Privacy Policy1

1. Introduction

This privacy policy describes how Aspire Innove collects, discloses, and uses your information when you access our services. This policy applies to all of the products and services owned and operated by Aspire Signature Interactive (collectively, “Aspire Innove,” “we,” “us,” or “our”), including the content, features, data, and software available on www.aspireinnove.com, our mobile applications, and other websites or applications that we operate (“Services”). For India residents, please see our Supplemental India Consumer Privacy Act Rights Notice at the end of this privacy policy.

To learn about the privacy practices of our affiliates, OS National (Aspire Signature Interactive and Innove Concepts). please visit their respective privacy policies at https://aspireinnove.com/privacy-policy.

2. The Kinds of Information We Collect

a. Information You Provide

We collect content, images, and other information that you provide to us when you access our Services, including when you complete webforms on www.aspireinnove.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 personal information that 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 through our Services and your opinions about those homes;
• Reviews or comments you leave on our Services or on other public websites or Services associated with us, such as social networking platforms;
• 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); or
• 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, which may or may not constitute personal 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 behaviours 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, as well as recording clicks, mouse movements, scrolls, keystrokes, and other information about your browsing session;
• 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 Services, and links you click on, as well as recording clicks, mouse movements, scrolls, keystrokes, and other information about your browsing session.

Our Services do not respond to Do Not Track signals. 

c. Information We Collect When You Call Us

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

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 Aspire Signature Interactive is not able to buy your home, 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 AI-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; or
• Information about how you engaged with the AI website, such as recording clicks, mouse movements, scrolls, keystrokes, and other information about your browsing session, or how you engaged with an AI advertisement or social media post.

Our service providers may collect information on our behalf. For example, third parties that we engage may collect information about your online activities over time and across different Websites when you use our Services.

e. Information We Collect from Public Sources

Much of the information necessary to help you buy or sell your home is available from public sources, such as government entities. 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 “comparable”);
• 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; or 
• 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, or, depending on your mobile device settings, your location information, including GPS coordinates. This information may also include a recording of your clicks, scrolls, keystrokes, and other information about
your mobile app session.

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 AI homes. This helps us keep you and our properties safe. 

When you first launch our application or when you use it to visit an AI 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 AI Home

If you use our application to unlock an AI 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. AI 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 personal 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.

h. Information We Collect Through Estimated Offers Via Text

Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes. 

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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 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

AI cares about your safety. We use the monitoring and identity verification technologies described above to help keep you safe when you visit an AI 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 AI 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 Services, combined with information you provide us and information we collect from other sources, to serve you relevant advertising.

You may have additional choices available to you with regards to some online behavioural advertising cookies. Please visit the Digital Advertising Alliance at https://optout.aboutads.info/?c=2&lang=EN or the Network Advertising Initiative at https://optout.networkadvertising.org/?c=1 for more information.

We may also allow third-party cookies on our website to assist in enhancing the website. For example, we allow Google to provide us with analytics on our website traffic. For more information about how to opt-out of Google Analytics, you can visit: https://tools.google.com/dlpage/gaoptout. For other privacy choices made available by Google, you can visit: https://policies.google.com/technologies/ads?hl=en-US.

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 analyse consumer information that we collect through our Services 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.

h. Uses of Device Information

We generally use this information for your convenience and to improve our Services. For instance, we may use it to: (i) remember your personal 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; or (v) diagnose or fix technology problems.

4. Why and How We Disclose Your Information

a. At Your Direction 

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

• Agent partnerships. AI works with both consumers and real estate agents. We may disclose 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. AI partners with homebuilders to provide buyers who are purchasing new homes from these builders with the opportunity to request offers from AI for their current homes. When you are working with a homebuilder, we may disclose your information with them. 
• Financing providers. If and to the extent you authorize us to do so, we may disclose your information with home financing providers.
• 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 disclose 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 disclose your information with renovation and construction companies.  
• Other partners with whom you ask us to disclose your information.

b. With Our Affiliated Companies

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

c. With Service Providers

We may disclose 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.  

d. With Law Enforcement, Courts, or Government Agencies

We may disclose 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 AI Disclosing Your Information to Them

a. “Selling” Your Data

AI is not a data broker. We have not sold your personal information to any third parties in the past 12 months. We have no actual knowledge that we have sold any personal information of consumers under 16 years of age.

However, in some circumstances we disclose your information to third parties not owned by or co-branded with AI. 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 disclose your information to institutional home buyers to try to find a purchaser for the home.
• Home insurance agencies. If you may need homeowners’ insurance, we may disclose your information to 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 AI, we may disclose your information to 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. We may disclose your information to services that perform various checks, including, but not limited to, background checks and credit checks, as permitted by law.

b. “Sharing” Your Data

We do not share your personal information with third parties for cross-contextual behavioural advertising.

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 AI 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 media 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 AI, 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 aspireinnove.com.  

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@aspireinnove.com or 1-888-352-7075.

8. Supplemental India Consumer Privacy Act Rights Notice

a. Our Collection of Personal Information under the India Consumer Privacy Act

We may collect the following categories of personal information:

• Personal identifiers, such as
• Your name, address, phone number, and e-mail address
• Personal information described in the India Customer Records statute (Cal. Civ. Code § 1798.80(e), such as
• Your signature
• Employment
• Protected classification characteristics under California or federal law, such as
• Age
• Veteran or military status
• Commercial information, such as
• Circumstances related to your purchase or sale of a home
• Real estate offer letters
• Internet or other electronic activity information, such as
• Browsing history
• Information related to your interaction with an internet website application
• Geolocation data, such as
• Physical location
• Sensory data, such as
• Audio, electronic, or visual information
• Professional or employment-related information, such as
• Work phone number
• Employer name
• Sensitive personal information, such as
• Your driver’s license or state ID information
• Your account log-in
• Precise geolocation
• Inferences, such as
• Time of day contact preference
• Preferences regarding how you like to tour home (e.g., with an agent)

Categories of sources from which we collect these categories of personal information about you:

• We collect the categories of personal information listed above from the types and categories of sources described above in Section 2 of this privacy policy.

Categories of third parties to which we may disclose these categories of person information:

• We may disclose the categories of personal information listed above to the categories of third parties described above in Sections 3, 4 and 5 of this privacy policy.

Operational purposes for disclosing these categories of personal information. We have disclosed these categories of personal information above and sensitive personal information for a range of operational purposes, including for business purposes such as:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

We do not sell or share your personal information or sensitive personal information. We have no actual knowledge that we have sold any personal information of consumers under 16 years of age.

b. Your California Rights

In addition to AI general privacy policies, consumers that are California residents (hereinafter, “you”) have specific rights under the California Consumer Privacy Act, as amended.  They include:

The right to request that we disclose what personal information we collect, use, and share about you during the preceding 12 months free of charge, unless subject to a legal exception. The request may include the following:

• The categories of personal information and sensitive personal information that we have collected about you.
• The categories of sources from which the personal information and sensitive personal information is collected.
• The business or commercial purpose for collecting or selling personal information or sensitive personal information.
• The categories of third parties with whom we share personal information or sensitive personal information.
• The specific pieces of personal information or sensitive personal information we have collected about you.

The right to opt-out of sale or sharing to third parties of your personal information (as sale and sharing is defined by the CCPA).

The right to request that we correct inaccurate personal information.

The right to request that we delete personal information collected or maintained by us about you, unless subject to a legal exception.

The right to know what personal information or sensitive personal information is sold or shared and to whom.

The right to limit use and disclosure of sensitive personal information.

The right to designate an authorized agent to make a request under state law on your behalf by having the authorized agent submit such request and provide appropriate documentation needed to substantiate the authorization and/or request.

The right to be notified that we collect personal information about you, and the purposes for which the information will be used.  

Job applicants, employees, directors, officers, and contractors should consult AI Indian Employee, Job Applicant, and Contractor Privacy Notice for more information.  

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.

d. Retention of Your Information

We retain the personal information and sensitive personal information we collect as described in this privacy policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. How to Make a Privacy Request

You may exercise any of your rights outlined above by going to aspireinnove.com/privacy or by calling 1-888-352-7075 toll-free.

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 toll-free at 1-888-352-7075. To process your request, our team may require identity verification. In some instances, we may decline to honor your request where an exception under law applies.

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 or sensitive personal information; and
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to the request.

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 fulfil a request to provide or delete personal information or sensitive personal information if we cannot verify your identity or authority to make the request and confirm that the personal information or sensitive 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.

10. Updates and Questions

This policy is updated regularly. We will promptly make any changes available at aspireinnove.com/privacy. Changes will be effective as soon as the updated policy is posted unless otherwise stated. Questions about this policy or if you would like to appeal our decisions with regards to a request, you can contact as at contact@aspireinnove.com or 1-888-352-7075. 

This policy was last modified on November 1, 2023.