Protecting your private information is our priority. This privacy notice (“Privacy Notice”) applies to Ruuster Inc., and its subsidiaries and affiliates (hereinafter, variously “Company”, “we”, “us”, or “our”), and our website, software-as-a-service platform, mobile or web applications, data analytics, management portal, content, products, services and any sites Company may have now and/or in the future including without limitation its homebuying management platform (collectively, the “Services”), and outlines our principles for collecting, using and protecting information that we maintain about any person whose personal data is being collected, held or processed by us including without limitation customers and/or site visitors (hereinafter the “Individual(s)” or “you”).

By using the Services in any manner, you indicate to Company that you have read and accept our Privacy Notice and consent to the data practices described in this Privacy Notice. If you do not accept this Privacy Notice or do not meet or comply with the provisions set forth herein, then you may not use the Services. If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services. Any consent shall be entirely voluntary. In the event you do not provide consent to use or process your personal data, then you may not access and/or use the Services.

INFORMATION WE COLLECT

When you use the Services, you may provide Company with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use the Services. We collect information from you when you (a) use and/or access the Services, (b) register an account and/or subscribe to Company, (c) open and/or respond to our emails, (d) contact Company, (e) visit any page online that displays our content, and/or (f) provide information to any of our service providers, partners, and/or other users.

Personally Identifiable Information You Choose to Provide

We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request. We collect personal information such as your:

(i) personal and/or business contact information (including name, telephone number, email and address, and business website address);

(ii) username and password;

(iii) demographic information (including age, birthdate and gender);

(iv) Credit score;

(v) Financial information;

(vi) location information (such as geographic location of the home and/or anticipated home you are looking to purchase);

(vii) property information; and/or

(viii) preferences and behavior (such as record of comments, responses and questions asked).

Once you register, you have opted in to receive electronic communications from Company.

Surveys

Company may also provide you with the opportunity to participate in surveys through the Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

Incentive Programs, Rebates, Contests and Sweepstakes

When you choose to participate in an incentive program, rebate, sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. The purpose of collection and use of this data is that we have a business need to operate the related program. In some contexts, we are also required by law to collect information about those that enter our incentive programs, and we have a business interest in complying with those laws.

Affiliate Linking/Marketing

On certain areas of the Services, Company is compensated in exchange for featured placement of products and services, or your clicking on links posted on the Services. The compensation may impact, where and what products appear. We do not include all companies or all available products on this portion of the Services.

Connecting with Social Media

If you so choose, you may connect to or register an account using an external third-party application, such as ‘Facebook’, ‘Twitter’, ‘Pinterest’, ‘LinkedIn’ ‘Google’, ‘Yahoo’, ‘Microsoft’ etc. Company may receive some data from such connected third-party applications. Connecting your account to third-party applications and/or services is optional, and when you connect your account to an external application, you will be given the opportunity to grant permission. By connecting to external third-party applications, we may help you find friends using your account or we may allow people to search for your account using your contact information. You can revoke the foregoing permissions under your account settings and/or with the external third-party application. Depending on which services you choose to use, Company may require additional information and contact information.

Information We Collect Automatically

Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Aggregate: We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information, and/or other interactions with the Services. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual.

Analytics: We use analytic software to gather statistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

Advertising Programs: A number of different targeting and advertising programs may be used on the Service, which will collect information about your online activities on the Service using Cookies, web beacons, mobile advertising identifies and other technologies. These third parties may use information to display online advertisements across your devices based on your interests and preferences.

Third Party Services:To support the services we provide to you we may use services hosted by third parties. These services may collect information sent by a browser as part of a web page request, including ‘Internet Protocol’ addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors. However, we may link the information we record using tracking technology to personal information we collect. In addition, we may allow third parties who list services to use Cookies in connection with your use of the Services. They may collect and store the same type of information and use it similarly to Company, as described in this Privacy Notice.

Information from Other Sources: We may also obtain information about you from third-party sources, such as our partners or advertisers. We may also, at your direction, receive credit reports or scores from consumer reporting agencies or third-party services that provide a mechanism to share information you have provided to the third-party through the use of an application program interface (API). If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Notice and applicable law.

Cookies: In an effort to be transparent with our data collection practice and the technologies we use to provide the Services, the following explains how we use Cookies. We use Cookies and web log files to improve the website experience and quality of the Services, and to customize your experience, by tracking website usage and trends, conducting research and development for additional services, and determining marketing efforts. A “Cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows Company to recognize you as a user when you return to our website using the same device and web browser and enables Company to collect information about how you use our Services. Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at using the Service. If you do not agree to our use of Cookies, you should set your browser settings accordingly or not use the Services. Company uses Cookies and web log files for the following, which may include without limitation (i) to track usage and trends, (ii) to improve the quality of the Services, (iii) to customize your experience and/or (iv) to compile anonymous, aggregated information that allow us to understand how our Services are used. Cookies are categorized by how long they are stored and their function. The Cookies Company may use are as follows:

· Persistent Cookies: Persistent Cookies remain on a visitor’s device for a set period of time specified in the Cookie. They are activated each time that the visitor visits the Services that created that particular Cookie.

· Session Cookies: Session Cookies are temporary and deleted from your computer when you close your web browser. They allow Company to link the actions of a user while using the Services.

· Strictly Necessary Cookies: Strictly necessary Cookies are essential to navigate around the Services and to use its features.

· Performance Cookies: Performance Cookies collect anonymous data for statistical purposes on how users use the Services, they don’t contain personal information and are used to improve the user experience.

· Functionality Cookies: Functionality Cookies allow Company to operate the Services in accordance with your choices, such as ‘remembering’ you in between visits.

You may remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use the Services and/or impact your user experience while using the Services. By accessing or using the Services, you consent to the placement of Cookies on your device as described in this Privacy Notice. If you prefer not to receive Cookies through the Services, you may control how your browser responds to Cookies by adjusting the privacy and security settings of your web browser.

Do Not Track:

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, we do not recognize DNT.

HOW WE USE INFORMATION

General Use

We use information collected as described in this Privacy Notice to provide you with the Services and/or information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services. We also use the information collected to take the following actions:

· operate, maintain and improve the Services;

· enable non-affiliated third parties to provide additional services to you;

· answer questions and respond to your requests;

· perform analytics and conduct research;

· send you reminders, support and marketing messages;

· manage our administration of the Services;

· improve the design and content of the Services;

· analyze programs, products and services we offer;

· market information or listings you provide to us;

· contact you through email, social media, blog or newsletter;

· collect feedback from you about third-party products and/or services;

· provide tailored ads based on your information and/or preferences provided while using the Services;

· inform you about products, events and/or other promotional purposes; and

· use information for other purposes about which we notify you.

The information collected in the aggregate enables Company to better understand your use of the Services and to enhance your enjoyment. We may use financial information to enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us at helpme@ruuster.com.

Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries and reviews, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect. Customers can reach Company by email at helpme@russter.com.

Parties with whom we may share your information:

Service Providers. We may share your personally identifiable information with employees, contractors, service providers and/or agents that help Company provide the Services to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services. We will not share your personally identifiable information in ways unrelated to those described in this Privacy Notice without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. Certain Service Providers will automatically collect non-identifying information about your use of the Services and Company shall not have any liability related thereto.

Network Partners. We may share information (including personal information) collected directly from you with non-affiliated third party partners or providers in connection with the Services (“Network Partners”) to deliver the products and services you requested or otherwise asked us to share. For example, you may request to contact a real estate agent, mortgage lender, marketplace, moving company, utilities provider and/or insurance provider. If you report a complaint with any third party on the Service, we may share that complaint with that Network Partner. We may also share deidentified and/or aggregate analytics with Network partners about how you interact with our Services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service. PLEASE NOTE: The Network Partners that interact with you may retain or use your information whether or not you use their services. You should contact these Network Partners directly concerning their privacy and information sharing practices. Pursuant to the contracts between Company and its Network Partners, if you select a Network Partner through our Services, we may also receive information about you from that Network Partner. Company and its Network Partners may exchange information about you and your accounts for the purpose of providing you with information about services and products.

Compliance with Laws. Company will not disclose your personal information to third parties except as set forth in this Privacy Notice and in the following circumstances: (i) to investigate and defend Company members against any third party claims and/or allegations and/or otherwise to protect Company from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service.

Business Transfer. If we sell or otherwise transfer part or all of Company or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

INFORMATION CHOICES

Your Information Choices

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Company, and you can limit the communications that Company sends to you.

Account

If you create an account through the Services and volunteer personally identifiable information, you can opt out of receiving certain notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting us and/or by changing your preferences on the Service.

Deactivating an Account

Please be aware that even after you deactivate an account, we do not delete information about you. Company may, for a time, retain information about you, which may include without limitation, for backup and/or archival purposes, analytics and legal compliance. Following termination and/or deactivation of your account, Company reserves the right to access and utilize collected user data in the future.

Emails

If you do not wish to receive emails or newsletters from us, you can opt out of those communications by using the unsubscribe process at the bottom of the email from us. Please note that you cannot unsubscribe from certain email communications which are essential to your transactions through the Services.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out penalties for violations. To be in accordance with the CAN-SPAM Act we agree to the following:

· We will not purposefully email recipients who have previously opted out of their communication.

· We will remove opt-outs from our email list within ten (10) business days

· We will provide an opt-out mechanism that makes it easy for you to opt out of future messages.

· Our emails will include our contact information for any inquiries or questions.

If at any time you would like to unsubscribe from receiving future emails, you can email us and we will promptly remove you from ALL correspondence. As for third party websites, please contact them directly to unsubscribe and/or opt out from their communications.

Calls and Texts

Some of our Services allow you to provide your phone number to us. If you give us your number, you expressly consent to, and authorize us or a third party on our behalf to deliver autodialed or prerecorded telemarketing calls and/or text messages to the number you provide. This consent encompasses all future autodialed or prerecorded telemarketing calls and text messages from us or a third party placing these calls on our behalf. We will contact you through these methods only in accordance with applicable legal requirements, and you always have the ability to opt out of further calls or texts.

Information You Share Socially

The Services may allow you to share your actions, content and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends. The Services may also allow you to connect with us on, share on, and use third-party website, applications and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. As a reminder, we do not control the privacy practices of third parties, so please contact other sites if you want to learn about their privacy practices.

SERVICE ELIGIBILITY

Company does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at helpme@ruuster.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the products and/or services through the Services.

CHANGES

In general, changes will be made to this Privacy Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Notice at any time, with or without advance notice, so please review it periodically. We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. You can determine when this Privacy Notice was last revised by referring to the date it was “Last Modified” above. Your continued use of the Services after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates.

SECURITY

We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. Company has adopted commercially reasonable physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Your account is protected by password for your privacy and security. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, Company cannot warrant the security of any information you transmit to Company or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Please do your part to help Company. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Company, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing your account. We are not responsible for the functionality, privacy and/or security measures of any other organization.

DATA TRANSFERS; INTERNATIONAL USERS

Please be aware that the Services are subject to United States laws, including those governing privacy and security of your information and is intended solely for users located in the United States. By using the Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Notice and understand that the laws of the United States and other countries and territories related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Notice.

CALIFORNIA PRIVACY RIGHTS

Under California Consumer Privacy Act (“CCPA”), California residents are entitled to receive the right to access and obtain a copy of your personal information. You may write us and ask for records of any and all personal information. The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. To obtain such information from Company, please email your request to helpme@ruuster.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above. The followingexceptions may prevail with respect to fulfillment of data access requests: (a) Company may not provide personal data to an Individual, if management determines that we cannot identify the Individual in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) Company may not provide personal data to an Individual, if the Individual is involved in a civil or criminal proceeding with Company.

OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including the information and/or content contained therein. Please remember that when you use a link to go from the Services to another website and/or service, our Privacy Notice does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on the Service, are subject to such third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

LANGUAGE

The governing language of this Privacy Notice is English, which shall prevail over any other languages used in any translated document.

HOW TO CONTACT US

If you have questions and/or comments about this Privacy Notice, please email us at helpme@ruuster.com. Because email communication is not always secure, please do not include sensitive personal information (such as race, ethnic origin, health and the like) in your emails to us.