MyHomePoint Privacy Policy

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Effective Date: June 15, 2006

At MyHomePoint, we take the privacy of our users very seriously. This Policy describes, in detail, what personal data we collect, why we collect it and how we use it. Our Privacy Policy is closely modeled after the US Dept. of Commerce Safe Harbor guidelines (http://www.export.gov/safeHarbor) for privacy practice both in the US and the EU. MyHomePoint is a product of ThinkFirst, LLC.

The following should be referenced as the available methods for contacting us regarding this Policy or any other privacy or data concerns:

By email: support@myhomepoint.com

By postal mail:
Privacy Matters
c/o ThinkFirst, LLC
5406 Evans Ave.
Austin, Texas 78751
USA

Data We Collect and How it is Used

MyHomePoint is an opt-in, subscription based service. So that we may provide the full range of services possible to our customers, we collect the following types of data:

• Contact Information. Every user who creates an account must supply a basic set of identifying data including name and email address. These are used both for contact purposes (as outlined below) and for display purposes within the user’s private account.
• Cookies. When you visit MyHomePoint.com, we send one or more cookies - small files containing a string of characters - to your computer that uniquely identifies your browser. This is done to provide certain services like automating login when requested by the user. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent – see your specific browser instructions for additional details. Note that some features and services of MyHomePoint may not function properly if your cookies are disabled.
• User Communications. Users may choose to contact MyHomePoint staff through a variety of means: email, forum posts, blog or forum comments, etc. We may retain any communications in order to process inquiries, respond to issues or requests, or improve our services. Please be aware that if you voluntarily post public information to our user forums, company blogs, etc. that the information you post can be accessed by the public and can in turn be used by those people to send you unsolicited communications. Please be careful about publicly posting any personally identifiable information such as email address.
• Data Logging. MyHomePoint maintains automated logging of certain details about our users when they visit the site. The logged data may include information such as the web page requested, Internet Protocol (IP) address, browser type, browser language, the date and time of your request, number of log-ins and one or more cookies that may uniquely identify your browser. This is done for internal reporting and troubleshooting purposes.
• Other sites. This Privacy Policy applies only to MyHomePoint.com and any other websites or services, developed by ThinkFirst, LLC, that are expressly affiliated with MyHomePoint.com. We do not exercise control over third party websites displayed as links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you, and are governed by their own respective privacy policies.

The private data that we collect and store is used for the following purposes:

• Providing our users with personalized services such as private and group-oriented event calendars, task lists, contacts, email and mobile reminders, etc.
• Troubleshooting technical issues that may arise during the course of operation
• Responding to customer-initiated issues or inquiries
• Research and analysis so that we can maintain and continue to improve upon our services
• Sending communications for things like system down time, account status updates, billing receipts, etc.
• We may also send communications related to general news or promotional offers – any such communications will be opt-in only, and will provide a simple and clear means of opting out at any time.

Your Privacy Choices

When you sign up for MyHomePoint, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use. You can decline to submit personal information to any of our services, in which case MyHomePoint may not be able to provide those services to you.

More than one user can share a MyHomePoint account at the same time. MyHomePoint takes no responsibility for either the content of data shared among account users or the exposure of personal or private data among account users. Although certain data within MyHomePoint can be marked as individually private, for the purposes of this Policy, all data within a shared account is assumed to be personal and private to all account holders equally. It is up to each individual user of a shared account to maintain the level of data privacy appropriate to whom the account is being shared with.

Sharing with Third Parties

MyHomePoint only shares personal information with other companies or individuals outside of MyHomePoint in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of MyHomePoint, its users or the public as required or permitted by law.

If MyHomePoint becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties aggregated, non-personal data for the purposes of advertising or other statistical reporting. This data will not individually identify users of MyHomePoint.

We will not sell or otherwise share with third parties any individually identifiable personal data.

Accessing Your Personal Data

When you use MyHomePoint services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

At any time, you may request that any or all of your personal data be permanently deleted from our systems. You may request this by contacting us through one of the means listed at the beginning of this Policy. Please note that once you request that your data be deleted, it may take up to two (2) business days for this deletion to take effect. Also, once your access to the data has been removed, it may still take up to several weeks for your personal data to be completely removed from all of our internal systems.

Data Security

We take appropriate security measures to protect against unauthorized access to personal data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to employees of ThinkFirst, LLC, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data Integrity

MyHomePoint processes personal information only for the purposes for which it was collected and in accordance with this Policy. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Enforcement

ThinkFirst, LLC regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or our treatment of personal information by contacting us through our website at http://www.MyHomePoint.com or by writing to us at the address listed at the beginning of this Policy.

When we receive formal written complaints, it is our policy to contact the person regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between ThinkFirst, LLC and an individual.

Changes to This Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for example, email notification of policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.