PRIVACY POLICY

Effective Date: January 1, 2025

1. Introduction

Open Sales, LLC and its subsidiaries and affiliates (“Open Sales,” “we,” “us,” “our”) are committed to building and maintaining a relationship of trust with you. This Privacy Policy (“Policy”) outlines how we collect, use, and disclose your Personal Information (as defined below) and the rights you may have regarding such information. It applies to Personal Information we collect through our website(s), microsite(s), mobile website(s), and mobile applications (collectively, “Sites”) as well as Personal Information we collect from you or third parties through any other means in order to provide our services or conduct other business activities (collectively, “Services”).

This Privacy Policy is part of our Terms of Use for our Sites. Please read this Privacy Policy carefully before using our Sites or Services. By accessing or using our Sites or Services, you agree to the collection and use of your information in accordance with this Policy and our Terms of Use.

If you are a California resident and have provided information to us as an employee, job applicant, contractor, or otherwise in connection with potential employment or engagement, or if you are a dependent, emergency contact, or beneficiary of such a person, the Privacy Practices Related to California Employees and Job Applicants section below describes our privacy practices with respect to such information.

2. Privacy Policy Changes

We may update this Privacy Policy from time to time. We encourage you to review it periodically for any revisions or updates. Unless otherwise stated, changes to this Policy will take effect immediately upon posting on our Sites. Your continued use of our Sites or Services after any changes indicates your acceptance of the updated Policy. If we make changes to this Policy that significantly affect how we use your Personal Information, we will provide you with notice before the changes take effect.

3. Conflict Between This Policy and Laws and Regulations

When federal, state, or local laws or regulations require a higher level of protection for your Personal Information, such laws or regulations take precedence over this Privacy Policy. In such cases, the specific requirements of those laws or regulations will apply.

4. Information We Collect

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including but not limited to:

• Identifiers: Such as name, mailing address, service address, email address, phone number, fax number, Open Sales account login credentials.

• Characteristics of protected classifications: Under California or federal law, such as age, marital status, gender, ethnicity, country of origin.

• Other demographic information: Such as the number and ages of children, languages spoken, property ownership status, number of persons living at the property, household income.

• Commercial information: Such as bank account number, payment card information, types of services subscribed to, service dates, customer type, account balance and status, information related to the financing of properties you own or that we service.

• Internet or other electronic network activity information: Such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications including device IDs, specifications, and operating systems.

• Geolocation data: Such as precise geolocation data (only as described below) and non-precise geographic location indicators from mobile devices, websites, and service addresses.

• Audio, electronic, visual, thermal, olfactory, or similar information: Such as call recordings, chat transcripts, and pictures or images of your properties.

• Professional/employment information: Such as employer, occupation.

• Education information: Such as education level.

• Inferences drawn from other Personal Information: Relating to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Personal Information as described in Cal. Civ. Code § 1798.80(e): To the extent collected under another category of Personal Information above.

Some of the Personal Information listed above may be considered Sensitive Personal Information under relevant privacy laws. This includes your Open Sales account login credentials, ethnicity, country of origin, and precise geolocation data. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.

The types of Personal Information we collect about you may vary based on how you use our Sites or Services and your relationship with us.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we automatically collect:

• The type of web browser you use

• The type of device you use

• Your operating system and version

• Your Internet Service Provider

• Your IP address

• The pages you view

• Referring and exit pages

• The date and time of your visit

• The number of clicks to, from, and within our Sites

• The duration of your visits to our Sites

If we can reasonably associate this information with you, directly or indirectly, we treat it as Personal Information under the categories of Identifiers or Internet or other electronic network information, as appropriate. If we cannot reasonably associate this information with you, we treat it as anonymous Usage Data.

Communication Recordings

We may record calls and retain the content of text messages, chat transcripts, emails, and other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

De-Identified Information

We may de-identify or anonymize Personal Information so that it is no longer capable of being associated with you and therefore is no longer Personal Information. We may use and disclose de-identified or anonymized information without restriction. We will not attempt to re-identify previously de-identified or anonymized information.

5. How We Collect Information

From You

We may ask you to provide us with Personal Information when you communicate with us online or offline, including through events, surveys, and marketing or promotional programs. Providing Personal Information is voluntary; however, if you choose not to provide the requested information, you may not be able to use some features of the Sites or Services, or we may not be able to fulfill your requested interaction. We may also capture Personal Information when you contact us by phone, email, or through other means.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokers, consumer reporting agencies, marketing agencies and partners, analytics firms, other consumers, and government agencies.

Cookies and Other Automated Tools

We and third parties use cookies (small text files placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels and clear gifs (collectively referred to herein as “cookies”) to track your interaction with our Sites and to improve your experience with our Sites and Services. This includes saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of our Sites may not work if you delete or disable cookies.

We use the following types of cookies:

• Strictly Necessary: These cookies are essential to operate the Sites and provide you with the services you have requested.

• Functional: These cookies enable certain features or non-essential functionality on our Sites. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Sites so we can provide you with a more personalized experience.

• Advertising Cookies: These cookies allow us and third parties to learn more about you, including your use of our Sites and other websites, and advertise products/services that might interest you as further indicated below.

• Analytics Cookies: These cookies help us and third parties understand how our Sites are working and who is visiting our Sites.

You can opt out of certain types of cookies by clicking the “Cookie Preferences” link in the footer on our Sites.

If you arrive at our Sites by “clicking through” from another website, certain information about you that you provided to that other website, such as the terms you searched that led you to our Sites, may be transmitted to us, and we may use it. You should review the Privacy Policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

6. Information Sharing and Disclosure

No Sale of Personal Information

We do not sell, rent, or lease your Personal Information to third parties. We may share your Personal Information only in the ways described in this Privacy Policy.

Interest-Based Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use by an Advertiser of information that they may collect from you. Advertisements may be shown via our Sites or on third-party websites.

If you do not want to receive interest-based advertising, you can visit the Digital Advertising Alliance (DAA) Consumer Choice Page or the Network Advertising Initiative Consumer Opt-Out Page. These websites allow you to opt out of participating interest-based advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, these organizations may offer browser extensions that help preserve the opt-out preferences you set. Please note that opt-outs only apply to interest-based advertising.

7. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your Personal Information:

• Access: You have the right to request copies of your Personal Information.

• Correction: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

• Deletion: You have the right to request that we delete your Personal Information, under certain conditions.

• Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.

• Object to Processing: You have the right to object to our processing of your Personal Information, under certain conditions.

• Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights, please contact us using the contact information provided below. We will consider and act upon any request in accordance with applicable data protection laws.

8. Data Security

We implement a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your Personal Information. These security measures include password-protected directories and databases to safeguard your information.

9. Children’s Privacy

Our Sites and Services are not intended for use by anyone under the age of 18 (“Children”). We do not knowingly collect Personal Information from Children. If you become aware that a Child has provided us with Personal Information, please contact us immediately.

10. International Data Transfers

Your information, including Personal Information, may be transferred to and maintained on servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

11. Contact Information

If you have any questions about this Privacy Policy, please contact us:

• Email: team@theopensales.com