Private Policy

Your privacy is important to us. This Privacy Policy (this “Policy”) applies to services provided by LUVA Homes, LLC. (“we,” “us,” “our”, “LUVA”, or “LUVA Homes”), as well as our affiliates and subsidiaries, and to our website (the “Site”), mobile app and/or other platform(s) (collectively, the “Services”) and explains what information we collect from users or visitors of our Services (each, a “user,” “you” or “your”), including information that may be used to personally identify you (“Personal Information”), and how we use it. We encourage you to read the details below. This Policy applies to any user of our Services. We will be the controller of your persona data provided to, collected by or for or processed in connection with our Services.

We reserve the right to change this Policy at any time. We will notify you of material changes to this Policy by sending notice to the primary email address specified in your account or by a prominent notice on our website. Changes and clarifications will take effect immediately. You should periodically check our website, including the page on which this Policy is located, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and/or sharing of your Personal Information is subject to the updated Policy.

1. What Information Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information. “Personal Information” generally refers to any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person, but, the definition of "Personal Information" may vary depending on the state or country in which you reside, and that state’s or country’s definition will apply to your Personal Information in the context of this Privacy Policy. Please see additional information below on the particular information we may collect.

Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

2. What Information Do We Collect?

Information Provided by You

We collect information that you knowingly give us when you create an account, contact us or otherwise access or use our Services. This may include:

Your full name, email address, residential address, zip code, citizenship, telephone number, date of birth, employment information (including status and employer information, if applicable), information regarding investor “accreditation” and suitability, responses to surveys that we may ask you to complete for research purposes or to help direct LUVA Homes activities and social media account information;
The contact information of your representative, if any; and/or
Details of any financial transactions you participate in on the Services, including the amount, currency and method of payment.

Information Collected Automatically

We automatically or passively collect information when you access or use our Services. This may include:

Device type used to access our website (i.e., computer or mobile device), unique number assigned to identify such device, your device's operating system, your device's application version and your device's internet protocol (IP) address;
Whenever you visit or interact with our website, information about how our website is accessed and used, including, but not limited to, click path taken through our website, your use of features or applications on our website and/or other publicly available information; this data is generally non-identifying, but, if we associate it with you as an identifiable person, we will treat it as Personal Information; and/or
If you access our Services from a mobile device, your device's unique mobile platform advertising identifier, such as Apple's “Identifier for Advertising ID” or Google's “Android Advertising ID” (“mobile advertising identifiers”), and the ways you use the Services.

3. How Do We Use the Information We Collect?

We use the information we collect to:

Deliver and improve the Services and your overall user experience;
Protect against, investigate and deter fraudulent, unauthorized and/or illegal activity;
Link or combine user information with other Personal Information;
Compare and verify information for accuracy and update our records;
Validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols;
Email, text message, message or otherwise contact you with information and updates about us and the Services, and respond to your comments and questions if you've provided us with the means to do so;
On a de-identified, aggregated basis, analyze how you use the Services with tools like Google Analytics to help us understand traffic patterns and know if there are problems with the Services; and/or
Create targeted advertising to promote the Services and engage our users.

4. Do We Share Your Personal Information?

We do not rent, sell or share your Personal Information with third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized in this Policy.

In connection with the Services, we may provide your Personal Information to the following third parties:

Partners: Sometimes we collaborate with others, including our broker-dealer and escrow partners, to deliver the Services, and may provide such Personal Information as required by our partners who do not have an independent use of the information we disclose to them.
Affiliates: We may share your information with our affiliates and/or subsidiaries.
Service providers: We work with a wide range of third-party service providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, identity verification services and other non-governmental organizations, and may provide such information as required by any such service provider in connection with the performance of the applicable service.
Payment providers: We work with payment providers such as Paypal, Stripe, Dwolla and Plaid to facilitate the payment process in the Services. These providers will store certain information about you.

LUVA uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant LUVA and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and/or to protect our rights or property. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in this Policy.

The manner in which partners, service providers and payment processors use, store and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s).

We will also share Personal Information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your Personal Information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harm our legal rights or safety. This may include the incorporation of your Personal Information into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.

5. How Do We Use Tracking Technologies?

A “cookie” is a small file placed on your hard drive by a web page. We, or third parties we do business with, may use cookies to help us analyze our web page flow; customize our services, content and advertising; measure promotional effectiveness; and promote trust and safety. Cookies and pixel tags are commonly used at most major transactional websites in much the same way we use them in our Services.

Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected. This information will be collected every time you access the Services and will be used for the purposes outlined in this Policy.

You can prevent or limit the usage of cookies collected from your device. An easy way of doing this is to change the settings in your browser. If you do so: (a) your use of the Services may be adversely affected (and possibly entirely prevented); (b) your experience of our website and other websites that use cookies to enhance or personalize your experience may be adversely affected; and (c) you may not be presented with advertising that reflects the way that you use our website and other websites. You find out how to make these changes to your browser at this site: https://www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings to refuse cookies, our system will send cookies as soon as you access our Services. By using the Services, you consent to this use.

Web beacons, also known as pixel tags, may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Site or access the Services and to help determine how you found the Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance's website, https://youradchoices.com/, or the Network Advertising Initiative's website, https://optout.networkadvertising.org/?c=1.

6. How Do We Secure Your Personal Information?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser, including by signing off after you have finished accessing your account.

We are committed to safeguarding the confidentiality of your information but cannot guarantee the security of your information. We provide physical, electronic and procedural safeguards to protect information we process and maintain. For example, we (a) encrypt any information we store, (b) transmit information via https and (c) limit access to this information to (i) authorized employees and contractors who need to know that information in order to operate, develop and/or improve the Services and (ii) third parties that must receive that information in order to facilitate provision of the Services. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. Unauthorized entry or use, hardware or software failure and/or other factors may compromise the security of user information at any time. If you believe your information may not be secure for any reason, please contact us immediately at info@luvahomes.com.

7. Your Choices Regarding Information

You have several choices regarding the use of Personal Information on the Services.

Changing or Deleting Your Personal Data

All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at info@luvahomes.com or, in certain cases, by accessing your user account. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account will be deactivated. If you wish to cancel your account, you may do so by emailing info@luvahomes.com, and any Personal Information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law, subject to our data retention policy.

Data Retention

We retain information we receive for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Download or Access Personal Information

You can ask us for a copy of your Personal Information, including a copy in machine readable form, by emailing us at info@luvahomes.com.

Opting Out of Email Communications

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at info@luvahomes.com to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this Policy.

8. Links to Third-Party Websites

We may provide links to third-party websites. We have no control over these websites, and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products or other materials on or available from, these third-party websites. By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products or other materials on or available from these third-party websites.

9. Links to Other Websites

You may find links to other Internet sites or resources on this Website that offer content, goods, or services. A link from this Website to a third party website does not imply endorsement of that website nor any ability to control that site’s contents, products or privacy practices. You acknowledge and agree that LUVA has no responsibility or liability (directly or indirectly) for: (1) the availability of such external sites or resources; (2) the availability or accuracy of any content, advertising, products, or other materials on or available from such sites or resources; or (3) any damage, loss, claim, or complaint (actual or alleged) caused by, arising from, or in connection with Your use of or reliance on any such content, goods, or services available on or through any such site or resource.

10. How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from your browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit https://allaboutdnt.com/.

If you access our Services from a mobile device, we may collect mobile advertising identifiers to provide certain Services. Users may be able to opt out of interest-based advertisements through the most recent applicable settings features of their mobile devices. These opportunities are subject to the offerings made available by the third-party operating system providers and subject to their privacy policies, and not any offerings by or the privacy policy of the Company. For convenience, the following are opt-out instructions that may apply to your mobile device, though please note that the setting features may vary from device to device:

For iOS devices with iOS 7 or higher: open Settings > select Privacy > select Advertising > enable Limit Ad Tracking; and
For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: open the Google Settings app > select Ads > enable Opt out of interest-based advertising.

Please note, however, that opting out of mobile advertising identifier collection may prevent certain Services from functioning properly.‍

11. Third-Party Direct Marketing

We do not share personal data with third parties for their direct marketing purposes without your consent.

12. A Note to Users Outside the United States

LUVA Homes is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. 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 consent to the transfer of information 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.

13. Plugins

We integrate social media application program interfaces or plug-ins from social networks, including Facebook, LinkedIn, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.

For example, when you visit our Website and create an account using your Facebook account login, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.
If you do so, you authorize us to access certain social media account information, such as your public social media profile (consistent with your privacy settings in your social media profile), name, email address, and profile picture. Plug-ins may transfer information about you to the plug-in's respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a plug-in will transmit information directly to that Plug-in's social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform's privacy policy, and not by our Privacy Policy. You can find the Privacy Policy for a platform on their website.

Cookie Policy: Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to perform such actions as including, but not limited to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up the page load time; and/or, (d) recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (such as Internet Explorer, Edge, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies. These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies. These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies. These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

You may refuse to accept browser cookies by activating the appropriate setting in your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We also use cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website which parts of our content interest you the most and which Service categories you request. This tracking uses De-Identified Personal Information data. We will not combine this data with your other Personal Information without your express permission. Some of our contracted vendors and affinity partners are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected.

Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using Cookies, the Website may employ "pixel tracking," a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A "pixel tag" is an invisible tag placed on certain pages of websites that is used to track an individual user's activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.

IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol ("IP") address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Google Services We Use

Google Analytics. We use, and some of our third-party service providers may use, Google Analytics or other analytics service to help us understand use of our Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.

Google Advertising Cookies. Google, as a third-party vendor, uses cookies to serve ads on our Website. Google's use of various advertising cookies enables it to serve ads to our users based on previous visits to our Website and other sites on the Internet.

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.

Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, and both of which are subject to their own terms of use and privacy policy.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out of seeing interest-based ads by using the Interest-Based Ads Opt Out Chrome browser extension.

You may also opt out of Network Advertising Initiative (NAI)'s interest-based advertising.

14. Children

We do not use the Services to knowingly solicit data from, or market to, children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@luvahomes.com. We will delete such information from our files within a reasonable time.

15. Contact Us

If you have any questions about this Policy, your Personal Information, or the Services, you can contact us in writing to info@luvahomes.com or to the following address:

LUVA Homes LLC

Attn: Claims Officer
1000 Brickell Ave STE 715

Miami, Florida 33131