notification of Privacy Policy changes).

This Policy is incorporated into Opendoor Home Loans’s Terms of Use (“Terms of Use”), and your consent to this Policy is a material term of our Terms of Use. By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of information about you as described in this Policy and our Terms of Use.

If you have any questions about this Policy, or any change thereto, please don’t hesitate to contact us at 800-860-0386.

Please note that this Privacy Policy does not govern the practices of third parties that we do not own or control, including but not limited to any third party websites, services, and applications ("Third Party Services") that you elect to access through our Services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

1. HOW AND WHY WE COLLECT INFORMATION ABOUT YOU

In order to personalize, improve and continue to operate the Services, we may collect the following types of information from you:

1.1 Information You Provide Us

You may provide information to us in various ways, including but not limited to when you enter information on our website, speak with one of our representatives, complete a loan application, upload documents to our website, or send us comments, questions, or feedback. The information you provide us fits into two general categories:

1.1.1 Personal Information

For purposes of this Policy, “Personal Information” means data that can reasonably be used to identify or contact a specific person, such as first and last name, street address, phone number, e-mail address, or social security number.

We generally use your Personal Information to provide you with the Services and Services-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Services, technical and security notices), as well as for identify verification and fraud avoidance purposes.

1.1.2 Non-Personal Information

For purposes of this Policy, “Non-Personal Information” means data that doesn’t reasonably allow someone to identify or contact a specific individual, such as occupation, language, zip code, and area code. It also includes de-identified or aggregate data. We generally use Non-Personal Information to better understand customer behavior and improve our Services.

1.2 Information We Collect About You

1.2.1 Mobile Device Data

When you access the Services through a mobile device, including but not limited to when you use your mobile device to electronically unlock our properties, we may receive or collect and store unique identification numbers associated with your device, your device type and manufacturer, your mobile carrier, subscriber status, and payment method, your phone number, caller ID data, and, depending on your mobile device settings, your location information, including GPS coordinates (“Mobile Device Data”). We generally collect this information including to provide the Services you request and to improve your experience with the Services, as well as for identity verification and fraud avoidance purposes. Types of Mobile Device Data that qualify as Personal Information under this Policy will be treated as such.

1.2.2 Usage Data

We may automatically collect certain types of usage information when you use our Services including but not limited to your browser type, operating system, Internet Protocol address, bandwidth speed, and information collected through cookies, web beacons, and other technologies (“Usage Data”). Some specific examples include:

• We may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer. Cookies uniquely identify your browser and allow us to help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), and allow us to track your usage of the Services over time.
• We may collect log file information from your browser or mobile device each time you access the Services. Log file information may include anonymous information such as your web request, Internet Protocol address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information.
• We may employ clear gifs to track the online usage patterns of our Users or which emails are opened and which links are clicked by recipients.
• We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Services.

We generally use Usage Data for user convenience, system administration, and statistical analysis, such as to: (i) remember information so that you will not have to re-enter it; (ii) provide customized content and information, including advertising; (iii) monitor the effectiveness of our Service; (iv) monitor aggregate metrics such as total number of visitors, traffic, and usage patterns; (v) diagnose or fix technology problems; and (vi) enhance our Services. Types of Usage Data that qualify as Personal Information will be treated as such under this Policy.

If desired, you can change your web browser's cookie settings, as discussed in these resources:

• Internet Explorer
• Firefox
• Chrome
• Safari

2. USE AND SHARING OF YOUR PERSONAL INFORMATION

2.1 Use of Your Personal Information

We use Personal Information to provide you with the services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our website, and to improve our products and services.

Here are some examples of ways in which we use your personal information:

1. To create and maintain your login information on our site
2. To underwrite and process your mortgage application
3. To contact you regarding your application
4. To contact third party vendors and other authorized third parties regarding your application
5. To investigate, prevent, or take action regarding suspected or actual illegal activities (including fraud or stalking), security or technical issues

2.2 Sharing your Personal Information

We may share your Personal Information as follows:

1. In connection with a merger or other business combination or separation (including, but not limited to, a voluntary or involuntary change in our business or structure, or a reorganization, financing, change of control, sale of all or part of our stock or assets, spinoff, bankruptcy, dissolution, or any related to similar proceedings)
2. To respond to legal process or to regulatory authorities (such as pursuant to a subpoena; warrant; investigative demand from law enforcement, regulators or others; national or international security letters, etc.)
3. To protect against fraud, claims, or other liability or harm to you, us, or others;
4. To exercise or perform a legal, ethical, contractual or other right or obligation, such as to enforce our Terms of Service or other agreements, or to investigate potential violations thereof
5. For such lawful purposes as may be disclosed or evident at the time that you provide Personal Information to us (e.g., when you provide Personal Information in response to a survey, to sign up for an event, or to register for a newsletter)
6. To engage in routine business uses that an ordinary and reasonable person should expect in the context of the Services that we provide, the reasons for which we collect Personal Information, and/or the ways that similar businesses ordinarily operate
7. To comply with applicable law

3. PROTECTING YOUR PERSONAL INFORMATION

We take our customer’s privacy very seriously, and use what we believe to be commercially reasonable physical, electronic, administrative, and procedural safeguards to preserve the integrity, confidentiality, and security of all Personal Information collected through the Services. However, no security measure, system, or control is infallible. Accordingly, WE DO NOT GUARANTEE OR WARRANTY THAT PERSONAL INFORMATION COLLECTED THROUGH OR STORED ON THE SERVICES MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED. WE DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES OR DUTIES IN THAT REGARD.

It’s important to note that you have a major role in the security and privacy of your own Personal Information. For example, you should not provide us with Personal Information that we do not request. Additionally, you are responsible for controlling access to any personal computing device through which your Personal Information may be stored or accessed. You are also responsible for safeguarding any passwords or other log-in credentials to may be used to access to your Personal Information.

We urge your caution when using public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, don’t use such computers to access your sensitive accounts, and if you must do, ensure that you logout of your account entirely.

Please remember to review the privacy settings and security policies of third party sites and services that you use, such as social networks. We are not responsible for the privacy or security measures of any third party.

In the event that the security of any Personal Information under our control is compromised, we will take reasonable steps to investigate and mitigate the situation, including, when and where appropriate, notifying those individuals whose Personal Information may have been compromised and taking other steps in accordance with applicable laws and regulations.

4. YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

4.1 Commercial/Transactional Communications

We use your Personal Information to send you emails regarding the Services (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Services, technical and security notices). We also may provide notifications to you that are required by law. You may not opt out of these communications. Subject to applicable law, we may provide such notifications to you via email, text message, hard copy, or through conspicuous posting on our Web Site or otherwise through the Services.

4.2 Marketing Communications

We may send you marketing emails, including promotions and new product offerings. You can stop receiving marketing email communications from us by clicking on the “unsubscribe link” provided at the bottom of the communications. We make reasonable efforts to promptly process all unsubscribe requests.

We may also send messages via SMS to your mobile phone. To opt-out of these messages, reply “STOP” to the sender. Please note that by opting out of SMS messages, we may not be able to provide all of the Services. In particular, many important messages may not be delivered to your mobile device.

4.3 Changing and Updating Your Personal Information

We want to provide you with the resources you need to keep your information with us correct and up-to-date. You can contact us to access and modify your personal and personally identifiable information by calling 800-860-0386.

4.4 Do Not Track

Our Services do not respond to Do-Not-Track signals from your browser at this time

5. CHILDREN’S PRIVACY

Opendoor does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Services are not directed at children under the age of 13. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child under 13, please contact us at 800-860-0386.

This Policy was last modified on 09-13-2019.

ANY RIGHTS NOT EXPRESSLY GRANTED HEREIN ARE RESERVED BY OPENDOOR HOME LOANS