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PRIVACY POLICY


1. INTRODUCTION

This policy describes how Opendoor collects, shares, and uses your information
when you access our services. This policy applies to all of the products and
services owned and operated by Opendoor Labs Inc., Opendoor Brokerage Inc., and
Opendoor Brokerage LLC (collectively, “Opendoor,” “we,” “us,” or “our”),
including the content, features, data, and software available on
www.opendoor.com, our mobile applications, and other websites or applications
that we operate (“Services”). 

To learn about the privacy practices of our affiliates, Opendoor Home Loans LLC,
or OS National (OS National LLC and OSN Texas LLC), and Digital Opendoor
Insurance Services LLC, please visit their respective privacy policies at
opendoorhomeloans.com/privacy_policy, https://osnational.com/privacy-policy, and
insurance.opendoor.com/privacy.


2. THE KINDS OF INFORMATION WE COLLECT

A. INFORMATION YOU PROVIDE

We collect content, images, and other information you provide to us when you
access our Services, including when you complete webforms on www.opendoor.com or
in our mobile application; create an account with us; communicate with us about
our Services via comments, direct message, e-mail, SMS message, or phone; or
respond to one of our surveys. 

Categories of information you may provide to us include:

 * Your name, address, phone number, and e-mail address;
 * Your account log-in details;
 * Photos and videos of your home (including metadata in the file);
 * Circumstances related to your purchase or sale of a home;
 * Homes you visit or view on our website or mobile application and your
   opinions about those homes;
 * Reviews or comments you leave on our website, mobile application, or on other
   public websites;
 * Your driver’s license or state ID information;
 * Real estate offer letters;
 * Information related to your financial ability to buy a home;
 * Citizenship status (for tax calculation purposes); and
 * Marital status (for tax calculation purposes).

When you request an offer for your home or do a virtual interior assessment with
us, please do not provide photos or record videos with people or any sensitive
information in them.

B. INFORMATION WE COLLECT FROM YOUR DEVICE(S)

We may collect the following information from the device that you use to access
our Services: 

 * Device attributes such as the operating system, hardware and software
   versions, battery level, signal strength, bandwidth, available storage space,
   browser type, app and file names and types, and plugins;
 * Information about operations and behaviors performed on the device, such as
   mouse movements (which can help distinguish humans from bots) or whether a
   window is in the foreground or background;
 * Identifiers unique to you, your device, or your account(s), such as device
   IDs, advertising IDs, and other similar static ID numbers such as those from
   apps or accounts you use;
 * Information you allow us to receive through device settings you turn on, such
   as access to your GPS location;
 * Network and connection information such as the name of your mobile operator
   or ISP, language, time zone, mobile phone number, and IP address; and
 * Data from cookies, tags, pixels, web beacons, and log files stored on your
   device, including cookie IDs, page views, how often you visit our website or
   mobile application, and links you click on.

We generally use this information for your convenience and to improve our
Services. For instance, we may use it to: (i) remember your information so that
you do not have to re-enter it; (ii) provide you with customized content and
information, including advertising; (iii) monitor the effectiveness of our
Services; (iv) monitor aggregate metrics such as total number of visitors,
traffic, and usage patterns; and (v) diagnose or fix technology problems.

C. INFORMATION WE COLLECT WHEN YOU CALL US

We may record phone or video calls with you for quality assurance purposes. Our
customer service team members also enter certain information you provide into
our customer service databases to ensure continuity and consistency throughout
your experience with Opendoor.

D. INFORMATION WE COLLECT FROM PARTNERS, SERVICE PROVIDERS, AND AFFILIATED
BUSINESSES

We may collect information about you from our partners, service providers, and
affiliated businesses in order to provide the Services, along with certain
related products and services such as home financing, title insurance, escrow
services, homebuilder partnership programs, real estate agent partnership
programs, and, in cases where Opendoor is not able to buy your home, access to
other potential purchasers or brokers, or to listing agents who may be able to
help with your home sale. 

Information we gather about you from our partners, service providers, and
affiliated businesses may include:

 * Multiple Listing Service (MLS) information about your home or the home(s) you
   are interested in buying;
 * Prequalification letters from financial institutions;
 * Construction or purchase contracts;
 * Verification of your identification and a risk score about you prior to
   allowing you smart-lock-enabled entry into an Opendoor-owned home;
 * Information related to completion of the construction of your new home (if
   you are working with a homebuilder);
 * Information about the condition of, and repairs to, your home and property;
 * Information related to your home purchase, sale, moving dates, and financing
   in connection with helping us facilitate “trade-in” deals;
 * Information about whether you may need homeowners insurance; and
 * Information about how you engaged with an Opendoor advertisement or social
   media post.

E. INFORMATION WE COLLECT FROM PUBLIC SOURCES

Much of the information necessary to help you buy or sell your home is available
from public government sources. We sometimes collect information from these
sources so that you do not have to spend time looking for and aggregating it for
us. For example, we may collect the following information about you and your
home from public sources:

 * Tax assessments of your home;
 * The school district and public transportation available near your home;
 * Information contained on the deed to your home, such as name, address, liens,
   encumbrances, and title;
 * Sale prices of homes similar to your home (called “comparables”);
 * The number of bedrooms and bathrooms in your home; 
 * Whether your home has access to features like a beach, boat dock, or parking
   garage;
 * Whether your home is in an earthquake or flood zone or has any other
   condition that would affect its market value;
 * Permits issued for remodels and additions; 
 * The finished and unfinished square footage of your home; and 
 * The year your home was built.

F. INFORMATION WE COLLECT THROUGH OUR MOBILE APPLICATIONS

When you access our Services through our mobile applications, we may receive
certain mobile device data such as a unique identification number associated
with your device, your device type and manufacturer, your mobile carrier,
subscriber status, payment method, phone number, caller ID data, and, depending
on your mobile device settings, your location information, including GPS
coordinates. 

We generally collect this information to provide and improve your experience
with the Services and to verify the identity and location of people who access
Opendoor homes. This helps us keep you and our properties safe. 

When you first launch our application or when you use it to visit an Opendoor
home, you may be asked to allow us to access your geographic location. If you
initially consent to this and change your mind, you can revoke your consent by
changing the geolocation preferences in your device settings.

G. INFORMATION WE COLLECT WHEN YOU VISIT AN OPENDOOR HOME

If you use our application to unlock an Opendoor home, we will know the date and
time the home was unlocked. Some of our homes also have additional monitoring
technologies such as motion sensors that tell us when there is activity in a
house and video cameras monitored by a security service provider. 

We may also request that you use your smart device to verify your identity by
uploading an image of a government ID before we remotely unlock a home. We use
an identity verification service provider to manage our ID verification.
Opendoor does not maintain a copy of your ID after you upload it and typically
would only obtain it from our identity verification service provider in
connection with a significant trust and safety incident or if requested by law
enforcement. We do, however, retain certain information obtained from the 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 one of our homes using a smart lock. When this
happens, you can still tour the home with the help of a real estate agent.


3. HOW WE USE THIS INFORMATION

A. TO PROVIDE OUR SERVICES

We use the information that we collect about you to deliver our Services,
including to personalize features and content to you. We use the information you
provide to give you options for home buying and selling that may be relevant to
your individual circumstances. As discussed in more detail below, you have
choices about how and whether we process some of your information. 

B. TO LEARN ABOUT THE HOME YOU MAY WANT TO SELL OR BUY

If you are interested in selling, we use information you provide to us about the
home, including photos and videos, to help us provide the Services to you and
others. If you are interested in buying a home, we may consider information you
provide us about the home you are interested in buying, including property
profiles that you have indicated your interest in, to try to match you with
homes you might want to purchase.

C. TO KEEP YOU, YOUR INFORMATION, AND OUR PROPERTIES SAFE

Opendoor cares about your safety. We use the monitoring and identity
verification technologies described above to help keep you safe when you visit
an Opendoor home and to prevent property damage and fraud.

D. TO ADVERTISE OUR SERVICES

We may use information collected about you to provide you with relevant
information about additional Services that Opendoor or our affiliated companies
offer, such as our trade-in program, home financing, and title insurance
services. Specifically, we use information about how you interact with our
website and mobile application, combined with information you provide us and
information we collect from other sources, to serve you relevant advertising.

E. TO DO MARKET RESEARCH

We are constantly striving to improve our customer experience. We conduct
research into all aspects of the home buying and selling process to try to
identify ways to make it better. Sometimes we use partner companies to conduct
surveys of willing participants who offer suggestions as to how we might improve
our Services. We also aggregate and analyze consumer information that we collect
on our website, mobile applications, and from conversations with our customer
service representatives to identify trends which inform how we change and
grow.  

F. TO SUPPORT INFORMATION SECURITY AND DEBUGGING

We may use information about you and your use of the Services to detect security
incidents, protect against malicious, fraudulent, or illegal activity, and
improve the security of our Services. We may also use this information to debug
our Services to identify and repair errors that impair existing intended
functionality.

G. IN CONNECTION WITH A DISPUTE

We may use personal information to prosecute or defend against claims in court
and other dispute resolution forums.


4. WHY AND HOW WE SHARE YOUR INFORMATION


A. AT YOUR DIRECTION 

We may share your information when you specifically direct us to do so. Examples
of these situations include:

 * Agent partnerships. Opendoor works with both consumers and real estate
   agents. We may share your information with our agent partners in order to
   pair you with an agent who can help you through the home buying or selling
   process. 
 * Builder partnerships. Opendoor partners with homebuilders to provide buyers
   who are purchasing new homes from these builders with the opportunity to
   request offers from Opendoor for their current homes. When you are working
   with a homebuilder, we may share your information with them. 
 * Financing providers. If and to the extent you authorize us to do so, we may
   share your information with home financing providers, including Opendoor Home
   Loans LLC.
 * Potential home buyers. We may work with trusted institutional home buyers to
   try to find a purchaser for the home.
 * Escrow, closing attorney, title, homeowners’ insurance. If you need escrow,
   closing attorney, title insurance services, or homeowner’s insurance
   services, we may share your information with escrow, closing attorney, title,
   and homeowner’s insurance companies. 
 * Renovation companies. If you need renovation services, or to help us evaluate
   or repair homes we may acquire, we may share your information with renovation
   and construction companies.  
 * Other partners with whom you ask us to share your information.


B. WITH OUR AFFILIATED COMPANIES

We may share your information between our affiliated companies to the extent
allowed by law.


C. WITH SERVICE PROVIDERS

We may share your information with service providers, including payment
processors, technology and infrastructure providers, digital communications
services, commercial data and market research analysts, consumer report
providers, auditors and accountants, physical site security providers, IT
security and bug-fix partners, customer service providers, and other providers
who perform services for and on our behalf for the sole benefit of us and our
customers.  


D. WITH LAW ENFORCEMENT, COURTS, OR GOVERNMENT AGENCIES

We may share your information as necessary to respond to legal process or to
regulatory authorities (such as pursuant to a subpoena, warrant, investigative
demand from law enforcement, regulators, or others; national or international
security letters; etc.); to investigate, prevent, or take action regarding
suspected or actual illegal activities (including fraud or stalking) and
security or technical issues; to respond to or participate in commercial
disputes (e.g., lawsuits or investigations); or to protect against fraud,
claims, or other liability or harm to you, us, or others.


5. WHEN THIRD PARTIES BENEFIT FROM OPENDOOR SHARING YOUR INFORMATION WITH THEM


A. “SELLING” YOUR DATA

Opendoor is not a data broker. However, in some circumstances we share your
information with third parties not owned by or co-branded with Opendoor
Specifically: 

 * Social media. If you use our Services, we may provide information about that
   use to social media networks who will use it to better target advertising. 
 * Third-party home buyers. We may share your information with institutional
   home buyers to try to find a purchaser for the home.
 * Home insurance agencies. If you may need homeowners insurance, we may share
   your information with homeowners insurance agencies and those agencies may
   reach out to offer you a quote.  
 * Vendor due diligence. If you are an individual or business that wishes to
   provide services to Opendoor, we may share your information with a due
   diligence service to perform vendor due diligence. The due diligence provider
   may use this information to inform and further refine its risk analysis
   tools. 


6. HOW WE PROTECT YOUR INFORMATION

A. SAFEGUARDS

We use commercially reasonable physical, electronic, administrative, and
procedural safeguards to preserve the integrity, confidentiality, and security
of all personal information collected through the Services. However, no security
measure, system, or control is infallible. Therefore, like all businesses, we
cannot guarantee that our Services are invulnerable to attack or misuse.

B. YOUR ROLE

You have a major role in the security and privacy of your own information. For
example, you should not provide us with personal information that we do not
request. Additionally, you are responsible for controlling access to any
personal computing device through which your information may be stored or
accessed. You are also responsible for safeguarding any passwords or other
log-in credentials that may be used to access your information, including in the
Opendoor environment. We recommend that you log out of any account when you are
done using it.

C. THIRD PARTIES

Please remember to review the privacy settings and security policies of
third-party sites and services that you use, such as social networks. We are not
responsible for the privacy or security measures of any third party.

D. INCIDENT RESPONSE

In the event that the security of any personal information under our control is
compromised, we will take reasonable steps to investigate and mitigate the
situation, including, when appropriate, notifying those individuals whose
information may have been compromised and taking other steps in accordance with
applicable laws and regulations.


7. OPTING OUT OF OUR COMMUNICATIONS

If you are interested in no longer being contacted by Opendoor, we want to
facilitate that.  You may click on the unsubscribe links in our marketing
emails, text STOP in response to marketing texts, and request removal from our
mailer list at opendoor.com/mail.  

If you prefer to no longer use our app, you can follow the standard process to
uninstall it from your device.

We are also happy to place you on our do-not-call list.  For assistance, please
contact us at contact@opendoor.com or 888-352-7075.


8. CALIFORNIA CONSUMER PRIVACY ACT RIGHTS


A. ABOUT THE CALIFORNIA CONSUMER PRIVACY ACT

In addition to Opendoor’s general privacy policies, consumers that are
California residents (hereinafter, “you”) have specific rights under the
California Consumer Privacy Act of 2018 (“CCPA”).  They include:

 * The right to request that we disclose what personal information we collect,
   use, and share about you, unless subject to a legal exception.
 * The right to opt-out of sale to third parties of any personal information
   about you (as sale is defined by the CCPA).
 * The right to request that we delete personal information about you, unless
   subject to a legal exception.
 * The right to be notified that we collect personal information about you, and
   the purposes for which the information will be used. This right applies to
   job applicants, employees, directors, officers and contractors, as well
   California consumers.  

Job applicants, employees, directors, officers and contractors should consult
Opendoor’s California Employee, Job Applicant, and Contractor Privacy Notice for
more information.  


B. HOW TO MAKE A CALIFORNIA CONSUMER PRIVACY ACT REQUEST 

You may request to know, delete, or opt out of sales under the CCPA by going to
opendoor.com/privacyrequest or by calling 888-352-7075. 

Only you or a duly authorized agent may make a CCPA request on your behalf. If
you are an authorized agent making a request on behalf of a California resident,
please call us.  

You have the right to make a free request twice during any twelve-month period.
The request must:

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

Submitting a request does not require you to create an account with us. 
However, for your safety and the safety of your information, we cannot fulfill a
request to provide or delete personal information if we cannot verify your
identity or authority to make the request and confirm the personal information
relates to you or an individual for whom you are an authorized agent. We may
require additional verification before deleting or disclosing particularly
sensitive information. We will only use the verification information you provide
for the purpose of verifying your identity or authority to make the request.

We do not charge you 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. 


C. NON-DISCRIMINATION

We will not discriminate against you for exercising your rights under the CCPA.
Unless permitted by law, 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 of quality of goods or services; or
 * Suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services.


9. UPDATES AND QUESTIONS

This policy is updated regularly. We will promptly make any changes available at
opendoor.com/privacy. Changes will be effective as soon as the updated policy is
posted unless otherwise stated.Questions about this policy can be directed to
contact@opendoor.com or 888-352-7075. 

This Policy was last modified on November 1, 2021.

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