A. Framework’s Respect for Privacy
B. Your Consent
C. The Information Framework Collects
Anonymous Electronic Information. In general, you can browse Framework’s websites without telling Framework who you are or revealing any personal information about yourself. However, Framework collects your IP address, which you necessarily disclose when you visit a Framework website. Your IP address is a number that is used by computers and mobile devices connected to the Internet to identify your computer or device so that data (such as the web pages you request) can be sent to you.
Home Buying and Home Ownership. Use of the Services may be made in connection with an individual’s efforts to purchase a home and/or maintain an existing home. In order to use the products and services available through the Services, which may include taking educational courses about buying a home, you will be required to provide information that lets Framework know the specifics of who you are, and may include, without limitation, your first and last name; mailing address; email address; date of birth; last four digits of your social security number; telephone and facsimile numbers; credit card number, debit card
information, or other payment processing information; and other personal identifying information. You may also be required to provide information about your race, gender, education, income, and various other demographic items or topics related to your personal life. If you take an educational course, the details about your use of the course will be collected and retained by Framework, and will include, without limitation, the means by which you paid for the course, coupon information, when you enrolled, when you took it, completion information, and your exam results. In addition, after you have completed a course, you will be required to take an exit survey or provide feedback about the course, the results of which will also be collected and retained by Framework. If you use the Services to store information about your existing home, such as information about repairs, improvements, expenses and other information, your disclosure of this information to Framework is optional, and Framework only collects the information you provide.
Framework’s guidance services are part of a platform available for you to communicate with live homebuying or homeowner guides (“Home Experts”) to answer your questions and provide you with certain additional information concerning your homebuying and homeownership journey. Home Experts may be provided by Framework’s third-party guidance service providers and, if you participate in these services, you are providing information to the Home Experts. If you use Framework’s guidance services, Framework collects information about such use, including communications with your Home Expert, and other information submitted by you or your Home Expert.
Other Activities. When you engage in certain activities through the Services, such as registering as a user of the Services; sending Framework a message using the Services; seeking guidance services; ordering a product or service; registering for an event, entering a contest or sweepstakes; participating in social media activities involving things such as Facebook, Twitter, YouTube, or Foursquare, whether through use of the Services or the related social media platforms; participating in studies or research activities; filling out a survey; or sending feedback or product reviews; Framework may ask you to provide personal information. If you choose to share any personal information with Framework, you will see that the amount and type of personal information Framework requests depends on how you use the Services. It is completely optional for you to engage in these activities. Depending upon the activity, some of the information Framework asks you to provide is identified as mandatory and some is voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. In addition, there may be instances where Framework will ask you for your permission to use certain of your personal information for various purposes, which might include, without limitation, to evaluate existing products and services; to assist in the development of new products or services; research; to identify trends and changes in relevant industries; and to file reports with various government agencies, associations, or other organizations. You may decline the request to do so.
D. The Way Framework Uses Personal and Other Information
Framework uses personal information to provide and improve its products and services, including the Services, for purposes in its legitimate interests, and for compliance with applicable laws. Framework processes personal information on the basis that it is: (a) necessary for the performance of a contract Framework has with you; (b) in Framework’s or a third parties’ legitimate interests; (c) where you give Framework your consent; or (d) for compliance with a legal obligation.
Framework may use your IP address to, among other things: (a) help diagnose problems with the Framework server, administer the Services, measure the use of the Services, and improve the content of the Services; (b) identify visitors’ domain names, the type of web browsers used, the pages viewed, the websites from which a visitor found the Services, the search terms and search engines used to find the Services; and (c) gather other web analytics information relating to visitors’ use and navigation of the Services. This information does not identify you personally. On occasion Framework may aggregate this
data with data on the pages visited by other users to track overall visitor traffic patterns and provide this aggregate information to vendors, potential advertisers, business partners, news agencies, or other parties to demonstrate the amount of interest in the Services and to help Framework plan for technical infrastructure requirements.
Note that Framework does not have any responsibility for the actions or policies of any business partners, many of which may have relationships with lenders, realtors, government agencies, or other parties. You should satisfy yourself about how your information may be used by any business partner.
Framework may always use the information it collects and that you provide (other than credit card, debit card, or other payment processing information), in an anonymous or aggregated format that does not identify you personally, which uses might include, without limitation, to evaluate existing products, services, and systems; to assist in the development of new products or services; research; to identify trends and changes; and to prepare and file reports with various government agencies, associations, lenders, realtors, educational institutions, or other organizations.
Framework may disclose personal information in any of the following circumstances: (a) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by applicable law or regulation; (b) to protect and defend Framework rights or property or those of its affiliates or business partners, or others; or (c) as Framework, in its sole discretion, believes is appropriate under exigent circumstances in response to a perceived threat to the personal safety, property, or rights of any person or organization.
In addition, since the Framework database is a business asset, in the event Framework is reorganized or becomes part of another organization, you consent to the sale, assignment, or transfer of your personal
information to a successor that acquires substantially all of the business assets of Framework, or to an affiliate, as applicable.
Framework will never request your password, user name, credit card information or other personal information through e-mail. This practice, called “phishing,” is a scam designed to steal your personal information. If you receive an e-mail that looks like it is from Framework asking you for your personal information, do not respond.
E. Framework’s Relationship to Other Sites that can be Accessed Through the Services
F. Access, Correction, or Deletion of your Personal Information
Framework strives to maintain the accuracy and integrity of the personal information in its databases and to keep that information up-to-date. Framework encourages you to promptly update your personal information if it changes.
You may have rights under applicable laws concerning personal information Framework has collected about you, which may include the right to access your personal information Framework has, to ask Framework to delete, correct, or restrict the use of your personal information, to withdraw your consent to Framework’s use of your personal information, to ask how Framework has used your personal information, and to ask whether Framework has shared your personal information. Framework will honor your rights under any such laws as applicable to Framework or as Framework may agree to honor in its sole discretion.
Privacy requests related to access to, rectification of, restriction of, processing of, sharing of, or objection to the processing of your personal information, withdrawal of consent to handle your personal information, or the right to be forgotten should be sent to Framework in one of three ways:
Or by U.S. Mail at:
Framework Homeownership, LLC Attention: Chief Technology Officer One Washington Mall, 12th Floor Boston, MA 02108
All communications must be in the English language. Please clearly state what information you are requesting and any other requests you are making.
Framework will respond to reasonable requests within the time limits established by applicable law or within a reasonable time if no time limit is established by applicable law. For your protection, Framework may ask you for additional information to verify your identity. If you send Framework an email requesting that Framework take action regarding your personal information or the right to be forgotten, the requesting email MUST come from the email address Framework has on file for you in order to verify that the request is valid and also to protect your personal information. In most cases, Framework will provide the access you request and correct or delete any inaccurate personal information you discover. Framework reserves the right, however, to limit or deny your request to the extent permitted by applicable law if: (a) the disclosure
may be a threat to the personal safety, property, or rights of any other person or organization; (b) the disclosure may lead to a violation of applicable laws or regulations; or (c) where you have failed to provide sufficient evidence to verify your identity.
G. How Long We Keep Personal Information
We retain personal information in accordance with any records retention policy or program we may implement from time to time. We will retain personal information for the length of time necessary to fulfill the purposes for which we collected the personal information or to demonstrate we have fulfilled our duties or obligations, or retention periods required by applicable law or in which claims may be made or the existence of legal proceedings.
H. Security of Your Personal Information
Framework takes what it believes to be reasonable precautions and has implemented managerial and technical procedures to try to protect the security of data and information, including personal information. Framework may transmit your personal data to third parties outside the United States for storage or processing. Framework will attempt to ensure that your personal information will be subject to appropriate safeguards and that it is processed and secured in accordance with applicable law. However, Framework cannot guarantee against any loss, misuse, unauthorized disclosure, or alteration or destruction of data or personal information. While Framework strives to protect your personal information, Framework cannot guarantee the security of any information you transmit to, from, or within the Services, by email or otherwise, and you provide such information at your own risk. You acknowledge that: (a) there are security and privacy limitations in computer systems and on the Internet which are beyond the control of Framework; (b) the security, integrity, and privacy of any and all information and data exchanged between you and Framework through the Services, including personal information, cannot be guaranteed; and (c) any such information and data, including personal information, may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.
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