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TERMS OF USE AND PRIVACY POLICY

Revised March 29, 2022

Holt Group Holdings, LLC (which together with its affiliates are collectively referred to herein as “Holt Homes” or “Holt” or “we” or “us”) has adopted this Privacy Policy because we respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you how and for what purposes we are collecting, processing, and using your Personal Information (as defined herein). We pledge that we will take reasonable steps to ensure that your Personal Information and Usage Information (as defined herein) will only be used in ways that comply with this Privacy Policy.

This Privacy Policy applies to any direct communication, web page, email list, online electronic data collection, generic information, and Personal Information collected and/or owned by us, including but not limited to our website, located at www.holthomes.com. This Privacy Policy is in effect no matter the method of collection (such as by mail, email, telephone call, direct or in-person data collection, facsimile, sign-up/sign-in page, survey, or promotion, etc.), including collection through our website and any online features, products, services, and/or programs we offer (collectively, the “Website”). We will treat any offline collection, uses, and disclosures of your Personal Information consistently with our online privacy practices set forth in this Privacy Policy.

This Privacy Policy informs you of the types of information that Holt Homes collects through this Website and any mobile sites, application forms, widgets, and other interactive features employed by Holt Homes. It also informs you how Holt Homes uses this information, the categories of third parties with whom Holt Homes may share this information, and how in certain cases you may “opt out” from the sharing of your information by Holt Homes. By accessing or using Holt’s website, you signify your acceptance of the provisions outlined in this Privacy Policy.

This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Website, unless otherwise noted.

Please read this policy carefully to understand our policies and practices regarding how we use your information. If you do not agree with the policies and practices outlined in this Privacy Policy, your choice is not to use our Website. By accessing or using our Website, you agree to this Privacy Policy.

This policy may change from time to time. Your continued use of this Website after we make changes is deemed acceptance of those changes, so please check the policy periodically for updates.

Notice to California Residents

Additional provisions, specifically developed and maintained for California residents, are outlined within this Privacy Policy, and can be found in Appendix A, entitled “Privacy Rights for California Residents.”

Notice to Nevada Residents

Additional provisions, specifically developed and maintained for Nevada residents, are outlined within this Privacy Policy, and can be found in Appendix B, entitled “Privacy Rights for Nevada Residents.”

Notice to Oregon Residents

Additional provisions, specifically developed and maintained for Oregon residents, are outlined within this Privacy Policy, and can be found in Appendix C, entitled “Privacy Rights for Oregon Residents.”

Notice to European Union and UK Residents

Additional provisions, specifically developed and maintained for European and UK residents, are outlined within this Privacy Policy, and can be found in Appendix D, entitled “Privacy Notice for European Union and UK Residents.”

Notice to Utah Residents

Additional provision, specifically developed and maintained for Utah residents, are outlined within this Privacy Policy, and can be found in Appendix E, entitled “Privacy Rights for Utah Residents.”

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to, or on, the Website. We do not knowingly collect, sell, share or disclose personal information from children under 18. If you are under 18, do not use or provide any information on this Website, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us at privacy@Holthomes.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please review Appendix A for more information.

Types of Information Collected

We collect information when you interact with Holt Homes. All information we collect may be combined with information obtained from other sources. This happens, for example, when you visit and use our Website, correspond with us via email, submit an employment application, respond to us on social media (e.g., Facebook, Twitter, or Instagram), or post on public social media pages and profiles. Holt, and any third party that we engage for the purpose of offering you our products and services, or for administering, operating, hosting, configuring, designing, maintaining, and providing support for our Website, may collect information from your interactions with us.

Personal Information

The types of information that Holt collects may include, among other things, the following categories of information (collectively, “Personal Information”):

  • Contact information (e.g., your first name, last name, title, physical address, zip code, phone number, email address);
  • Username, password, and security questions and answers;
  • Demographic information, such as your date of birth and nationality, which allows us to verify your identity and comply with federal law;
  • Social security number (SSN), driver’s license, passport, and other government ID numbers and government documents;
  • Internet Protocol (or IP) address or device ID/UDID, protocol, and sequence information;
  • Loan account information; and
  • Bank account and credit/debit card numbers.

Usage Information

The types of usage information that Holt collects may contain generic information about you when you visit the Website, which may include, among other things, the following categories of information (collectively, “Usage Information”):

  • Browser language and type;
  • Domain name system requests;
  • Browsing history (such as, time spent at a domain, time and date of your visit, links clicked on, search data and terms, usernames, physical location) and number of clicks;
  • Http headers, application client and server banners, and operating system and fingerprinting data;
  • Aggregated information, including De-identified Data (as defined herein); and
  • Type of computer, mobile device or tablet you are using, your MAC address, your operating system and version, your IP address, and your internet service provider.

How Information is Collected

Various automated technologies are used to track and collect information about you and your Website visits or online interactions with us including: cookies, information from your browser, information from our server, web beacons, pixel tags, clear GIFs, and other means. In addition, during the normal course of our business, we may collect Personal Information and Usage Information about you from the following sources:

  • Directly from you. You may provide information to us online for any number of reasons. For example, you may sign your home purchase agreement over the Internet, request information about our homes or communities, submit a warranty request, respond to a survey, or submit a job application. In such cases, we will collect the information that you provide, which may include information regarding your Holt home, your name, telephone number, email address, physical address, name of your present community or a Holt Homes community in which you are interested, or certain demographic information, such as your age range, gender, and areas of interest and, in the case of a job application, may include your resume and social security number.
  • Information from third parties. We may collect or purchase information from third parties, including marketing companies. If you have responded to or interacted with third parties who share your information with us, we collect the information the third party provides to us, including your email address.
  • Social media. Holt Homes maintains profiles and pages on social media platforms including, Facebook®, Twitter®, Instagram®, Pinterest®, LinkedIn®, YouTube®, Instagram®, and others. Holt Homes may collect the information that you post on social media platforms including Personal Information, pictures, or other information. Information posted on any such pages is also subject to the privacy policies and terms of use of the respective social media platforms.
  • Applications or other forms we receive from you or your authorized representative, which may include information about your assets and income, and identifying information, such as name, address, and SSN;
  • Your communication to us (for example, an inquiry about a property, or a request to sign up for a mailing list or to receive updates from us);
  • Information we receive from you through the Website and as a result of your use of our services;
  • Information we receive from your computer or mobile device;
  • Information we receive from our affiliates, partners, or service providers;
  • Information we receive from bank statements, lender approvals, or W-9 forms;
  • Information from consumer or other reporting agencies and public records maintained by governmental entities that we obtain directly from those entities, from our affiliates or others, such as your creditworthiness and credit history; and
  • Information we receive from other sources, as permitted by applicable laws, rules, and regulations.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, our third-party vendors may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information collected automatically may include personal information.  It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
  • Identify individual preferences for marketing purposes.

The technologies used for this automatic data collection may include:

  • Cookies, or browser cookies. A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website.  Flash cookies are not managed by the same browser settings as are used for browser cookies.  For information about managing your privacy and security settings for Flash cookies, see the section entitled Choices About How We Use and Disclose Your Information, found below.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.  They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.  For information about how you can opt out of receiving targeted advertising from many providers, see the section entitled Choices About How We Use and Disclose Your Information, found below.

 

Google Analytics

Our Website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies and similar technologies to collect and store anonymous information about you, which may include the non-personal information described above. You can read information about how Google Analytics may use your data at http://www.google.com/policies/privacy/partners/, Google’s Privacy Policy at http://www.google.com/intl/en/policies/privacy/, and Google Analytics Terms of Use at http://www.google.com/analytics/terms/us.html. Our Website may use certain features of Google Analytics, including:

(a) “Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Website.  We use such non-personal information in the same manner as we use other non-personal information as described in this Privacy Policy.

(b) “Remarketing with Google Analytics” to place ads on other sites directed to people who have visited the Website.

(c) “Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Website.

You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings at https://support.google.com/ads/answer/2662856. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at https://tools.google.com/dlpage/gaoptout/.

How We Use Information We Collect

Holt Homes will use and disclose the information we collect for any lawful purpose we deem appropriate. This includes in connection with your purchase of a Holt home; to fulfill your requests; to answer your questions; to manage our business; to recruit and hire employees; to protect our interests; to comply with law enforcement; and, to support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy. In this regard, we may contact you by email, postal mail, text message, social media, telephone, or other means regarding our products, services, promotions, and employment opportunities.

We may transfer your Personal Information to third parties, including our hosting partners and other trusted third parties who assist us in operating the Website. You can read more about this in the section entitled, “When Information is Disclosed and to Whom.”

Unless otherwise required by law, Holt Homes will treat all information shared with us online as non-confidential and non-proprietary. Holt Homes will utilize such information in accordance with this Privacy Policy. If you use or visit our Website, submit any content to us, or post any content on our Website or our social media pages or profiles, you agree that, with respect to such content, Holt Homes is granted an unlimited, non-exclusive, worldwide, irrevocable, perpetual license to reproduce, duplicate, transmit, display, publish, create derivative works, sublicense, and otherwise use any such information for any lawful purpose whatsoever, including marketing and you agree to hold us harmless with respect thereto.

Length of PI Retention
We retain personal information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us or keep using our products and services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transaction or communications for a certain period of time before we can delete them); and
  • Whether retention is advisable in light of our legal rights (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

When Information Is Disclosed and to Whom

We may provide your Personal Information (excluding information we receive from consumer or other credit reporting agencies) and Usage Information to various individuals and companies, as permitted by law, without obtaining your prior authorization. You can learn how you can limit the discretionary disclosure of your Personal Information and Usage Information in the section entitled, “Choices with Your Personal Information.”

We may allow web analytics providers and other third parties including our advertisers, email vendors and other service companies to collect information, including Personal Information, about your online activities, over time and across different websites, when you use this Website. These third parties may use the technologies mentioned above and other technologies to track your online behavior. These technologies may be used to collect certain information about your visits to our Website or other websites (including the types of information previously mentioned).

Disclosures of your Personal Information may be made to the following categories of affiliates and nonaffiliated third parties, unless prohibited by applicable law:

  • Contractors, Subcontractors and Service Providers Providing Services to Holt Homes and Holt Homeowners. If you are a Holt homeowner or prospective homeowner, we share your information, which may include Personal Information, with our contractors, subcontractors, service providers, and developers of communities (for example, electricians, painters, land developers, and telecom providers) in connection with your purchase of a Holt home and in response to your warranty or customer service requests and to provide services to you and our other homeowners. We may share your information with contractors and service providers who perform services on our behalf, such as those that perform technology services for us.
  • Holt Homes Business Relationships. If you enter into a purchase agreement for a new home, we may share your information, including your Personal Information, with others, such as Westwood Insurance Agency, and, unless you opt-out as described in the new home documentation, such sharing may be for direct marketing purposes.
  • Other Third Parties. We may share your information, including your Personal Information, with other third parties, and, unless you opt-out, such sharing may be for direct marketing purposes.
  • Legal Matters. We may share your information, including your Personal Information, with third parties, including law enforcement; in response to legal process; and, to investigate, prevent, or take action regarding illegal, suspicious, or fraudulent activities involving this Website, you, or us.
  • Business Transactions. We may share your information, including your Personal Information, with potential buyers in the event of the sale or a proposed sale of a business unit or property or other business transaction.
  • Storage. We share your information, including your Personal Information, with third parties for the purpose of helping us gather, store, and maintain data.
  • To third parties to provide you with services you have requested, and to enable us to detect or prevent criminal activity, fraud, material misrepresentation, or nondisclosure.
  • To our subsidiaries and affiliates.
  • To our outside marketing consultant.
  • To nonaffiliated third-party service providers who provide or perform services on our behalf and use the disclosed information only in connection with such services.
  • To law enforcement or other governmental authority in connection with an investigation, or civil or criminal subpoena or court order.
  • To lenders, lien holders, judgment creditors, or other parties claiming an interest in title whose claim or interest must be determined, settled, paid, or released prior to closing on your new home.
  • To other third parties for whom you have given us written authorization to disclose your Personal Information.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Holt’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which person information held by Holt about our users is among the assets transferred.

Disclosures of your Personal Information may also be made in the following circumstances, unless prohibited by applicable law:

  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent or as directed by you.

We might disclose Personal Information and/or Usage Information when required by law or in the good-faith belief that such disclosure is necessary:

  • To comply with a legal process or applicable laws.
  • To enforce this Privacy Notice.
  • To enforce or apply our Terms and Conditions of Use of this Website.
  • To take precautions against liability and respond to any claim that any information provided by you violates the rights of a third party.
  • To assist government enforcement agencies.
  • To protect our rights or property
  • To protect the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies.
  • To investigate potential unauthorized access or misuse of the Website.
  • To enforce or apply our Terms of Use and other agreements.

We maintain reasonable safeguards to keep your Personal Information secure. When we provide Personal Information to our affiliates or third-party service providers as discussed in this Privacy Notice, we require that these parties agree to process such information in compliance with our Privacy Notice or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own privacy notice. Unless permitted by law, we do not disclose information we collect from consumer or credit reporting agencies with our affiliates or others without your consent.

In addition to the other rights described herein, we have the right to exploit, share, and use, for any purpose, the collected Personal Information in an aggregated, anonymized form, such that you are not individually identified (collectively, “De-identified Data”).

We may allow you to create a user profile for use in connection with the Website (“Profile”). When you open an account with us and create a Profile, we may obtain, verify, and record information that identifies you, including Personal Information. We may be required to verify, record or share such information to help the government fight the funding of terrorism and money laundering activities.

We reserve the right to transfer your Personal Information (as well as any information about or obtained from you) in connection with the event of a merger, sale, or other disposition of all or part of our business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of our creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the previously described proceedings. We are not responsible for any breach of security or action by any of these third parties.

We may disclose your Personal Information for any purpose disclosed by us when you provide the information. We may also disclose your Personal Information with your permission or as directed by you.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. Here are examples of how you can control the use and disclosure of your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to privacy@holthomes.com.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to privacy@Holthomes.com. If we have sent you a promotional email, you may send us an email reply asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Data Security

Holt Homes has implemented safeguards as required by law to protect your Personal Information. Unfortunately, however, no information or data transmitted electronically, including information or data transmitted over the Internet or stored electronically, should be assumed safe and secure. We do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error. ANY TRANSMISSION OF PERSONAL INFORMATION IS AT YOUR OWN RISK. If you believe that the security of any information or data that you have provided to us has been compromised, please immediately notify us of the problem in accordance with the section entitled, “Contacting Us.”

For certain features available through the Website, including use of a Profile (if applicable), we may require the use of encryption technologies for your protection. We administer safety measures and use reasonable precautions to protect the privacy of your username, password, and Profile information and to ensure that information collected through the Website is not lost, misused, or altered inappropriately. You are ultimately responsible for protecting your username, password, and Profile information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. WE ARE NOT RESPONSIBLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS OR SECURITY MEASURES CONTAINED ON THE WEBSITE. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Privacy Outside the Website

The Website may now, or in the future, contain links to other websites. Holt is not and cannot be responsible for the privacy practices or the content of any of those other websites. Please check with those websites in order to determine their privacy policies and your rights under them.

We may use the services of third-party service providers, for example to process payments and other transactions or to provide analytics services. By using our Website, you grant us all necessary rights and consents under applicable laws to disclose to the third-party service providers and/or allow those third-party service providers to collect, use, retain and disclose to us any Personal Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

Additional Privacy Rights / Notices

Depending on your residency, you may have additional rights pertaining to your personal information.  If you are a resident of one of the following jurisdictions, please see the appropriate Appendix.

California Resident – Appendix A

Nevada Resident – Appendix B

Oregon Resident – Appendix C

European Union or UK Resident – Appendix D

Utah Resident – Appendix E

Updates/Changes to Our Privacy Policy

Holt Homes reserves the right to change this Privacy Policy from time to time. Holt Homes will notify you of changes to this Privacy Policy by updating this Privacy Policy on this Website and setting forth the date on which the update was made. We encourage you to retain a copy of this Privacy Policy and periodically to check this Website for updates. Your use of our Website indicates your acceptance of the latest version of this Privacy Policy. The most recent version of the policy will be posted here with the revision date at the top.

EQUAL HOUSING OPPORTUNITY

Holt Homes is pledged to equal housing opportunity and provides housing without discrimination or other limitation based on race, color, religion, sex, handicap, familial status, or national origin.

 

Appendix A – Privacy Rights for California Residents

If you are a California resident, California law provides you with additional rights regarding our use of your personal information, as set forth in this Appendix.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@Holthomes.com or a written notice by mail to:

Holt Homes Attn: Legal Department 1300 Esther St. Vancouver, WA 98660

The following supplemental privacy notice entitled, “Notice at Collection,” is for California residents and supplements the information contained in the previous portions of this privacy policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), along with any regulations and amendements thereto.  Any terms defined in the CCPA have the same meaning when used in this notice.

Notice at Collection

Privacy Policy and Information We Collect

Holt Homes respects your privacy and is committed to protecting it through our compliance with a Privacy Policy. Holt Homes’ Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Website, information we may collect through our other business dealings, as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read the policy carefully to understand our policies and practices regarding your information and how we will treat it.

We collect several types of information from and about our customers and potential customers, including:

  • Personal Identifiers, such as name, address, email address, social security number, and other similar information.
  • Personal Information, such as name, telephone number, IP address, financial information, and similar information.
  • Characteristics of Protected Classifications, such as age, citizenship, marital status, and veteran status.
  • Internet or Other Similar Network Activity, such as IP address, browsing/search history, and interaction with our Website.
  • Professional/Employment Information, such as employment status and job history.

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To confirm your identity.
  • To fulfill your requests and answer your questions.
  • To determine eligibility for home ownership.
  • To run and manage our business and protect our interests.
  • To support direct marketing and other opportunities.
  • To comply with state and federal laws.
  • To determine eligibility for certain housing programs.
  • To estimate our audience size and usage patterns, as well as customize our Website.
  • For any other purpose with your consent.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Information We Collect

We collect through our Website and normal business operations information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Holt has collected the following categories of personal and usage information from its consumers within the last twelve (12) months and indicated in the table below which sets forth a summary of Personal Information collected:

Category of PI Collected Specific PI within Category How PI in this Category Collected (Categories of Sources) Business purpose for PI in this Category
Personal Identifiers Name, signature, physical address, email address, username, social security number, driver’s license number, passport number. Applications, direct communication from you, through the Website, from third parties, from other entities as permitted by law. To confirm your identify, fulfill your requests, answer your questions, run and manage our business, protect our interests, and support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy.
Personal Information Name, signature, social security number, address, telephone number, passport number, driver’s license number, IP address, loan information, bank account numbers, credit card numbers and other financial information. Applications, direct communication from you, through the Website, from third parties, and from other entities as permitted by law. To confirm your identify, fulfill your requests, answer your questions, run and manage our business, protect our interests, and support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy.
Characteristics of Protected Classifications Age (40 years or older), citizenship, marital status, veteran or military status. Applications, direct communication from you, from third parties, and from other entities as permitted by law. To verify your identity, comply with state and federal laws, and to determine eligibility for certain housing programs.
Internet or Other Similar Network Activity Internet Protocol (or IP) address or device information, browsing history, search history, and interaction with our Website. Website interaction. Used to estimate our audience size and usage patterns, allow us to customize our Website according to individual preferences, speed up searches when you return to our Website, and identify individual information/ preferences for marketing purposes
Professional/ Employment Information Employment status, job history. Applications, third parties. To determine eligibility for home ownership.
Sensitive Personal Information Social security number, passport number, driver’s license number Applications, direct communication from you, through the Website, from third parties, and from other entities as permitted by law. To confirm your identify, fulfill your requests, answer your questions, run and manage our business, protect our interests, and support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy.

 

Sharing Personal Information

Holt may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Contractors.
  • Outside marketing consultant.
  • Third-party vendors.

Below you will find a table summarizing how your Personal Information has been disclosed or shared in the past 12 (twelve) months:

Category of PI Shared Specific PI shared within Category To Whom is PI Shared Business purpose for Sharing PI
Personal Identifiers Name, physical address, email address. Service providers, outside marketing consultants, and third-party vendors. To fulfill warranty requests, answer your questions, run and manage our business, protect our interests, and support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy.
Personal Information Name, address, telephone number. Service providers, outside marketing consultants, and third-party vendors. To fulfill warranty requests, answer your questions, run and manage our business, protect our interests, and support direct marketing and other opportunities of Holt Homes and third parties as described in this Privacy Policy.
Internet or Other Similar Network Activity Internet Protocol (or IP) address or device information, browsing history, search history, and interaction with our Website. Outside marketing consultant. To support direct marketing and other opportunities of Holt Homes.

Sales of Personal Information

In the preceding twelve (12) months, Holt has not sold any personal information for monetary consideration.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Holt disclose certain information to you about our collection and use of your personal information over the past 12 months, or since January 1, 2022. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, specifically:
      • Sales, identifying the personal information categories that each category of recipient purchased; and
      • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not knowingly collect, sell, share, or disclose information from children under 18.

Deletion Request Rights

You have the right to request that Holt delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correction

You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Personal Information Sales and Sharing Opt-Out Rights

You have the right to direct us to not sell or share your personal information we have collected or will collect at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may do so by one of the following means:

  • Submitting a request to using the contact information found here or listed below:
  • Calling us at 1.360.892.0154
  • Emailing us at privacy@Holthomes.com

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by emailing Holt at privacy@Holthomes.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services.

You have the right to direct to limit the use and disclosure of your sensitive personal information at any time (the “right to opt-out”).  To exercise the right to opt-out, you (or your authorized representative) may do so by one of the following means:

  • Submitting a request to using the contact information found here or listed below:
  • Calling us at 1.360.892.0154
  • Emailing us at privacy@Holthomes.com

You do not need to create an account with us to exercise your limit use and disclosure rights.  We will only use personal information provided in a limit use request to review and comply with the request.

Please note that Holt can use sensitive personal information for the following purposes, and you do not have the right to limit the use and disclosure of sensitive personal information being used in the following ways:

  • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
  • To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
  • To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
  • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
  • To perform services on behalf of the business, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the
  • To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by one of the following means:

  • Calling us at 1.360.892.0154
  • Emailing us at privacy@holthomes.com
  • Utilizing the consumer request form, found here 
  • Sending a written notice by mail to: Holt Homes Attn: Legal Department 1300 Esther St. Vancouver, WA 98660.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Before responding to a request by you, we will ask you to verify your identity using personal information you have previously provided to us, in order to protect your privacy. The manner in which we do so will vary on how you make a request and what is being requested. For example, if you submit an inquiry via email, we will respond with an email requesting verification. Otherwise, we may ask you verbally if you make this request over the phone (or in person). We may not be able to oblige all requests, as we are prohibited from disclosing some information.

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

In the event that you are using an authorized agent to request a disclosure or the deletion of your information, we may request that you send us a signed letter, including your name, email, your agent’s name, and your agent’s email, authorizing your agent. We may then ask you to verify your identity with us by email before responding to a request by your agent. Alternatively, you may directly confirm with us that the agent is authorized to submit the request.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, review the section entitled, “Personal Information Sales Opt-Out and Opt-In Rights (for California residents).”

Response Timing and Format

We endeavor to respond to a verifiable consumer request for access, data portability, correction, and deletion within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt, or the period following January 1, 2022, as you request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales and Sharing Opt-Out and Opt-In Rights (for California Minors)

If you are 16 years of age or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

In the preceding twelve (12) months, Holt has not sold personal information for monetary consideration.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by one of the following means:

  • Submitting a request to us by visiting the following Internet Web page link: here
  • Calling us at 1.360.892.0514
  • Emailing us at privacy@Holthomes.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing Holt at privacy@Holthomes.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Under California Civil Code Section 1789.3, California residents who use the Website are entitled to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through the Website, you may contact us through one of the following means:

  • Calling us at 1.360.892.0514
  • Emailing us at privacy@Holthomes.com
  • Sending a written notice by mail to: Holt Homes Attn: Legal Department 1300 Esther St. Vancouver, WA 98660

California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by one of the following means:

  • Sending a written notice by mail to:
  • 1625 North Market Blvd., Suite N 112 Sacramento, CA 95834
  • Calling 916.445.1254 or 800.952.5210

Appendix B – Privacy Rights for Nevada Residents

If you are a Nevada resident, Nevada law may provide you with additional rights regarding our use of your personal information. These additional rights are set forth below.

This privacy notice for Nevada residents supplements the information contained in the previous portions of this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of Nevada (“consumers” or “you”). We adopt this notice to comply with the Nevada Privacy Law and any terms defined in the Nevada Privacy Law have the same meaning when used in this notice.

The Nevada Privacy Law provides consumers (Nevada residents) with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

Personal Information Sales Opt-out Rights (for Nevada residents) You have the right to direct us to not sell your personal information we have collected or will collect at any time (the “right to opt-out”). The categories of covered information we collect are as follows:

  • Your first and last name.
  • Your home or other physical address which includes the name of a street and the name of a city or town.
  • Your electronic mail address.
  • Your telephone number.
  • Your social security number.
  • An identifier that allows you to be contacted either physically or online.
  • Any other information concerning you collected from you through Holt’s Internet website or online service and maintained by Holt in combination with an identifier in a form that makes the information personally identifiable.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us using the contact information found here.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by emailing Holt at privacy@Holthomes.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

We endeavor to respond to an opt-out request within sixty (60) days of its receipt. If we reasonably believe we require more time (up to 30 days), we will inform you of the extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Appendix C – Privacy Rights for Oregon Residents

We will not share your Personal Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to indicate that you do not want a disclosure made for marketing purposes.

Contacting Us; Opt-Out, and Unsubscribing

If you are currently receiving emails from Holt Homes and wish to be removed from our mailing list, please notify us of your request through one of the following means:

  • Clicking the “unsubscribe” link located on the email
  • Emailing us at privacy@holthomes.com with “unsubscribe” in the subject line
  • Sending us a written notice by mail to: Holt Homes Attn: Legal Department 1300 Esther St. Vancouver, WA 98660

 

Appendix D – Privacy Notice to European Union and UK Residents

The Website and our products and services are hosted in the United States and are governed by United States law. If you are using the Website or our products or services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Website or our products and services, you consent to your Personal Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

 

Appendix E – Privacy Rights for Utah Residents

This Section provides additional information to Utah residents at the time their personal information is collected by Us.

Utah residents have the following specific rights with respect to their personal data:

  • Right to access. Consumers have the right to (a) confirm whether the Company is processing the consumer’s personal data; and (b) access the consumer’s personal data;
  • Right to delete. Consumers have the right to delete the consumer’s personal data that the consumer provided to the Company.  Consumers do not have the right to delete all personal data that We have about You, only the right to delete the personal data You provided directly to Us.
  • Right to data portability. Consumers have the right to obtain a copy of the consumer’s personal data that the consumer previously provided to Us, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows the consumer to transmit the data to another controller without impediment, where the processing is carried out by automated means.”
  • Right to opt out of certain processing. Consumers have the right to opt out of the processing of the consumer’s personal data for the purposes of targeted advertising; or the sale of personal data.

To exercise your rights, you must submit a verifiable consumer request to Us by either:

  • Calling us at 1.360.892.0514
  • Emailing us at privacy@Holthomes.com
  • Utilizing the consumer request form, found here
  • Sending a written notice by mail to: Holt Homes Attn: Legal Department 1300 Esther St. Vancouver, WA 98660.