Privacy Policy

OUR PRIVACY POLICY

Last updated November 17, 2023

This privacy notice for ROMS HOUSING LLC (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

-1)Visit our website at https://romshousing.com, or any website of ours that links to this privacy notice -2)Download and use our mobile application, or any other application of ours that links to this privacy notice. -3)Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact

us at customers@romshousing.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find

out more details about any of these topics by clicking the link following each

key point or by using our table of contents below to find the section you are

looking for.

What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

us and the Services, the choices you make, and the products and features you use.

Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive

personal information when necessary with your consent or as otherwise permitted by

applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We do not receive any

information from third parties.

How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal

information? We may share information in specific situations and with specific

categories of third parties. Learn more about when and with whom we share your

personal information.

What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by

submitting a data subject access request, or by contacting us. We will consider and

act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the

privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL

INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. CONTROLS FOR DO-NOT-TRACK FEATURES

8. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

9. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register

on the Services, express an interest in obtaining information about us or our products

and Services, when you participate in activities on the Services, or otherwise when

you contact us.

Personal Information Provided by You. The personal information that we collect

depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect

may include the following:

names

phone numbers

email addresses

billing addresses

debit/credit card numbers

mailing addresses

Sensitive Information. When necessary, with your consent or as otherwise

permitted by applicable law, we process the following categories of sensitive

information:

financial data

social security numbers or other government identifiers

Payment Data. We may collect data necessary to process your payment if you make

purchases, such as your payment instrument number, and the security code

associated with your payment instrument. All payment data is stored by ROMS

HOUSING LLC. You may find their privacy notice link(s) here: RomsHousing.com.

Application Data. If you use our application(s), we also may collect the following

information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track

location-based information from your mobile device, either continuously or

while you are using our mobile application(s), to provide certain location-based

services. If you wish to change our access or permissions, you may do so in

your device’s settings.

This information is primarily needed to maintain the security and operation of our

application(s), for troubleshooting, and for our internal analytics and reporting

purposes.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply

with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage

user accounts. We may process your information so you can create and log

in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process

your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your

information to respond to your inquiries and solve any potential issues you

might have with the requested service.

To send administrative information to you. We may process your

information to send you details about our products and services, changes to

our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill

and manage your orders, payments, returns, and exchanges made through the

Services.

To enable user-to-user communications. We may process your information

if you choose to use any of our offerings that allow for communication with

another user.

To save or protect an individual’s vital interest. We may process your

information when necessary to save or protect an individual’s vital interest,

such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS

YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary

and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like

with your consent, to comply with laws, to provide you with services to enter into or

fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain

the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission

(i.e., consent) to use your personal information for a specific purpose. You can

withdraw your consent at any time. Learn more about withdrawing your

consent.

Performance of a Contract. We may process your personal information when

we believe it is necessary to fulfill our contractual obligations to you, including

providing our Services or at your request prior to entering into a contract with

you.

Legal Obligations. We may process your information where we believe it is

necessary for compliance with our legal obligations, such as to cooperate with

a law enforcement body or regulatory agency, exercise or defend our legal

rights, or disclose your information as evidence in litigation in which we are

involved.

Vital Interests. We may process your information where we believe it is

necessary to protect your vital interests or the vital interests of a third party,

such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.,

express consent) to use your personal information for a specific purpose, or in

situations where your permission can be inferred (i.e., implied consent). You

can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to

process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be

obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to

assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next

of kin

If we have reasonable grounds to believe an individual has been, is, or may be

victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise

the availability or the accuracy of the information and the collection is

reasonable for purposes related to investigating a breach of an agreement or a

contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or

rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,

or profession and the collection is consistent with the purposes for which the

information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share

your data with third-party vendors, service providers, contractors, or agents (“third

parties”) who perform services for us or on our behalf and require access to such

information to do that work. We have contracts in place with our third parties, which

are designed to help safeguard your personal information. This means that they

cannot do anything with your personal information unless we have instructed them to

do it. They will also not share your personal information with any organization apart

from us. They also commit to protect the data they hold on our behalf and to retain it

for the period we instruct. The categories of third parties we may share personal

information with are as follows:

Payment Processors

Order Fulfillment Service Providers

Government Entities

Finance & Accounting Tools

Data Storage Service Providers

Sales & Marketing Tools

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection

with, or during negotiations of, any merger, sale of company assets, financing,

or acquisition of all or a portion of our business to another company.

Business Partners. We may share your information with our business

partners to offer you certain products, services, or promotions.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements). No purpose

in this notice will require us keeping your personal information for longer than the

period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.

6. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United

Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review, change, or

terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain

rights under applicable data protection laws. These may include the right (i) to

request access and obtain a copy of your personal information, (ii) to request

rectification or erasure; (iii) to restrict the processing of your personal information; (iv)

if applicable, to data portability; and (v) not to be subject to automated decisionmaking.

In certain circumstances, you may also have the right to object to the

processing of your personal information. You can make such a request by contacting

us by using the contact details provided in the section “HOW CAN YOU CONTACT

US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data

protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing

your personal information, you also have the right to complain to your Member State

data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and

Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.

Account Information

If you would at any time like to review or change the information in your account or

terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your

account and information from our active databases. However, we may retain some

information in our files to prevent fraud, troubleshoot problems, assist with any

investigations, enforce our legal terms and/or comply with applicable legal

requirements.

If you have questions or comments about your privacy rights, you may email us at

customers@romshousing.com.

7. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.

8. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of Virginia, Utah, Connecticut, Colorado or California,

you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months:

Category Examples Collected

A. Identifiers

Contact details, such as real name, alias,

postal address, telephone or mobile

contact number, unique personal identifier,

online identifier, Internet Protocol address,

email address, and account name

YES

B. Personal information as

defined in the California

Customer Records statute

Name, contact information, education,

employment, employment history, and

financial information

YES

C. Protected classification

characteristics under state

or federal law

Gender and date of birth YES

D. Commercial information

Transaction information, purchase history,

financial details, and payment information

YES

E. Biometric information Fingerprints and voiceprints YES

F. Internet or other similar

network activity

Browsing history, search history, online

behavior, interest data, and interactions

with our and other websites, applications,

systems, and advertisements

YES

G. Geolocation data Device location YES

H. Audio, electronic, visual,

thermal, olfactory, or similar

information

Images and audio, video or call recordings

created in connection with our business

activities

I. Professional or

employment-related

information

Business contact details in order to

provide you our Services at a business

level or job title, work history, and

professional qualifications if you apply for

a job with us

J. Education Information Student records and directory information NO

K. Inferences drawn from

collected personal

information

Inferences drawn from any of the collected

personal information listed above to create

a profile or summary about, for example,

an individual’s preferences and

characteristics

L. Sensitive personal

Information

Account login information, state id card

numbers, social security numbers, drivers’

licenses and debit or credit card numbers

YES

We will use and retain the collected personal information as needed to provide the

Services or for:

Category A – 6 months

Category B – 6 months

Category C – 6 months

Category D – 6 months

Category E – 6 months

Category F – 6 months

Category G – 6 months

Category L – 6 months

Category L information may be used, or disclosed to a service provider or contractor,

for additional, specified purposes. You have the right to limit the use or disclosure of

your sensitive personal information.

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the

context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, “HOW DO WE

PROCESS YOUR INFORMATION?”

We collect and share your personal information through:

Social media plugins: sassy social share. We use social media features, such

as a “Like” button, and widgets, such as a “Share” button, in our Services.

Such features may process your Internet Protocol (IP) address and track which

page you are visiting on our website. We may place a cookie to enable the

feature to work correctly. If you are logged in on a certain social media platform

and you interact with a widget or button belonging to that social media

platform, this information may be recorded to your profile of such social media

platform. To avoid this, you should log out from that social media platform

before accessing or using the Services. Social media features and widgets

may be hosted by a third party or hosted directly on our Services. Your

interactions with these features are governed by the privacy notices of the

companies that provide them. By clicking on one of these buttons, you agree

to the use of this plugin and consequently the transfer of personal information

to the corresponding social media service. We have no control over the

essence and extent of these transmitted data or their additional processing.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Learn more about how we

disclose personal information to in the section, “WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be “selling” of your personal information.

We have disclosed the following categories of personal information to third parties for

a business or commercial purpose in the preceding twelve (12) months:

Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a

business or commercial purpose can be found under “WHEN AND WITH WHOM DO

WE SHARE YOUR PERSONAL INFORMATION?”

We have sold or shared the following categories of personal information to third

parties in the preceding twelve (12) months:

The categories of third parties to whom we sold personal information are:

NONE

The categories of third parties to whom we shared personal information with are:

Local Government

Attorneys

Banking Services

Real Estate Professionals

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law

permits our users who are California residents to request and obtain from us, once a

year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the

immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered account

with the Services, you have the right to request removal of unwanted data that you

publicly post on the Services. To request removal of such data, please contact us

using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will

make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our

systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer

Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a “residents” as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and

obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal

information, subject to certain exceptions provided by law, such as (but not limited to)

the exercise by another consumer of his or her right to free speech, our compliance

requirements resulting from a legal obligation, or any processing that may be

required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a

business purpose;

the categories of third parties to whom the personal information was sold,

shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal

information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer request

or to reidentify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

social security information, drivers’ licenses, state ID cards, passport numbers

account login information

credit card numbers, financial account information, or credentials allowing

access to such accounts

precise geolocation

racial or ethnic origin, religious or philosophical beliefs, union membership

the contents of email and text, unless the business is the intended recipient of

the communication

genetic data, biometric data, and health data

data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal

information to that use which is necessary to perform the Services.

Once a business receives your request, they are no longer allowed to use or disclose

your sensitive personal information for any other purpose unless you provide consent

for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without

the purpose of inferring characteristics about a consumer is not covered by this right,

as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information,

please email customers@romshousing.com or submit a data subject access request.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are

the same person about whom we have the information in our system. These

verification efforts require us to ask you to provide information so that we can match it

with information you have previously provided us. For instance, depending on the

type of request you submit, we may ask you to provide certain information so that we

can match the information you provide with the information we already have on file,

or we may contact you through a communication method (e.g., phone or email) that

you have previously provided to us. We may also use other verification methods as

the circumstances dictate.

We will only use personal information provided in your request to verify your identity

or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot

verify your identity from the information already maintained by us, we may request

that you provide additional information for the purposes of verifying your identity and

for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer

relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on

your behalf. We may deny a request from an authorized agent that does not

submit proof that they have been validly authorized to act on your behalf in

accordance with the CCPA.

You can opt out from the selling or sharing of your personal information by disabling

cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My

Personal Information link on our homepage.

To exercise these rights, you can contact us by submitting a data subject access

request, by email at Customers@romshousing.com, by calling toll-free at

+19299926102, by visiting romshousing.com, or by referring to the contact details at

the bottom of this document. If you have a complaint about how we handle your data,

we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act

(CPA), you have the rights listed below. However, these rights are not absolute, and

in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects (“profiling”)

We sell personal data to third parties or process personal data for targeted

advertising. You can opt out from the selling of your personal data, targeted

advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit

a request to exercise any of the other rights described above, please email

customers@romshousing.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our

decision, please email us at customers@romshousing.com. Within forty-five (45)

days of receipt of an appeal, we will inform you in writing of any action taken or not

taken in response to the appeal, including a written explanation of the reasons for the

decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data

Privacy Act (CTDPA), you have the rights listed below. However, these rights are not

absolute, and in certain cases, we may decline your request as permitted by law.