Homes for Heroes Privacy Policy

Click here to jump to Section 18.H – Do Not Sell or Share My Personal Data – Opt-Out Rights.

Last Updated: January 29, 2025
Effective Date: January 29, 2025

Contents of this Notice

1. Introduction
2. What is Personal Data?
3. About Us
4. Who are Homes for Heroes Affiliates?
5. Our Services
6. When does this Notice apply to your Personal Data?
7. Homes for Heroes’ Relationship with You
8. Children and Teens Under 18
9. Information We Collect About You and How We Collect It
10. Sources of Data and Purpose for Use
11. How and Why Homes for Heroes Discloses your Personal Data
12. Your Choices About Collection, Use, and Disclosure of your Personal Data
13. How does Homes for Heroes protect financial-related information?
14. What security precautions are in place to protect against the loss, misuse, or alteration of your information?
15. How long do we keep your Personal Data?
16. International Data Transfers
17. What else should you know about your privacy?
18. Privacy Rights for Residents of U.S. States with Applicable Privacy Law
19. Updates to this Notice
20. Contact Us

1. Introduction

This Privacy Notice explains how Homes for Heroes, Inc. and our charitable nonprofit, the Homes for Heroes Foundation (the “Foundation“), (collectively referred to as “Homes for Heroes” “we,” “our,” or “us” in this Notice) collect, use, and disclose Personal Data about you through your use of our Services. This Privacy Notice also explains your privacy rights and the options you have regarding your Personal Data. If you have questions about our privacy practices, please feel free to get in touch with us using the contact information provided in Section 20 of this Notice.

2. What is Personal Data?

In this Notice, “Personal Data” or “Data” refers to any information that identifies, or can reasonably be associated with or linked (directly or indirectly) to an individual. Some laws also define Personal Data to include information that could identify or be linked to a specific household or device. 

Generally, (except in California) Personal Data also excludes information exchanged when a person acts within their role as an employee or representative of an organization. 

Anonymous statistics or de-identified information are not considered Personal Data because they don’t identify individuals. In addition, publicly available information is not protected as Personal Data. Please note that, outside of this Notice, Personal Data may also be referred to as “personal information.”

3. About Us

We have built a nationwide network of real estate, mortgage, and local business specialists aimed at making it easy for firefighters, EMS, law enforcement, military (active, reserves, and veterans), healthcare professionals and teachers, collectively, (“Heroes“) to connect with real estate and mortgage specialists, community programs, and businesses that help Heroes save money when they buy, sell, or refinance their homes and make everyday home-related purchases. When Heroes work with a Homes for Heroes Affiliate (see Section 4) during a real estate transaction or service, Homes for Heroes, Inc. donates a portion of its earnings to the Foundation to support Heroes in need.

4. Who are Homes for Heroes Affiliates?

In this Notice, “Affiliate” (with a capital “A”) means the third-party real estate agents, lenders, title companies, home inspectors, and other businesses and specialists that have an ongoing contract with Homes for Heroes and offer real estate, mortgage, or other home-related services to Heroes. Aside from the Foundation, Homes for Heroes does not have a corporate structure that includes affiliate relationships in the traditional sense, such as parent companies or subsidiaries.

5. Our Services

Our Services include provision of our website at https://www.homesforheroes.com (the “Site“) which features information and other resources for Heroes and Affiliates including our blog, the Friends of Heroes business network, the Foundation page at https://www.homesforheroes.com/about/foundation, forms for Hero and Affiliate sign-up, and other digital resources such as our FAQ and the Affiliate toolbox. For Heroes, our Services also include Hero registration, access to our Affiliate network, and Hero Rewards. For Affiliates, our Services also include marketing services, training, and educational resources, including through our Affiliate toolbox, (the “Membership Services“).

Together, the Site, our network of Affiliates, Membership Services, Hero Rewards, and all resources, information, and real estate and lender referral Services we provide to Site visitors, Heroes, and Affiliates, such as phone and email support, membership management, referrals and matching, are our “Services“.  To be clear, the services that Affiliates provide directly to Heroes are not part of the Homes for Heroes Services. The term “Services” (with a capital “S”) only refers to what Homes for Heroes provides directly to Heroes, Affiliates, and Site visitors. It does not include the services (referred to using a lowercase “s” in this Notice) provided by other entities, such as the services that Affiliates offer directly to Heroes. 

Please keep in mind that some Services mentioned in this Notice may not be available at this time.

6. When does this Notice apply to your Personal Data?

Unless otherwise indicated, we follow this Notice with respect to Personal Data obtained from or about individuals in the United States through our Services. In certain cases, we may provide different or additional notices about our Data practices. For example, if you reside in a U.S. State with a consumer privacy law, Section 18 of this Notice applies to you in addition to the rest of this Notice.

This Notice applies when Homes for Heroes acts as the “Controller” of the Personal Data we collect through our Services, both online and offline (a Controller is called a “Business” in California). However, it does not cover Data that Affiliates or other business contacts collect and share with Homes for Heroes where we are a “Processor” or “Service Provider.” 

The Data we share with Affiliates is covered by this Privacy Notice, but any Data you share directly with Affiliates is not. In those cases, the Affiliate’s own terms, conditions, and privacy policies and practices apply. We only share Data with Affiliates after a Hero completes their registration, which indicates that they want us or an Affiliate to contact them. While we are the Controller of the limited Personal Data about Heroes that we share with Affiliates, a Hero and Affiliate form a separate relationship when they choose to work together. Once a Hero-Affiliate relationship is established, the Affiliate is the Controller of any Data the Hero shares with the Affiliate, not Homes for Heroes.  If an Affiliate provides some of your Personal Data back to us to enable us to process your Hero Reward, we will treat that data as Personal Data under this Notice. In addition, our Site may contain links to other websites, applications, and services from third parties (like YouTube, for example). We are also present on social media, and you might see content about us elsewhere on the Internet. Please note that we do not own or control these third party sites, including social media sites, which are controlled by and can be changed by the website owner for any reason at any time. The privacy and data security practices of third-party sites are governed by the privacy policies of those third parties, and not by Homes for Heroes.

7. Homes for Heroes’ Relationship with You

Different categories of Data are collected and processed differently based on the relationship we have with you. The relationship we have with Heroes is different than the relationship we have with Site visitors, Affiliates, or businesses that participate in our Friends of Heroes or Hero Partner programs.

A. Heroes and Site Visitors

Homes for Heroes acts as a Controller when you visit our public-facing Site. In addition, if you registered as a Hero; communicated with us via phone, email, or text; received a Hero Reward; left a public comment on our blog; submitted a Hero review; signed up to our mailing list or text message program; or otherwise interacted directly with our Services, Homes for Heroes acts as the Controller of the Personal Data associated with your use of our Services.

However, as Section 6 above describes, any direct dealings with Affiliates are not a part of our Services, and Homes for Heroes is not the Controller of Data shared directly to an Affiliate. Please direct any privacy-related inquiries related to such Data to the Affiliate.

B. Affiliates and Other Business Contacts

If you interact with Homes for Heroes or its Services on behalf of an Affiliate or another organization, such as your employer or a business that you own or manage, that organization is the Controller and Homes for Heroes acts as the Processor. Any Personal Data generated during these interactions is a part of your organization’s account with us, and is governed by that organization’s policies, not ours. Please direct any privacy inquiries to your organization’s administrator. 

However, please note that Homes for Heroes is the Controller of Data for any non-business interactions with us, such as visits to the Site or interactions with our Services in your personal capacity.

C. Employees, Job Applicants, and ContractorS

If you are a Homes for Heroes employee, completing our employee on-boarding processes, a job applicant, or a contractor working for us, any Data we collect from you in that capacity, including through your use of the Site, is governed by our internal policies, not this Privacy Notice.

8. Children and Teens Under 18

Our Services are not geared toward or intended to solicit, collect or process Personal Data from any individual under the age of 18, and we do not knowingly collect, sell, or share the Personal Data of anyone under the age of 18.  Please contact us using the information in Section 20 if you believe information regarding your child under age 13 has been collected by us through our Services.

9. Information We Collect About You and How We Collect It

Some of the information we collect is personal to you. Other information is anonymous. To learn more about your choices for the collection, use, and disclosure of your Personal Data, please see Section 12 of this Notice. Additionally, if you reside in a U.S. State with a consumer privacy law, Section 18 also applies to you.

We collect the following categories of information:

i. Identifying Information

We collect this type of Data when someone chooses to share it with us, for example:

• • When you use an online form to register as a Hero, you provide your name, email address, phone number, information about what kind of Hero experience you have, and whether you are interested in buying, selling, or refinancing a home.
  • During Affiliate sign-up, you provide your name, the business name, email address, phone number, website, city, state, and information about how you heard about us. If you sign on as an Affiliate, we also ask you to provide a profile photo for your Affiliate toolbox.
  • If an Affiliate adds a Hero, we will receive information the Affiliate shares about that person; we may also receive information if two or more Affiliates are partnered on a Hero record and communicate about that Hero within the Affiliate toolbox on our Site.
  • We may acquire Affiliate information from reliable sources such as professional databases or lists of real estate professionals.
  • When a Hero closes their real estate transaction, the Affiliate they were partnered with will provide a copy of the settlement statement or Closing Disclosure so we can pay the Hero Reward.
  • When you contact us by online form, email, mail, or phone, we may keep a record of the message or conversation, including your contact information and any information submitted to us, or what was discussed.
  • If you opt-in to promotional SMS alerts or sign up to our mailing list, we collect the contact information you provide and create a record of your sign-up.
  • When you post a public comment to our blog, we collect the name and email address you provide and the content of your comment. We also offer a place for you to share your website information. 
  • If you donate to the Foundation or pay for an Affiliate membership, the payment processor will share your name and email address with us.
  • We collect reviews about our Services from Heroes, including written feedback and video testimonials that Heroes provide for us to share.
  • We may receive information when you post on a third party service where we have a profile or presence, such as on social media.
  • We may also collect information in other interactions, such as

ii. Device and Usage Information

We collect information about the device you use to access our Services and your interactions with our Services. Examples include:

• • Technical information like your device and browser type, operating system, system configuration, and unique device identifiers.
  • Information about how your device has interacted with our Site, including the pages accessed, links clicked, forms completed, date and time stamps associated with usage, referring website, search engine queries used to get to our Site, content you viewed, shared, or downloaded, and other technical information.
  • We may look at how often you visit the Site and where you accessed it from based on your IP address to get a general idea of your location, such as zip code and time zone. We might also recognize that it is you if you use different devices to access the Site.

iii. Internet or other Network Activity Information

This type of Data is collected when you browse our Site, other websites, or open our emails. This may include technical information like your IP address, mobile network details, device ID, and details about what you viewed.

iV. Event Information

We collect information if you sign up for webinars or events, such as contact information and mailing address. We may also collect Personal Data you provide to us during an interaction at a webinar or event.

V. Account Credentials

We collect Affiliate account access credentials and passwords to protect our Services and your security and to manage Affiliate memberships, to the extent permitted or required by applicable law. We do not use this Data for the purpose of inferring characteristics about you.

Vi. Demographic Information

We collect demographic details, including zip code and job details, when you submit a form on the Site. The Hero registration form asks about Hero experience, like whether you’ve worked as a teacher, healthcare professional, firefighter, in law enforcement, or served in the military. For Affiliates, we gather occupation and location details related to the services you offer Heroes.

Vii. Location Information

We can always detect where the Site is accessed from based on IP address, which gives us a general idea of device or network location, like country, city, and zip code.  We may also collect location information such as zip code from you directly.

Viii. Commercial and Transaction Information

When you use an Affiliate service or engage in a real estate, mortgage, or local business transaction, we may keep a record of the details like the type of service, transaction dates, and the location where the service was used. If you shop through a Friends of Heroes link with a business offering Hero savings, we may receive information about the amount you spend so that we can fulfill our promise to make a donation to the Foundation based on the amount of your purchase. When you subscribe as an Affiliate, we collect your name, business name, logo, business contact information, and our payment processor collects payment information.

10. Sources of Data and Purpose for Use

This section outlines the sources and purposes for collecting the categories of Personal Data described in Section 9 above.  To learn more about your choices about the collection, use, and disclosure of your Personal Data, please see Section 12 of this Notice. Additionally, if you reside in a U.S. State with a consumer privacy law, Section 18 also applies to you.

A. Overview of our Data Sources

We collect Data from a variety of sources, including but not limited to:

i. Directly

from the person who is the subject of the Personal Data.

iI. Indirectly

from our service providers, publicly available sources (such as voting records, business information, or social media), third-party advertisers, Affiliates who added a Hero, real estate business contact lists, and interactions related to us on third-party services where we have a profile or a presence.

iII. Automatically

(directly or indirectly) from the device used when you visit the Site, your network, or from cookies and other tracking technologies.

iV. derived

information we infer about you based on what we collect.

B. Overview of our Data Use

Our main goal in collecting information is to provide and improve our Services and provide you with the best possible experience. For example, by using the information we collect, we can provide an easy to use and readily available forum for Heroes and Affiliates to connect to help Heroes to save on their real estate, mortgage, or local business transaction. 

We will also use your Personal Data for purposes including but not limited to the following:

i. Service Fulfillment

• • Complete, manage, and communicate about Hero enrollment;
  • Calculate and pay-out Hero Rewards;
  • Set up and service Affiliate accounts including provision of the Membership Services;
  • Enable other Affiliate toolbox functions, such as the Affiliate locator service, or communication between agents and lenders that are partnered on a Hero record;
  • Facilitate donations to the Foundation, including through Friends of Heroes purchase tracking;
  • Communicate about the Services, or any experience and feedback related to the Services;
  • Provide customer service; 
  • Alert you about features, functions, or opportunities we offer through the Services, including via text message, if you signed up; and
  • Enhance our Services.

ii. Internal Operations

• • Make our Services better;
  • Strategize to plan Site content;
  • Conduct research and analytics for our operations and Services; 
  • Improve the effectiveness of our vendors, systems, Affiliates, and Services;
  • Compile, analyze and do research on our users’ demographics and behavior; and
  • Perform other digital coordination and operational activities.

iii. Payment Processing

• • Coordinate with service providers to process payments;
  • Address inquiries or requests about Affiliate memberships or Foundation donations.

iv. Security, compliance, legal obligations and fraud prevention

• • Detect, investigate and prevent activities that may be illegal or violate our policies;
  • Protect our assets (on and offline) and prevent fraudulent activities;
  • Validate credentials and authenticate user log ins;
  • Protect the security and integrity of our Services and our data; and 
  • Assist law enforcement and respond to legal/regulatory inquiries, if necessary.

v. Marketing, promotions and advertising

• • Improve marketing performance;
  • Notify you of other Services we offer, including personalized offers by email or by text message, if you subscribed;
  • Personalize online content so it applies to your interests;
  • Identify user preferences;
  • Provide you with advertising matched to your interests;
  • Track activity on our Site, the Services you are interested in, and how often you visit, and 
  • Oversee contests, promotions, or surveys.

vi. Anonymized or De-Identified Uses

• • To the extent we anonymize or de-identify Data, we will not attempt to re-identify it.

C. Information you Provide Directly to Homes for Heroes

We collect much of the information mentioned above directly from the individuals the information is about. For example, we collect information you share with us in your Hero or Affiliate sign up, via email, during phone calls, in reviews, in your account or profile details, or when you sign up for our emails or text messages. 

The Personal Data we request, along with the reasons for its collection, will be explained at the time of request unless it is obvious from the context.

If you do not want to share your information, you can choose not to participate in a particular Service or activity.

D. Information Inferred or Derived about You

We may derive information or draw inferences about you based on the information we collect. For example, we might use your IP address to estimate your approximate location or infer the type of real-estate or home-related service you may need based on the search parameters, browsing behavior, or content viewed on our Site. For instance, if you search for and spend time viewing a blog post geared toward first-time homebuyers, we might infer that you are more likely interested in purchasing a home than refinancing one.

E. Information from Your Device

We and third parties we hire to provide services—such as Site hosting, management, and development; web form and Site content management; Site security services; embedded content hosting (like YouTube); and marketing—may automatically collect certain information from your device when you use our Services. The Data protection laws that apply in some jurisdictions may consider this information Personal Data.

Collecting this information provides a better understanding of the visitors who come to our Site, where they come from, and what content on our Site interests them. This information is used for our internal analytics, to improve the quality and relevance of Services to Site visitors, to build value in our Membership Services, and to enhance the security of our Services by detecting and preventing fraud, security threats, or other illegal or suspicious behavior on our Services.

F. Data from Cookies and Tracking Technologies

Like most websites and other places on the Internet, our Site use cookies, web beacons, pixels and other online tracking technologies (collectively, cookies) to store and sometimes track information about Site visitors. 

As part of offering and providing customizable and personalized Services, we may use these technologies to:

• Enable you to more easily use our Services by remembering information such as links and menus you have navigated through during a browsing session, or login and contact details;
• Track activity on our Site, the Services you are interested in, and how often you visit our Site; 
• Provide you with personalized content based on your use of our Services;
• Evaluate, monitor and analyze Site use and traffic patterns to help improve our online Services; 
• Follow purchases made using a Friends of Heroes link to make a donation to the Foundation based on the transaction amount; 
• Administer your cookie preferences selection; and
• Assist us with ad reporting functions such as to learn which ads are bringing users to our Site.

We may also use (or allow others to use) cookies or similar tracking technologies which, if enabled, follow your use and behavior across our Site and the Internet over time to serve and enable targeted advertising, interest-based advertising, and cross-context behavioral advertising (generally referred to as “Targeted Ads” or “Targeted Advertising”). We may use your Personal Data to facilitate the delivery of Targeted Ads. You can manage your consent options for Targeted Advertising based on Personal Data collected by cookies on our Site by visiting our Cookie Preferences Center, and Section 12.A has additional information.

For further information about the types of cookies we use and why we use them, please see our Cookie Policy.

G. Data from Third Party Sources

Our Services may contain links to third party websites, embedded content from or about third party websites and services (like embedded videos), and buttons from third party websites and services (such as social media links and sharing buttons). These third party sources can collect Personal Data from you when you interact with our Services or other websites, and we may receive Personal Data about you from third party sources, including but not limited to our suppliers and service providers, third party web analytics services, and social networking platforms.

The types of information we may receive from these third parties includes information about your web activity, how you interact with our Site and their services, and aggregated analytics. We use this information to help improve and sometimes offer our Services, share information and advertising, and to analyze aggregate click statistics and trends. For example, we may obtain analytics information from social networks that help us measure the effectiveness of our content and advertisements on those platforms (e.g., impressions and clicks).  We may also obtain aggregated information, including analytical results, about your use of the Site for fraud detection, prevention, and reporting purposes.

i. social Networking plugins and platforms

When you use social networking platforms (such as YouTube, LinkedIn, X, Facebook, and Instagram) and plugins (such as “share,” and “like” buttons) on our Services, your username and password for that platform may be shared with us. By using these platforms and plugins, you also share your information with the social networking platform and their privacy notice governs how they handle or disclose that information. Additionally, they may collect information about your activity on our Site, and may notify your connections on the social networking platform about your use of the Homes for Heroes Site. Such services may enable tracking of your activity across multiple websites to deliver Targeted Advertising to you.  Please note that their privacy polices apply, and we encourage you to read them.

In Section 12.D.ii below we provide instructions and educational resources on how to manage Data generated by social media platforms and plugins in connection with your use of our Site and other websites.

ii. google analytics

Google, Inc. utilizes Data collected by Google Analytics tools operating on our Site to track and examine how our Site is used, create reports on its activities, and share those reports with us and with other Google, Inc. services. In addition, Google, Inc. contextualizes and personalizes ads within its own advertising network to serve ads to you based on your visits to our Site and other sites on the Internet. 

For information on how to prevent collection of Data generated by Google Analytics related to your use of our Site, please refer to Section 12.D.i below.

11. How and Why Homes for Heroes Discloses Your Personal Data

This section describes when and to whom we disclose the categories of Personal Data described in Section 9 above.  

In the circumstances described below, we disclose (or permit others to directly collect) information about you. Here are some of the ways that your Data may be shared:

i. With Your Consent

ii. To Fulfill the purpose for which you provided the data

iii. For any purpose Disclosed by us in this notice or when you provided the data

iv. Data in the Aggregate

We may disclose “blinded” aggregated data and user statistics without restriction. Blinded data is data that does not identify any individual.

v. To Service Providers

We may disclose Personal Data that we collect or you provide to service providers and other third parties we use to support our business. We occasionally hire other companies to provide limited Services on our behalf, such as sending postal mail or email; Site development and operation including managing reviews, form submissions, browsing sessions, and presenting Site content; providing our cookie preferences center to facilitate your privacy choices; tracking Site visitor activity for analytics; administering donations to the Foundation by keeping track of purchases you make on Friends of Heroes websites; analyzing Site use; providing Site security; fraud detection; facilitating marketing by helping us understand what keywords, ads, and campaigns are most effective; personalizing content for Site visitors; processing payments; and processing Data. We will only provide those companies the information they need to deliver the service.

vi. To Third Parties

We will not share your Personal Data—such as your email address, phone number, name, mailing address, or any other private details—with telemarketers or marketing agencies other than Affiliates. We will share this kind of Data with Affiliates only after you complete Hero registration. If you ask us to contact a third party on your behalf, you are giving us permission to share your Data with them, including your contact details and any other Data we collect through your use of our Site.

If you have not opted out of Data collection for purposes of Targeted Advertising, we allow certain third-party advertising companies to collect Personal Data directly from you through your use of the Site. These companies use cookies to collect Data from you to show you ads that are more relevant to your interests based on information such as the pages you viewed, materials you downloaded, links you followed, your search queries, and any other online activities and behavior on our Site and other websites. Additionally, we may use this Data to improve our Services and provide useful information to our sales and marketing teams.

To learn more about your Data choices, please see Section 12 of this Notice. Additionally, if you reside in a U.S. State with a consumer privacy law, Section 18 also applies to you.

vii. In Special Cases

Homes for Heroes and our service providers may disclose, access, or monitor your Personal Data in special cases, such as the following

• • When we believe that we must disclose Data to identify, contact or bring legal action against someone who may be violating our Terms and Conditions, or may be causing injury to or interference with our rights or property, other Site visitors, Heroes, or Affiliates and their Data, or anyone else who may be harmed by such activities. 
  • When we believe in good faith that the law requires it. 
  • For administrative and other purposes that we deem necessary to maintain, service and improve our Services and our information security. This includes third party partners and service providers we use to enable the detection of devices connected with fraud and other types of information security vulnerabilities, to prevent fraud, security threats and illegal or malicious behavior, and to enhance security on our Site and other pages on the Internet. 
  • In the event that we buy or sell businesses or assets. In such transactions, confidential customer Data generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of Homes for Heroes’ businesses, Affiliate, Hero, and Site visitor Data may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction. In such case, the transferred Data may become subject to a different privacy notice.

12. Your Choices About Collections, Use, and Disclosure of Your Personal Data

A. Managing Your Data Preferences with Us

I. Revoking Consent

If we are collecting, using, or disclosing your Personal Data with your consent, you can withdraw your consent to future use of your Personal Data on the grounds of consent at any time by following the instructions described in the relevant subsections, below

II. Affiliate Account Information

You can directly manage certain information stored within your online account by logging in and viewing, changing, or deleting that information

III. Information Associated with an email address

To manage all of the Personal Data associated with your email address in our database, please contact us using one of the contact methods in Section 20 of this Notice

IV. Tracking Technologies

We configured our Site to give you two options to control how cookies collect your Data on this Site:

• Select Your Cookies – Visit our Cookie Preferences Center anytime to pick which types of cookies you want to allow while using our Site. You will need to update your choices if you visit the Site on a different device or browser, or if you clear your cookies
• Automatic Cookie Preferences – You can also pre-set your browser with a legally recognized opt-out signal, like the GPC, to automatically send us your cookie preferences. We provide more details about the GPC and how to enable it in your browser in Section 12.B.i below. If your GPC signal is active and working, we will honor your cookie choices.
• •  

V. Promotional Communications

You may opt out of receiving recurring marketing communications from us by following the instructions in each marketing email or subscription service from us to let us know that you no longer wish to receive such communications from us. For example, use the “unsubscribe” link in an email from us, or text “STOP” in reply to a SMS message from us. If you opt out, we may still send you non-promotional messages, such as emails about your account, membership, donation, or ongoing transactions.

VI. General

If you believe that any inaccurate or inappropriate information has been obtained or provided to others through your use of our Services, you should contact a representative of Homes for Heroes using one of the contact methods in Section 20 of this Notice.

B. Browser Settings to Control Your Data

i. The Global Privacy Control Browser Opt-Out Preferences Signal

The Global Privacy Control (GPC) is an option you can configure in your browser’s settings (or by downloading a browser extension, for certain browsers) to signal to websites that you want to limit Data sharing as much as possible. Our Site listens for and responds to GPC signals, so when you enable GPC in your browser, we treat it as your request to opt-out of sale or sharing of Data for Targeted Advertising. This means we will not use cookies on our Site to gather Data to personalize suggestions or ads based on your activity, and third parties will also be prevented from doing so. 

Visit https://globalprivacycontrol.org/ for the latest information on how to enable GPC in participating browsers including instructions on downloading and setting up any browser extensions, if necessary.

iI. Do NOt Track Codes

Some web browsers offer a “do not track” (DNT) privacy preference setting. When you turn on the DNT setting in your browser, your browser will send a signal to websites, analytics companies, ad networks, and other web services that have been integrated across the Internet (such as buttons, widgets, and other embedded features or content) requesting that those applications stop tracking and sharing your activity. Web browsers that support DNT provide instructions on how to enable it. Search for instructions in your browser’s help section.

iII. Browser Settings

Internet browser cookie settings are usually found in the “settings,” “preferences,” or “options” menu of your browser. In order to understand more about these settings, the following links may be helpful. You can also use the “Help” option in your browser for more details.

• • Cookie settings in Edge
  • Cookie settings in Firefox
  • Cookie settings in Safari
  • Cookie settings in Chrome

C. Industry Program for Controlling Interest-Based Advertising

You can also take advantage of industry-sponsored programs to better manage how some companies advertise to you anywhere online, including but not limited to the following resources:

• The Network Advertising Initiative’s Opt-Out page: https://thenai.org/opt-out/
• The Digital Advertising Alliance’s WebChoices tool: https://optout.aboutads.info/
• The European Interactive Digital Advertising Alliance’s Guide to Online Behavioural Advertising and Online Privacy:  http://www.youronlinechoices.com

These tools will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each browser or device you use. These tools will not opt you out of non-Targeted Advertising.

D. Service-Specific Information on Cookies and Online Advertising Choices

I. Google and Google Analytics

You can prevent Google, Inc. from accessing future Data about your use of our Site generated by the Google Analytics tools we use by downloading and installing the Google Analytics opt-out browser add-on as instructed here: https://tools.google.com/dlpage/gaoptout. This link provides instructions for installing an opt-out extension to your browser. For as long as the opt-out extension remains installed and active on the browser you are using, Google, Inc. will no longer receive Data about your activity generated by the Google Analytics tools on our Site, but we will still receive it and use it for operational purposes. 

For information on how Google Analytics uses Data, please visit “How Google uses information from sites or apps that use our services,” located at https://policies.google.com/technologies/partner-sites. You may view Google’s privacy policy here: https://policies.google.com/privacy?hl=en, More information is located here: https://www.google.com/policies/privacy/partners/ (including information regarding how to control how information is shared through your Ads Settings) and here: https://support.google.com/analytics/answer/6004245?hl=en.

II. Other Services

You may also opt-out of information sharing from third party websites using information in their privacy policies. We have provided informational links for some common services, below

• • Meta (Facebook and Instagram): Meta offers information about Data it collects and how Data is used for advertising here: https://www.facebook.com/policy.php. You may opt-out of Meta’s Data collection and sharing using the instructions at this link: https://www.facebook.com/settings?tab=ads. You will need to log in.
  • YouTube: YouTube is owned by Google, and the Google privacy policy offers some information about YouTube. YouTube also offers information here: https://support.google.com/youtube/answer/10364219?hl=en. 
  • X (Formerly “Twitter”): X publishes information about how it uses Data here: https://x.com/en/privacy information and provides instructions on how to manage your privacy and advertising choices here: https://business.x.com/en/help/troubleshooting/how-x-ads-work. Additional controls are available in X account settings https://x.com/settings/account.
  • LinkedIn: The LinkedIn Privacy Policy offers information about advertising opt-outs and settings to control your Data here: https://www.linkedin.com/legal/privacy-policy#choices. More detailed instructions about privacy and advertising Data are available here https://www.linkedin.com/help/linkedin/answer/a1337839/?trk=microsites-frontend_legal_privacy-policy&lang=en.
  • Microsoft and Microsoft Ads (also known as Bing Ads): provides detailed information on how it uses Data in its Privacy Statement, including how it identifies unique users online https://www.microsoft.com/en-us/privacy/privacystatement#mainadvertisingidmodule, and how to control Data collected by Microsoft https://www.microsoft.com/en-us/privacy/privacystatement#mainhowtoaccesscontrolyourdatamodule. For an overview of Microsoft’s answers to common privacy questions, visit the FAQ https://www.microsoft.com/en-us/privacy/faq.

13. How does Homes for Heroes protect financial-related information

A. Heroes

Homes for Heroes will never attempt to collect payment or payment information from a Hero interested in using our Services. There is no cost to a Hero for using the Services.  We will use commercially reasonable efforts to protect any financial information that may be provided in information sent to us by an Affiliate to process your Hero Rewards.

B. Donations and Affiliate Membership Payments

We use third party payment processors to process donations to the Foundation and Affiliate membership payments, and we do not collect or retain your payment card or bank information. As a matter of policy and long-time business practice, we do not sell financial Data. Any statistics that we may provide to prospective partners regarding financial matters are provided in the aggregate only and do not include any personally identifiable Data about any individual person.

14. What security precautions are in place to protect against the loss, misuse, or alteration of your information?

Because information sent through the Internet travels from computer to computer throughout the world, information you give us may be sent to servers outside of the country where you originally entered the information. While no Data transmission over the Internet can be guaranteed to be 100% secure, our Site uses Transport Layer Security (TLS) to encrypt Personal Data transfers. You can identify TLS in use on a page within our Site by the padlock symbol 🔒 or “https” in the URL. We also use firewalls and other security measures to protect your information. 

Your Affiliate member account is protected by a password that you create, and we encrypt passwords and account registration information. Remember to enable security settings on your mobile device such as by setting up a device passcode or biometric unlock, and sign out, close your browser, or lock your screen when you are away from your device to prevent unauthorized access to your account information. 

Information you disclose while using our Services (as with any non-secure site), such as by posting a public review or using e-mail, may potentially be collected and used by others. This may result in unsolicited messages from third parties or misuse of your information for various purposes, legal or illegal. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any information you transmit to us or from our Services, and you do so at your own risk. If we receive a nonpublic transmission from you, we use commercially reasonable efforts to ensure its security on our systems. We limit access to your Personal Data to those who reasonably need it to provide and improve our Services and process your information appropriately.

15. How long do we keep your Personal Data?

We store Personal Data for as long as necessary to carry out the purposes for which we originally collected it as disclosed to you in this Notice or elsewhere when Data is collected. The length of time we retain Personal Data will be determined based upon criteria such as: the length of time your Personal Data remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators; or the type of contract we have with you, the existence of your consent, and our legitimate interest or business need in keeping such information (for example, to provide you with a Service you have requested or to comply with applicable legal, tax, compliance, or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Data in accordance with our Data retention policies such as when you request to end your participation in the Homes for Heroes program, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

16. International Data Transfers

Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have Data protection laws that are different to the laws of your country and, in some cases, may not be as protective. Specifically, our Site servers are located in the United States, and our third party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Notice

17. What else should you know about your privacy?

Please keep in mind that whenever you voluntarily disclose information online, that information is accessible to others. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.

18. Privacy Rights for Residents of U.S. States with Applicable Privacy Law

A. U.S. States with Applicable Privacy Laws

Residents of certain U.S. states may have rights (now or in the future) under privacy laws in effect in their state, such as under the California Consumer Privacy Act (CCPA), Colorado Privacy Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, Virginia Consumer Data Privacy Act, and any other U.S. privacy law and implementing regulations (collectively, State Privacy Laws). Some of these laws may not take effect until a future date.

We will adhere to the privacy rights below to the extent that they apply to you and to us.

In general, the State Privacy Laws provide (now or in the future) consumer state residents with rights to:

• Confirm whether we process their Personal Data and access it (the Right to Know).
• Delete certain Personal Data.
• Correct inaccuracies in their Personal Data, taking into account the nature of the information and the Controller’s processing purpose (excluding Iowa and Utah).
• Obtain a Copy of their Personal Data (the Right of Data Portability).
• Opt-out of Personal Data processing for:
  • Targeted Advertising (excluding Iowa); or
  • Sales.
• Some State Privacy Laws provide additional rights related to the use of automated technologies to make important decisions. Since Homes for Heroes does not engage in these activities, those rights are not covered in this Notice.

The exact scope of these rights vary by state, may change, and new privacy rights may become applicable as State Privacy Laws and implementing regulations are passed or amended. Homes for Heroes is working to maintain this Privacy Notice with accurate and relevant information about consumer rights and each State Privacy Law as they are passed and amended, and as guidance is issued by each state. Please check this section of our Privacy Notice for periodic updates, as we may update it to address new laws as appropriate. 

California Civil Code Section 1798.83 permits individuals who are California residents that have a business relationship with us to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to or write us using the contact information in Section 20 of this Notice. Make sure to state that you are a California resident.

Nevada Rev. Stat. § 603A.345, permits consumers in Nevada to opt-out of the sale of certain kinds of Personal Data. A sale under Nevada law is the transfer of this Personal Data to third parties for monetary consideration so these third parties can then re-sell or license the sold Data. We do not sell your Personal Data to third parties as defined in Nevada law.

B. Privacy Rights for Affiliates and Business Contacts

The State Privacy Laws apply to U.S. “consumers” who are natural persons acting in their personal or household capacities. The State Privacy Laws (other than the CCPA, for California residents), do not cover Personal Data collected in the business-to-business (B2B), workforce, or employment contexts. This means that if you interact with Homes for Heroes as a contractor, employee, or business representative of an organization, Data we collect or process from those interactions is generally not tied to Personal Data rights under State Privacy Laws (except for the CCPA). We may not process privacy requests in cases where such exceptions apply. 

When you are acting as business representative of an organization, we generally collect, retain, and use your Personal Data for business purposes and limited, if any, commercial purposes. Business purposes generally are not tied to an opt-out right under the State Privacy Laws because they do not implicate a sale, sharing or Targeted Advertising of a consumer’s Data as defined under those laws.

Commercial purposes, on the other hand, generally trigger opt-out rights for consumers under the State Privacy Laws, particularly where sales, sharing, or Targeted Advertising of a consumer’s Personal Data is involved. An example is where a third-party business collects a consumer’s Personal Data using cookies, and that Data is used for certain advertising purposes. To make inquiries or exercise rights in Personal Data based on your interactions with Homes for Heroes in your personal capacity, such as personal inquiries or visits to the Site, you can contact Homes for Heroes directly using one of the methods in Section 20 of this Notice.

C. Our Collection, Use, and Disclosure of Personal Data

As noted above in Section 9, we collect Data that identifies, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer (Personal Data or Data, also known as “personal information”). 

Personal Data, however, does not include:

i. Publicly available information

iI. De-Identified or aggregated consumer information

iII. Information Excluded from most state privacy laws’ scope, such as:

• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
  • data collected in the business-to-business (B2B) context (except for California consumers, as defined under the CCPA); and
  • data collected in the employment context (except for California consumers, as defined under the CCPA).

Below is a table that details our Data practices over the last twelve (12) months.

Identifiers (such as name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or similar identifiers)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We collect identifiers such as those listed above. We do not collect social security numbers, driver’s license numbers, or passport numbers from consumers.	Directly from individuals submitting Data to us; certain Data is automatically collected from Site visitors; business report providers; advertising and marketing partners and list brokers; social media; Affiliates who sign up a Hero	Performing Services; remembering cookie consent preference; maintaining account information; providing customer service; verifying Affiliate or Hero information; processing Affiliate payments or donations to the Foundation; providing advertising and marketing Services; providing analytics; programmatic advertising; Targeted advertising; conversion tracking; auditing related to Affiliate or Hero interactions and transactions; security detection and enhancement; enhancing Services	For as long as reasonably necessary to: maintain an Affiliate account or Hero record; fulfill our obligations related to a transaction; provide a requested Service; protect our Site and Services from security threats or fraudulent activity; spot preferences and trends and otherwise analyze Data for the disclosed purposes; comply with applicable law and regulatory obligations; comply with a request or order from a government entity or law enforcement. We may also retain Data for the duration the user consented; or until the user asks us to delete the Data. We may also de-identify the Data and continue to use it for a longer period of time	Affiliates; marketing and advertising service providers and vendors; cloud storage providers; social media partners and online search platforms; security services; payment and chargeback processors; government entities and law enforcement, if necessary; Affiliates; Heroes

Financial, medical, or health information (such as insurance policy number, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
Our payment processors collect the financial information necessary to process donations, Affiliate payments, and set up Affiliate memberships, but we do directly collect financial information. We do not collect medical or health information.	Directly from individuals submitting Data to the payment processor.	Performing Services.	N/A	Technology service providers such as payment processors, financial reporting companies, or address verification providers; government entities and law enforcement, if necessary;

Characteristics of protected classifications under California or federal law (such as such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We collect information on military and veteran status during Hero registration.	Directly from individuals submitting Data to us; Affiliates who sign up a Hero	Performing Services.	As long as reasonably necessary to perform the Services and to demonstrate we have fulfilled our duties and obligations. We may also de-identify the Data and continue to use it for a longer period of time.	Cloud storage providers; Affiliates; government entities and law enforcement, if necessary

Commercial information (such as transaction history, services purchased, obtained, or considered, records of personal property, or other purchasing or consuming histories or tendencies)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We collect commercial information relating to Hero real estate inquiries and transactions; from browsing activity; and from transactions made using a Friends of Heroes link.	Directly from individuals browsing the Site; submitting Data in online forms; engaging in real estate transactions or making inquiries; Homes for Heroes internal processes; advertising and marketing partners; Affiliates	Performing Services; maintaining Hero record information; providing customer service; verifying Hero information; providing advertising and marketing services; providing analytics; auditing related to Hero and Affiliate interactions, transactions, and Site use; security detection and enhancement; enhancing Services	For as long as reasonably necessary to:  demonstrate we have fulfilled our duties and obligations related to a transaction; maintain an active Hero record; provide a requested Service; spot preferences and trends and otherwise analyze Data for the disclosed purposes; comply with applicable law and regulatory obligations. We may also retain Data for the duration the user consented; or until the user asks us to delete the Data. We may also de-identify the Data and continue to use it for a longer period of time.	Affiliate sales and marketing representatives; cloud storage providers; social media partners and online search platforms; marketing and advertising service providers and vendors; government entities and law enforcement, if necessary; Affiliates

Biometric information (physiological, biological or behavioral characteristics, including images, voice recordings, keystroke patterns)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We do not collect biometric information	N/A	N/A	N/A	N/A

Internet or other electronic network activity information (such as browsing history, search history, and information regarding an interaction with a website, application, or advertisement.

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We collect electronic identifiers such as IP address, cookies, Site browsing and interaction activity such as how often you visit the Site and which pages you view, features you use, content you capture, download, or interact with, and links you follow; browsing and search history such as the links, ads, or search queries that led you to the Site; advertisement interaction information such as whether you submitted a form after interacting with an ad; and other device or browser identifiers.	Web browsers and devices; advertising and marketing partners; analytics providers; social media partners; technology vendors	Performing Services; enabling Site functionality; maintaining account information; providing customer service; verifying Hero or Affiliate information; providing advertising and marketing Services; analytics; auditing related to Hero or Affiliate interactions and transactions; security detection and enhancement; enhancing Services	For the duration of the current browsing session, at minimum; or for as long as reasonably necessary to: spot preferences and trends and otherwise analyze for the disclosed purposes; to comply with a request or order from a government entity or law enforcement. We may also retain Data for the duration the user consented; or until the user asks us to delete the Data. We may also de-identify the Data and continue to use it for a longer period of time	Marketing and advertising service providers and vendors; cloud storage providers; social media partners and online search platforms; security services; suppliers; third party advertising companies;  government entities and law enforcement, if necessary; Affiliates

Geolocation

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We collect approximate zip code location Data.	Web browsers and devices; technology providers	Verifying customer information; fraud and spam detection, security detection and enhancement; enhancing Services	For as long as necessary to protect our Site and Services from security threats or fraudulent activity; comply with applicable law and regulatory obligations; or comply with a request or order from a government entity or law enforcement. We may also retain Data for the duration the user consented; or until the user asks us to delete the Data. We may also de-identify the Data and continue to use it for a longer period of time.	Marketing and advertising service providers and vendors; cloud storage providers; social media partners and online search platforms; security services; government entities and law enforcement, if necessary, Affiliates

Audio, electronic, visual, thermal, olfactory, or similar information

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
Telephone calls may be recorded; Hero reviews provided in video format; Affiliates may provide a profile picture.	Directly from individuals submitting Data to us; technology vendors	Performing Services; providing customer service; providing advertising and marketing services; analytics; auditing related to customer interactions and transactions; security detection and enhancement; enhancing Services; as part of Site content	For as long as necessary to protect our Site and Services from security threats or fraudulent activity; for as long as the Affiliate account profile information remains relevant; for the duration the user consented; or until the user asks us to delete the Data	To the public at large, for reviews posted on the Site; marketing and advertising service providers and vendors; cloud storage and providers; security services; government entities and law enforcement, if necessary; Affiliates

Professional and employment-related information

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
Professional and employment-related Data is collected for Heroes and Affiliates.	Directly from individuals submitting Data to us; list brokers; Affiliates who add a Hero	Performing Services; Business-to-business commercial interactions including: performing Services; maintaining Affiliate account information; providing customer service; verifying Affiliate information; providing advertising and marketing Services	For as long as necessary to maintain the Hero record or Affiliate account information, or until that Hero or Affiliate asks us to delete it	Marketing and advertising service providers and vendors; cloud storage providers; security services; suppliers; government entities and law enforcement, if necessary; Affiliates; Heroes

Educational information

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
We do not collect educational Data.	N/A	N/A	N/A	N/A

Inferences drawn from any information identified above (such as to create a profile about preferences, characteristics, rends, predispositions, behavior, or attitudes)

Information Collected or Processed	Categories of Sources	Business or commercial purpose for which it will be used	Intended Retention Period	Categories of third parties with whom Personal Data is shared
Homes for Heroes collects preferences and derives behavior and trends to create Hero and Affiliate profiles. We may infer a broad approximate location based on IP address. We may infer educational information about Affiliates based on professional certification.	Web browsers and devices; advertising and marketing partners; social media partners; technology vendors; internal processes	Performing Services to improve the Hero experience; maintaining account information; providing customer service; verifying Hero or Affiliate information; Targeted Advertising; auditing related Affiliate or Hero and employee interactions and transactions; security detection and enhancement; Service enhancement	For as long as reasonably necessary to: maintain an active Affiliate account or Hero record; spot preferences and trends and otherwise analyze for the disclosed purposes; for the duration the user consented; or until the user asks us to delete the Data	Marketing and advertising service providers and vendors; security services; suppliers; government entities and law enforcement, if necessary; Affiliates

D. Right to Know and Data Portability

If you are protected by an applicable State Privacy Law, you have the right to request access and disclosure of certain information about our collection and use of your Personal Data as well as to have a copy of that Data (collectively referred to here as the right to know). Once we receive your request and confirm your identity (see Section 18.F below), we will disclose the following information to you, per your request.

i. The categories of Personal Data we collected about you.

iI. The categories of Personal Data we are processing, or have processed.

iII. The categories of sources for the Personal Data we collected about you.

Vi. Our business or commercial purpose for collecting, selling, or sharing the Personal Data.

V. A list of the categories of third parties with whom we have shared your Personal Data, if any, and the categories of Personal Data shared with each category of third parties.

Vi. A list of the categories of Personal Data we disclosed about you for a business purpose, if any, identifying the categories of persons or recipients that obtained each category of Personal Data.

ViI. A copy (if requested) of the specific pieces of Personal Data collected and maintained in a commonly used electronic format.

If you are protected by the Oregon Consumer Privacy Act (which is currently in effect) or the Minnesota Consumer Data Privacy Act (which will take effect on July 31, 2025), you have additional rights to obtain,  [start OPTION 1] a list of the specific third parties to which we have disclosed your Personal Data [end OPTION 1] [Start OPTION 2] a list of specific third parties to whom we have disclosed any consumer’s Personal Data[end OPTION 2]. To obtain a copy of this information, be sure to indicate that you are an Oregon or Minnesota resident when you submit your request.

E. Right to Delete and Correct

If you are protected by an applicable State Privacy Law, you have the right to request that we delete the Personal Data collected or maintained about you, or correct inaccuracies in such Data, subject to certain exceptions (collectively referred to here as the right to delete). Once we receive a request and confirm the identity of the requestor and the Data subject (see Section 18.F below) we will review the request to see if an exception allowing or requiring us to retain the Data applies. We may deny a deletion request if retaining the information is necessary for us or our service provider(s) to:

i. Complete the transaction for which we collected the Data, provide requested Service, take actions reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform our contract with any consumer.

iI. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.

iII. Debug the Services identify and repair errors that impair existing intended functionality.

iV. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

V. Comply with applicable state law, including the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Vi. 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 informed consent was previously provided.

VIi. Comply with a legal obligation.

VIIi. Other purposes as permitted under State Privacy Law.

Upon receipt of your verifiable request, we will delete or de-identify and/or correct any Personal Data not subject to one of these exceptions from our records and will direct our service providers (and Affiliates, to the extent we are the Data Controller) to take similar action.

F. Exercising Your Rights to Know or Delete

To exercise the rights to know or delete described above, please submit a request using one of the methods in Section 20 of this Notice.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. You may only submit a request to know twice within a twelve (12) month period. Your request to know or delete must:

• • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or their authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Verifying Requests. We cannot respond to your request or provide you with Personal Data unless we verify your identity or authority to make the request and confirm the Data relates to you. To protect your privacy and maintain security, we will take steps to verify your identity before complying with requests. For example, for requests to know and delete, we will attempt to match your identity to Data in our records. If needed, we may ask for additional information. The Data you provide will be used solely for identity or authorization verification purposes.

Authorized Agents. You may designate an authorized agent to make a request on your behalf, but they must submit proof of authorization. We may deny requests if proof is inadequate. We will not process privacy requests from third-party services that haven’t passed our verification process, because these services often request that we click on hyperlinks which we will not do for data security reasons. In addition, these services are also susceptible to spoofing and other phishing attacks. One of our highest priorities is to treat your Data safely and securely. If your state allows third-party agents for privacy requests, please have them contact us directly using the information in Section 20 of this Notice, and we will take steps to identify them and ensure that they are your agent. 

Responses to Requests. We will try to respond to your request within 45 days. If more time is needed (up to 90 days), we will notify you in writing with the reason for extension. Responses will be delivered by mail or electronically, at your option, and if we cannot comply with a request we will explain why in our response. For Data portability requests, we will select a readily usable, electronic format to provide your Data that should allow you to transmit the Data to another entity.

We do not charge a fee unless requests are excessive, repetitive, or unfounded. If a fee is warranted; we will explain why and provide you with a cost estimate before completing your request.

G. Sensitive Data Rights

Sensitive Data is a subtype of Personal Data consisting of specific Data categories described in the State Privacy Laws. We generally do not collect information that is considered “sensitive” under State Privacy Laws. In the limited circumstances that we do, such as collection of Affiliate account login credentials and password, which is considered “sensitive” under the CCPA, we do not use or disclose sensitive Personal Data for the purpose of inferring characteristics about you, and we do not sell or share it as defined by the CCPA, and thus it is not subject to CCPA requests to limit.

H. Do Not Sell or Share My Personal Data – Opt-Out Rights

Your State Privacy Law may provide you with the right to Opt-Out of the Sale or Sharing of your Personal Data, and the right to Opt-Out of use of your Personal Data for Targeted Advertising or Cross-Context Behavioral Advertising.

Please continue reading for details on our practices and instructions on how to opt-out.

I. Homes for Heroes Does Not Outright “Sell” Personal Data

We do not sell consumer Personal Data in the traditional sense of the word “sell.” Homes for Heroes does, however, share Data in a way that is considered a “sale” under certain State Privacy Laws. For example, we utilize third-party service providers for analytics purposes, and for our marketing efforts across the internet, including social media platforms.

II. Homes for Heroes Does Engage in the “Sharing” of Personal Data for Targeted Advertising

We use cookies, and allow our service providers and advertising partners to use similar technologies, so we can, among other things, show you ads promoting Homes for Heroes on other sites and services. In this Notice, we generally use the term Targeted Advertising, but these activities may be considered “sales,” “sharing,” “targeted advertising,” or “cross-context behavioral advertising” under State Privacy Laws or other applicable laws. The CCPA, for instance, defines “sharing” to include cross-context behavioral advertising, which means disclosing Personal Data for purposes of serving you advertisements that are relevant to you based on your activity across our Services and other sites. Like many companies, we use outside services to help deliver interest-based ads to you, and our Site uses cookies which allow advertising companies to collect your Personal Data for our or their benefit.  

However, we have configured our Site so that you control Targeted Advertising and other cookies on our Site. Please review the information below, and visit Section 12 of this Notice for specific instructions on how to opt-out.

III. Opt-Out of Tracking on this Site

You can opt out of having your Personal Data used or disclosed for these purposes via cookies, web beacons, pixel tags, and similar tracking technologies placed during your visit to this Site by indicating your choice using our Cookie Preferences Center, or by visiting this Site with a legally recognized opt-out preference signal such as the GPC. You will need to renew your opt-out choice if you visit the Site with another device or browser, or if you clear your cookies. You may disable cookies in your browser or set your browser to warn you when a cookie is being sent. You may lose some features or functionality when you disable cookies. Remember, also, that disabling cookies is browser specific. If you log on using Microsoft Edge, you must also disable cookies in Safari, Google Chrome, Firefox or other browsers if you use those browsers at a different time. Please note certain cookies and other technologies allow our Site to securely operate, provide a better navigation experience, and facilitate Services you may request from Homes for Heroes. Those essential, functional, and analytic technologies provide you with a more efficient and functional experience, and help us to understand how you navigate and use our Site. When you refuse those supporting technologies, it will affect how our Site functions and whether our Site recognizes you as a prior user or not.

IV. Opt-Out of Disclosure to Others for Ads

We also disclose certain information to our advertising or other partners, such as your email address, so they can show you ads that are more relevant to your interests. To opt-out of “sales,” “sharing,” “Targeted Advertising,” or “cross-context behavioral advertising” associated with your email address, visit this form and submit the required information. Note that some transfers of your Personal Data may not be considered “sharing,” and certain exemptions may apply under State Privacy Law or other applicable law. Your choices do not affect other disclosures of your Personal Data, as outlined in this Privacy Notice, such as when we process payments, provide Services you request, or prevent fraud.

V. We do not Use or Disclose Sensitive Data for Advertising Purposes

We do not process or share sensitive Personal Data for cross-context behavioral advertising, for Targeted Advertising, and we do not sell it.

I. Right to Non-Discrimination and No Retaliation

The State Privacy Laws provide consumers the right not be discriminated against for opting out or exercising privacy rights conferred by applicable State Privacy Laws. Unless permitted by applicable State Privacy Laws, we will not:

• Deny you Services;
• Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of Services;
• Suggest that you may receive a different price or rate for Services or a different level or quality of Services.

However, we may offer you certain financial incentives permitted by applicable privacy laws that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your Personal Data’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

19. Updates to this Notice

We may change this Privacy Notice from time to time so please check back often. If we make changes, we will notify you by updating the Effective and Last Updated dates at the top of this Notice. If we significantly change our collection, use, or disclosure practices, we may provide additional notice such as by adding a statement to our home page, by sending you a notification, or sending an email if you have provided us with an email address. Please note that some of the Services mentioned specifically in this notice may not be immediately available on the Site at this time.

20. Contact Us

If you need further assistance, have questions about our privacy practices, or if you would like to exercise your privacy rights, please contact us using one of the methods below:

Phone: (866) 433-7637

Email: support@homesforheroes.com

Submit a request: through the TLS encrypted web form available here.

Write us: 

Homes for Heroes, Inc. and the Homes for Heroes Foundation receive mail at :

14702 Excelsior Blvd. #1147

Minnetonka, MN 55345. 

Please address your letter to the entity you wish to reach.
If you wish to appeal a denial or limitation of your privacy rights request, you may email us at support@homesforheroes.com.