CINC Systems, LLC Homeowner Portal Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

TABLE OF CONTENTS

• INTRODUCTION
• SOURCES OF PERSONAL INFORMATION
• HOW WE USE YOUR PERSONAL INFORMATION
• HOW WE DISCLOSE YOUR PERSONAL INFORMATION
• EXTERNAL SERVICES AND ANALYTICS
• YOUR CHOICES
• USER-GENERATED CONTENT
• ARTIFICIAL INTELLIGENCE
• MINORS
• SECURITY
• DATA RETENTION
• CALIFORNIA AND OTHER REGION SPECIFIC DISCLOSURES
• COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION
• Sources of Personal Information
• RIGHTS UNDER APPLICABLE STATE LAW
• CHANGES TO THIS POLICY
• CONTACT US

Introduction

This Homeowner Portal Privacy Policy ("Policy") describes how CINC Systems, LLC , a Georgia limited liability company ("CINC", "we", "us", "our"), collects, uses and discloses personal information about individuals who use homeowner portals or who otherwise interact with us via homeowner mobile applications (“you”), which we operate on behalf of our customers (community association management companies or individual community associations) (collectively, our "Services"), and the choices you can make regarding your privacy rights.

This Policy does not apply to:

• CINC’s corporate websites, social media accounts, and on any mobile applications or digital platforms where other privacy policies are posted.

• Information about our employees, contractors, agents, and job applicants.

• The practices of companies we do not own or control.

CINC is headquartered at 3055 Breckinridge Blvd., Suite 310, Duluth, Georgia 30096 in the United States ("U.S."). The Services are intended for use by residents of the United States, in accordance with applicable law, and the applicable Terms of Use.

Any personal information we collect about you may be transferred to other countries outside of the U.S. by us or our Service Providers (as defined below). If your information is transferred outside the U.S., we work to ensure that such transfers comply with applicable laws, including providing adequate protection through contractual clauses or other mechanisms. By using our Services, you acknowledge the terms of this Policy and the collection, use, maintenance, transfer to and processing of your personal information in the U.S. and in other countries or territories..

Sources Of Personal Information

a. Information You Provide.

Depending on how you interact with our Services, you may provide us, our agents, our customers, CINC's service providers, our licensees, and other third parties who perform services on our behalf under written contract (collectively, "Service Providers") with the following personal information:

• your name, email address(es), username, password, alias, unique identifier, signature, billing address(es), home address(es), phone number(s), financial account number(s) and other financial information, e.g., credit card and bank account numbers, gender, physical characteristics, and other registration information;
• information about your preferences;
• non-precise geolocation for Services based on information you provide;
  transaction-related information, such as your payment of fees, assessments, or penalties to your community association, if any, that you make through us or our Service Providers;
• information you otherwise provide us or our Service Providers, such as when you contact us for assistance; and
• other information related to your use of our Services.

You must maintain the confidentiality of your account access information and are responsible for controlling access to your account. If you ever use a public computer to visit your account, we strongly encourage you to log out at the conclusion of your session. CINC does not store your payment card information unless you choose to include it in your account.

b. Information Collected Automatically.

We and our Service Providers may automatically collect certain information when you use our Services, including by automatically receiving or collecting certain information, which may include your:

• browser or operating system;
• manner of connecting to the Internet, including your device type, and the name of your Internet provider or wireless carrier;
• Internet protocol ("IP") address;
• data relating to malfunctions or problems, if any, that may occur when you use our Services;
• log file information, including your referring and exit pages and URLs, number of clicks and how you interact with links on our Services, domain names, landing pages, pages viewed, and other similar information;
• non-precise geolocation based on IP address for other Services collected automatically such as through tracking technologies;
• browsing and purchasing behavior; and
• preferences.

c. Information From Other Sources.

We may also collect personal information about you from our affiliates that have shared management or ownership with us, as well as external sources, including our Service Providers, our customers, including applicable management companies and community associations, and other third parties that provide information to us.

HOW WE USE YOUR PERSONAL INFORMATION

We may use the personal information we collect for various purposes, including to:

• process and verify your registration, fulfill your request(s) for Services, and process your transactions;
• manage your account, including your payment information and preferences;
• improve our Services;
• fulfill other purposes disclosed to you at the time you provide us, our customers, or our Service Providers with your information or otherwise where we are legally permitted to do so;
• respond to your inquiries;
• provide you with Services updates, legal notices and other information regarding our Services;
• understand your non-precise geolocation based on IP address;
• keep our Services safe and secure, and to prevent and detect fraud, abuse, or other illegal activities;
• comply with our legal obligations, policies, and procedures including, without limitation, our agreements with applicable management companies, community associations and Service Providers; and
• administer and manage our Services, including content and layout, usage, troubleshooting, data analysis, testing, research, and for statistical and survey purposes.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information to:

• CINC affiliates. We may disclose your personal information to our affiliates who may have content of interest to you;
• Service Providers. We may disclose your personal information to our Service Providers who assist with the delivery of our Services and the performance of our business operations, such as hosting, payment processing, analytics, and maintaining the integrity of our Services;
• Management Companies and Community Associations. We may disclose your personal information to your management companies and community associations with whom we contract, and certain of such parties’ subcontractors;
• Government and law enforcement authorities. We may disclose your personal information as required or permitted by law, such as in response to a verified request, e.g., court order, search warrant, or subpoena, relating to a criminal investigation or alleged illegal activity, or any other activity that may expose us, you, or any other party to legal liability;
• Security and safety. Where permitted by applicable law, we may disclose your personal information for the purpose of protecting the rights, property, life, health, security, and safety of CINC, our Services, our users, or any other party. We may also disclose your personal information if we have a good faith belief that a crime has been or is being committed; and
• Business transactions. We may disclose your personal information in connection with, or during negotiations of, any proposed or actual business transaction, e.g., merger, purchase, sale, or any other type of business transaction regarding all or any portion of our assets, including transfer of all or any portion of our business to another party.

EXTERNAL SERVICES AND ANALYTICS

Please note that any links to external services are provided for your convenience only. Since this Policy does not apply to the practices of companies that we do not own or control, if you wish to learn more about the privacy practices of any external services or certain vendors or Service Providers, we encourage you to review their privacy policies directly.

• Analytics. We may use third party tools, such as Google Analytics, to help us analyze our performance, and to deliver Services to you.

YOUR CHOICES

When it comes to your personal information, you have options, and we want to make sure you are informed of your choices.

Access, Update, or Correct Your Information. If you have an account on our Services, you may access, update, and/or correct the information you provide to us at any time by accessing your account settings.

CINC may implement Google's Invisible reCAPTCHA technology on our Services in order to reduce spam and prevent abuse of our Services. Your use of the Invisible reCAPTCHA is subject to the Google Privacy Policy and Google Terms of Service.

USER-GENERATED CONTENT

Our Services may permit you to post or submit User Generated Content ("UGC") including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including personal information. If you choose to submit UGC to any public area of our Services, your UGC will be considered "public" and will be accessible by anyone with access to such public areas of our Services, including CINC. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, personal information included in UGC is not subject to our usage or sharing limitations, or other obligations, and may be used and shared by CINC and other parties. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the applicable Terms of Use.

ARTIFICIAL INTELLIGENCE

We may offer you the ability to interact with our interactive artificial intelligence (“AI”) chatbots (the “Chatbot”). By using the Chatbot, you are interacting with CINC’s Generative AI platform and not a live person, and you are subject to our Terms and Conditions and this Privacy Policy. Do not provide confidential or proprietary information when using the Chatbot. Use of the Chatbot is for general information only; please understand that information, decisions, or advice provided by the Chatbot or any materials retrieved therefrom, including those to any third party, have not been reviewed for content or accuracy. Please contact us as provided below with questions regarding the Chatbot or if you require further information with the subject line “AI Help”. Some technologies used on our Services allow us and our service providers to monitor and analyze how visitors use our Services to better understand user behavior and improve our Services. When you interact with us online, information related to your behavior may be collected by us and our service providers.

MINORS

Our Services are intended for homeowners and tenants that reside in communities that are managed by the community association management companies that engage us to provide the Services for the community associations that they manage. Our Services are not intended for children under the age of 18 and we do not knowingly collect personal information from children under the age of 18. If we become aware that we have obtained personal information from a child under the age of 18, we will delete such information in accordance with applicable law.

SECURITY

We take steps to help protect your personal information. We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through our Services. Additionally, we limit access to personal information to employees and authorized parties who need to access that information to operate, develop, or improve our Services. Although we use reasonable efforts to safeguard personal information, transmission via the Internet is not completely secure and we cannot guarantee the security of your personal information collected through our Services.

DATA RETENTION

To determine the appropriate retention period for personal information, we consider applicable legal requirements, 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 we process your personal information for, and whether we can achieve those purposes through other means. We will maintain certain types of personal information for a limited duration.

CALIFORNIA AND OTHER REGION SPECIFIC DISCLOSURES

The following states in the U.S. have enacted comprehensive consumer privacy laws (the “Applicable Laws”): California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia. If you reside in a state governed by Applicable Law, you may have certain rights regarding the processing of your personal information. For the purpose of this notice, Personal Information applies to "Personal Information" and "Personal Data" as defined by Applicable Laws.

This information supplements other sections of this Policy and provides additional information for residents of certain states in accordance with the requirements of Applicable Law. Information provided here details our Personal Information processing practices in the previous twelve months and our current Personal Information collection practices. This section should be viewed in conjunction with the other portions of this Policy. For example, we have described the Personal Information we collect, the sources from which we collect Personal Information, our purposes for that collection, and how we disclosed Personal Information in this Policy.

COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION

What Personal Information We Collect and Why We Collect It.

We collect the categories of Personal Information that are indicated in the chart below. Note that the specific pieces of Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed.

Sources of Personal Information

We collect Personal Information from:

• you;
• your devices and/or browsers;
• our affiliates;
• Service Providers;
• applicable community association management companies and/or community associations; and
• other external sources, including publicly available sources.

Categories of Recipients of Personal Information.

We may disclose each category of Personal Information and sensitive Personal Information, described herein, to these categories of recipients:

• our affiliates;
• Service Providers; and
• applicable management companies and/or community associations; and
• governmental and law enforcement authorities.

Selling and Sharing of Personal Information.

We do not sell and/or share with third parties for cross-context behavioral advertising.

RIGHTS UNDER APPLICABLE STATE LAW

Applicable Law give residents of certain states certain rights. As used in this section, the term "Personal Information" includes "Personal Data" as defined by Applicable Laws.

We collect personal information directly from you that you share with us through the Services and from your community association management company. To the extent that we act as a service provider or processor for your community association management company, when you submit requests related to your personal information, we forward your request to your community association management company and your community association management company will address your request according to their privacy policy. To the extent that we act as an independent business or controller, when you submit requests related to your personal information, we will respond to your request in accordance with Applicable Laws.

Subject to certain conditions and restrictions, which are set out in such Applicable Laws, you may have the following rights with regard to your Personal Information:

Right to Know Categories of Information (California Only).

California consumers have the right to request more information about the following:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• Our business or commercial purposes for collecting, selling, or sharing your Personal Information;
• The categories of third parties to which we disclosed your Personal Information;
• The categories of Personal Information we sold or shared about you and the categories of third parties to which each category of Personal Information was sold or shared; and
• The categories of Personal Information we disclosed about you for a business purpose and the categories of recipients to which it was disclosed.

Right to Access and Data Portability (California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia)

You have the right to confirm whether we are processing your Personal Information, to access your Personal Information, and to obtain a copy of your Personal Information in a portable format.

Right to Request Deletion of Personal Information (California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia)

You may request that we delete your Personal Information that we have collected directly from you on behalf of your community association management company as a service provider and processor and are currently maintaining on your community association management company’s behalf. We will forward your request to your community association management company and your requests will be processed according to your community association management company’s policies.

You may request that we delete your Personal Information that we have collected directly from you while acting as an independent business or controller and are currently maintaining. Please note, however, that we may have a legal basis for retaining certain Personal Information under the CCPA, despite your request. Requests of this nature may be made no more than twice in a twelve-month period.

Right to Know Third Parties (Oregon and Delaware Only)

Oregon and Delaware consumers may also request either a list of third parties or categories of third parties to which we disclosed Personal Information.

Right to Opt-out of the Sale and Sharing of Personal Information and Targeted Advertising (California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia)

We do not engage in sales, sharing or targeted advertising via tracking technologies.

Right to Correct Personal Information (California, Colorado, Connecticut, Delaware, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia Only)

You may request that we correct inaccuracies in your Personal Information that we maintain about you. We may request documentation from you in connection with your request.

Right to Limit Use of Your Sensitive Personal Information (California, Utah and Virginia Only)

We limit the use and disclosure of your sensitive Personal Information to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. You do not have the right to further limit our use of your sensitive Personal Information.

Right to Non-discrimination for the Exercise of Your Privacy Rights (California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia)

We will not discriminate against you if you choose to exercise any of the privacy rights described herein.

Right to Opt Out of Profiling (California, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas and Virginia)

You have the right to opt out of our processing of Personal Information for the purposes of profiling. We do not process Personal Information for the purposes of profiling, and as such this right is not applicable.

Right to Appeal (Colorado, Connecticut and Virginia Only)

If you are unsatisfied with our actions related to the exercise of one of your privacy rights described herein, you may appeal our decision using the contact email address below.

Exercise Privacy Rights.

You may submit Privacy Rights-related requests to CINC for CINC-controlled sites via email at compliance@cincsystems.com, or toll-free at 1-855-943-8246 ext. 2138.

If you submit privacy rights requests regarding Personal Information that we maintain about you on behalf of your community association management company as a service provider and processor, we will forward your request to your community association management company and your community association management company will process your request according to their policies.

Please note that, if you submit privacy requests regarding Personal Information that we maintain about you while acting as an independent business or controller, we may ask you for specific information to help us confirm your identity prior to processing your request. Please follow any instructions provided and promptly respond to any follow-up inquiries so that we may confirm your identity and respond to your request. If you ask that we give you specific pieces of Personal Information or that we delete or correct certain types of Personal Information, we may apply heightened verification standards, which require additional proof of your identity.

Only you, or someone you authorize to act for you, may make a request related to your Personal Information. If you designate an authorized agent to make a request for you, you may still need to verify your identity directly with us before your request can be processed.

If we decline to fulfill your privacy rights request, we will tell you why, unless we are not legally permitted to do so.

California Shine the Light.

California law permits customers in California to request certain details about how their Personal Information is shared with third parties, and in some cases our affiliates, if Personal Information is shared for those third parties' or our affiliates' own direct marketing purposes. We do not share Personal Information with third parties or our affiliates for those third parties' or affiliates' own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at compliance@CINCsystems.com or by mailing:

CINC Systems, LLC
3055 Breckinridge Blvd., Suite 310
Duluth, Georgia 30096
United States
Attention: Chief Administrative Officer

Any such request must include your name and "California Shine the Light Privacy Rights Request" in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code.

Please note that "Shine the Light" rights and CCPA rights are granted by different laws and must be exercised separately.

Exercise Applicable Law Rights.

Your Nevada Privacy Rights.

Under Nevada privacy law, Nevada residents may opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not "sell" covered information as "sale" is defined by such law, and we do not have plans to "sell" this information.

Changes To This Policy

From time to time, we may amend this Policy. If we amend this Policy, we will post an updated date at the top of the Policy. Your continued use of our Services after any update to this Policy will constitute your acceptance of the changes.

To the extent any provision of this Policy is found by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder of this Policy to be valid and enforceable.

Contact Us

If you have any questions or concerns about this Policy or if you wish to exercise your privacy rights, you may contact us:

By email:  compliance@CINCsystems.com

By mail:

CINC Systems, LLC
3055 Breckinridge Blvd., Suite 310
Duluth, Georgia 30096
United States
Attention: Chief Administrative Officer