PRIVACY POLICY

Last Updated: October 16, 2015

Welcome, and thank you for your interest in Properly, Inc. (“Properly”, “we,” or “us”) and our website at www.getproperly.com, as well as all related websites, networks, applications, and other services provided by us (collectively, our “ Service”).

This Privacy Policy (the “Policy”) describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Policy.

This Policy is incorporated into and is subject to the Properly Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Properly Terms of Service.

Information We Collect on the Service:

How We Use the Information We Collect . We use information we collect on the Service to provide the Service and operate our business in the following ways:

· We use the information that we collect on the Service to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users.

· We use the information that we collect on the Service to understand and analyze the Service usage and preferences of our users, to improve the Service, to generate statistics and Reputation Scores, to make recommendations, and to develop new products, services, features, and functionality.

· We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including updates relating to products or services we offer.

· We may use cookies and automatically collected information to: (i) personalize our Service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized content and information; (iii) monitor and analyze the effectiveness of the Service and marketing activities; and (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed.

When We Disclose Information . Except as described in this Policy, we will not disclose your Personal Information that we collect on the Service to third parties. We may disclose information to third parties in the following circumstances:

· Any information that you voluntarily choose to expose to other users of the Service will be available to anyone who has access to that content. For example, when a Host sends a Job to a Cleaner, that Cleaner will be able to view information about the Host and the Job.

· In connection with any disclosure of Personal Information that is permitted under this Policy, we may also disclose your Reputation Scores. Thus, any person who can see other information about you on the Service, such as your name or a profile image, may also be able to see your Reputation Scores.

· We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

· We may disclose your information if required to do so by law, or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement, regulators, or other governmental agencies.

· We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

· We may disclose your Personal Information to third parties if you give your consent to such disclosure.

· Information about our users, including Personal Information, may be disclosed and transferred to an acquirer, successor, or assignee of Properly as part of any merger, acquisition, debt financing, sale of stock or assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

· We may make certain aggregated, automatically-collected, or otherwise non-Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

Your Choices

You may, of course, decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your account information and preferences at any time by accessing your account preferences page on the Service. If you wish to access or amend any other Personal Information we hold about you, you may contact us at legal@getproperly.com. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

We do not provide your Personal Data to third parties for their marketing purposes, and therefore do not offer an opt-out for third-party marketing programs. If, in the future, we implement any program that shares your Personal Information with third parties for their marketing purposes, we will modify this Policy accordingly.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

Your device operating system or browser may include settings, options, or add-on components to control the placement and presence of cookies and access to location information. Please note that if you choose to refuse or delete cookies from the Service, or to deny the Service access to your location information, you may not be able to utilize the features of the Service to their fullest potential.

We do not track our website visitors over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities, including across other websites on the internet, which enables these websites to tailor what they present to you. If you are visiting such websites, your browser may allow you to set a DNT signal on your browser so that third parties know you do not want to be tracked.

Third-Party Services

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Our Service is not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from a child under 13 years of age, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, please alert us at legal@getproperly.com.

Data Security

Please be aware that no security measures are perfect or impenetrable. Although we use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Data that we collect and maintain, we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service.

International Visitors

The Service is hosted in the United States. If you are located in the European economic area or other regions of the world with laws governing data collection and use, we comply with applicable legal requirements providing adequate protection for the transfer of personal information. We may transfer the personal information we collect about you to countries other than the country in which the information was originally for the purposes of storage and processing of data, fulfilling your requests, and operating the service. By providing information, including Personal Information, to the service you consent to such transfer, storage, and processing. Note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to those countries may not have the same data protection laws as the country in which you initially provided the information. If we transfer your information to other countries, we will protect that information as described in this Policy.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make the revised Policy available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the revised Policy.

Our Contact Information

The Service is offered by Properly, Inc., located at 611 S Van Ness Street 2nd floor, San Francisco, CA 94110, USA. Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices, either at that address or by email at legal@getproperly.com.