Privacy Policy

LAST UPDATED: June 29, 2020

Welcome to Toura! Toura is provided by Toura LLC, a wholly-owned subsidiary of Simple Showing, Inc.(collectively referred to herein as “we,” “us,” “our,” or “Toura”). We respect your privacy and the importanceof the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to helpyou understand the kinds of information we may gather about you when you use our online and/or mobileservices, website, and software provided by or in connection with the service (collectively the “Services”), howwe may use and disclose the information, and how you can control, correct and/or update the information. Byaccessing or using the Services, you are accepting the policies and practices described in this Policy. Each timeyou visit or use the Services, and whether you interact with the Services as a seller, prospective purchaser oragent (“User”), you agree and expressly consent to our collection, use and disclosure of the information that youprovide as described in this Policy. Any capitalized terms not defined herein shall have the meaning as set forthin the Toura Terms of Service.

Please note that this Policy does not apply to your use of third-party sites, services, or applications you mayaccess through the Services. We encourage you to review the privacy policies of those third parties for moreinformation regarding their privacy practices.

INFORMATION WE MAY COLLECT

Information You Provide to Us

We collect information you provide directly to us when using the Services. For example, we collect informationwhen you download our mobile application(s), register for our Services, sign up for an account, complete aform, participate in any interactive features of the Services, request customer support, or otherwisecommunicate with us. The types of information we may collect include your name, phone number, emailaddress, mailing and billing address and payment information, and any other information you choose to provide.For purposes of registering and using the Services, we collect certain information that can identify you, such asyour name and contact information (email, address and phone number) (“Personal Information”). Dependingon the type of User, we may also ask for additional information, including but not limited to, details about theproperty listing, location information, government photo identification, and photos. We will never sell, share,trade or use Personal Information other than as needed to verify a User’s identity, provide information asapplicable to another User and directly related to the Service being provided to you, and provide the Servicesrequested by you. For example, we may share your information if you request to be pre-approved for amortgage, or if you request Services that require engaging a real estate professional to complete such as anagent-assisted home showing or home valuation report.. Toura discloses Personal Information only to those ofits Users, employees, contractors and affiliated organizations that (i) need to know the information in order toprocess it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least asstrong as those herein. We also may collect device-specific information (such as your hardware model,operating system version, unique device identifiers, and mobile network information including phone number).We may associate your device identifiers or phone number with your account. Depending on the nature of yourinquiry or activities on the Services, we may also ask for other information relevant to your use of the Services.

Information We Collect Automatically When You Use the Services

When you access or use the Services, we automatically collect certain information about you, including the following:

  • Location Information: We may collect, now or in the future, information about the geo-location of yourdevice (using GPS or other geo-location data) to manage certain of the Services;
  • Log Information: We log information about your use of the Services, including the type of browser youuse, access times, pages viewed, your IP address, and the page you visited before navigating to theServices. Publicly available tools can sometimes provide the approximate location for IP addresses.
  • Device Information: We collect information about the computer or mobile device you use to access theServices, including the hardware model, operating system and version, unique device identifiers, andmobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies tocollect information, and this may include sending cookies to your computer or mobile device. Cookiesare small data files stored in device memory that help us to improve the Services and your experience,see which areas and features of the Services are popular, and count visits. We may also collectinformation using web beacons (also known as “tracking pixels”). Web beacons are electronic imagesthat may be used in the Services or emails and help deliver cookies, count visits, understand usage andcampaign effectiveness, and determine whether an email has been opened and acted upon.

We also may collect other types of information in the following ways when you use the Services:

  • Details of how you used and interacted with the Services, such as your search queries and how youresponded to certain questions.
  • Device event information such as crashes, system activity, hardware settings, browser type, browserlanguage, the date and time of your request and referral URL.
  • Our server logs automatically collect information, such as your IP address, your browser type andlanguage, and the date and time of your visit, which helps us track your movements around the Servicesand understand trends.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through theServices. For example, we may collect information about you from third parties who provide services on ourbehalf, such as maintaining and monitoring usage of the Services and processing payment transactions, whenapplicable. We also may receive information about you from the third parties with whom you interact throughthe Services. If you use the social networking connection functions offered through the Services, we mayaccess all of your social network profile information that you have made available to be shared and use it inaccordance with this Policy. Please refer to the instructions governing your social network account to managethe information that is shared through your account.

When you use the Services to visit a property, we will know the date and time the home was unlocked. Someproperties also have additional monitoring technologies such as motion sensors that provide information whenthere is activity in a house and video cameras monitored by a security service provider. We may also requestthat you use your smart device to verify your identity by uploading an image of a government ID and yourlikeness before we remotely unlock a home. We use an identity verification service provider to manage our IDverification. Toura does not maintain a copy of your ID after you upload it, and you may be required to resubmitverification information periodically at a later date. We do, however, retain certain information obtained fromthe ID such as your name, address, and whether you are over the age of 18 (but not your specific date of birth).There are some situations where we cannot get enough information from you to remotely unlock the door to aproperty using a smart lock. When this happens, you can still tour the home with the help of an agent.

USE OF INFORMATION

We may use information about you for various purposes, including the following:

  • Provide, maintain, and improve the Services:
  • Provide and deliver the products and services you request (including referrals when explicitlyrequested), process transactions, and send you related information;
  • Verify your identity and, if applicable, authorization for you to use the Services;
  • Process payment for Services;
  • Facilitate use of the Services;
  • Manage your account and your preferences;
  • To prevent or address service, security, technical issues at your request in connection with customersupport matters
  • Respond to your comments, questions, and requests;
  • Send you technical notices and other administrative messages;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by usor others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage, and activities in connection with car crashes, car crash data and theServices;
  • Conduct research, analysis, and surveys;
  • Personalize and improve the Services and provide content or features that match user profiles orinterests;
  • Enforce our Terms;
  • Link or combine with information we get from others in connection with the Services; and
  • Carry out any other purpose for which the information was collected

This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified soit is no longer associated with an identifiable user of the Services.

SHARING OF INFORMATION

We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:

  • With third party affiliates, contractors, and other Users in connection with providing the Services;
  • With affiliates, contractors, and other Users who need access to such information to carry out work onour behalf;
  • In response to a request for information if we believe disclosure is in accordance with any applicablelaw, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
  • If we believe your actions are inconsistent with the spirit or language of our Terms of Service orpolicies, or to protect the rights, property, and safety of you, us, or others;
  • In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition ofall or a portion of our business to another company;
  • With your consent, at your direction and/or as part of the service(s) you request (for example, we mayshare your information with agents when you request an agent-assisted or self-tour home showing orwhen you request more information about selling your home, or with financial partners if you requestmortgage preapproval.)
  • If we notify you through the Services that certain information you provide will be shared in a particularmanner and you provide this information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

ANALYTICS AND ADVERTISING SERVICES

Link or combine with information we get from others in connection with the Services; and Carry out any other purpose for which the information was collected.This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified soit is no longer associated with an identifiable user of the Services. SHARING OF INFORMATIONWe may share or transfer information about you as follows or as otherwise described in this Privacy Policy: With third party affiliates, contractors, and other Users in connection with providing the Services; With affiliates, contractors, and other Users who need access to such information to carry out work onour behalf; In response to a request for information if we believe disclosure is in accordance with any applicablelaw, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation; If we believe your actions are inconsistent with the spirit or language of our Terms of Service orpolicies, or to protect the rights, property, and safety of you, us, or others; In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition ofall or a portion of our business to another company; With your consent, at your direction and/or as part of the service(s) you request (for example, we mayshare your information with agents when you request an agent-assisted or self-tour home showing orwhen you request more information about selling your home, or with financial partners if you requestmortgage preapproval.) If we notify you through the Services that certain information you provide will be shared in a particularmanner and you provide this information.We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.ANALYTICS AND ADVERTISING SERVICESWe may allow others to provide analytics services in connection with the Services. In addition, our third-partyad servers, ad network providers, and third-party advertisers (the "Toura Ad Providers") may provide you withadvertisements that you may see on the Services or on other affiliated websites. These entities may use cookies,web beacons, clear .gifs and other technologies to collect information about your use of the Services, includingyour IP address, web browser, pages viewed, time spent on pages, links clicked, and to learn what types ofinformation are of most interest to the Users. We and others may use this information to, among other things,analyze and track data, determine the popularity of certain content, personalize the user experience, and betterunderstand your activity. Use of these technologies by Toura Ad Providers is subject to their own privacy policies and is not covered by our privacy policy. For more information regarding the choices you have aboutthese technologies (such as opting-out), click here to learn about Toura Ad Providers participating in theNetwork Advertising Initiative, and click here to learn about the Toura Ad Providers participating in the DigitalAdvertising Alliance. Toura has or may develop relationships with the following services: DoubleClick, Google,Marin Marketer and AdRoll. The Network Advertising Initiative and Digital Advertising Alliance offer somecentralized opt-out tools; otherwise you must visit each provider's website individually and opt out of Touramarketing service providers. If you do not want Toura and its marketing services providers to follow your usageof our Services via cookies and Web beacons, you can opt out of Cookies/Web beacons from: comScore,Google Analytics, Omniture and Yahoo! Opting out of these services does not mean you will no longer receiveonline advertising. It does mean that the service from which you opted out will no longer deliver ads tailored toyour Web preferences and usage patterns. Please note that, if you opt out and later delete your cookies, use adifferent browser, or use a different computer or other electronic device, you will need to renew your opt-outchoices.

SECURITY

We work hard to protect your information and take appropriate commercially reasonable physical, electronic,and other security measures to help safeguard personal information from loss, unauthorized access, alteration,or disclosure. Personal information will be processed and stored by Toura in databases hosted in the UnitedStates. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sentto or from the Services may not be secure. Therefore, you should take special care in deciding whatinformation you send to us via e-mail.

PHONE CALLS AND TEXT MESSAGES

You may receive phone calls and/or text/SMS messages from Toura and affiliated or independent partner agentsfor a variety of reasons – for example, you request a home showing, more information about selling your home,or to be contacted by an agent. You consent to receiving text messages when requesting our Services, even ifyou are registered on a federal or state do-not-call list. Note that standard carrier rates and charges may apply.You may opt out of text messages by emailing hello@tourahome.com.

PRIVACY POLICY CHANGES

Toura reserves the right to change, modify, add, or remove portions of this Policy at any time and without priornotice, and any changes will become effective immediately upon being posted unless we advise you otherwise.However, we will not use your Personal Information in a way that is materially different than the uses describedin this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of theServices after this Policy has been amended shall be deemed to be your continued acceptance of the terms andconditions of the Policy, as amended. We encourage you to review this Policy regularly.

CALIFORNIA PRIVACY RIGHTS

California law permits users who are California residents to request and obtain from us once a year, free ofcharge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to thoseparties. If you are a California resident and would like to request this information, please submit your request inan email tohello@tourahome.com.

Toura shall comply with the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq.,(“CCPA”), which may be amended from time to time. Per the terms of the CCPA, Toura is a Service Providerand not a Third Party as described in the CCPA. Therefore, Toura shall not:

a. Sell the Personal Information.

b. Retain, use, or disclose the Personal Information for any purpose other than providing theServices or for a Business Purpose. Specifically, Company shall not retain, use, or disclose thePersonal Information for a Commercial Purpose.

c. Retain, use, or disclose the Personal Information outside of the direct business relationshipbetween Toura and its Users.

Notwithstanding anything in the Terms of Service and End User License Agreement or any related order formor other document, the parties acknowledge and agree that a User’s provision of Personal Information is not partof and explicitly excluded from the exchange of consideration, or any other thing of value, between the parties.

CHILDREN UNDER THE AGE OF 13

The Services are intended for users who are eighteen (18) years of age and older. If you are under the age of 13,you are not permitted to submit any Personal Information to us. If you believe we might have any informationfrom or about a child under 13, please contact us at hello@tourahome.com.

RETENTION

We will retain your Personal Information for the period of time that is necessary to fulfil the original purposesfor which it has been collected. Please keep in mind that, in certain cases, a longer retention period may berequired or permitted by law or to allow us to pursue our business interests, conduct audits, comply with ourlegal obligations, enforce our agreements or resolve any dispute. The criteria used to determine our retention periods include:

  • Time needed to provide you with our Services.
  • Whether your account with us is active. You may contact us to make your account inactive at any time.
  • Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.

Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.

TRANSFER OF PERSONAL INFORMATION; INTERNATIONAL VISITORS

The Services are provided for access and use by persons located in the United States. If you use the Servicesfrom outside of the United States, you do so at your own risk. You are solely responsible for ensuringcompliance with the laws of your specific jurisdiction, including the specific laws of your jurisdiction regardingthe import, export, or re-export of the Services. If you are an international visitor, you acknowledge that byproviding your Personal Information, you are: (a) permitting the transfer of your Personal Information to theUnited States which may not have the same data protection laws as the country in which you reside; and (b)permitting the use of your Personal Information in accordance with this Privacy Policy.

OPTIONS

Your Information

You may update, correct or delete your information at any time by contacting us at hello@tourahome.com.Please note that we may retain certain information as required by law or for legitimate business purposes. Wemay also retain cached or archived copies of information about you for a certain period. Please note that we arenot responsible for storing any information that you provide to us or a third party or for any content orinformation that we or a third party provide to you. You are solely responsible for retaining backup files of anyinformation and content that you provide or receive in connection with the Services.

Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in thosecommunications or by emailing us at hello@tourahome.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations

HOW TO CONTACT US

If you have any questions about this Policy, or our information practices, please contact us by email at hello@tourahome.com.

LAST UPDATED: June 29, 2020