Privacy Policy

1. INTRODUCTION

Opteon AMC, Inc. and Opteon Appraisal, Inc. (together, “Opteon,” “we,” “us,” and “our") respect your privacy and are committed to protecting it. Please read this privacy policy (“Privacy Policy”) carefully to understand how and why Opteon collects, stores, uses, discloses, sells, shares, and otherwise processes personal data. It also explains your rights in relation to your personal data and how to contact us or applicable supervisory authorities if you have a complaint. This Privacy Policy covers Personal Data we receive from various sources, as outlined below. By using Opteon’s website or engaging in transactions with Opteon by any other means, you acknowledge that you have reviewed the practices and policies outlined in this Privacy Policy. Opteon, to the extent it collects any Personal Data, it is collected directly from you – in person, by telephone, by text or email, or via our website or online forms. To the extent Opteon receives such information, Opteon uses, discloses, shares, and otherwise processes Personal Data as described in this Privacy Policy, and as permitted or required by applicable law. Where consent is required, Opteon requests it separately and clearly.

2. PERSONAL DATA WE MAY COLLECT

"Personal Data means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual, household, or device. Personal Data may include, depending on the context, identifiers such as name, postal address, email address, telephone number, IP address, device identifiers, account or transaction information, property or appraisal-related information, internet or electronic network activity information, commercial information, professional or employment-related information, and other information described in this Privacy Policy. Personal Data does not include information that is excluded from the scope of applicable privacy laws, such as publicly available information from government records, lawfully obtained truthful information that is a matter of public concern, deidentified or aggregated information, or other information exempt under applicable law. Because Opteon’s services are primarily provided in connection with appraisal management, valuation, real estate, loan originations, and related business services in the United States, this Privacy Policy is intended to describe our privacy practices for U.S. operations. If a separate jurisdiction-specific notice applies, we will provide it as required by applicable law.

For purposes of this Privacy Policy, “sell,” “share,” “service provider,” “contractor,” “third party,” “sensitive personal information,” and related terms have the meanings given to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and other applicable U.S. state privacy laws. “Sharing” generally means disclosing Personal Data to a third party for cross-context behavioral advertising, whether or not money is exchanged.

We may collect and use the following Personal Data that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Data	Specific Types of Personal Data Collected
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Name, telephone number, email address, subject property address(es), postal address(es), file ID, loan number IP address
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Name, telephone number, employer or company name, credit card information Opteon never stores credit card information; all payment processing is encrypted and conducted via third parties. Please review their privacy policies for more information.
Characteristics of protected classifications under California or federal law.	None
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Financial and real estate transactional information (such as details about relevant mortgage or rental history); property ownership information (such as details about tenant and lender history); loan type
Biometric information	None
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	IP address, device identifiers, browser type, operating system, pages viewed, referring URLs, interaction with website features, cookie identifiers, pixels, tags, session replay or analytics data, and other information regarding interaction with our websites, applications, emails, or advertisements, where used.
Geolocation data	None
Audio, electronic, visual, thermal, olfactory, or similar information	None
Professional or employment-related information	Job title, employer or company name
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	None
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	None
Sensitive personal information	Sensitive personal information may include Social Security number, driver’s license, state identification card or passport number; account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials; precise geolocation if collected; contents of communications where Opteon is not the intended recipient; and any Personal Data of consumers we have actual knowledge are under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law, such as providing requested services, ensuring security and integrity, preventing fraud, complying with legal obligations, or other purposes expressly permitted by regulation.

3. HOW WE COLLECT PERSONAL DATA

We collect most of this Personal Data directly from you—in person, by telephone, by text or email, or via our website or online forms. By providing us with this Personal Data, you expressly agree to our collection, use, storage, and disclosure of it as detailed in this Privacy Policy. Personal Data is required for Opteon to provide you with our products and services; if you elect not to provide the Personal Data we ask for, it may delay or prevent us from providing you with those products and services.

We may also collect information:

From publicly accessible sources (e.g., property records);

Directly from a third party (e.g., credit reporting agencies, customer due diligence providers);

From a third party with your consent (e.g., your bank);

From cookies on our website; and

Via our IT systems, including:

Door entry systems and reception logs;

Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

When our website uses cookies, pixels, tags, analytics tools, session replay technologies, chat tools, advertising technologies, or similar technologies, we endeavor to provide notice and, where required, obtain consent before non-essential technologies are activated. We do not intend to use these technologies to intercept communications in a manner prohibited by applicable law, including the California Invasion of Privacy Act (“CIPA”). Website users should use available cookie preference tools to manage non-essential tracking technologies.

Our services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. We also do not knowingly sell or share Personal Data of consumers under 16 years of age. If we learn that we have collected Personal Data from a child under 13, or that we have sold or shared Personal Data of a consumer under 16 without legally required consent, we will take reasonable steps to delete the information or stop the sale or sharing, as applicable.

4. HOW AND WHY WE USE YOUR DATA

We may use or process Personal Data for any purpose permitted under applicable data protection laws in accordance with this Privacy Policy. “Processing” of Personal Data includes collecting, recording, organizing, structuring, storing, altering or modifying, retrieving, transmitting, disclosing or otherwise making available to third parties, deleting, or otherwise using or dealing with your Personal Data. We may process your Personal Data with or without automatic means.

The purposes for which we process your Personal Data include:

What we use your Personal Data for	Reasons
To provide products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Opteon	For our legitimate interests or those of you or a third party, i.e. to minimize fraud that could be damaging for us and for you
Verifying customer identities Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations To protect us and you against fraud or misappropriation of your personal data
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best services to you
Operational reasons, such as improving efficiency, training, or quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you and all our customers at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base and satisfaction, product range, or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best services to you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of you or a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. ensuring we can contact our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: · existing and former customers; · third parties who have previously expressed an interest in our services; · third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or those of you or a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

Artificial Intelligence and Automated Tools. We may use artificial intelligence, machine learning, generative AI, large language models, automated workflows, analytics tools, and similar technologies to support our business operations and services, including order management, document intake, data extraction, quality control, fraud prevention, security, customer support, internal training, analytics, product development, and service improvement.

We do not use these technologies to make a final decision that produces a legal or similarly significant effect concerning a consumer, such as eligibility for housing, credit, lending, insurance, employment, health care, education, or other consequential services, unless we provide any notice, explanation, correction, opt-out, appeal, human review, or other rights required by applicable law.

We do not knowingly submit Personal Data to public generative AI tools in a manner that permits the tool provider to use that Personal Data to train its general-purpose models, unless permitted by applicable law, contract, and Opteon policy.

When using AI-enabled service providers, Opteon seeks to use reasonable contractual, technical, and organizational safeguards designed to protect Personal Data, limit unauthorized use, and maintain confidentiality and security.

If California law requires notice[JB6.1], access, opt-out, or other rights related to Opteon’s use of automated decision-making technology, Opteon will provide those rights as required. Depending on the context, this may include information about the logic, role, intended use, categories of Personal Data processed, and potential outcome of the automated decision-making technology, as well as any legally required method to opt out or request access to additional information.

If Opteon uses automated decision-making technology [JB7.1]to materially influence a consequential decision about a Colorado consumer in a covered area such as housing, financial or lending services, insurance, employment, education, health care, or essential government services, Opteon will provide any notice, explanation, correction right, personal-data access right, and meaningful human review or reconsideration process required by Colorado law.

Where required by applicable law[JB8.1], Opteon will provide notice when users are interacting with generative AI or AI-enabled features and may disclose that AI-generated outputs can be incomplete, inaccurate, or require human review before reliance.

5. WHO WE SHARE PERSONAL DATA WITH

We routinely share personal information with:

Our affiliates, including companies within Opteon AMC, Inc. and Opteon Appraisal, Inc.;

Service providers we use to help deliver our services to you, such as technology and payment services;

Service providers we use to help deliver our services to you, such as payment services;

Credit reporting agencies, insurers, and brokers; and

Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to confidentiality, to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. While we typically anonymize information, this may not always be possible. The recipient of such information will be bound by confidentiality obligations.

We do not sell Personal Data for money. We also do not sell or share mobile telephone numbers for third-party marketing. However, certain disclosures to advertising, analytics, or technology partners may be considered a “sale” or “sharing” under California and other state privacy laws, even where no money is exchanged. Where applicable, you may opt out of such sale or sharing as described in this Privacy Policy.

6. RETENTION, STORAGE, AND DISPOSAL OF PERSONAL DATA

Opteon is required by law to store some information for a defined period of time. In some cases, Opteon may retain information indefinitely. We keep your Personal Data while you have an account with us or while we are providing you with products or services. Thereafter, we retain Personal Data in order to respond to questions, complaints, or claims made by you or on your behalf, to show we treated you fairly and acted in accordance with the law, or to keep records otherwise required by law. We archive all Personal Data on an annual basis and regularly backs up all data in order to maintain data integrity and business continuity.

Personal Data may be held at our offices and those of our affiliates, third party agencies, service providers, representatives, and agents as described elsewhere in this Privacy Policy.

When Opteon disposes of Personal Data, it does so completely so that no trace of the information exists other than in aggregate, anonymized data.

Opteon takes appropriate security measures to prevent accidental loss, unauthorized access, and misappropriation of your Personal Data. We limit access to your Personal Data to those who have a genuine business need for access. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. Opteon’s Information Technology team continually tests our systems, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

7. SALE AND RENTAL OF PERSONAL DATA

Except as disclosed in this Privacy Policy, Opteon does not sell or rent Personal Data for money. In the preceding 12 months, we may have disclosed Personal Data to service providers, contractors, affiliates, customers, lenders, appraisal providers, payment processors, technology providers, analytics providers, auditors, professional advisers, regulators, and other parties as reasonably necessary for the purposes described in this Privacy Policy. We may also have shared online identifiers, internet or electronic network activity information, and related device or usage data with advertising or analytics partners in a manner that may be considered “sharing” for cross-context behavioral advertising under California law.

8. YOUR RIGHTS RELATING TO YOUR DATA

If you wish to opt out from any of the uses of Personal Data that are specified in this Privacy Policy, except in the case of legal proceedings or where your data is required for tax and transactional purposes, please contact us as described in Section XIII below. Subsequent disclosure of Personal Data to us nullifies prior opt-out requests.

While Opteon does not discriminate against those who opt-out, opting out may prevent us from conveniently and efficiently providing further product support services and information to you.

Unsubscribing to marketing communications: You may unsubscribe from marketing communications at any time. To unsubscribe to marketing communications, please contact us as set forth in Sections X and XIV below.

9. MARKETING COMMUNICATIONS

We may use your personal information to send you offers, promotions, and updates by email, text message, telephone or mail about products and services offered by Opteon and our Partners.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside of Opteon AMC, Inc. and its affiliated entities.

You have the right to opt out of marketing communications at any time by: (i) using the “unsubscribe” option provided within marketing emails or (ii) contacting us directly as set forth in Section XIV below.

If you chose to opt-out or update your marketing preferences, please allow us sufficient time to process your request. We may still contact you for transactional and informational purposes, such as customer service issues, in response to inquiries relating to Opteon products and services, outstanding payment inquiries, surveys and recalls, or any questions regarding a specific request.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

10. DEIDENTIFIED AND AGGREGATED INFORMATION

We may create, use, retain, disclose, and analyze deidentified, aggregated, or statistical information derived from Personal Data for lawful business purposes, including analytics, benchmarking, quality control, fraud prevention, product development, service improvement, model evaluation, and operational reporting. We maintain and use deidentified information in deidentified form and do not attempt to reidentify it except as permitted by applicable law, such as to test the effectiveness of our deidentification processes. We also require recipients of deidentified information to agree not to attempt to reidentify it where required by law or contract.

11. CHANGES TO PRIVACY POLICY

We review this Privacy Policy regularly and may make changes from time to time. We will post any changes on this page and may also provide notice of material changes via the contact information you provide. Each time you use a product or service of Opteon, you agree that the current version of this Privacy Policy applies.

12. EXTERNAL LINKS

This site may contain links to third-party websites, including websites operated by our suppliers and commercial partners. These linked sites are not under our control or subject to this Privacy Policy, and we are not responsible for content on these sites. Before using any third-party website, we recommend you examine the terms of use and privacy policy of that site.

13. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Personal Data that we hold about you, have any complaints, would like to opt out of marketing communications, would like to exercise any of your other rights related to your Personal Data, or need any extra help accessing this Privacy Policy in a different format (for example: audio, large print, braille), please contact us:

By email: legal@opteonusa.com; or

By telephone: +1 (833) 740-2739

14. ADDITIONAL CALIFORNIA CONSUMER RIGHTS NOTICE

The CCPA provides California residents: with rights to know, access, delete, correct, opt out of sale or sharing, limit certain uses and disclosures of sensitive personal information, receive non-discriminatory treatment for exercising privacy rights, and, where applicable, receive information about automated decision-making technology.

Right to Disclosure of Personal Information We Collect About You	You have the right to know: · The categories of personal information we have collected about you; · The categories of sources from which the personal information is collected; · Our business or commercial purpose for collecting or selling personal information; · The categories of third parties with whom we share personal information, if any; and · The specific pieces of personal information we have collected about you. Please note that we are not required to: · Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; · Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or · Provide the personal information to you more than twice in a 12-month period.
Right of Correction	You have the right to request that we correct inaccurate personal information, taking into account the nature of the personal information and thus purposes of the processing of the personal information.
Personal Information Sold, Shared, or Disclosed for a Business Purpose	You have the right to know the categories of Personal Data we sold, shared, or disclosed for a business purpose; the categories of third parties to whom Personal Data was sold or shared; and the categories of service providers, contractors, or third parties to whom Personal Data was disclosed for a business purpose. You have the right to opt out of the sale or sharing of your Personal Data. If we receive a valid opt-out request or applicable opt-out preference signal, we will process that request and provide confirmation where required by law. To opt out, use the “Do Not Sell or Share My Personal Information” or “Your Privacy Choices” link on our website, if available, or contact us using the methods listed below.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: · Delete your personal information from our records; and · Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: · Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; · Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; · Debug to identify and repair errors that impair existing intended functionality; · Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; · Comply with the California Electronic Communications Privacy Act; · Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; · Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; · Comply with an existing legal obligation; or · Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right of Portability	You have the right, upon request, to obtain your personal information by mail or electronic delivery without charge and in a readily usable format that allows you to transmit the information from one entity to another without hindrance.
Right of No Discrimination or Retaliation	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: · Deny goods or services to you; · Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; · Provide a different level or quality of goods or services to you; or · Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information	You may have the right to limit our use and disclosure of sensitive personal information to purposes permitted by law. Opteon does not use or disclose sensitive personal information for purposes that require a right to limit unless we provide the required notice and mechanism for exercising that right.
Automated Decision-Making and Artificial Intelligence	If Opteon uses automated decision-making technology or artificial intelligence to make or materially influence a decision that produces a legal or similarly significant effect concerning you, we will provide any notice, explanation, access, correction, opt-out, appeal, or human review rights required by applicable law, including state laws governing automated decision-making in housing, financial, lending, employment, or similar consequential decisions.

California residents who would like to exercise a right as described in this Privacy Policy, should:

Complete a data subject request form available on our website at opteonsolutions.com/us;

Call us toll-free at (888) 887-0207 or

Email us at legal@opteonusa.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within any 12-month period.

If you choose to contact us, please provide us with:

Enough information to identify you (e.g., your name, address, and customer or matter reference number);

Proof of your identity and address (e.g., a copy of your driver’s license or passport and a recent utility or credit card bill); and

A description of what right you want to exercise and the information to which your request relates.

If we cannot verify that the person making a request is the person about whom we collected information or is otherwise authorized to act on such person’s behalf, we are not obligated to make a data access or data portability disclosure. Any personal information we collect from you to verify your identity in connection with your request under this section will be used solely for the purposes of verification.

If your request relates to an opt-out of sale or sharing, we will also honor legally recognized opt-out preference signals, such as Global Privacy Control, where required. If applicable, we may ask you to confirm whether an opt-out request applies to the browser, device, account, or broader consumer profile associated with the request.

Residents of other states with comprehensive privacy laws may have similar rights, including rights to access, correct, delete, obtain a copy of Personal Data, opt out of targeted advertising, opt out of sale, opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, and appeal a denied request. We will respond to such requests as required by applicable law.