1. What Information We Collect
In order to personalize, improve and continue to operate the Services, we may collect the following types of information from you:
1.1 Information You Provide to Us
You may provide information to us in various ways, such as when you request an offer, register for an account, request to enter one of our properties, make an inquiry to purchase a home, or send us comments, questions, or feedback. The information you provide us fits into two general categories:
1.1.1 Personal Information
For purposes of this Policy, “Personal Information” means data that can reasonably be used to identify or contact a specific person, such as first and last name, street address, phone number, or e-mail address. Driver’s license, state-issued identification, social security, bank account, and credit and debit card numbers are also included in this category of data. We generally use your Personal Information to provide you with the Services and Services-related communications (e.g., account verification, purchase confirmations and reminders, changes/updates to features of the Services, technical and security notices), as well as for identity verification and fraud avoidance purposes.
1.1.2 Non-Personal Information
For purposes of this Policy, “Non-Personal Information” means data that doesn’t reasonably allow someone to identify or contact a specific individual, such as occupation, language, zip code, and area code. It also includes de-identified or aggregate data. We generally use Non-Personal Information to better understand customer behavior and improve our Services.
1.1.3 Identity Verification Data
1.2 Information We Automatically Collect
1.2.1 Mobile Device Data
When you access the Services through a mobile device, including but not limited to when you use your mobile device to electronically unlock our properties, we may receive or collect and store information including but not limited to unique identification numbers associated with your device, your device type and manufacturer, your mobile carrier, subscriber status, payment method, your phone number, caller ID data, and, depending on your mobile device settings, your location information, including GPS coordinates (“Mobile Device Data”). We generally collect this information to provide the Services and to improve your experience with the Services, as well as for identity verification and fraud avoidance purposes. Types of Mobile Device Data that qualify as Personal Information under this Policy will be treated as such.
When you first launch our mobile application, you may be asked to consent to our application’s collection of location information. If you initially consent to our collection of location information and change your mind, you can revoke your consent by changing the preferences on your mobile device. Or, if you prefer, you can follow the standard uninstall process to remove our application from your device.
1.2.2 Usage Data
We may automatically collect certain types of usage information when you use our Services including but not limited to your browser type, operating system, Internet Protocol address, bandwidth speed, and information collected through cookies, web beacons, and other technologies (“Usage Data”). Some specific examples include:
- We may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer. Cookies uniquely identify your browser and allow us to help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), and allow us to track your usage of the Services over time.
- We may collect log file information from your browser or mobile device each time you access the Services. Log file information may include anonymous information such as your web request, Internet Protocol address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information.
- We may employ clear gifs to track the online usage patterns of users of our Services or which emails are opened and which links are clicked by recipients.
- We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Services.
We generally use Usage Data for user convenience, system administration, and statistical analysis, such as to: (i) remember information so that you will not have to re-enter it; (ii) provide customized content and information, including advertising; (iii) monitor the effectiveness of our Service; (iv) monitor aggregate metrics such as total number of visitors, traffic, and usage patterns; (v) diagnose or fix technology problems; and (vi) enhance our Services. Types of Usage Data that qualify as Personal Information will be treated as such under this Policy.
If desired, you can often delete or disable cookies through your web browser’s settings. Read more in Section 4.3 below.
2. Sharing of Your Personal Information
The only reasons that we may use and share your Personal Information are as follows:
- To create de-identified, anonymized, aggregated or similar non-personally identifiable data, which we may use for any lawful business purpose;
- In connection with a merger or other business combination or separation (including, but not limited to, a voluntary or involuntary change in our business or structure, or a reorganization, financing, change of control, sale of all or part of our stock or assets, spinoff, bankruptcy, dissolution, or any related to similar proceedings);
- To comply with applicable law;
- To respond to legal process or to regulatory authorities (such as pursuant to a subpoena; warrant; investigative demand from law enforcement, regulators or others; national or international security letters, etc.);
- To investigate, prevent, or take action regarding suspected or actual illegal activities (including fraud or stalking), security or technical issues;
- To respond to or participate in commercial disputes (e.g., lawsuits or investigations);
- To protect against fraud, claims, or other liability or harm to you, us, or others;
- To exercise or perform a legal, ethical, contractual or other right or obligation, such as to enforce our Terms of Service or other agreements, or to investigate potential violations thereof;
- For such lawful purposes as may be disclosed or evident at the time that you provide Personal Information to us (e.g., when you provide Personal Information in response to a survey, to sign up for an event, or to register for a newsletter); and
- To engage in routine business uses that an ordinary and reasonable person should expect in the context of the Services that we provide, the reasons for which we collect Personal Information, and/or the ways that similar businesses ordinarily operate, including, but not limited to, the following uses and disclosures:
- To technology providers, vendors, consultants, marketing, and other third party service providers who reasonably need the information to help us to operate and improve our business, including by providing analytic services, diagnosing technical problems, delivering communications, and/or protecting the security or integrity of the Services;
- To other companies in the Opendoor family which are owned by us or under common ownership, including to our subsidiaries, such as Opendoor Mortgage, LLC and Open Listings Co., or to our ultimate holding company and any of its subsidiaries;
- To business partners with whom we may jointly provide Services to you; and
- To persons appearing to have a lawful interest in the Personal Information (e.g., to an insurance company processing an insurance claim involving you).
3. How We Protect Your Information
We take our customers’ privacy very seriously, and use what we believe to be commercially reasonable physical, electronic, administrative, and procedural safeguards to preserve the integrity, confidentiality, and security of all Personal Information collected through the Services. However, no security measure, system, or control is infallible. Accordingly, WE DO NOT GUARANTEE OR WARRANT THAT PERSONAL INFORMATION COLLECTED THROUGH OR STORED ON THE SERVICES MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED. WE DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES OR DUTIES IN THAT REGARD.
It’s important to note that you have a major role in the security and privacy of your own Personal Information. For example, you should not provide us with Personal Information that we do not request. Additionally, you are responsible for controlling access to any personal computing device through which your Personal Information may be stored or accessed. You are also responsible for safeguarding any passwords or other log-in credentials that may be used to access your Personal Information. We recommend you ensure that you log out of any account when you are done using it.
Please remember to review the privacy settings and security policies of third party sites and services that you use, such as social networks. We are not responsible for the privacy or security measures of any third party.
In the event that the security of any Personal Information under our control is compromised, we will take reasonable steps to investigate and mitigate the situation, including, when and where appropriate, notifying those individuals whose Personal Information may have been compromised and taking other steps in accordance with applicable laws and regulations.
4. Your Choices about Your Information
4.1 Commercial Communications
As noted above, we may use your Personal Information to send you Services-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Services, technical and security notices). We also may provide notifications to you that are required by law. You may not opt out of such Services-related and legally-required communications. Subject to applicable law, we may provide such notifications to you via email, text message, hard copy, or through conspicuous posting on our Web Site or otherwise through the Services.
You can update your account information and profile settings at any time by logging into your account and changing your profile settings. If you have any questions about this process, contact us at firstname.lastname@example.org.
4.2 Marketing Communications
We may also send you marketing emails, including promotions and new product offerings. You can stop receiving marketing email communications from us by clicking on the “unsubscribe link” provided at the bottom of the communications. We make reasonable efforts to promptly process all unsubscribe requests.
If you opt in, we may also send marketing text messages to your mobile phone. Standard message and data rates may apply. You can opt-out of these messages by replying “STOP” to the sender or by emailing us at email@example.com.
4.3 Cookies and Interest Based Advertising
As discussed above in Section 1.2.2, we may collect information about your use of our Services through cookies, web beacons, and similar technologies, including to provide enhanced Services to you. However, if desired, you can change your web browser’s cookie settings, as discussed in these resources:
You can learn more about managing your preferences for ads online through resources made available by the Digital Advertising Alliance at http://www.aboutads.info or via the Network Advertising Initiative at http://optout.networkadvertising.org. You may also opt out of interest-based advertising on an iOS or Android device by selecting the “Limit Ad Tracking” option in the device’s settings.
Please note that if you decide to disable or delete cookies in your browser settings, you may not be able to use all of Opendoor’s Services. In particular, many personalized features may not function properly.
4.4 Do Not Track
Our Services do not respond to Do-Not-Track signals from your browser at this time.
5. Children’s Privacy
Opendoor does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as users of its Services. The Services are not directed at children under the age of 13. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child under 13, please contact us at firstname.lastname@example.org.
This Policy was last modified on January 23rd, 2019.
ANY RIGHTS NOT EXPRESSLY GRANTED HEREIN ARE RESERVED BY OPENDOOR.