Last updated March 01, 2021
Collection of Personal Information
We collect personal information directly from you when you visit and interact with the Site, and when you when you open and/or click on email advertisements, as well as if you request to unsubscribe from receiving future email advertisements from us.
The types of personal information that we collect automatically through the Site include: (i) your IP address; (ii) referring web page; (iii) your age range; (iv) cookies, beacons, pixel tags, and mobile ad identifiers; and (v) geolocation data. Our servers automatically recognize your IP address each time you visit the Site and the web page from which you came. Your IP address is used to help identify you and to gather broad demographic information about you to and to better tailor our product and service offerings contained within the Site. Your IP address can also be used to help diagnose problems with our servers, and to administer the Site. We also collect additional personal information which you submit to us through the Site including: (i) your first name; (ii) your last name; (iii) your email address; (iv) your telephone number; and (v) any other information requested in a web form contained on the Site.
The first time that a user provides an email address in connection with their activities at the Site, we assign an identification number to that email address and deploy a cookie to the applicable user's PC. A cookie is a small data text file, which is stored on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. The cookies may collect information about you, such as the referring website address, your IP address, your browser type and version, your Internet service provider, the area code and zip code associated with your server, the time and date of your visit, and the time spent on the Site. Whenever a user comes back to the Site using the same PC, the cookie allows the Site to identify the user and to recall the user's email address. If, at any time, a user provides other information in connection with their activities on the Site (such as name, address, etc.), we may store that information, along with a user's email address, in our database. We may use the information stored in our database: (i) to effectuate the purpose or transaction for which the information was originally provided by a user; (ii) to ensure that a user will not be repeatedly exposed to the same advertisements, offers and/or promotions while visiting the Site; (iii) to pre-populate information fields in the event that user wishes to purchase products and/or services or sign up for and/or subscribe to services, promotions or other offers in the future; (iv) to, in connection with regular communication with a user, include offers, promotions or advertisements that were historically, or are likely to be, of interest to that user; or to track your use of the Site, and to customize the content that you might see on the Site. To disable and reject cookies, adjust the settings via the options menu of your Internet browser. Many web browsers offer their users to opt to not be tracked, however unless otherwise required by law, we do not guarantee that we will respond to such Do Not Track signals.
Other methods of tracking: An action tag or a web-beacon (also known as a clear gif/pixel tag) is a method used to track responses or actions by visitors who view certain advertisements and/or other information on the Site. Action tags are 1x1 pixel images embedded in a website page that are used to transparently collect information. We may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Site and to provide information about what products/services are viewed or purchased. We reserve the right to retain this cookie and action tag data indefinitely, and to share information generated by these cookies and action tags with our advertisers, affiliates and service providers.
We also collect personal information through advertising networks, internet service providers (ISPs), operating systems, and social networks.
Usage of Personal Information
The above personal information is used: 1) to provide you with the ability to access and interact with the Site; 2) personalize and improve the Site and/or to contact you when necessary in connection with transactions entered into by you on the Site; 3) to provide you with information that you may request and fulfill requests submitted through the Site; 4) to track consumer interaction with the Site and with our email advertisements (counting ad impressions, verifying positioning and quality of ad impressions); 5) for advertising/marketing services; 6) to detect security incidents, or protect against malicious, deceptive, fraudulent, or illegal activity; 7) to debug to identify and repair errors that affect functionality; 8) for short-term, transient use; 9) for customer service; 10) for analytics, internal research and business purposes; 11) to verify and maintain quality or safety on the Site; and 12) for legal compliance.
We may also combine the information we have gathered about you with information from other sources. We may use third parties to help us operate our business and the Site or to administer activities on our behalf.
Home Approach provides its users with the opportunity to receive special products, offers and/or services from third parties including, but not limited to, our third party service providers. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your personal information that was provided during the information collection process will be shared with the applicable third party so that such third party may provide their product or service to you and so that you do not have to complete another information collection form to purchase or receive that product or service.
We may share the personal information that you supply to us with any third party and we may work with other businesses to bring selected retail opportunities to our users. These businesses and third parties may include, but are not limited to third party individuals, companies, and/or service providers we use to perform certain functions on our behalf. Examples of such functions include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. Such third party service providers performing these limited functions on our behalf shall have access to our users' personal information as needed to perform their functions for us, but we do not permit them to use your personal information for other purposes.
By registering at the Site, you agree that such an act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR § 310 et seq.), as amended from time to time and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, and/or on applicable state do-not-call lists, we, as well as our third party service providers, retain the right to contact you via telemarketing in accordance with the Rule and applicable federal and state do-not-call regulations.
You may unsubscribe from any of our email marketing programs at any time via an unsubscribe hyperlink that allows the recipient to unsubscribe from the specific marketing program by clicking the hyperlink provided and following the instructions that follow. We process all unsubscribe requests in a timely fashion, but cannot guarantee that you will never receive another mailing from us, as we may obtain your e-mail address again through a different email marketing program that you have opted in to. If you receive another e-mail communication from us, you will be able to remove your email address via the unsubscribe hyperlink. We are able to offer our free services, in part, based upon the willingness of our users to be contacted by our marketing partners, including affiliated third party advertisers. By allowing us to make the information that you supply available to our third party marketing partners, you will receive free product and service information that may be of interest to you. You may, at any time, notify us that you do not wish to have your personal information disclosed to third parties for offers and promotions by sending an e-mail to [email protected].
The privacy of your personal information is very important to us. As such, we endeavor to safeguard our users' personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot guarantee or warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site is at your own risk.
All of our users' personal information is restricted in our offices. Only employees or third party agents who need the personal information to perform a specific job function are granted access to personal information. Employees not adhering to our policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Age Restrictions (Minors)
No information should be submitted to, or posted at, the Site by visitors under eighteen (18) years of age or the applicable age of majority (if greater than eighteen 18 years of age). Persons under eighteen (18) years of age or the applicable age of majority are not permitted to access the Site and we do not knowingly collect personal information from such individuals. We encourage parents and guardians to spend time with their children and to participate and monitor their online activities. To the extent that you believe that we have acquired the personal information of minors, please contact us immediately using the contact information below.
Third Party Partner Websites
The Site may contain links to other third-party owned and/or operated websites including, but not limited to, the websites of our third party service providers. Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of their third party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such a website. These third party websites have separate privacy and data collection practices and Company has no responsibility or liability relating to them.
Updating Your Information
At any time you may request Home Approach to: (i) amend the personal information that we have on file for you and/or (ii) remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via email at [email protected]; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, amended or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical.
Please be advised that deleting your personal information may terminate or limit your ability to apply for services through the Site. If you wish to apply for services without any hindrance or limitation, you may decide not to delete the personal information that we have on file for you. Note that after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Option to Opt Out
We provide users with the option to opt-out from receiving information sent via electronic mailings on our own behalf and that of our third party advertisers. Users may unsubscribe from receiving email at any time by following the instructions contained at the end of every e-mailing. Unsubscribe requests can only be processed if you have registered with us in the first instance. If you have not registered with us and wish to opt out of receiving email from a particular sender, please consult that sender's opt out policy, or contact that sender. Information sent on behalf of third party advertisers are prepared several days in advance, so users may continue to receive email from us for up to ten (10) days following the unsubscribe procedures detailed above. If, after that point, a user is still receiving email from us, the user should contact us at [email protected] Notwithstanding the foregoing, we may continue to contact you for purposes of communicating information relating to your application for the services, as well as to respond to any inquiry or request made by you. To opt-out of receiving services-related and/or inquiry response-related messages from us, you must cease applying for services, and cease submitting inquiries to us.
Your California Privacy Rights
This section is specific and applies only to web visitors who are California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations.
If you would like to learn how your personal information is shared with third parties (as defined in the Shine the Light Law, Cal. Civ. Code Sec. 1798.83), or what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, and also if you would like to opt-out from the disclosure of your personal information to any third party for marketing purposes please contact us at: [email protected], or send postal mail to Home Approach c/o Palindrome Performance, 603 E Boston Post Rd #5004, Mamaroneck, NY 10543. Please be advised that where California residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from Home Approach, in accordance with applicable laws.
Under the California Consumer Privacy Act of 2018 ("CCPA"), up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding our collection, disclosure, and sale practices are detailed below, in addition to instructions on how to exercise your rights regarding your personal information.
What Personal Information Do We Collect?
|Categories of Personal Information (PI)||Specific Types||Categories of Personal Information (PI) Specific Types Business or Commercial Purpose for Which Each Category Will be Used|
|Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)||First name;
|Site access and interaction; Fulfillment of requests submitted through the Site; Personalize and improve the Site; Marketing; Internal database; Analyze the Site; Secure the Site; Customer service; and Legal compliance|
|Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Age range; Phone number||Site access and interaction; Fulfillment of requests submitted through the Site; Marketing; Internal database; Internal analysis; Customer service; and Legal compliance|
|Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)||Time and date of your visit to the Site; Time spent on the Site; Referring web page; Specific webpages you visited, including any third party websites reached through the Site; Internet service provider; Domain name servers; Types of computers or devices accessing the Site; Web browser type and version; and Behavioral data (opens, clicks)||Site access and interaction; Fulfillment of requests submitted through the Site; Personalize and improve the Site; Marketing; Internal database; Analyze the Site; Secure the Site; Customer service; and Legal compliance|
|Geolocation data||Geographic region based on IP address; Area code and zip code associated with your web server||Site access and interaction; Fulfillment of requests submitted through the Site; Personalize and improve the Site; Marketing; Internal database; Analyze the Site; Secure the Site; Customer service; and Legal compliance|
What Personal Information Do We Disclose or Sell?
We have disclosed personal information for a business purpose, or sold personal information to third parties in the preceding 12 months in the following categories:
|Categories of Personal Information (PI)||Categories of Third Parties to Whom Such Information Was Disclosed or Sold|
|Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)||Direct lead buyers, including investment companies; and marketing partners|
|Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Direct lead buyers, including investment companies; and marketing partners|
A comprehensive list of the third parties which we disclosure personal information can be found at: https://homeapproach.com/partners/
In addition to the above, to the extent legally required to comply with applicable laws and regulations, or to respond to a lawful request, or to otherwise protect our rights, we may also disclose any of the above personal information to the requesting governmental agency, entity, or person. As we continue to develop our business, we might sell or buy assets. In such transactions, personal information collected through the Site may be one of the transferred business assets. Also, in the event that we, or substantially all of our assets, are acquired, such personal information will be included within the transferred assets.
We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.
Your Right to Request to Know and How to Submit a Verified Request to Know
A "request to know" is a request related to the personal information that a business has about such a consumer. It may include a request for any or all of the following from us: 1) specific pieces of personal information that we have collected about you; 2) categories of personal information that we have collected about you; 3) categories of sources from which the personal information was collected; 4) categories of personal information that we have sold or disclosed for a business purpose about you; 5) categories of third parties to whom the personal information was sold or disclosed; and 6) the business or commercial purpose for collecting or selling personal information.
The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.
To submit a request to know, please email your request to: [email protected] To process your request, you may be required to submit your name, address, email address, and phone number in conjunction with your request. The name, address, email address and phone number which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.
Your Right to Request Deletion and How to Submit a Verified Request to Delete
You have the right to request the deletion of any personal information which we have collected about you, or which we maintain. To submit a verifiable request to delete, please click here: https://homeapproach.com/contact/, or [email protected] To process your request, you may be required to submit your name, address, email address, and phone number in conjunction with your request. The name, address, email address and phone number which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required.
To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.
Your Right to Opt-Out of the Sale of Your Personal Information
California affords consumers with the right to opt-out of the sale of their personal information. To submit a request to opt-out of the sale of your personal information, you may complete the information requested in our webform https://homeapproach.com/contact/, or you may email us at [email protected]
To process your request, to opt-out, you may be required to submit your email address and phone number in conjunction with your request. The email address and phone number which you provide will be used to verify your request and to attempt to identify you within our data records. You may exercise your right to opt-out through an authorized agent. If you elect to use an authorized agent to exercise your right to opt-out of the sale of your personal information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your opt-out request will be used for the express purposes of verification and complying with your opt-out request.
Your Right to Non-Discrimination for the Exercise of Your Privacy Rights
California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer's data. A business shall notify consumers of any financial incentive or price or service difference.
Unauthorized Changes Liability
In no event shall we be liable for any damages of any kind arising in connection with: (i) your use of the Site; (ii) the unauthorized modification of your personal information; or (iii) advertisements provided by us, our marketing partners or any other third parties.