Privacy Policy

(Effective January 1, 2023)

Who We Are

Honor leads the world’s largest home care network with the most advanced care platform. Honor partners with home care agencies to jointly provide in-home care services to clients and is the parent company of Home Instead, Inc.,the franchisor of the Home Instead® network. The Home Instead franchise network is made up of independently owned and operated franchise and master franchise businesses.

Scope of Policy

This Privacy Policy explains how Honor Technology, Inc., and its affiliates (“Honor,” "we," “our,” "us") may collect, use, and share information we collect about You as a: consumer; another person for whom You have the legal authority to represent, such as Your family member, friend, or client; Care Professional (“Care Pro”); other employee; or home care partner (collectively “You,” “Your”). This Privacy Policy also specifically applies to Your use and access to technology, applications, platforms, websites, content, products, and services we provide, or another party is contracted to provide on our behalf, (the "Services").

Subsidiaries, such as Home Instead, Inc. may utilize their own privacy policy.

This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Privacy Act (“HIPAA”), and its implementing regulations. Where subject to HIPAA, client health information is subject to the linked Notice of Privacy Practices.

Notice of Collection of Personal Information

We may collect the following categories of personal information:

Identifiers,
Customer personal information under California. Civ. Code § 1798.80(e),
Voluntarily provided information on personal characteristics of protected classes,
Commercial information & financial information,
Professional or employment-related information,
Sensitive personal information,
website/Application interaction or similar network activity,
Biometric Information,
Sensory data,
Health & Physical Characteristics, and
Inferences drawn from the above.

We collect this information so that we may:

Communicate with you
For administration of our business
Anonymize Your data for further internal and external use in a manner that does not identify You
Enhance security and preventing fraud or illegal activity
Perform our contractual duties and obligations or enter into an agreement
Verify and onboard home care partners on to the Honor care platform
Ensure compliance with legal obligations
Facilitate of online or platform interactions, (excluding use of web tracking technologies for targeted advertising),
Care coordination & customer service,
Provide educational resources/ learning management,
Identify and test business innovations,
Perform market research and analytics,
Advertise/market for employment, recruitment, products and Services

We may share identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity for purposes of targeted advertising. We do not sell or share client health information.

A more detailed description with examples is provided below in the Data We Collect, Data We Use, and Data Sharing sections.

We will retain and use Your Personal Information for as long as necessary to satisfy the purpose(s) for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements. Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.

Consumer Consent and Choices

Communications Consent

By utilizing our Services or providing information about You, You acknowledge and consent to the terms of this Privacy Policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority.

Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.

By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. You agree to be contacted by telephone call or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. Your consent is not a condition of purchase.

Communication Opt-Out or Unsubscribe

You may choose to have Your name taken off of our registration list, cease marketing communications or newsletters from us by using the opt-out option in any marketing emails or text messages You receive from us or contacting us using the information provided at the bottom of this Privacy Policy. We will respond to Your request within 10 days or as otherwise required by law.

Opting out of one form of communication does not mean You have opted out of other forms as well. For example, if You opt-out of receiving marketing emails, You may still receive marketing text messages if You have opted-in to receiving them. However, if You submit a general opt-out request on this Site, we will take action to unsubscribe You based upon the information provided. For example, if You provide Your name, email address, and phone number we will unsubscribe You from any lists linked to either Your name, email address or phone number.

Managing Web Tracking Technologies

Opt-in

When You first visit our site, a banner will appear and request consent to our use of online technologies that are not necessary for the function of our site. Our site only uses such optional online technologies when You consent by clicking “accept” in the banner.

If you accept the use of tracking technology, then a third party advertiser, search provider or ad network partner may collect information about Your activity on our website, on devices associated with You, and on third-party sites and applications to decide which ads You see both on our websites and applications and on third-party sites and applications.

You may opt-in or opt-out of the placement of optional technology going forwards, at any time, via our Cookie Preferences using this link:

Browser Settings

We generally use local storage ("LS") also referred to as HTML5 to store web content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity use local storage to collect and store information. Service providers that collect tracking data on our behalf may provide an opportunity for You to choose not to be tracked online. Various browsers may also offer their own management tools for removing HTML5 LS.

You may be able to adjust Your settings to limit ad tracking (e.g. “Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads'' or “Opt Out of Ads Personalization” on Android).

You may also be able to control receipt of targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers by visiting the Digital Advertising Alliance.

If You are seeing one of our advertisements on a third-party site, such as a social media site, You may also have the option to opt-out of such behavioral advertising through that site’s preference settings. Even if You opt out of personalized advertising, You may still see ads based on factors such as Your general location derived from Your IP address, Your browser type, and Your search terms.

Do Not Track

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting the user's activity that such activity will not be tracked. If You are using a “do not track” function on Your web browser, our cookie manager software will recognize this as an opt-out preference signal, such that we will not collect or share Personal Information we associate with your browser or device for purposes of targeted advertising.

You may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”).

You can also opt out of Google Analytics by installing Google’s opt-out browser add-on. We will process the GPC signal and Google’s opt-out browser add-on as a request to opt out. When we receive a do not track signal, your opt-out of web tracking technologies will be automatic.

Data We Collect

There are four main ways we collect personal information:

Data You Provide: Data You provide to Us;
Automated Data: Data collected through electronic/automated means; and
Partner Data: Data we are authorized to access and receive as an affiliate and partner; and
Other Data Sources: Data from other sources (such as our service providers or public sources).

We may combine data You provide to us with automated data and from other data sources. For example, we may receive automated data about those accessing our applications and combine that with data You provide to assess and improve the quality of our applications and Services.

Data You Provide

We collect data You provide to Us when You use our Services, including, but not limited to, communicating with Us over the telephone, through our mobile application(s), email, SMS, or complete a website form. This includes personal information, which identifies, (whether directly or indirectly), a particular individual.

Personal information You provide includes the types of data listed below (with examples).

1. Identifiers: name, postal address, phone number, or email address.

2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.

3. Personal characteristics of protected classes. Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.

4. Commercial information. Records of Services obtained or considered, client payor sources, benefits, and budgets.

5. Financial Information. Banking information, account numbers, routing numbers, revenue, payments,invoices, expenses relative to payment for Services or for employee payroll.

6. Professional or employment-related information. We may receive employment-related information from applicants and employees, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.

7. Sensitive Personal Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.

8. Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.

9. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.

10. Sensory data. Audio or similar information, such as recording phone calls for quality assurance.

11. Health & Physical Characteristics. medical conditions, diagnosis, care needs, and other similar information You provide. For Care Pros, we are required by law to collect certain medical information from you to provide home care in various states (e.g. tuberculosis tests or proof of vaccination). In the case of injury, illness, or potential disability we may also collect doctor’s notes and assessments, work status reports, or other medical information to clear you for work or arrange alternative work.

Automated Data

As is true of most websites and applications, we gather certain information about Your usage, patterns and location. We, our affiliates, and third-party vendors/service providers use online technologies such as cookies, flash cookies, pixels, tags, scripts, software development kits, application program interfaces, and web beacons.

These technologies may be used for many purposes including, for example, to:

Provide useful features to simplify Your experience when You return to or navigate our websites or applications (for example, remembering the contact information You entered so You don’t need to re-enter it)
Deliver relevant content and advertising based on Your preferences, usage patterns and location;
Monitor, evaluate, and optimize the use and operation of our websites and applications; and
Analyze traffic on our websites, applications and on the sites of third parties.

We may receive reports from our third-party vendors/service providers based on the use of these technologies that contain personal information, aggregate information, or anonymous information.

Personal information we may automatically collect includes the types of data listed below, and any inferences drawn from such data, (with examples).

1. Identifiers: online identifier, Internet Protocol (IP) address, or unique device identifiers.

2. Site interaction or similar network activity: interaction with our website or advertisements including logs and session data, and browser, network, device and operating system information. We also collect information about how You interact with our mobile applications, including how much time You spend in particular parts of the mobile applications. We may also track the site You visited prior to our website or what website You visit when You leave us.

3. Sensitive Personal Information–Geolocation data: Physical location, such as country or state from which You access the website or application(s).

Home Care Partner Data

We may require access to data of home care partners, including independently owned and Home Instead franchises, with whom we partner to provide Services. The Personal information we may receive includes the types of data listed below (with examples).

1. Identifiers. name, postal address, phone number, or email address.

3. Personal characteristics of protected classes of clients. Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.

4. Commercial information. Records of Services obtained or considered, client payor sources, benefits, and budgets.

5. Professional or employment-related information. We may receive employment-related information about partners and our applicants and employees, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.

6. Sensitive Personal Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.

7. Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information you may have so that we can connect clients with the appropriate resources and Services.

8. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Other Data Sources

We may also collect Personal Information from other sources (such as our service providers, including lead generation services, or public sources). Personal information we collect from other sources includes the types of data listed below (with examples).

1. Identifiers. name, postal address, phone number, or email address.

3. Personal characteristics of protected classes. Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.

4. Commercial information. Records of Services obtained or considered, client payor sources, benefits, and budgets.

5. Professional or employment-related information. We may receive employment-related information, for employees or applicants including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.

7. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.

8. Website/Application interaction or similar network activity–information You provide Us in website contact forms, applications or through any chat functionality administered by a third-party.

9. Sensory data. Audio or similar information, such as recording phone calls for quality assurance, administered by a third-party.

10. Health & Physical Characteristics. Applicant health screening results, client diagnosis or care needs, and other similar information.

11. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Data Use

For each type of data we collect, we may draw inferences from such data to create a profile, and use Personal Information for the business purposes set forth below:

1. Communicating with You–For example, we may use client personal information to respond to an online or phone inquiry, provide care updates, or other information related to our Services. We may also gather information to ensure the timely arrival and departure of Care Pros for the safety of care recipients, match client needs with Care Pros, optimize scheduling and Care Pro shift selection.

2. Verify and enhance quality of products and Services–For example, we may use data about application usage, caller inquiries, or perform surveys to continuously improve the experience of those using our Services.

3. Administration of our business–For example, we may use your personal information for customary business functions like obtaining legal and tax advice, obtaining payment, audits, the provision of care and Services, or for HR functions like applicant reviews, provision of offer letters, onboarding, payroll, reports, complaints, compensation reviews, and performance management.

4. Anonymizing Your data for further internal and external use in a manner that does not identify You–For example, we may aggregate and de-identify data for analysis of survey results and related insights.

5. Enhancing security and preventing fraud or illegal activity–For example, we may use personal information to verify your identity when you access our application or submit a data request.

6. Performing our contractual duties and obligations or entering into an agreement–For example, we may use personal information to enter into a client service agreement or agreement with a home care partner.

7. Verification and onboarding of home care partners on to the Honor care platform.

8. Ensuring compliance with legal obligations–For example, state licensure requirements may require us to maintain a client’s personal information, including details about care, or employee’s personal information to verify eligibility or completion of specific onboarding documentation.

9. Facilitation of online or platform interactions–For example, we may use web tracking technologies to improve your user experience on our websites or for our application’s self-service features, such as Care Pro clock-in.

10. Care Coordination & customer service–For example, we may use client information to coordinate with a local home care partner or third-party facility or health care provider for further support.

11. Providing educational resources/ learning management–For example, we may document employee orientations and training for the purposes of confirming compliance with our requirements, payroll or compliance with regulatory requirements.

12. Identifying and testing business innovations–For example, we may review application usage data to determine the success of a new application function.

13. Market research and analytics–For example, we may use Personal Information about employees to determine where we should focus future recruitment and advertising efforts.

14. Advertising/marketing for employment, recruitment, products and Services–For example, if you accept cookies on our website, we may use Personal Information to determine the effectiveness of our advertising.

We may use the information we collect about You in other ways, which we will tell You about at the time we collect it or before we begin using it for those other purposes. In such instances, You will have an opportunity to limit our uses at the time Your Personal Information is collected.

Data Sharing

We may disclose Personal Information to third-parties for business purposes as follows:

Home Care Partners and Subsidiaries.

We may share the following categories of Personal Information with our subsidiaries and home care partners: identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, financial information, professional or employment-related information, Website/Application interaction or similar network activity, and Health & Physical Characteristics.

We may disclose such Personal Information for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, verification and onboarding of home care partners on to the Honor care platform, ensuring compliance with legal obligations, facilitation of online or platform interactions, (excluding use of web tracking technologies for targeted advertising), care coordination & customer service, providing educational resources/ learning management, identifying and testing business innovations, or market research and analytics.

We may also share sensitive personal information concerning a consumer’s health, to the extent reasonably necessary to coordinate client care, perform our Services and verify and enhance the quality of our Services.

2. Clients and Third-Party Facilities.

We may disclose the following categories of Personal Information to our clients and facilities in which clients may reside: identifiers, customer personal information under California. Civ. Code § 1798.80(e), professional or employment-related information.

We may disclose such Personal Information for the purposes of: administration of our business, ensuring compliance with legal obligations, performing our contractual duties and obligations or entering into an agreement, and care coordination and customer service. For example, we may disclose a Care Pro’s identifying information needed to keep clients, their family members, and facilities in which clients may reside, informed of who will be providing care.

3. Third-Party Service Providers .

We may share all categories Personal Information collected with service providers, who have entered into an agreement to only process data on our behalf and not sell or share the data.

We may disclose Personal Information to service providers for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, verification and onboarding of home care partners on to the Honor care platform, ensuring compliance with legal obligations, facilitation of online or platform interactions, (excluding use of web tracking technologies for targeted advertising), care coordination & customer service, providing educational resources/ learning management, identifying and testing business innovations, or market research and analytics.

4. Legal and Administrative Authorities, Officials and Courts

We may disclose all categories of Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website or application users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena. We may also disclose Personal Information to public health authorities as required by law.

Such disclosures may include sensitive personal information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.

5. Business Transfers

We may disclose any category of Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction,or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy . Disclosures will only include Personal Information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.

We may disclose or share Personal Information to third-parties for commercial purposes as follows:

1. Third-Party Vendors

We may share the following categories of Personal Information with third-party vendors who do not process data solely on our behalf or utilize the data for targeted advertising: identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity.

We may disclose Personal Information to such vendors for the purposes of: communicating with You and advertising and marketing for employment, products, Services, and employment.

You have the ability to opt-out of such sharing, as outlined in the Consumer Consent and Choices section.

We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.

We do not use or disclose sensitive personal information of California residents for purposes other than those specified in regulation as not requiring the ability of consumers to limit use.

Links to Other Websites and Social Media

Our Site may offer links to websites that are not run by us but by third parties. If You visit one of these linked websites, Any information You give to those organizations is subject to their privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third parties. You understand and agree that by clicking on a link to a third party site You have left the Site, and this Privacy Policy is no longer in effect.

We may maintain profiles or accounts with various third-party social media providers, which may include Facebook, Twitter, Instagram, LinkedIn, YouTube, and Google+. While our collection, use, and disclosure of information obtained through the Social Media Properties and/or the Features is governed by this Privacy Policy to the same extent as information gathered through the Site, the information third-party social media providers collect or access through Your use of the Social Media Properties is governed by such third-party’s privacy policy. We encourage You to review the social media provider’s privacy policy before interacting with a Social Media Property and/or Feature.

Security

In order to prevent unauthorized access or disclosure we have put in place reasonable security measures, including physical, electronic and managerial procedures to safeguard and secure Your Personal Information.

We use standard Transport Layer Security (TLS) certificates to secure pages used for inputting users' Personal Information. However, unless we expressly advise You otherwise, the functionality on our Site does not provide a means for completely secure and private communications between us. Due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties.

If You believe that the Personal Information You have provided us has been compromised, or if You become aware of a potential security vulnerability in our Platform, please contact us using the contact Information provided below.

International Service Users

Our website and applications are hosted in the United States. They are not currently intended for users residing or located in other countries, including those within Canada or the European Economic Area. Please be aware that as a user of our Services Your personal information may be transferred to and maintained on servers or databases located outside Your state, province or country and that such information may be processed and stored in the United States. By providing Your personal information, You confirm Your consent to having such personal data hosted and accessed in the United States.

To the extent that We collect and access data regarding individuals outside of the United States via our affiliates and subsidiaries, we will act in accordance with their applicable Privacy Policy(ies) under which the data was collected.

Guidelines for Children

We do not specifically collect information about children nor market our products or Services to children. We have no reason to believe that the Site will attract children, or that children will access the Site or provide Personal Information.

State-Specific Data Privacy Rights

Certain states provide residents with privacy rights. Such rights are not absolute and in certain cases are subject to conditions or limitations as specified in your state’s privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under applicable state privacy law.

Nevada Resident Privacy Rights

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell Your personal information to third parties as defined in Nevada law, and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.

Virginia Resident Privacy Rights

1. Right to Access

You have the right to confirm whether we are processing your personal data and to access your personal data.

2. Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.

3. Right to Delete

You have the right to delete personal data provided by or obtained about you.

4. Right to Portability

You have the right to obtain a portable copy of the personal data that you provided to us.

5. Right to Opt-Out

You have the right to opt-out of targeted advertising (as defined under Virginia law ). We do not sell data as defined under Virginia law.

California Resident Privacy Rights

These rights are not absolute and in certain cases are subject to conditions or limitations as specified in California privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under California privacy law.

1. Right to Know

You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

2. Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

3. Right to Delete

You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

4. Right to Portability

You have the right to obtain a portable copy of the personal data that you provided to us.

5. Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law). However, Honor does not sell or share its clients’ health information. Honor also does not exchange Your data for for financial gain and has not done so in the past 12 months. We do not do not knowingly sell any personal information of children under age .

California privacy law does not apply to data protected under certain federal and state laws. For example, it does not apply to:

HIPAA protected health information collected by a covered entity or business associate;
Data of franchisees that are Covered Entities subject to HIPAA, to the extent the entity maintains the information in the same manners as protected health information;
Receipt and use of consumer reports (i.e. background checks) by an employer in accordance with the Fair Credit Reporting Act.

California privacy law also has a limited application to financial data subject to the Gramm-Leach-Bliley Act or state motor vehicle records subject to the Driver’s Privacy Protection Act of 1994.

Exercising State-Specific Privacy Rights

Request Form

To exercise your state-specific privacy rights, you may submit an online Privacy Request Form or call us as indicated below in the “Contact Us” section.

You may use the same form to appeal our decision regarding a request related to your rights under Virginia law, if applicable.

To submit a request to opt out of the sale or sharing of your personal information, you may click on the link “Do Not Sell or Share My Personal Information” on the footer of our websites. In the alternative, you may choose to enable online a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out as outlined in the section above.

Verification Process

To protect Your privacy, we will verify Your identity prior to acting on a request to produce, delete or correct data. The request form will require some initial contact information that we will compare against our records.

Upon submission of the request form You will be required to confirm Your request via email. You may receive an email from “On Behalf of Our Privacy Team” to which You must respond in order to verify Your identity and access our response(s).

If You request disclosure of specific pieces of personal information, we may take additional steps as permitted or required by law. For example, we may call You to verify Your request, in addition to matching at least three pieces of personal information You provide with information we maintain, and require a signed declaration, under penalty of perjury, that You are requesting Your own personal information.

Please note that state law may prohibit us from disclosing highly sensitive information in response to a request, including Your: social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, inform You if we have collected such information and identify the type of information with sufficient particularity.

If an authorized agent is submitting on Your behalf, we will require submission of either 1) a written authorization, signed by You, that authorizes that agent to make the specific request on Your behalf; or 2) other valid legal authorization.

Any personal information collected from You in connection with verification of Your request will be used solely for the purposes of verification.

Contact Information

If You have any questions about this Privacy Policy, the practices of the Site, or Your dealings with the Site, please contact us via the following methods:

Honor Technology, Inc.

Attn: Privacy Team
13323 California Street
Omaha, NE 68154
Privacy Request Form (linked)

Toll-free: 1.855.969.6345

We will not retaliate against any person for filing a privacy complaint. Your privacy and confidence in our abilities is of utmost importance to us.

Policy Updates

This Privacy Policy may change from time to time. This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the “effective date” to show the date from which the new policy will apply. We may also contact You directly where we deem appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately. We encourage You to check here regularly for the most up-to-date version.