Supplemental Privacy Notice for California Residents

Effective Date: December 20, 2021

Last Revision or Review: December 20, 2021

This is the Supplemental Privacy Notice for California Residents (the “California Notice”) of Highland Homes LLC (the “Company” or “us”). This supplements the information contained in the Company’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt the California Notice to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. In the event that any provisions of the California Notice conflict with other provisions of the Company’s Privacy Notice, the provisions in the California Notice will control with respect to California residents.

The California Notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in the California Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (”B2B personal information”) from some of its requirements.

Personal Information Collected by Company and Purposes of Collection

For purposes of the California Notice “personal information” or “PI” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” “PI” includes eleven categories of information (the “PI Categories”): (1) identifiers, (2) other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), (3) protected classification characteristics under California or federal law, (4) commercial information, (5) internet or other similar network activity, (6) geolocation data, (7) biometric information, (8) sensory data, (9) professional or employment-related information, (10) non-public education information, and (11) inferences drawn from other personal information. As provided by the CCPA, PI does not include publicly available information from government records, deidentified or aggregated consumer information, or certain personal information protected by other sector-specific federal or California statutes.

Company collects PI from PI Categories (1), (2), (3), (4), (5), (9) and (11) listed above. We obtain this personal information from the following categories of sources:

Customer-provided information from forms or direct interactions with Company
Customer interactions with Company’s website
Internet cookies
Data brokers or resellers

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information
To facilitate future communications with you
To provide, support, personalize and develop our Website, products and services
To process your requests and transactions and prevent fraud
To provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
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.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users or customers is among the assets transferred.

Company will not collect PI from additional PI categories or use the PI collected by the Company for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of Personal Information

The Company may disclose your personal information to third parties for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. However, in the preceding twelve (12) months, Company has not sold personal information to any third party. Company does not and will not sell personal information.

For each of the PI Categories, the chart below indicates

whether the Company has collected the PI Category from its consumers within the last 12 months,
the categories of third parties to whom PI within the PI Category has been disclosed in the last 12 months.

Category	Collected	Business Purpose Disclosures
Identifiers, such as real name or alias, postal address, email address, unique personal or online identifier, internet protocol (IP) address, account name, Social Security Number (SSN), driver’s license or passport number, or another form of persistent or probabilistic identifiers that organizations can use to identify a particular consumer, family or device.	YES	Service providers Advertisers / advertising networks Affiliates, partners, parent and/or subsidiary organizations Social media companies Internet cookie data recipients (like Google Analytics) Internet service providers Data analytic providers Government entities Operating systems and platforms Data aggregators
The California Customer Records statute’s personal information categories, which include both the identifiers listed above and a person’s signature, state identification card number, physical characteristics or description, insurance policy number, education, employment or employment history, bank account number, credit card number, debit card number, or any other financial information, or medical or health insurance information.	YES	Service providers Advertisers / advertising networks Affiliates, partners, parent and/or subsidiary organizations Social media companies Internet cookie data recipients (like Google Analytics) Internet service providers Data analytic providers Government entities Operating systems and platforms Data aggregators
Protected classification characteristics under California or federal law (such as race, national origin, religion, gender, or age (40 years or older)).	YES	Service providers Affiliates, partners, parent and/or subsidiary organizations
Commercial information (including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	YES	Service providers Advertisers / advertising networks Affiliates, partners, parent and/or subsidiary organizations Social media companies Internet cookie data recipients (like Google Analytics) Internet service providers Data analytic providers Government entities Operating systems and platforms Data aggregators
Internet or other similar network activity including browsing history, search history, or information regarding a consumer’s interaction with an internet website, application or advertisement	YES	Service providers Advertisers / advertising networks Affiliates, partners, parent and/or subsidiary organizations Social media companies Internet cookie data recipients (like Google Analytics) Internet service providers Data analytic providers Government entities Operating systems and platforms
Geolocation data (such as physical location or movements)	NO	N/A
Biometric information including genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	N/A
Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.	NO	N/A
Professional or employment-related information.	YES	Affiliates, partners, parent and/or subsidiary organizations
Non-publicly available educational information (as defined under the Family Educational Rights and Privacy Act and related regulations (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO	N/A
Inferences drawn from other personal information to create consumer profiles reflecting: preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.	YES	Service providers Advertisers / advertising networks Affiliates, partners, parent and/or subsidiary organizations Social media companies Internet cookie data recipients (like Google Analytics) Internet service providers Data analytic providers Government entities Operating systems and platforms Data aggregators

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.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”) over the past 12 months. Once we receive and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or disclosing that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).

The above access and data portability rights do not apply to B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions (the “right to delete”). Once we receive and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; and/or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

The above deletion rights do not apply to B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Calling us at 1-888-379-1635.

Emailing us at [email protected]

Visiting Highlandhomes.com and clicking on the email link provided

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent you must provide the authorized agent written, signed permission to make the verifiable consumer request on your behalf. Additionally, before we will provide specific pieces of Personal Information to an agent, you must verify your identity directly with us and confirm (directly with us) that you have given the agent permission to submit the request for specific pieces of information. Alternatively, an authorized agent may make a verifiable consumer request based upon a power of attorney pursuant to California Probate Code sections 4000 to 4465. We may deny a request from an agent if these requirements are not met.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative), which may include:
Email and password (for customers with password protected accounts)
For non-account holders who make requests to know categories of personal information or for deletion, personal information data points that match at least two data points maintained by us
For non-account holders who make requests for specific pieces of personal information, personal information data points that match at least three data points maintained by us, together with a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request
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.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account if possible. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of you request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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

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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We do not currently provide financial incentives.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or a letter to Highland Homes, Attn: Doug Lukasik, 5601 Democracy Drive, Suite 300, Plano, TX 75024.

Changes to the California Notice

We reserve the right to amend this Supplemental Privacy Notice for California Residents at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-888-379-1635
Email: [email protected]

Highland Homes
Attn: Doug Lukasik
5601 Democracy Drive, Suite 300
Plano, TX 75024

If you need to access the California Notice in an alternative format due to having a disability, please contact [email protected] or call 1-888-379-1635.

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