Effective Date: January 6th, 2026

This Privacy Policy for California Residents supplements the information contained in HomeExchange Inc. with an address at C/O WEWORK, 625 Massachusetts Avenue, Cambridge, MA 02139 (“HomeExchange” or “we”) Privacy Policy and describes how HomeExchange collects and uses personal information from users who reside in the State of California across various platforms, including www.homeexchange.com, the HomeExchange application, other websites, mobile sites, services, applications, and platforms operated by HomeExchange where this Privacy Policy for California Residents is featured or referenced, or where no separate Privacy Policy for California Residents is provided, as well as from customers who reside in the State of California and interact with us through other channels (collectively, the “Sites”). The words “user”, “you” and “your” in this Privacy Policy for California Residents refer to a user of the Sites. 

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA) (collectively, the “CCPA”) and other California privacy laws, and any terms defined in the CCPA have the same meaning when used in this notice. 

Information We Collect
HomeExchange has collected the following categories of personal information from its consumers within the last twelve (12) months: 

A. Identifiers
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

• Examples: A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.

• Examples: Age (40 years or older).

D. Commercial information.

• Examples: Records of personal property, services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Internet or other similar network activity.

• Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

F. Inferences drawn from other personal information.

• Examples: Profile reflecting a person’s preferences and characteristics.

HomeExchange may collect some sensitive personal information, such as your driver’s license, state identification card, or passport number, for the purpose of providing you with the service you requested.

Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, and information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

A. Sources From Which Personal Information is Collected

HomeExchange obtains the categories of personal information listed above from the following categories of sources:

• Directly from you: Information provided by registering on our Sites, subscribing to our newsletter, purchasing a membership, contacting us through the Sites or via email, etc.;
• Automatically collected information: When you access our Sites, some information is automatically collected, such as through cookies and web beacons as specified in the Cookie Policy [Provide link], in order to ensure the functionality of our Sites; and 
• Third party sources: We may collect information from third parties to whom you have provided your information, and consented to the sale, rental or transfer thereof (for example, through social media). 

B. Business or Commercial Purposes for Collection of Personal Information

We may collect the personal information for one or more of the following business or commercial purposes:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a service, we will use that information to process your order and provide the service;
• To monitor and analyze trends, usage, and activities in connection with our services;
• To provide, support, personalize, and develop our Sites and services;
• To create, maintain, customize, and secure your account with us;
• To process your requests, purchases, transactions, and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses;
• To provide you with email alerts, promotional offers and other notices concerning our services;
• To facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 
• To personalize your Sites experience and to deliver content, information and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email, push notifications or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Sites and services, databases and other technology assets, our clients and business, and to ensure that our Sites are working as intended and for analytics, auditing and technical assistance purposes and other general business purposes;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HomeExchange’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by HomeExchange about our Sites users is among the assets transferred. 

HomeExchange will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice. 

II. Data Retention
HomeExchange retains personal information only for as long as necessary to provide our services and process your requests, purchases, transactions, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

III. Disclosing, Sharing for Cross-Context Behavioral Advertising, or Selling Personal Information
HomeExchange may disclose for a business or commercial purpose or share for cross-context behavioral advertising your personal information to a third party. When we disclose or share personal information, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

A. Personal Information We Disclose for a Business or Commercial Purpose 

In the preceding twelve (12) months, HomeExchange has disclosed the following categories of personal information for a business or commercial purpose: 

Categories of Personal Information Disclosed for a Business or Commercial Purpose

A. Identifiers.

• Categories of Third Parties: Hosting providers, CRM platforms, customer support vendors, email/SMS providers, identity verification vendors, payment processors, professional advisors, HomeExchange’s affiliates, HomeExchange’s successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies. 

B. California Customer Records personal information categories.

• Categories of Third Parties: Payment processors, fraud-prevention vendors, CRM and billing service providers, professional advisors, HomeExchange’s affiliates, HomeExchange’s successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

C. Commercial information.

• Categories of Third Parties: CRM platforms, analytics providers, customer support vendors, professional advisors, HomeExchange’s affiliates, HomeExchange’s successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

D. Internet or other similar network activity.

• Categories of Third Parties: Analytics providers, hosting providers, security vendors, professional advisors, HomeExchange’s affiliates, HomeExchange’s successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

E. Inferences drawn from other personal information.

• Categories of Third Parties: Analytics providers, CRM platforms, professional advisors, HomeExchange’s affiliates, HomeExchange’s successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

Business or Commercial Purposes for Disclosing your Personal Information
We may disclose the personal information we collect for one or more of the following business or commercial purposes: 

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a service, we will use that information to process your order and provide the service;
• To monitor and analyze trends, usage, and activities in connection with our products and services;
• To provide, support, personalize, and develop our Sites and services;
• To create, maintain, customize, and secure your account with us;
• To process your requests, purchases, transactions, and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses;
• To provide you with email alerts, promotional offers and other notices concerning our services;
• To facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 
• To personalize your Sites experience and to deliver content, information and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email, push notifications or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Sites and services, databases and other technology assets, our clients and business, and to ensure that our Sites are working as intended and for analytics, auditing and technical assistance purposes and other general business purposes;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HomeExchange’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by HomeExchange about our Sites users is among the assets transferred. 

B. Personal Information We Share for Cross-Context Behavioral Advertising or Sell

In the preceding twelve (12) months, HomeExchange has not sold personal information of California residents. 
In the preceding twelve (12) months, HomeExchange has shared for cross-context behavioral advertising the following categories of personal information: 

Categories of Personal Information Shared for Cross-Context Behavioral Advertising

A. Identifiers.

• Categories of Third Parties: Advertising partners, analytics providers, social media platforms

B. Commercial information.

• Categories of Third Parties: Advertising partners, analytics providers

C. Internet or other similar network activity.

• Categories of Third Parties: Analytics cookie vendors, advertising cookie vendors, social media, tracking tools

D. Inferences drawn from other personal information.

• Categories of Third Parties: Advertising partners, analytics providers

1. Business or Commercial Purposes for Sharing for Cross-Context Behavioral Advertising or Selling your Personal Information

We may share personal information for cross-context behavioral advertising the personal information we collect for one or more of the following business or commercial purposes: 

• To deliver content and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law); and
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

2. Right to Opt-out of Sharing for Cross-Context Behavioral Advertising or Selling
If you are age 16 or older, you have the right to direct us not to share for cross-context behavioral advertising or sell your personal information at any time. We do not share for cross-context behavioral advertising or sell the personal information of consumers we have actual knowledge are less than 16 years old.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link: “Do Not Sell or Share My Personal Information”.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing for cross-context behavioral advertising. 

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Please note that if you visit our Sites with the Global Privacy Control opt-out preference signal enabled, we will automatically treat this as a request to opt-out for the device and browser that you use to visit the Sites. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.

IV. Use and Disclosure of Sensitive Personal Information 
We do not use or disclose your sensitive personal information for any other purpose other than to perform business services, including providing our products and services to you.

V. Your Rights and Choices 
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights

You have the right to request that HomeExchange disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will disclose to you:

1. The categories of personal information we collected about you;
2. The categories of sources from which we collected personal information about you;
3. Our business or commercial purpose for collecting, selling or sharing your personal information for cross-context behavioral advertising;
4. The categories of third parties with whom we share your personal information for cross-context behavioral advertising; and
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. Additionally, if we sold, shared for cross-context behavioral advertising, or disclosed your personal information for a business or commercial purpose, we will provide you with two separate lists disclosing: (i) The categories of personal information HomeExchange shared for cross-context behavioral advertising or sold to third parties and for each category identified, the categories of third parties to whom it sold or with whom it shared for cross-context behavioral advertising that particular category of personal information; and (ii) The categories of personal information HomeExchange disclosed for a business or commercial purpose to third parties and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.

B. Deletion Request Rights 

You have the right to request that HomeExchange delete any of your personal information that it collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 
We may deny your deletion request in compliance with the CCPA if retaining the information is necessary for us or our service provider(s) to, among others: complete the transaction for which we collected the personal information, provide a good or service that you requested or take actions reasonably anticipated within the context of our ongoing business relationship with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Correction of Inaccurate Personal Data Rights 

You may update or correct your personal information free of charge, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct (and direct our service providers to correct) your personal information in our records, unless an exception applies. We may ask that you identify yourself and the information you wish to change for security purposes.  

VI. Exercising Access, Data Portability, Deletion and Correction Rights
To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us via our Contact form.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format
We shall confirm receipt of a customer’s request to know or delete within ten (10) business days. We endeavor to respond to a verifiable consumer request to access, delete or correct within forty-five (45) days of its receipt, and to a verifiable consumer request to opt-out of selling or sharing their personal information or to limit use of their sensitive personal information within fifteen (15) business days of its receipt. If we require more time (up to 45 days) to respond to a verifiable consumer request to access, delete or correct, we will inform you of the reason and extension period in writing within the initial forty-five (45) days after receipt of the verifiable consumer request.

If you have an account with us, our written response to your verifiable consumer request will be delivered through such account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Any disclosures we provide pursuant to a verifiable consumer request will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. If applicable, our response will also explain the reasons we cannot comply with your request.  

We do not charge a fee to process or respond to your verifiable consumer request, unless such request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons of such decision and provide you with a cost estimate before completing your request. 

VII. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliate against you for exercising your CCPA rights.

VIII. Other California Privacy Rights
Pursuant to California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834; or by telephone at (800) 952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: www.ftc.gov.

IX. Changes to Our California Privacy Notice
HomeExchange reserves the right to amend this privacy notice at its discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. 

X. Contact Information
If you have any questions or comments about this notice, the ways in which HomeExchange collects and uses your information described above and in the Privacy Policy your choices and rights regarding such use, please do not hesitate to contact us at dpo@homeexchange.com.