PRIVACY POLICY
Effective Date and Last Revised: May 10, 2024
As used in this Privacy Policy, “Company,” “we,” “our,” and “us” refers to Trumark Companies, together with its affiliates, subsidiaries, divisions and brands.

Your privacy is very important to us. Accordingly, we have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data (“Processing”) when you use any Company website displaying or linking to this Privacy Policy (“Site”) and other services offered by us (“Services”), such as when you: subscribe to or engage with our newsletters or other electronic communications; interact with our social media pages; click on our ads through third party websites or media;  communicate with members of our organization or other features of our Services (including chat, email, text, phone, or generative AI features); visit our physical locations; sign up for contests or respond to surveys; and otherwise use our Services where we collect information from you with reference to this Privacy Policy.

This Privacy Policy does not apply to: 
Third party services, websites, applications, digital media (embedded or direct links), or other third-party materials or content that we may link to that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed. 

Workforce Members and Candidates. Our processing of the personal information of current or former workforce members and job applicants is not governed by this policy.

The processing of non-personal information that cannot be linked to an identifiable or identified individual, including, for example, non-identifying aggregate information. We may process this data for any legitimate business purpose.

We may update this Privacy Policy from time to time. We encourage you to review the Privacy Policy whenever you access our Site and Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

OUR COMMITTMENT TO PRIVACY
Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively referred to herein as (“CCPA”), and the Colorado Privacy Act (“CPA”), if you are a California or Colorado resident, you may have certain additional rights. Please visit the California and Colorado Privacy Rights Page at https://trumarkhomes.com/ccpa/ for a description of those rights and how California and Colorado residents may exercise them.

Consumer Privacy Requests and Communication
You can review, correct, update, or change your Personal Information, as defined in Section 2, below, or opt out of receiving certain e-mails by e-mailing us at privacy@trumarkhomes.com. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as certain informational e-mails. Please note that the Company does not sell to third parties the Personal Information it collects from your use of the Site or from the Services. However, pursuant to applicable law, you may email us at privacy@trumarkhomes.com to request that your information not be sold in the future.
If you have other questions or concerns regarding this Privacy Policy, please e-mail us at privacy@trumarkhomes.com or call us at 1-800-888-4444. We will do our best to respond promptly to you.

Global Privacy Controls
To utilize GPC to manage your privacy preferences, including opting out of the sale or sharing of your personal information, you will first need to enable this feature in your web browser or through certain privacy-focused browser extensions. Many leading browsers and extensions support GPC, allowing you to send a clear signal to websites, including ours, about your privacy preferences with minimal effort. Once enabled, GPC automatically communicates your 'Do Not Sell or Share My Personal Information' preference to all participating websites you visit, streamlining your privacy controls across the web. For detailed instructions on how to activate GPC in your browser or through an extension, and to learn more about how GPC works, please visit the Global Privacy Control website at https://globalprivacycontrol.org. We are committed to recognizing and respecting your GPC signals as part of our dedication to your privacy rights.

2. INFORMATION WE COLLECT
Throughout the course of business, we collect certain personal information from you for the purposes of providing our services, improve our customer offerings, creating and improving internal operations and business practices.  Such personal information may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). 

The means for collection of such Personal Information may be directly from you, through your interactions with our Sites or Services, as well as through automatic collection means (such as information that is automatically sent from your device when navigating to our Sites) and such information may be combined with other information that we collect about you.  Please note that we do utilize third parties to assist with such collection, wherein your personal information is provided to third party service providers for processing on our behalf to provide the functionality of the Sites and Services that we provide you.

Personal Information that we collect falls generally within the following categories.

Personal Identifiers
We collect information that personally identifies you, such as your name, address, phone number, mobile phone number, e-mail, and other personally identifiable information that you choose to provide us with (“Personal Identifiers”). You may be asked to provide us with Personal Identifiers when you register with the Site or use any of our Services, and at other times. We may receive Personal Identifiers, including your name, e-mail address, and social network ID from social media websites and services if you chose to enable features such as logging in with your social media or third party account information, for example, login with Facebook, Google, or LinkedIn features to facilitate the ease of your login experience.

Additionally, for the purpose of enhancing our services and your user experience, we collect detailed information regarding your purchasing behavior, such as purchase history and customer profiling, as well as technical information including IP address, browser type, browsing history, device type, and interactions with our web pages. This information allows us to tailor our offerings and understand how our services are used, aiding in our ongoing improvement efforts.

We do note that collection of information such as IP addresses, browser type, and device type, are done so automatically when someone navigates to a website, the action of going to a specific domain name customarily involves the transmission of information in what is referred to as an HTTP header. These headers typically contain a set of information, which often include things such as an Internet Protocol (IP) address from which the request originates, the type of browser software being utilized by the visitor, the classification of the device initiating the request, among other data elements. This information is sent as part of a request to the server where the website you are visiting is located.

Upon receipt of the request by a website’s server, the server, records various details of the transaction (i.e. the information sent above) in something called “logs” on the server. 
When visiting our Sites or using our Services online, we use such logs to analyzing traffic to our websites, monitor for security breaches, optimize our website performance, and improve our Sites and Service offerings for a better experience for our customers.

Third Party Services
The Site and Services may link to other websites and services that collect Personal Information such as financial information to provide you with services, such as mortgage quotes. [These websites and services are operated by other companies or by affiliates of Company that are not governed by this Privacy Policy. To learn how your information will be used by these companies, please consult the applicable privacy policy when providing your information on that website.

When you search for homes on our Site or in connection with our Services, where we provide buttons or links to “Pre-Qualify” with certain third-party lenders, such links will navigate you away from our Site and to a website that is not owned or controlled by Trumark Companies. Such third-party lender websites are governed by separate privacy policies, and you should review such third party privacy policies when interacting with such third party lenders. 

Employment Information
You may provide us with requested information to apply for a job listed on the Site. Employment Information may include Personal Information through the collection of materials such as resumes, cover letters, letters of recommendation, references, employment history, salary history, and educational history.

Cookies and Anonymous Identifiers
We may use cookies (a small text file placed on your computer to identify your computer and web browser) and anonymous identifiers (a random string of characters that is used for the same purposes as a cookie) to analyze the use of and improve the Site and Services, and as further described in the “Advertising and Online Tracking” section of this Privacy Policy. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent; however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

Google Analytics and Looker Studio
We use Google Analytics and Google Looker Studio to collect usage data, to analyze how users use the Site, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit the following URL for a browser plugin for opting out of the use of Personal Information in connection with google analytics services: 
https://tools.google.com/dlpage/gaoptout/.  

Alphabet (the owner of Google and associated services like Google Analytics, Google Looker, and Nest) has recommended visiting the following URL to opt out of targeted advertising services based on your browsing history:
https://myadcenter.google.com/personalizationoff?sasb=true&ref=ad-settings.

For information relating to Google Looker Studio and its privacy practices you may find the applicable privacy policy at:
https://services.google.com/fh/files/misc/looker_com_trust_center_privacy_policy_privacy_sep_2020.pdf.

Facebook Pixel
Our Site uses the Facebook Pixel which may be used to understand how visitors interact with our Site and for remarketing and targeted advertising purposes.  You may review information on the privacy practices of Facebook Pixel at: 
https://www.facebook.com/privacy/policy

We may also share the data we collect on our site with third parties that assist us in determining how to contact you to provide you further information about our Company and its products.

Text Messages, Website Submissions and Emails
We may communicate information regarding our homes and other products and services through email, phone calls and text messages from time to time.  We collect information that is disclosed by you when you interact with us through such communication methods. 

3.   HOW WE USE INFORMATION AND WHEN WE MAY SHARE AND DISCLOSE INFORMATION GENERALLY
We may use your Personal Information for internal purposes, such as to provide you with the Site and Services, to improve the Site and Services, to notify you of new products or services, and to otherwise communicate with you about our Company to personalize your experience by tailoring recommendations and offers to your interests. We may also use your Personal Information to provide more relevant search results from the search functions of the Site and the Services. Except as otherwise explained in this Privacy Policy, we will not disclose your Personal Information to third parties, other than our Service Providers (as defined below), without your consent. However, we may disclose to third parties, certain usage data regarding the Site and Services.
We may also share Personal Information with: affiliates of our Company such as companies under common control and individuals having a fiduciary capacity within our business(s); businesses that we work with in connection with the Site and Services such as providers of promotional social media campaigns; certain service providers or entities with whom we have a relationship to provide business operations services and support to the operations of our Company; providers of advertising, direct marketing, and lead generation, affiliate marketing programs, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers; certain advisors such as lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent fraud or abuse, and defend against attacks; parties to whom we are required by law to provide information, such as pursuant to a subpoena or a court order; individuals or entities involved in the event of a business transaction that we are involved in, such as the sale, merger, consolidation, acquisition, change in control, transfer of assets, investments, bankruptcy, or reorganization; and any party when you authorize the sharing of such information.

Additional information regarding certain foregoing types of sharing is further detailed in the below sections.

We may use your Employment Information to contact you about and evaluate you for jobs posted by Company. We may disclose or transfer Employment Information to employees and consultants involved in the recruiting and hiring of job applicants.

4.   SERVICE PROVIDERS

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf.

Trumark Homes partners with various third-party software providers to enhance our services, optimize operations, and improve user experience. These software providers assist us with services such as customer relationship management, data analytics, project management, and communication tools. Such providers may include but are not limited to: Newstar Enterprise, DataRails, Lasso ECI, Homefiniti. We only share personal information with software providers to the extent necessary for them to perform their functions and require that they protect this information in line with industry-standard data protection and security practices.

5.   ADVERTISING AND ONLINE TRACKING

We may collect certain anonymous information when you visit the Site or use the Services. We also may allow third-party companies to serve our ads to you after you visit the Site or use the Services, and these third parties may collect information about your online activities over time and across different internet websites or online services. These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about our goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.

We may from time to time provide your email address (either in actual or encrypted format) to resources such as Google and Facebook (“Online Resources”) for marketing purposes. The Online Resources then will use your email address to show you Company advertisements when you are on the Facebook and Google platforms or services. Based on your use of an Online Resource, that Online Resource will send Company advertisements to others who use it and who have home shopping characteristics similar to yours. The Online Resources may provide you with the ability to opt out of or limit the display of these ads and certain uses of your information. For information on how to do so, please check your account settings on and the information provided by these services.

6.   OTHER TRANSFERS

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with our Company. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.

7.   COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

8.   BE CAREFUL WHEN YOU SHARE INFORMATION WITH OTHERS
Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

9.   SECURITY
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

10.   LINKS
Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

11.   DATA RETENTION
We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR CALIFORNIA AND COLORADO PRIVACY RIGHTS
California and Colorado residents who provide certain types of Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year (for California residents) or twice a calendar year (for Colorado residents) information about certain types of personal information we shared, if any, with other businesses for their own direct marketing uses. To obtain this information, please send an email message to privacy@trumarkhomes.com with “Request for California or Colorado Privacy Information” on the subject line and in the body of your message.
To confirm whether we process the consumer’s personal information and to access such personal information;
To correct inaccuracies in the consumer’s personal information;
To delete and erase personal information in our possession that was provided by or obtained about the consumer;
To obtain a copy of the consumer’s personal data that the consumer previously provided to the us in a commonly used and machine readable format; and
To opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or significant effects concerning the consumer.
[For further information regarding information for California and Colorado please see our California and Colorado specific privacy notice page found at: https://trumarkhomes.com/ccpa/]
The Site and Services are intended for users who are 16 years old or older. We do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records. California users under the age of 16 may request the removal of their content or information publicly posted on the Site or Services by e-mailing us at privacy@trumarkhomes.com. 

PROCESSING IN THE UNITED STATES
Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

Please print a copy of this privacy policy for your records and check this page frequently for any changes.