Last Update: April 17, 2024

Natomas Labs, Inc. d/b/a Villa Homes (referred to in this Privacy Policy as the “Company”, “Villa”, “we”, “us”, and “our”) strives to offer America’s leading next-generation homebuilding platform.  Villa respects the privacy of the visitors to our digital properties and the users of our products and services, and we are committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes how Villa collects, stores, uses, and safeguards your information when you use our website at https://villahomes.com/ (the “Site”), any mobile/tablet applications we may use (“Apps”), the user portal located at app.villahomes.com (the “Portal”), and through any other websites, pages, features, or content owned and operated by Villa that direct to this Privacy Policy (collectively, including the Site and Apps, the “Services”)

By using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Policy, and you consent to the practices and terms set forth in our Terms of Use, available here.  If you do not feel comfortable with any part of this Privacy Policy or our Terms of Use, please discontinue use of the Services or engaging with Villa immediately.

CONTENTS

1. Updates to this Privacy Policy
2. Personal Information We Collect
3. How We Use Your Personal Information
4. Sharing and Disclosure of Personal Information
5. Cookies and Other Tracking Technologies
6. Retention
7. Your Privacy Rights and Choices
8. Additional Notice to California Residents
9. International Transfers
10. Data Security
11. Integration of Third-Party Platforms and Services
12. Children’s Privacy
13. Contact Us

1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in the law or as we update or expand our Services. When we make a change, we will provide you with notice of such updates as required by applicable law, and we will revise the “Last Updated” date at the top of this Policy. All changes will be effective as of the “Last Updated” date. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services. If you have any questions about this Privacy Policy, please reach out to us anytime at privacy@villahomes.com, or as described in the contact information included within the “Contact Us” section below.

2. PERSONAL INFORMATION WE COLLECT

Villa collects personal information when you interact with our Services. Personal information is any information that identifies or makes an individual identifiable. The definition of personal information depends on the applicable law based on your residence. Only the definition that applies to where you reside will apply to you under this Privacy Policy.

The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Services, and information from third parties.

a. Information You Voluntarily Provide to Us:  The personal information we collect on or through our Services may include:

• Account Registration: information relating to the creation of a Villa account such as first and last name, email address, property address, telephone number, a unique individual password and your status (e.g., homeowner, investor, parcel owner, real estate agent, etc.);
• Form Submissions:  contact information that you provide by filling in forms that we make available, such as to schedule a tour, receive an estimate or to speak to one of our experts about a potential project;
• Customer Service:  records and copies of your correspondence or requests for technical support (including email addresses), if you contact us by telephone or in writing or via an automated or live chat service available on our Services;
• Promotions and Feedback: information relating to your participation in a promotion, to request a referral program code, or survey that we may ask you to complete for research purposes;
• Marketing or Company Communications Sign-ups:  information relating to our products, services, giveaways, discount offers, and other information about our services and offerings, including name and email address;
• Payment Information: payment card, transaction or financial account information;
• Job Applications: employment- and background-related information provided to us as a part of the job application process;
• Device Permissions: information relating to your use of features of our Services that may ask you to grant us access to location information, photos, microphone, video camera, or media on your computer or mobile device.

b. Information from Third Parties:  When you interact with our Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.

The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms.

c. Information Collected Automatically:  As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Information About Your Use of the Services: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.
• Device Information: if you access the Services through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
• Performance Data: information about your preferences to make your use of the Services more productive, via the use of Cookies or similar tracking technologies. 

For more information about how we collect your information automatically, please see the “Cookies and Other Tracking Technologies” Section below.   

3. HOW WE USE YOUR PERSONAL INFORMATION

Villa will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. We process your personal information for the following purposes:

a. To Provide You Our Services: providing any services that you request in connection with the Services;

b. To Provide You with Service-Related Communications and Customer Support: contacting you regarding the administration of any features or functions of the Services you have registered to use, and notifying you about changes to our Services, our policies, terms, or any products or services we offer or provide though our Services;

c. To Send You Marketing and Promotional Emails: contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the Services that you already use or the offerings that you have already inquired about, unless you have opted not to receive such information;

e. For Internal Use and Services Improvement: accumulating and reporting aggregate, statistical information in connection with the Services and user activity, including determining which features and services users like best to help us operate, enhance, and improve our Services;

f. To Enforce Compliance with Our Agreements or Policies: keeping you secure and safe while using our Services, which requires us to process your personal information in accordance with this Privacy Policy to combat spam, malware, malicious activities, fraud, or security risks as part of our ongoing maintenance and enforcement of our security measures, and carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;

g. To Maintain Legal and Regulatory Compliance: processing personal information to pay our taxes, fulfill our business obligations, for compliance with employment and recruitment laws, or as necessary to manage risk under applicable law;

h. For Customization: saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the services; tailoring your experience on the Services; and/or otherwise customizing what you see when you visit and use the Services;

i. For Research Purposes: for research purposes and to provide anonymous reporting for internal and external clients and business partners;

j. With Your Consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction;

k. For Employment Purposes: processing job applications, including to communicate with you and to conduct applicant and employment-related statistical evaluation and record-keeping.

We may also aggregate or deidentify any personal information that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated or de-identified information for our own legitimate business purposes without restriction.

4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may share or disclose your personal information in the following circumstances:

a. Within Our Corporate Organization. We may share your personal information with any subsidiaries and affiliates in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.

b. Service Providers. We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Services are used. These service providers provide us support services such as credit card processing (such as for ordering feasibility studies), payment gateways, suppliers or building and construction subcontractors receiving certain information in relation to your housing project, website hosting, customer relationship management, appointment scheduling, shipping, email and postal delivery, analytics, surveys, referral rewards, marketing services, and videoconferencing. The service providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

c. Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information, unless you contact us to request opting out of such disclosure. 

d. As Required by Law and to Protect Lawful Interests. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Villa or our customers.

e. With Your Consent. We may disclose your personal information for any purpose with your consent.

Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services., including to:

• Analyze our web traffic
• Identify whether you already visited our Services
• Store information about your preferences
• Recognize you when you return to our Services
• Show you interest-based advertisements
• Personalize your user experience

Analytics.  We and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. For more information on how to opt out of Google Analytics tracking, click here.

Opt-Outs. To opt-out of the advertising, analytics & customization, and performance & functionality cookies used on our Services, view the cookie banner visible when you first visit the Site or click the link here to re-open the cookie banner. 

Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt-out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal, or visit the NAI’s opt-out portal.

We also may implement on our Services debugging tools, behavior analytics software and session replay services, such as from Hotjar (https://www.hotjar.com/legal/policies/privacy/) or LogRocket (https://logrocket.com/privacy/), which are designed to give website owners an aggregated view of their users’ behavior while browsing their site and to help identify where issues may occur that need remediation. This provides website owners like Villa Homes with the insights needed to improve the overall experience for our users. If you would like Hotjar to not collect your information while on our Services, please visit Hotjar’s “Do Not Track” page here:  https://www.hotjar.com/policies/do-not-track/.  You can email support@logrocket.com  to request that any information LogRocket collected on you be deleted, and/or to disable future information collection.

We may also use the Meta Pixel on our Site to measure the usage of our site or the effectiveness of our advertising by understanding the actions people take on our website.  You have the right to opt-out of the collection and use of such information for ad targeting, which you may do via the DAA and NAI links above.

Managing Cookies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you choose to disable cookies in your browser, you can still use the Services, although your ability to use some of the features may be affected. If you want to exercise your rights regarding personal information collected via cookies and similar tracking technologies, please see the “Your Rights and Choices” section below.

Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

6. RETENTION

Villa will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data or the information you provided to us to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will retain your marketing contact information until you unsubscribe from our marketing communications. We will also retain Services usage data for internal analysis purposes.

7. YOUR PRIVACY RIGHTS AND CHOICES

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the table below to determine the rights you have in your jurisdiction.

Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

Privacy Rights include the following:

1. Right to Know/Access.  You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.

2. Right to Correct.  You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate. In addition to the methods described below, you can correct your personal information through your account settings.

3. Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable laws and their exceptions.

4. Right to Portability. You may have the right to receive a copy of the personal information we have collected about you in a structured, commonly used and machine-readable format.

5. Right to Opt-Out Sale / Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of: (i) the sale of your personal information; and (ii) the sharing of your personal information for targeted advertising.

While we do not sell your personal information for money, like many websites, we use cookies, pixels, and similar technology, and we make available certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under some state privacy laws’ broad definition of “sell”, this could be considered a sale, and it could be considered “sharing” of your personal information for targeted, cross-context behavioral advertising purposes.

You have the right to direct us not to sell your personal information to third parties, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please submit a request as described below. 

Villa processes opt-out preference signals in a frictionless manner in alignment with applicable law. To start using an opt-out preference signal for your web browser, please refer to the Global Privacy Control instructions provided here. You will need to submit a separate opt-out of selling/sharing request on each device and browser you use to visit our Site. Please note that you may still receive generalized ads after opting out of targeted advertising.

6. Right to Limit Use and Disclosure of Sensitive Personal Information. If you are a California resident, to the extent your sensitive personal information, as that term is defined under California privacy law, is used to infer characteristics about you, you have the right to object to our processing of your sensitive personal information. We do not process your sensitive personal information to perform our Services.

7. Right to Opt-Out of Automated Decision-making or Profiling. You may have the right not to be subject to a decision which significantly impact your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

8. Right Against Discrimination.  You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.

9. Shine the Light. If you are a California resident, you have the right to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information.

10. Marketing Communications.  You may choose to provide us with your email address to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. If you sign up to receive text messages from us that contain promotional information, you can opt-out of receiving future messages by replying “STOP.”

As mentioned above, depending on where you reside or are located, you may be able to assert certain rights with respect to your personal information. To determine which rights you have, please refer to the table below that references the rights as described above in the Privacy Rights and Choices Section. Any places that are not listed either do not have a law providing such rights, or their law does not apply to our operations.

Submitting a Request to Exercise Your Rights.  You may exercise these rights by: emailing us at privacy@villahomes.com with the subject line “Privacy Rights Request”; or sending your request via mail to the address provided in the Contact Us section below.

Before fulfilling your request, we may be required by law to have you verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

You may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.

8. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

In the preceding 12 months, depending how you interact with our Services, we may have collected the following categories of personal information (as defined under Cal. Civ. Code  §1798.140(v)(1)):

• Identifiers, such as your name, mailing address, unique personal identifier, email, phone number, driver’s license or ID number, or similar identifiers.
• Characteristics protected under state and federal law, such as your age, gender and other demographic information.
• Commercial information, such as your transaction records, payment information, property records, or related purchase history. 
• Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including your browsing history, search history, the webpage visited before you came to our Services, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, and system configuration information.
• Geolocation data, such as geolocation, to the extent you have configured your device to permit us to collect such information.
• Professional or employment-related information, if you have applied for a job at Villa.
• Inferences drawn from any of the information listed above, such as your preferences, characteristics, and behavior.

For more information about the personal information we collect and how we collect it, please refer to Section 2 above, “Personal Information We Collect.”

For more information about the business purposes for which we collect your personal information, please refer to Section 3 above, “How We Use Your Personal Information.” 

To learn the categories of third parties with whom we may share your personal information, please refer to Section 4 above, “Sharing and Disclosure of Personal Information.”  

9. INTERNATIONAL TRANSFERS

When you access or use our Services, your personal information may be processed in the United States or any other country in which Villa, its affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

10. DATA SECURITY

We believe that it takes reasonable measures, including administrative, technical, and physical safeguards, as required by state and/or Federal law to protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information to perform our business purposes, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately as described below.

11. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES

The Services may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including third-party services. The Services may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Services or for the privacy practices of third party advertising companies. Once you leave our Services via a link, access a third-party service or click on an advertisement, you should check the applicable privacy policies to determine, among other things, how related companies process personal information they may collect about you. This Privacy Policy applies solely to information collected by Villa.

12. CHILDREN’S PRIVACY

Villa Services are not directed toward children under the age of 16, and we do not knowingly collect any personal information from children under the age of 16. If a child under 16 provided our Services with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.

13. CONTACT US

We welcome your questions, comments, and concerns about privacy. You can contact us anytime via email at privacy@villahomes.com or via phone at +1 (415) 968-1625.