Ponds Properties want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect about consumers (“you”) through:

Collectively, we refer to the Ponds Properties Websites, the Apps, our emails, and offline interactions as the “Services.”

Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information including:

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

—We collect Personal Information through the Services, for example, when you fill out a user profile when using our Services, register an account to access the Services, request a market analysis of your home, or contact us by telephone.

—We receive your Personal Information from other sources, for example: ○publicly available databases;

○joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people, such as your friends or family, to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes including:

—To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related user support services.

—To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions or comments, or when you request other information about our Services.

—To send administrative information to you, such as changes to our terms, conditions and policies.

—To allow you to send messages to another person through the Services if you choose to do so. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

—To send you marketing related emails with information about our services, new products, and other news about our company.

—To facilitate social sharing functionality that you choose to use.

—We will engage in this activity with your consent or where we have a legitimate interest.

—To analyze or predict our users’ preferences in order to prepare aggregated trend reports, so we can improve our Services.

—To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

—To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

—We may offer you the opportunity to participate in a sweepstakes, contest or other promotion. —Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

—We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

—For data analysis, for example, to improve the efficiency of our Services;

—For audits, to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements;

—For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

—For developing new products and services;

—For enhancing, improving, or modifying our current products and services;

—For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

—For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

—For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interests.

Disclosure of Personal Information

We disclose Personal Information:

—These can include providers of services such as data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, user support service, email delivery, auditing, and other services.

—We may share your Personal Information with selected third-party business partners for our partners’ own business purposes, including to enable them to send information about products and services that may be of interest to you, consistent with your choices. Please refer to “Choices and Access” below, for information about the choices we offer concerning such sharing.

—On message boards, chat, blogs, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

—This may include laws outside your country of residence.

—To respond to a request or to provide information we believe is important. —These can include authorities outside your country of residence.

—For example, when we respond to law enforcement requests and orders or provide information we believe is necessary or appropriate.

—To enforce our terms and conditions; and

—To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

—We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

—Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

When you download and use Ponds Properties Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

—Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs. You can learn more about our cookie policy here: http://www. Ponds Properties.com/ Ponds Properties /cookie-policy.html

—We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the“Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

TO OPT OUT– Please contact us at [email protected]PondsProperties.com for assistance with the above. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as certification to the EU-U.S. Privacy Shield Framework, to protect your Personal Information (please see our EU-U.S. Privacy Shield Statement at the end of this policy). You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Updates to this Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected] Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Additional Information Regarding the EEA

You may lodge a complaint with an EU/EEA data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

EU-U.S. Privacy Shield Statement

Ponds Properties comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Ponds Properties have certified that they adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification pages, please visit: https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Ponds Properties commit to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact [email protected]. Ponds Properties have further committed to refer unresolved Privacy Shield complaints to BBB EU PRIVACY SHIELD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information or to file a complaint. The services of BBB EU PRIVACY SHIELD are provided at no cost to you.

Ponds Properties are subject to the investigatory and enforcement powers of The Federal Trade Commission (FTC). It is possible, under certain conditions, for individuals to invoke binding arbitration.