Your California Privacy Rights
Effective Date and Last Revised: December 30, 2022
As used in this California Privacy Policy, unless otherwise specified, “Company”, “we”, “our” and “us” refers to Tri Pointe Homes, Inc., together with its affiliates, subsidiaries, divisions and brands. Notwithstanding the foregoing, please note that where an affiliate of Tri Pointe Homes, Inc. has adopted a different privacy policy, such privacy policy will supersede this California Privacy Policy for purposes of such affiliate.
This California Privacy Policy (i) describes the rights of California residents (“Consumers”) under the California Consumer Privacy Act of 2018, as amended (“CCPA”); (ii) describes our practices regarding the collection, use, and disclosure of the personal information of Consumers, except to the extent such personal information is exempt from the CCPA or otherwise does not constitute “Personal Information” as defined by the CCPA; and (iii) explains how Consumers may contact us to exercise those rights. This California Privacy Policy supplements the Company’s main Privacy Policy and applies only to the personal information of Consumers. In the event of any inconsistency or conflict of any kind between the provisions of this California Privacy Policy and the Company’s main Privacy Policy or any other Company policy, statement or notice, this California Privacy Policy shall control as to Consumers and their rights under the CCPA.
This California Privacy Policy sets forth applicable privacy practices of all our homebuilding operations. This policy does not apply to the practices of Tri Pointe Advantage Insurance Services, Inc. (“Tri Pointe Advantage”), Tri Pointe Assurance, Inc. (“Tri Pointe Assurance”) or Tri Pointe Connect, L.L.C. (“Tri Pointe Connect”). For a copy of the Tri Pointe Advantage privacy policy, please click here; for a copy of the Tri Pointe Assurance privacy policy, please click here; and for a copy of the Tri Pointe Connect privacy policy, please click here. This policy also does not apply to our employees, former employees, or applicants for employment. Such individuals receive a notice specific to our personal information processing practices during the course of their application and/or employment.
Consumer Rights
This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact us to exercise these rights, please see the section below entitled, “How to Submit a Request”.
Right to Know
A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells with respect to such Consumer. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:
- The categories of personal information it has collected about that Consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that Consumer.
A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:
- The categories of personal information that the business collected about the Consumer.
- The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the Consumer for a business purpose.
A Consumer also has the right to know about financial incentives we may offer for the collection, sale, or retention of personal information. However, we do not currently offer any such incentives.
Right to Request Deletion
A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for us to maintain the personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
Right to Opt Out of Sale or Sharing of Personal Information
A Consumer has the right to direct a business that sells personal information about the Consumer to third parties not to sell the Consumer’s personal information. Consumers also have the right to opt out of the sharing of personal information for cross-contextual behavioral advertising purposes. To exercise either right to opt out, you may visit our Do Not Sell My Personal Information web page.
No Discrimination
A Consumer has the right not to be discriminated against because the Consumer exercised any of its rights under the CCPA.
Right to Restrict Processing of Sensitive Personal Information
A consumer has the right to restrict the processing of their sensitive personal information. However, at this time, we do not process sensitive personal information.
Correction of Inaccuracies
A Consumer has the right to make a request for the correction of errors or inaccuracies in its personal information.
Third Party Direct Marketing
California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Any inquiries regarding personal information sharing with third parties may be directed to us at the contact information set forth below.
How to Submit a Request
To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting us toll-free at (855) 947-0468, privacy@tripointehomes.com or by submitting a request online at https://preferences.tripointehomes.com/privacy.
You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.
To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity, including your name, email address, phone number and/or information regarding your previous interactions with us. The information we ask you to provide to initiate a request may differ depending upon the type of request; the type, sensitivity and value of the personal information that is the subject of the request; and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. As required by the CCPA, in response to a Consumer request, we will never disclose a Consumer’s social security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, account password, or security questions and answers, as applicable.
You may make a verifiable Consumer request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf. If you designate an authorized agent to make a request on your behalf, we reserve the right to require verification of your authorized agent’s identity and authority, which may include, among other things, a requirement that your authorized agent provide us with (i) your written authorization permitting the authorized agent to submit a request on your behalf or (ii) a duly executed power of attorney pursuant to California Probate Code sections 4000 to 4465 permitting the authorized agent to submit a request on your behalf. If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
How We Collect, Use and Share Personal Information of Consumers
Categories of Personal Information We Collect
Depending on how a Consumer interacts with us, we may collect the categories of personal information described below. The nature of both the categories and the specific pieces of personal information that we may collect about a Consumer will vary depending on numerous factors, including whether or not a Consumer chooses to buy one of our homes.
We have collected the following categories of personal information about Consumers in the twelve (12) months prior to the effective date of this California Privacy Policy:
- Name, signature, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, insurance policy number and financial information.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet website, application, or advertisement.
- Geolocation data.
- Audio recordings.
- Professional or employment-related information.
- Education information.
- Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Retention of Your Personal Information
We retain personal information only for as long as is necessary for the purposes set out in this Privacy Policy or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data:
- Retention and legal limitation periods established under applicable law;
- Industry best practices;
- Whether the purpose of processing is reasonably likely to justify further processing;
- Risks to individual privacy in continued processing;
- Applicable data protection impact assessments;
- IT systems design considerations/limitations; and
- The costs associated continued processing, retention, and deletion.
Sources of Personal Information
We collect the personal information described above from the following categories of sources:
- From you directly, including through in-person visits to one of our new home galleries or model homes (whether verbally or in writing), phone calls, text messages, our website/web forms, our design studio web forms, online chats, purchase agreements executed by you in connection with a purchase of one of our homes or when you otherwise correspond with one of our employees or agents.
- From real estate agents.
- From your browsing activity on our or one of our affiliate’s or partner’s websites.
- From service providers, including marketing partners, data providers who provide us with information about individuals in order for us to understand who may be interested in our products and/or services, data aggregators, analytics providers and companies that help us provide our website to you.
- From affiliates and partners, including any of our homebuilding or financial services brands, and master developers or other homebuilders in certain communities in which we build homes.
Business Purposes for Personal Information
We collect the personal information described above for a variety of business purposes. Generally, we collect and use such personal information to provide, improve and enhance our products and services, to communicate with you and to ensure the uninterrupted and secure operation of our business. In particular, we use the personal information:
- To provide our services to you and activities related to our provision of such services, including maintaining or servicing accounts, providing customer service, processing transactions, or providing advertising or marketing services.
- To improve, upgrade, or enhance our products, services and advertising.
- To provide you with information about services that we and our affiliates may provide that we think may be of interest to you.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
- To debug to identify and repair errors that impair existing functionality.
Categories of Third Parties with Whom We Share Personal Information for a Business Purpose
We do not share your personal information with third parties other than in accordance with this California Privacy Policy. To the extent permitted by applicable law, we share each of the categories of the personal information described above with the following categories of third parties :
- Service Providers: We may share your personal information with service providers to assist us in providing our services to you, including service providers that host our databases, infrastructure, CRM systems and websites or provide other cloud-based services and e-signature platforms; assist us with communicating with you on our websites; provide analytics services to help us understand the activity on our website; assist us with marketing and communications with our customers or potential customers; assist us in the development of your community and the design and construction of your home; assist us with providing you updates regarding the construction process of your home; assist in financial processing and home sales and closing transaction processes (including, without limitation, escrow, closing and title companies and lenders); provide utilities services to certain of our homes and communities; install various smart home and alternative energy technologies in our homes; assist us with the financial, regulatory and legal aspects of our business; assist us with understanding customer needs and customer satisfaction with our services and products through surveys; and assist us with managing warranty requests.
- Affiliates and Partners: We may share your personal information with affiliates and partners, including any of our homebuilding or financial services brands, our design studio partners and master developers or other homebuilders in certain communities in which we build homes.
- Homeowners Associations: We may share your personal information with homeowners associations in a particular community in connection with your purchase of one of our homes.
- Courts or Government Entities: We may share your personal information with courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.
- Business Transactions: We may share your personal information with actual or potential acquirors or other parties to a transaction in the event of an asset sale, spin-off, merger or similar corporate transaction involving the Company or one of our business units.
- Marketing Firms: We may share your personal information with third parties who help us determine how to contact you with additional information about the Company and our products.
Sales of Personal Information
We do not sell your personal information for monetary consideration. However, California law broadly construes the term “sale” to include any exchange for value and, as such, for purposes of the CCPA, we may have “sold” (as defined under the CCPA) personal information about Consumers in the twelve (12) months prior to the effective date of this California Privacy Policy. To the extent California law would characterize any of our disclosures of personal information about Consumers as a sale under the CCPA, we may have sold (as defined under the CCPA) the following categories of personal information about Consumers in the twelve (12) months prior to the effective date of this California Privacy Policy:
- Name, signature, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and financial information.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet website, application, or advertisement.
- Geolocation data.
- Inferences drawn from any personal information to create a profile about a Consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Disclosure of Personal Information for a Business Purpose
We have disclosed personal information about Consumers for a business purpose in the twelve (12) months prior to the effective date of this California Privacy Policy. In particular, we have disclosed the following categories of personal information about Consumers for a business purpose in the twelve (12) months prior to the effective date of this California Privacy Policy:
- Name, signature, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, insurance policy number and financial information.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet website, application, or advertisement.
- Geolocation data.
- Audio recordings.
- Inferences drawn from any personal information to create a profile about a Consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information of Minors
We do not sell personal information about minors under the age of 16.
Contact for More Information
If you have any questions or concerns about this document or our personal information practices, please contact us at (855) 947-0468 or privacy@tripointehomes.com.