State Privacy Policy Supplement
Homebot's takes your privacy seriously. Our State Privacy Policy Supplement is provided below and is accessible from within all Homebot products and services.
Homebot, Inc. Supplemental Privacy Notice for California, Virginia, Colorado, Connecticut, and Utah Residents
Last Updated: June 30, 2023
If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, this Supplemental Privacy Notice for California, Virginia, Colorado, Connecticut, and Utah Residents (“Supplemental Privacy Notice”) applies to you and supplements the Homebot Privacy Policy, available at https://homebot.ai/privacy-policy. This Supplemental Privacy Notice provides information about certain rights with respect to our collection, use, and disclosure of your Personal Information that may be available to you under applicable state law (generally, the “Privacy Rights”), an overview of our general processes for responding to Privacy Rights requests we receive, and state-specific information about exercising a Privacy Right and other information under applicable laws.
Please note, the scope of some of the rights described in this policy and our process for responding to them differ from state-to-state, so please refer to the specific information where applicable.
Overview of Privacy Rights
In certain jurisdictions, applicable law may provide you with the following rights with respect to your Personal Information – Right to Know, Right to Delete, Right to Correct, Right to Data Portability, and Right to Opt-Out of Certain Processing Activities (each, a “Privacy Right”). This section provides a general overview of each of these Privacy Rights. Please review the specific information for your state of residence for more detailed information about how these Privacy Rights may apply to you.
Please note, you must provide sufficient information to enable us to respond to requests you make the exercise your Privacy Rights, which may include, consistent with applicable law and based on the nature of the applicable Privacy Right, providing us with information that is sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person and providing sufficient detail in connection with your request to allow us to properly understand, evaluate, and respond to it.
Right to Know
Subject to applicable law, the Right to Know provides you with the right to obtain certain information from us about the Personal Information we have collected from or about you which may include:
- confirming whether or not we are processing your Personal Information;
- the categories of Personal Information we have collected about you;
- the categories of sources of the Personal Information we have collected about you;
- our business or commercial purpose(s) for collecting, selling, or sharing that Personal Information;
- the categories of third parties to whom we disclose, sell, or share that Personal Information; and
- the specific pieces of Personal Information we have collected about you.
All Right to Know requests are subject to verification of your identity, and, subject to applicable law, we are required to fulfill these requests no more than twice within a 12-month period.
Right to Delete
Subject to applicable law, the Right to Delete provides you with the right to request we delete any Personal Information we have collected and retain about you, subject to certain exceptions such as our need to comply with legal obligations, fulfill orders, complete transactions, etc.
All Right to Delete requests are subject to verification of your identity.
Right to Correct
Subject to applicable law, the Right to Correction provides you with the right to request that we correct inaccurate Personal Information that we have collected and maintain about you.
All Right to Correct requests are subject to verification of your identity.
Right to Data Portability
Subject to applicable law, the Right to Data Portability provides you with the right to request a copy of Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
All Right to Data Portability requests are subject to verification of your identity, and, subject to applicable law, we are required to fulfill these requests no more than twice within a 12-month period.
Right to Opt-Out of Certain Activities
Subject to applicable law, the Right to Opt-Out of Certain Activities provides you with the right to opt-out of having the Personal Information we have collected from or about you sold to third parties, shared with third parties for behavioral advertising purposes, processed for targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.
Subject to applicable law, Right to Opt-Out of Certain Activities requests may not be subject to verification of your identity, however, if we have a good-faith, reasonable basis to believe that Right to Opt-Out of Certain Activities request is fraudulent, we may deny the request and provide an explanation of the reason for the denial.
Exercising Your Privacy Rights
To exercise a Privacy Right, in addition to other applicable options provided in our Privacy Policy or this Supplemental Privacy Notice, you may submit a request to exercise a Privacy Right by contacting us by:
- calling us at 1-877-554-3696;
- emailing us at privacy@homebot.ai; or
- filling out a Data Subject Access Request form, available at www.homebot.ai/privacy
- writing to us at Homebot, Inc., 1500 Market Street, Denver, CO 80202.
Overview of Our Process for Responding to Requests to Exercise Privacy Rights
Subject to applicable law, our general process for responding to requests to exercise a Privacy Right is to, where applicable, verify your identity and then respond to your request, either by fulfilling your request or, if we cannot fulfill your request, in whole or in part, providing you about why we cannot fulfill your request. This section provides a general overview of this process. Please review the specific information for your state of residence for more detailed information about how our process may apply to your request.
Verifying Your Identity
Subject to applicable law, when we receive a request to exercise a Privacy Right, we will:
- acknowledge receipt of your request;
- try to match the information you provide in making the request with information we already maintain about you;
- if required to verify your identity, we may ask you to provide additional information, including Personal Information; and
- consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
Making a request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in connection with a request to verify the requestor's identity or authority to make the request.
Responding to Your Requests
We will try to promptly respond to your request and, subject to applicable laws, in any event within 45 days after we receive the request. If we require additional time, we will inform you of the reason we need additional time and the extension period. Generally, except as otherwise required under applicable law and where applicable to the particular Privacy Right covered by your request, any disclosures or actions we take with respect to your Personal Information will only cover the 12-month period immediately preceding our receipt of your request. Additionally, with respect to our response to a request to exercise a particular Privacy Right:
- Where we fulfill all or part of a Right to Know request, we will select a format to provide your Personal Information to you.
- Where we fulfill all or part of a Right to Delete request:
- we may permanently and completely erase the Personal Information from our existing systems (except for archived or backup systems), deidentify the Personal Information, or aggregate the Personal Information;
- for any Personal Information stored on our archived or backup systems, we will delete, deidentify, or aggregate that Personal Information once the archived or backup system is restored to an active system or is next accessed or used for a sale, disclosure, or commercial purpose; and
- we will direct our Service Providers and other Third Party Sources to do the same, subject to certain exceptions permitted by applicable law.
- For Right to Correct requests:
- we may deny your request if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances and we may request that you provide us with documentation that is relevant to your request; and
- we may choose to delete the contested Personal Information as an alternative to correcting it if doing so would not negatively impact your or you consent to our deletion.
- Where we fulfill all or part of a Right to Opt-Out of Certain Activities we may still:
- disclose or otherwise provide your Personal Information to applicable Third Party Sources, such as our Service Providers and other entities for business purposes consistent with applicable law; and
- disclose or otherwise provide your Personal Information in connection with certain business transactions as described in our Privacy Policy.
Subject to applicable law, we may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
California
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Category
Examples / Explanations
Right to Know
Subject to applicable law, you have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
Right to Delete
Subject to applicable law, you have the right to request that we delete the Personal Information we have collected about you, subject to certain exceptions.
Right to Correct
Subject to applicable law, you have the right to request that we correct your inaccurate Personal Information.
Right to Opt-Out of Certain Activities
Subject to applicable law, you have the right to opt-out of having your Personal Information sold to or shared with third parties.
In addition to the other methods available to submit a request to exercise a Privacy Right, you may make a request to exercise the Right to Opt-Out of Certain Activities by clicking the Do Not Sell or Share My Personal Information link on our website or by clicking here.
Additionally, we honor the Global Privacy Control (GPC) as set through various browsers or browser plug-ins. You can find more about how to enable the GPC on your browser on the GPC website. When we receive a valid signal sent through GPC, we honor that communication as a valid request to opt-out of the sale or sharing of Personal Information associated that browser or device, and we may ask you to log into your account or otherwise identify yourself so we can link your opt-out preference to your account. We may also notify you if your request to opt-out sent through GPC conflicts with your previous consent to the sale or sharing of your Personal Information.
Right to Non-Discrimination
We will not discriminate against you for exercising any Privacy Right provided under applicable law.
Who May Exercise Your Privacy Rights
Only you or a person that you authorized to act on your behalf may make a Privacy Request concerning your Personal Information. A parent or legal guardian may make a Privacy Right request on behalf of their child.
If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit Privacy Right requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the Privacy Right request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
Collection, Source, Purpose, and Sharing of Your Personal Information
To learn about the categories of Personal Information we collect, see the “Categories of Personal Information We Collect” section in our Privacy Policy.
To learn about the categories of sources from which your Personal Information is collected, see the “Sources of Personal Information We Collect” section in our Privacy Policy.
To learn about our purposes for collecting and using Personal Information, see the “Our Purposes for Collecting and Using Personal Information” section in our Privacy Policy.
To learn about how long we retain Personal Information, see the “How Long We Retain Personal Information” section in our Privacy Policy.
Categories of Personal Information Collected
During the past 12 months, we have collected the following categories of Personal Information: Identifiers; Customer Records; Legally Protected Characteristics; Commercial Information; Internet or Other Electronic Network Activity Information; Non-Sensitive Geolocation Information; Professional or Employment-Related Information; and Inferences.
Categories of Personal Information Disclosed for a Business Purpose
During the past 12 months, we have disclosed the following categories of Personal Information for a business purpose: Identifiers; Customer Records; Legally Protected Characteristics; Commercial Information; Internet or Other Electronic Network Activity Information; Non-Sensitive Geolocation Information; Professional or Employment-Related Information; and Inferences.
Categories of Sensitive Personal Information Collected
During the past 12 months, we have collected the following categories of Sensitive Personal Information: Account Log-In Credentials; Racial Origin; Ethnic Origin; and Religious Beliefs.
Please note, we only collect Sensitive Personal Information relating to Racial Origin, Ethnic Origin and Religious Beliefs in connection with submission of photos that may reveal these types of information and your language preference selection through the Services. We do not use these types of information for any purpose apart from displaying your photo through the Services and providing the Services to you in the language you selected.
Categories of Sensitive Personal Information Disclosed for a Business Purpose
During the past 12 months, we have disclosed the following categories of Sensitive Personal Information for a business purpose: Account Log-In Credentials; Racial Origin; Ethnic Origin; and Religious Beliefs.
Additional Uses or Disclosures of Sensitive Personal Information
We do not use or disclose Sensitive Personal Information for any purpose other than our business purposes, as specified under applicable law.
Categories of Personal Information Sold or Shared
During the past 12 months, we have not sold, rented, leased, or otherwise disclosed, released, disseminated, transferred or made Personal Information available to any third party for monetary or other valuable consideration.
During the past 12 months, we have shared the following categories of Personal Information with third parties for the purpose of providing the Service: Identifiers, Commercial Information; Internet or Electronic Network Activity Information; Non-Sensitive Geolocation Information; and Inferences.
California Shine the Light
Under California's Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Information to third parties for direct marketing purposes: (a) the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (b) the names and addresses of the third parties that received the information; and (c) if the nature of the third party's business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Homebot, Inc.
Attn: CA Privacy Rights Request
1500 Market St
Denver CO 80202
Virginia
PRIVACY RIGHTS FOR VIRGINIA RESIDENTS
Collection, Source, Purpose, and Sharing of Your Personal Information
To learn about the categories of Personal Information we collect, see the “Categories of Personal Information We Collect” section in our Privacy Policy.
To learn about the categories of sources from which your Personal Information is collected, see the “Sources of Personal Information We Collect” section in our Privacy Policy.
To learn about our purposes for collecting and using Personal Information, see the “Our Purposes for Collecting and Using Personal Information” section in our Privacy Policy.
To learn about how long we retain Personal Information, see the “How Long We Retain Personal Information” section in our Privacy Policy.
Right to Know
Subject to applicable law, you have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Delete
Subject to applicable law, you have a right to request that we delete the Personal Information we collected from you. If we have obtained Personal Information about you from another source, we will either: (a) retain a record of the Right to Delete request and the minimum data necessary for the purpose of ensuring that your Personal Information remains deleted from our records and not using such retained data for any other purpose; or (b) offer to opt you out of the processing of such Personal Information for any purpose except for those exempted purposes under applicable law.
Right to Correct
Subject to applicable law, you have the right to request that we correct your inaccurate Personal Information.
Right to Data Portability
Subject to applicable law, you may request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right to Opt-Out of Certain Activities
Subject to applicable law, you may direct us to cease processing your Personal Information for targeted advertising, sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects.
Who May Exercise Your Privacy Rights
Only you may make a Privacy Request concerning your Personal Information. A parent or legal guardian may make a Privacy Right request on behalf of their child.
Request to Appeal Our Response to Your Request
If you disagree with our refusal to take action on your request to exercise a Privacy Right, you have the right to ask us to reconsider. You must submit your request within 60 days of your receipt of our denial. Once we receive your request, we will acknowledge and start processing your request. Within 60 days of receiving your request, we will inform you in writing of any action taken or not taken in response to your request, including a written explanation of the reasons for our decision.
Colorado (Effective July 1, 2023)
PRIVACY RIGHTS FOR COLORADO RESIDENTS
Right to Know
Subject to applicable law, you have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Delete
Subject to applicable law, you have a right to request that we delete the Personal Information we collected from you. If we have obtained Personal Information about you from another source, we will either: (a) retain a record of the Right to Delete request and the minimum data necessary for the purpose of ensuring that your Personal Information remains deleted from our records and not using such retained data for any other purpose; or (b) offer to opt you out of the processing of such Personal Information for any purpose except for those exempted purposes under applicable law.
Right to Data Portability
Subject to applicable law, you may request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right to Opt-Out of Certain Activities
Subject to applicable law, you have the right to opt-out of the processing of your Personal Information for targeted advertising, sale of Personal Information.
In addition to the other methods available to submit a request to exercise a Privacy Right, you may make a request to exercise the Right to Opt-Out of Certain Activities by clicking the Do Not Sell or Share My Personal Information link on our website or by clicking here.
Additionally, we honor the Global Privacy Control (GPC) as set through various browsers or browser plug-ins. You can find more about how to enable the GPC on your browser on the GPC website. When we receive a valid signal sent through GPC, we honor that communication as a valid request to opt-out of the sale or sharing of Personal Information associated that browser or device, and we may ask you to log into your account or otherwise identify yourself so we can link your opt-out preference to your account. We may also notify you if your request to opt-out sent through GPC conflicts with your previous consent to the sale or sharing of your Personal Information.
Who May Exercise Your Privacy Rights
Only you or a person that you authorized to act on your behalf may make a Privacy Request concerning your Personal Information. A parent or legal guardian may make a Privacy Right request on behalf of their child.
If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit Privacy Right requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the Privacy Right request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Request to Appeal Our Response to Your Request
If you disagree with our refusal to take action on your request to exercise a Privacy Right, you have the right to ask us to reconsider. You must submit your request within 60 days of your receipt of our denial. Once we receive your request, we will acknowledge and start processing your request. Within 45 days of receiving your request, we will inform you in writing of any action taken or not taken in response to your request, including a written explanation of the reasons for our decision.
Connecticut (Effective July 1, 2023)
PRIVACY RIGHTS FOR CONNECTICUT RESIDENTS
Right to Know
Subject to applicable law, you have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Delete
Subject to applicable law, you have a right to request that we delete the Personal Information we collected from you. If we have obtained Personal Information about you from another source, we will either: (a) retain a record of the Right to Delete request and the minimum data necessary for the purpose of ensuring that your Personal Information remains deleted from our records and not using such retained data for any other purpose; or (b) offer to opt you out of the processing of such Personal Information for any purpose except for those exempted purposes under applicable law.
Right to Correct
Subject to applicable law, you have the right to request that we correct your inaccurate Personal Information.
Right to Data Portability
Subject to applicable law, you may request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right to Opt-Out of Certain Activities
Subject to applicable law, you have the right to opt-out of the processing of your Personal Information for targeted advertising, sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects.
Who May Exercise Your Privacy Rights
Only you or a person that you authorized to act on your behalf may make a Privacy Request concerning your Personal Information. A parent or legal guardian may make a Privacy Right request on behalf of their child.
If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit Privacy Right requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the Privacy Right request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Request to Appeal Our Response to Your Request
If you disagree with our refusal to take action on your request to exercise a Privacy Right, you have the right to ask us to reconsider. You must submit your request within 60 days of your receipt of our denial. Once we receive your request, we will acknowledge and start processing your request. Within 60 days of receiving your request, we will inform you in writing of any action taken or not taken in response to your request, including a written explanation of the reasons for our decision.
Utah (Effective December 31, 2023)
PRIVACY RIGHTS FOR UTAH RESIDENTS
Right to Know
Subject to applicable law, you have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Delete
Subject to applicable law, you have a right to request that we delete the Personal Information we collected from you.
Right to Data Portability
Subject to applicable law, you may request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right to Opt-Out of Certain Activities
Subject to applicable law, you have the right to opt-out of the processing of your Personal Information for targeted advertising or the sale of Personal Information.
Who May Exercise Your Privacy Rights
Only you may make a Privacy Request concerning your Personal Information. A parent or legal guardian may make a Privacy Right request on behalf of their child. A guardian or conservator may make a Privacy Request on behalf an individual subject to guardianship, conservatorship, or other protective arrangement under applicable law.
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