PRIVACY POLICY

Cookies. Cookies are pieces of information stored directly on a computer or mobile application you are using. We or our service providers may place cookies, or similar files, on your device, including for security purposes, to facilitate navigation, and to personalize your experience while using the Website Cookies allow us to collect technical and navigational information, such as browser type, time spent on a website or mobile application, and pages visited. Cookies allow us to select which advertisements or offers are most likely to appeal to you and display them to you. We may also use cookies in online advertising to track responses and may use cookies or other files to track your use of other websites. Cookies and other technologies provide us the capability to monitor the use of the Website so we can continually improve the design and functionality to better serve you.

If you do not accept these cookies, you may experience some inconvenience in your use of some online options. We use cookies to display information more effectively to you and to gather data about the usage of the Website.

At times, we may also use other technologies to capture customer specific data to help understand how customers use the Website and to assist us with resolving customers’ questions regarding the use of the Website.

Do-Not-Track Signals. Many web browsers possess a do-not-track feature that lets your browser tell websites you visit that you do not want to have your online activities tracked. At this time, the Website does not respond to browser do-not-track signals.

Security. To protect your personal information from unauthorized access, we use security and safeguarding measures that comply with federal and state law. These measures include but are not limited to computer and electronic safeguards and secured files and buildings. However, you acknowledge that no security measure or modality of data transmission over the Internet can be guaranteed to be 100% secure. You should not expect that any personal information provided to us through the Website is free from the risk posed by unauthorized access.

If you are visiting the Website, your Internet session should be encrypted if your security-enabled browser is connected using the Secure Hypertext Transport Protocol. URL strings beginning with “HTTPS://” instead of the usual “HTTP://” indicate that the secure protocol is in effect. Your internet browser may also show an icon indicating that the Website is considered secure.

Minors. You must be 18 years of age or older to register as an account user and receive services through the Website. The Website is not directed at people under 18 years of age and we do not knowingly collect any information about such persons.

Changing Your Information. If you would like to review and request changes to the personally identifiable information that we use as part of servicing your loan, please contact your loan servicer directly. If you would like to review and request changes to the personally identifiable information that you have provided to us in your interactions with the LKV Realty website, please reach out to hello@lkvrealty.com.

Call Monitoring. You consent to the recording and monitoring of any call for quality assurance, training, risk management, collection purposes, or any other legitimate purpose, that you place to us (or our service providers) or that we (or our service providers) place to you.

Consent to Receive Email Communications. You consent to receiving emails at any email address you provide to us, including marketing-related messages. You may opt out of receiving marketing emails by utilizing the “unsubscribe” functionality preferences included in those emails.

State Privacy Disclosures. Some states provide certain rights concerning your personal information, unless an exception applies. These exceptions include information subject to federal privacy laws, specifically the federal Gramm-Leach-Bliley Act (“GLBA”) and Fair Credit Reporting Act (“FCRA”), or entities that are subject to the GLBA. In addition to these exceptions, state privacy laws do not consider information to be personal information if it cannot be reasonably linked to any consumer or household. The information that LKV Realty or its affiliates collect, uses, and shares may be exempt from state privacy laws as it is subject to the GLBA, subject to the FCRA, it is not deemed to be personal information, or LKV Realty is subject to the GLBA.

Additional Notice for California Residents

At LKV REALTY, LLC. (“LKV REALTY”), we are mindful of our responsibilities under the California Consumer Protection Act (“CCPA”) (Cal. Civ. Code § 1798.100 et seq.) regarding the collection, use, and disclosure of your personal information, both online and offline. This online notice applies only to California residents who are subject to the CCPA.

Most visitors to our website are either representatives of businesses seeking to interact with us as part of their jobs, or individuals engaging with us in connection with using our services. Please note that personal information we obtain, use, or is disclosed through these business-to-business interactions or pursuant to the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“CFIPA”) are exempt from the CCPA.

Personal Information of California Residents Collected in the Last Twelve Months

We collect information that identifies, relates to, describes, references, and is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have obtained the following categories of Personal Information on California residents within the last twelve months:

Identifiers such as real name, alias, postal address, email address, IP address, unique personal identifier, online identifier, account name, and phone number when you submit this information to create an account, request to learn more about our real estate offers and services or subscribe to email alerts.

As applicable, the following categories of protected classification characteristics under California or federal law: date of birth/age (40 years or older), gender, race, color, national origin, citizenship, or marital status, if you provide it to us.

Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, and information on your interaction with our websites or applications when you choose to visit and interact with our websites or applications.

As applicable, audio information such as recordings of when you may have called into our customer contact line; visual images from security cameras in our branch offices; and electronic information in the form of Internet or other electronic network activity information, as described above.

For each of the above categories, most of the Personal Information we have obtained was provided by you as part of your enrollment in our home rewards programs or request for more information on real estate services and offers.

We use commercially reasonable security measures to protect the information we have obtained, in accordance with federal and state regulations. Please visit our Privacy Policy for more information about the security measures to maintain information.

Please note that Personal Information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information; and
• Information exempted from the CCPA’s scope, including without limitation, the GLBA, the Fair Credit Reporting Act (FCRA), California Financial Information Privacy Act (CFIPA), the Driver’s Privacy Protection Act of 1994, and certain information associated with business-to-business transactions.

Our Use of Personal Information for Business Purposes in the Last Twelve Months

• We use the Personal Information we obtain, identified in each of the above categories, for the business purposes listed but not limited to the below:
• Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf
• Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same
• Debugging to identify and repair errors in our systems;
• Providing services on our behalf or on behalf of another, including maintaining accounts, providing customer service, fulfilling transactions, verifying identity information, and other services;
• Conducting internal research to develop and demonstrate technology;
• Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
• Preparing statistics and performing analysis to support our operations;
• Conducting surveys regarding our products, services, and client satisfaction; and
• Receiving and responding to inquiries.

Disclosures of Personal Information for Business Purposes

LKV REALTY does not share any information about you or your company to unaffiliated third parties, except as necessary to participate in the Lakeview Home Rewards Program and as permitted by law. Within the last twelve months, we have disclosed Personal Information identified in the Categories listed above only (i) at your express request; (ii) as part of an exempt business-to-business commercial transaction; (iii) in connection with providing you a real estate service or product for personal, family, or household, pursuant to the GLBA; or (iv) to our service providers for the business purpose(s) described above.

No Sales of Personal Information

We do not sell Personal Information within the meaning of the CCPA nor do we plan to sell Personal Information. If that changes, we will let you know in advance and provide you with information so that you may understand and exercise your right to opt-out of the future sale of your Personal Information.

Please note that we do not collect, use, sell or disclose Personal Information of individuals we know to be under the age of 18 to business partners or third parties.

Privacy Rights and Choices for California Residents

If you are a California resident, the CCPA provides you with certain rights related to your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

As discussed above, the CCPA does not apply to all or nearly all information we obtain, use, or share as part of our role as a real estate brokerage or resulting from certain business-to-business transactions. We will, however, continue to evaluate our business-to-business activities and update our Privacy Policy consistent with California laws and regulations, where applicable.

Access to Personal Information and Data Portability

You have the right to know what Personal Information we have obtained and disclosed about you for a business purpose in the last twelve months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following:

• The categories of Personal Information we collected about you;
• The categories of sources from which the Personal Information was collected;
• Our business or commercial purpose for collecting that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific pieces of Personal Information we collected about you (or portability request); and
• If we disclosed your Personal Information for a business purpose, a disclosure identifying the categories of Personal Information that each category of recipient obtained.
• We are not required to comply with a verifiable consumer request for access or data portability twice within a 12-month period.

Deletion Request

You have the right to request that we delete (and direct our service providers to delete) Personal Information we collected about you and retained, subject to certain exceptions.

• We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• complete the transaction for which we collected the Personal Information,
• provide a good or service that you requested,
• take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• debug products to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement,
• if you previously provided informed consent;
• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• comply with a legal obligation; or
• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt-out of Sale of Personal Information

The CCPA provides you with the right to direct us to not sell your Personal Information. However, as discussed above, we do not engage in the sale of Personal Information as contemplated by the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.

Exercising Your CCPA Rights

To exercise one or more of the above rights, you or someone you authorize, may submit a request by:

Writing us at LKV REALTY. Compliance Department, 4425 Ponce De Leon Boulevard, 4th Floor, Coral Gables, FL 33146 or email at privacy@lkvrealty.com. Reminder: please include the statement “Attention: California Privacy Rights Request” in the subject line of your email or within the body of your written request, as well as your name, email address, phone number, property address, and your account number. We may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.

However, as discussed above, the CCPA does not apply to all or nearly all information we obtain, use, or share as part of our role as a real estate brokerage or through certain business-to-business transactions, and we will not include any of that information in responding to your request.

Please note that we are not responsible for notices that are not labelled or sent properly, or that do not have complete information. If applicable, we will provide you with information on how to submit the request or remedy any deficiencies with the request. Responses to your CCPA request will be delivered in the same manner that we received it.

Verifiable Request

As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. You must provide us with enough information to allow us to reasonably verify you are the person about whom we collected Personal Information, or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Please include the statement “Attention: California Privacy Rights Request” in the body of your written request, as well as your name, email address, phone number, property address, and Community account number. We may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.

Agent Authorization and Disability Access

You may designate an authorized agent to make a CCPA request for personal information on your behalf. To designate an authorized agent to act on your behalf, you must provide the agent with written permission to do so and provide proof of your identity. Written permission may include a power of attorney sufficient under California Probate Code §§ 4121 to 4130.

You may also make a verifiable consumer request on behalf of your minor child, but you must also provide proof that you are that child’s parent or legal guardian.

Other California Privacy Rights

California “Shine the Light” Law (Civil Code Section § 1798.83)

Under the Shine the Light Law, a California resident may ask us to refrain from sharing your Personal Information with third parties for their direct marketing purposes. Please know that we do not share Personal Information of California residents with third parties for their marketing purposes.

California Do Not Track Disclosure

Our website and applications are not designed to respond to “Do Not Track” requests from browsers.

Contact Information Regarding this California Notice

You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law by writing to us at LKV REALTY. Compliance Department, 4425 Ponce De Leon Boulevard, 4th Floor, Coral Gables, FL 33146 or email at privacy@lkvrealty.com. Reminder: please include the statement “Attention: California Privacy Rights Request” in the body of your written request, as well as your name, email address, phone number, property address, and your account number. Again, we may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.