Effective Date of Current Policy: May 8th, 2017

Overview
Heavy Hammer New Media Solutions maintains a cooperative of subsidiary real estate related websites and apps which are referred to in this document as “The USHUD Cooperative” or “USHUD.com” or “Sites” for purposes of clarity. The USHUD.com Cooperative is committed to keeping our individual and business clients informed about how we use the information we gather from users through the use of The USHUD Cooperative of websites located at www.ushud.com, www.Allhud.com, www.Hudexchange.com and www.usahud.com.

Please read this privacy policy (“Policy”) carefully to understand how we will use and protect your personal information. We will not share your personal information with anyone except as described in this Policy. Changes to this Policy will be announced on our Sites, so please check back periodically. By using the Sites or obtaining any product or service through the Sites, you agree to the collection and use of information as set forth in this Policy. If you do not agree to this Policy, please do not use the Sites. This Policy is incorporated into, and considered part of, our Terms and Conditions. Capitalized terms not defined herein are defined in the Terms and Conditions. Questions regarding this Policy should be directed to INFO@USHUD.COM or we may also be contacted directly at the following address:

Attn: USHUD.com
65 Old Solomons Island Road, Suite 202
Annapolis, MD 21401

1.    What information does USHUD.com collect from you or about you?
In order to better provide you with numerous products and services, our Sites collect two types of information about its visitors: Personally Identifiable Information and Non Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Sites.

Personally Identifiable Information:
“Personally Identifiable Information” refers to information that lets us know the specifics of who you are and can be used to identify, contact or locate you. Personally Identifiable Information is requested when you register with us, order a product or service, fill out surveys, correspond with us, or otherwise volunteer information. Personally Identifiable Information might include your name, mailing address, telephone number, mobile phone number, email address, and other identification and contact information. For example, certain online forms on our Sites request that consumers provide financial details about their property search, household income and credit history. For realtors, this may include a personal photo, a personal URL or a description of your practice. We may also collect certain financial information, like your credit card number or checking account details (or a physical check or money order if using such payment method while ordering via mail); whenever we do so, we will attempt to provide a link to this Policy so that you can confirm how this information will be used.

Non Personally Identifiable Information:
“Non Personally Identifiable Information” refers to information that does not identify a specific individual by itself or in combination with other information. This information typically relates to your activity on our Sites, and may include the websites‘ Uniform Resource Locator (URL) that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol (IP) address. A URL is the global address of documents and other resources on the Internet. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, such as the Internet. Networks use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Internet, allowing Internet servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse and shop. This information may be compiled and analyzed on both a personal and an aggregated basis.

2.    Where do we collect information from you and how do we use it?
Our primary goal in collecting information is to provide our customers and realtor clients with a superior customized online experience. Among other things, we use customer contact information to relay information and communications, contact prior subscribers to inform them of their order status, to remind individuals of events or the availability of property types through our alert service(s), and to send service emails, newsletters, and promotional emails from us or third parties. We may perform statistical analyses of aggregate or segmented customer behavior. This allows us to measure relative interest in the various areas of our Sites for development purposes and to improve the design of our Sites. We may also use information to notify you about updates to our Sites, to complete user initiated transactions, and to contact you directly, or through our third-party service partners, for marketing purposes. In addition, we may seek to update your personal information in our records through third party services that provide updated names, emails, addresses, phone numbers, and other information. We may then use this acquired information to enhance our services or marketing efforts to you.

Corporate Account:
When you set up a corporate account – typically as a realtor client – with us or when you contact us to inquire about corporate programs (either via email, telephone, letter or our online web forms), we collect, for example, your name, company name, email and telephone or mobile number. We may send you newsletters and promotional emails (as described below). Upon signing up for a corporate account we will contact you by either email or telephone to determine how we can best serve your corporate needs. We will also give you the opportunity to receive periodic updates regarding our corporate services. If you make purchases through your corporate account we shall gather similar information that we gather when you subscribe as an individual, plus certain information regarding your corporation.

Surveys and Polling:
In order to improve our services to you, we may ask some of our users to voluntarily complete surveys online or via telephone, which may be collected by an independent third-party. Individual survey answers are confidential, although Non Personally Identifiable Information may be collected and disclosed to third parties. If you do not wish to participate in a survey, simply decline to participate when asked.

Newsletters & Promotional Emails:
We may offer free electronic newsletters and promotional emails for products and/or services offered on our Site, or from our third party partners, as a service to our customers from our Sites. We may send you newsletters and emails periodically listing current specials and deals from us or through our third party service partners. There may be opportunities to subscribe to an email list that will send you information about the events on our Sites, but we will only add you to the list with your consent. You may opt out of receiving any such newsletters and promotional emails as described below.

Cookies/Clear GIFs:
In conjunction with our third-party service partners, we make limited use of cookies and clear GIFs to gather information when you visit our Sites, make a purchase and when you click through to our Sites from a targeted email, newsletter or partner site. We may also use cookies and clear GIFs to gather and compile such information about you when you return to our Sites so that we may better customize our services to you. To find out what cookies and clear GIFs are and how they can be used, please refer to Section 8 of this Policy below.

Other Information You Provide:
If you contact us by telephone, email or letter, we may keep a record of your contact information, correspondence or comments. If you report a problem with our Site, we may collect such information in a file specific to you. If you provide us feedback through our Sites, by email or by calling one of our customer service representatives, we may ask for your name and email address in order to send you a reply. If other users or third parties send us correspondence about your activities on our Sites, or if you are the recipient of products sent by another customer, we may keep the information in a file specific to you. We store this information for the purpose of sending one or more emails in connection with such an event.

Greeting, Hint and Reminder Services:
If you choose to use an email a friend, reminder, or other service on our Sites, we may ask for and store the name, email address, mailing address, telephone number, mobile phone number, other identification and contact information, of you or another person so that we may send them or you a message about an event. We store this information for the purpose of sending one or more electronic newsletters or promotional emails in connection with such an event. Misuse of our service by providing false email addresses or posing as someone else when sending a greeting or email may result in legal action and the disclosure of information about you, including your computer’s IP address, as part of any investigation into your actions.

Co-Branded Sites:
With respect to our co-branded sites maintained by us in conjunction with our business partners, we may share information collected by us to our business partners under our separate agreements with them. These business partners may use your personal information to communicate with you about offers from us as well as offers from such partners. If you opt out of receiving newsletters and promotional emails from us, you will automatically opt out of receiving newsletters and promotional emails from such business partners through their use of personal information which we collected from you on our co-branded sites and which we provided to such business partners. We may ask you to share your information with our business partners via an opt in or opt out request on such sites. Please note that with respect to personal information our third-party business partners may collect from you independent of us and outside the scope of co-branded or private label sites maintained by us on our servers, we will have no control over the use of such information by such third-party business partners and the use and gathering of such data will be subject to the third party’s privacy policies.

Non Personally Identifiable Information:
We use Non Personally Identifiable Information to analyze request usage patterns, and other customer behavior so that we may enhance our Site, products and services, and for our marketing purposes. For example, this allows us to measure relative customer interest in the various areas of our Sites for development purposes and to improve the design of our Sites. We also may use your IP address to diagnose problems with our servers and software and to administer our Sites. We reserve the right to use and disclose Non Personally Identifiable Information to any third-party in our discretion. For example, we may share aggregated or segmented statistics about pages viewed on our Site and sales and other shopping information with third parties.

3.    Who is collecting your information?
Except as otherwise expressly discussed in this Policy, we are the only entity collecting your information. This Policy only addresses the use and disclosure of information we collect from you online via the Sites. We encourage you to ask questions and to be very cautious before you disclose your Personally Identifiable Information to others.

Third-Party Advertising Service Partners:
We may utilize third-party advertising service partners that may collect information about you on our behalf through the use of cookies or clear GIFs when you click on its advertisements, open promotional emails or newsletters, or visit our Sites via a link on another website or in a promotional email or newsletter. Any Personally Identifiable Information that may be gathered in this manner is solely for our use; however, the third-party advertising service partner may use this information in a non personally identifiable form for its own purposes.

Third-Party Survey Providers:
From time to time, we may utilize the services of third-party survey providers that may collect Personally Identifiable Information from you for certain services, including voluntary surveys that are conducted on our behalf and certain of our reminder services. This may include information regarding you, as well as third parties about whom you provide information. If you chose to participate in these surveys, or use these services, this Personally Identifiable Information may be stored on the servers of the third-party survey providers used by us, but this Personally Identifiable Information will remain the sole property of us and will be handled in accordance with this Policy.
Third-Party Traffic Tracking Providers: In addition, we may employ one or more third-party service partners that track the traffic on our Sites. However, the only information that may be gathered by such third parties is Non Personally Identifiable Information, with the exception of email addresses.

4.    With whom do we share your information?
Except as otherwise stated in this Policy, we do not sell, trade or rent your Personally Identifiable Information collected on our Site to others. You expressly consent to the sharing of your Personally Identifiable Information with third-parties as described below.

Third-Party Service Providers:
We may share your Personally Identifiable Information with our third-party service providers for tracking purposes, to charge your credit card (or process your check or money order, as appropriate), fill your subscription, improve the functionality of our Sites, customize our marketing efforts with you and perform statistical and data analyses, deliver promotional emails to you from us, or to provide us other services we request. These third parties may not use your Personally Identifiable Information other than to provide the services requested by us.
For example, we must release your credit card number to confirm payment. We also share website usage information we gather from visitors to our Sites who have received a targeted promotional campaign with our third-party advertising service partner for the purpose of targeting future campaigns and upgrading visitor information used in reporting statistics. For this purpose, we and our third-party service partners note some of the pages you visit on any one of our Sites through the use of clear GIFs.

Facilitating Introduction:
Of course, the core purpose of the Sites is to facilitate the introduction of individuals searching for property and participating Real Estate Professionals. Therefore, we will be sharing certain Personally Identifiable Information with USHUD.com participants. This will not include any payment or credit card data, but will include information, such as your contact details, property description, and other basic information you have voluntarily submitted on USHUD.com.

Direct Marketing Companies:
From time to time we may disclose certain information (names, postal addresses and non-sensitive transactional information) to direct marketing companies for trade or rental purposes. You may opt out of this disclosure as described below.

Your California Privacy Rights:
In certain circumstances under California law, consumer customers of USHUD.com are entitled to certain information regarding any personally identifiable information (as defined by certain California laws) we may share with direct marketing companies. Personally identifiable information generally is defined under California law as information that identifies specifics about an individual and can be used to identify, contact, or locate an individual including that individual’s name, mailing address, telephone number, mobile phone number, email address and other identification and contact information. If you are an eligible customer of USHUD.com and would like to receive a list detailing the types of personally identifiable information we share with direct marketing companies and the names and addresses of all direct marketing companies that we provide personally identifiable information to, please email us at MS@USHUD.COM. We will respond to any request for information at such email address within thirty (30) days.
Non-personally Identifiable Information: We may provide non-personally Identifiable Information, including aggregated or segmented statistics about our customers, sales, traffic patterns, and related site information, to third parties.
Friends and Other Third Parties You Select: If you are using an email a friend or reminder service on our Sites, then you may have the option of sharing your Personally Identifiable Information, as well as information that you have entered regarding third parties, with others. If you share this information with third parties, these parties may disclose or use this information in ways not described in this Policy.

Third-Party Partner Companies:
If you provide any of our third-party partner companies with consent for USHUD.com to provide your Personally Identifiable Information to such company, then we will provide such information to them. You acknowledge and agree that we may rely on the third-party company’s representation that it has received such consent.

Enforcement of Law and Other Disclosures:
We may disclose Personally Identifiable Information if we believe in good faith that such disclosure is necessary to comply with relevant laws or to respond to subpoenas or warrants served on us or to protect or defend the rights, property, or safety of our users, other and ourselves. For example, we may release account information when we believe that such release is reasonably necessary to enforce or apply our Terms and Conditions of Use or to protect or defend the rights, property and safety of our users, others and ourselves. We may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

Merger and Acquisitions:
In the event of a merger, consolidation, or sale or transfer of all or substantially all of the assets or business of our corporate entity or Sites, one of the assets that would generally be transferred is the information we collect from our visitors and customers (including both financial records and consumer information). However, the use of this information by any successor entity would still be governed by the terms of this Policy, as amended from time to time, including any amendment after such transaction.

5.    How may you update, correct or delete your Personally Identifiable Information?
Information About You: During the online registration and profile management process you can review, change or delete the information that you have submitted. You may change any of your personal information in your account(s) online at any time. You may ask us in writing via mail or email at MS@USHUD.COM to have the information on your account deleted, updated or corrected; however, because we keep track of past transactions, you cannot delete information associated with past purchases. We may also be required by law or otherwise to keep certain information and therefore will not delete it or will delete it only after we have fulfilled the applicable requirements. Note that we may retain changed or deleted information for archival or other purposes.

Information About Others: As described above, if you are using an email a friend or reminder service on our Sites, we may ask you to provide certain information about you or a friend or other third parties. You, the friend, or other third-party, may contact us at MS@USHUD.COM to request the removal of such information from our database.

6.    What are your choices regarding marketing correspondence?
Our Newsletters and Promotional Emails:
You will have the choice to opt out of receiving newsletters and promotional emails for products and/or services offered on any one or more of our Sites. Once we have processed your request, we will not send you promotional emails with respect to products and/or services offered by us through the Sites unless you opt back in to receiving such communications.

You can opt out of receiving newsletters, promotions, non-transactional related emails or phone calls from us either (a) by following the unsubscribe instructions in the applicable email you receive from us (if applicable), (b) while you are completing our online web form (if applicable), (c) by calling us at 800-880-8584, or (d) by sending an email to us at INFO@USHUD.COM.

Our Operational Emails:
Despite your choices regarding promotional emails, we may continue to send you Operational Emails. Please note that our Operational Emails about your subscription or account may contain some additional marketing offers from us or our trusted third-party partners, but the primary purpose of such Operational Emails is to inform you about your account. Should you not wish to receive such Operational Emails from us, please do not register on our Sites.

If we send you a communication requesting your consent or permission (a “consent”) in connection with this Policy or our Terms and Conditions (including a consent to modifications thereto), such consent is deemed to be given unless (a) you contact us to withhold such consent within the time stated in the communication (“opt out”) or (b) applicable law expressly prohibits an opt out with respect to such request for consent.

7.    What security precautions are in place to protect against the loss, misuse or alteration of your information under our control?
We employ reasonable security measures to protect the security of the information you submit to us. Our servers protect this information using password protection and advanced encryption, and we may use firewall technology for additional protection.

In order to most efficiently serve you, credit card transactions and checking account transactions are handled by established third-party banking institutions, process agents and distribution institutions. They receive the information they need to verify and authorize your credit card transactions and to process your request. When collecting credit card information for online purchases, we offer secured server transactions that encrypt your information in transit to reduce the chance of someone intercepting it and misusing it. When you access your account information, the information is kept on a secure server. Furthermore, all of the customer data we collect is protected against unauthorized access by physical security means.

We also encourage our partners and service providers to adopt and follow stringent consumer privacy policies.

8.    Cookies/Clear GIFs.
Cookies: Like many other commercial sites, our Sites utilize standard technologies called “cookies” and clear GIFs to collect information about how our Sites are used. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to us. Cookies were designed to help a website recognize a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. A cookie cannot be read by a website other than the one that set the cookie. Cookies can securely store a customer’s password, personalize home pages, identify which parts of a site have been visited or keep track of selections, such as those selected in a “shopping cart.”
We send a cookie to your hard drive when you register initially. No Personally Identifiable Information is recorded. When you click through to our Sites from a promotional email, our third-party advertising service partner may send a cookie to your hard drive recording your IP address and other related information.

Clear GIFs: At times, we work with third-party service partners such as Google AdSense that employ clear GIFs (also known as pixel tags, single pixel GIFs, web beacons or action tags) for our benefit or the benefit of a third-party to help us or such third-party measure advertising effectiveness. Clear GIFs help to better manage content on our Sites by informing us of what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of our users. The main difference between the two is that clear GIFs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. These third-party service partners use clear GIFs: (i) in HTML based emails to let us know which emails have been opened by recipients; (ii) to record when products have been ordered from our Sites; and (iii) to track the visitor traffic on our Sites. These clear GIFs allow us to measure the usage of our Site by our visitors and the effectiveness of certain communications and marketing campaigns. We may also use clear GIFs in a similar manner in our own emails and on our Site.

9.    Children and privacy.
The Children’s Online Privacy Protection Act took effect on April 21, 2000, and imposes certain requirements on websites directed toward children under 13 that collect information on those children, or on websites that know they are collecting Personally Identifiable Information from children under the age of 13. We want to let you know that it is our policy not to collect Personally Identifiable Information from any person under 13 because children are not permitted to use the Sites or services on the Sites, and we request that children under 13 not submit any personal information to us via the Sites. If we learn that we have inadvertently gathered Personally Identifiable Information from children under 13, we shall erase such information from our records and terminate the applicable account.

10.    Right to Opt-out.
This Right to Opt-Out Policy encompasses Heavy Hammer New Media Solutions, Inc and its subsidiary, the USHUD.com Cooperative (which includes, but isn’t limited to, the sites USHUD.com, ALLHud.com, HUDExchange.com and USAHUD.com). Emails will primarily originate from USHUD.com, but may occasionally arrive from one of the Cooperative’s other domains. All emails from the USHUD.com Cooperative (referred to in this policy document simply as USHUD.com) are covered by this Right to Opt-Out. Note that opting out of important service related emails may prevent USHUD.com from providing services requested.
(a) California & Canadian Users: Your California Privacy Rights. California's “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information sharing. We have such a policy in place. Section 10(d) explain our practices and how you can opt-out of having your information shared with third parties for the third parties’ direct or indirect marketing purposes, in accordance with such laws. In addition to reviewing Section 10(d), if you wish to find out about any rights you may have under California Civil Code section 1798.83, you may notify us in writing at Mail Preference Service, 65 Old Solomons Island Rd, Suite 202, Annapolis, MD 21401 or by contacting us at MS@USHUD.com. For the avoidance of doubt, these opt-out options are available for all users and are not limited to Californian and Canadian users.
(b) Mobile Opt-out. We may provide you messages, including marketing, via your wireless email address or by short message service (“SMS Service”), WAP or Mobile Services as described in Section 6. You may opt-out of these messages from us by replying “STOP” or following the instructions provided in the message.
(c) Marketing provided by third parties. From time to time we may send you promotional materials on behalf of third parties. If you want us to stop sending you promotional materials to your email, please follow the unsubscribe instructions in the email or other electronic methods. We do not send physical mail for advertising purposes.
(d) Marketing provided by Third Parties. From time to time we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us at MS@USHUD.com.
(e) Exceptions. If you have opted-out as described above, and thereafter you elect to use a service or promotion that requires us to contact you or share your information with a third party (e.g., you enter into a contest or sweepstakes or use an ecommerce service after opting-out), then your previous opt-out preferences will not apply to such service. Despite your indicated preferences, we may send you service related communications, including notices about your subscription, and we may continue disclosing your information to third parties under the Service Provider Exception, Legal Exceptions, and Acquisition Exception described above. Please provide ALL of your email addresses so that we can take the proper measures to ensure that you are not being sent emails to those addresses and unintentionally forwarding those emails to the single email address that has been added to our do not email list.
(f) Device Settings. Our digital applications may provide you alerts and you can change your preferences regarding these alerts through your device settings.

11.    You should carefully review privacy policies of any third-party sites accessible from any of our Sites and any co-branded websites not covered by this Policy.
Other sites accessible through any of our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Please be aware that our Sites may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our Site are not covered by this Policy. These other sites may send their own cookies or clear GIFs to users, collect data or solicit Personally Identifiable Information. Additionally, other companies that place advertising on our Sites may collect information about you when you view or click on their advertising through the use of cookies or clear GIFs. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.
We also may have co-branded websites that are maintained by us in connection with one or more of our third-party business partners but which sites do not contain this Policy or a link to this Policy. When you submit information to one of these websites, the websites may share your information with USHUD.com and our third-party business partners or just with our third-party business partner. Note that these websites may contain, or link to, privacy policies that contain terms and conditions different than those contained in this Policy. Again, this Policy only pertains to the information USHUD.com collects from the Sites and we are not responsible for the privacy policies or practices of our business partners. We encourage you to read the privacy policies of those co-branded sites so that you will always know what information we gather and what information is gathered by our third-party business partner, how each of us might use that information, to whom each of us will disclose it and what choices you have.

12.    Contacting us about privacy questions or concerns.
If you have any questions about this Policy, the practices of any of our Sites, or your dealings with any of our Sites, please contact us by sending a letter to: USHUD.com, 65 Old Solomons Island Rd., Suite 202, Annapolis, MD 21401, or by sending an email to INFO@USHUD.com.

13.    Policy changes.
This Policy was last changed on May 8th 2017. If we make changes to any terms or conditions of the Policy, the changes will be posted on this portion of the Site so that you will always know what information we gather, how we might use that information, to whom we will disclose it and what choices you have. Any change, modification, addition or removal of portions of this Policy will be announced on our Site. Please be sure to check this page before proceeding to use our Sites.