Privacy Notice for California Real Estate Agents and Service Contractors

Information We Collect

We collect Personal Information as defined in the CPRA.  Personal Information can generally be described as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. 

We have collected the following categories of Personal Information from real estate agents and service contractors within the last twelve (12) months (and anticipate collecting these categories of Personal Information in the future):  

1. Identifiers and identifying items

Examples

Real name, business or other entity name, signature, social security number, passport number, driver’s license number, state identification card number, insurance policy numbers, unique personal identifier, internet protocol address, email address, postal or billing address, telephone number, education, employment, employment history, account name, bank account number, credit card number, debit card number or other financial information

Sources (see categories below)

1, 2, 3, 4

Purpose

Those purposes listed below under “Use of Personal Information”

2. Internet or other electronic network activity

Examples

Browsing history, search history or other information on your interaction with our website, application or advertisement

Sources (see categories below)

2

Purpose

Those purposes listed below under “Use of Personal Information”

3. Sensory data

Examples

Audio, electronic, visual, or similar information, including security footage if you visit one of our locations

Sources (see categories below)

1, 3

Purpose

Those purposes listed below under “Use of Personal Information”

4. Geolocation data

Examples

Device location and Internet Protocol (IP) location

Sources (see categories below)

1, 3, 4

Purpose

Those purposes listed below under “Use of Personal Information”

5. Professional or employment-related information

Examples

Current or past job history or performance evaluations, including information collected during the course of our business relationship

Sources (see categories below)

2, 3

Purpose

Those purposes listed below under “Use of Personal Information”

6. Inferences drawn from other Personal Information

Examples

Profile created to reflect abilities and aptitudes, including any “preferred provider” profile

Sources (see categories below)

2, 3

Purpose

Those purposes listed below under “Use of Personal Information”

Sources of Information Collected

We collect the Personal Information listed and described above from the following categories of sources:

1. directly from you or your agents.  For example, from forms you complete (whether on a Frontdoor Application or otherwise) or in connection with the products and services that you provide to Frontdoor customers;
2. indirectly from you or your agents.  For example, from observing your actions, and collecting information requested from you, on Frontdoor Applications;
3. from consumers with whom you interact (including on our behalf) in the course of your provision of goods or services to such consumers; and
4. from public sources, such as county and state tax and property records, government agencies and multiple listing services.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes:

1. to build a business relationship with you and provide you with equipment, training and support;
2. to pay or reimburse you;
3. to manage staffing resources, for financial planning, corporate compliance, internal audits and other administration;
4. to communicate with you and facilitate communications between you and other individuals;
5. to comply with legal obligations, including health and safety requirements and requests for information, and to assert, and defend against, any legal claim or inquiry;
6. to monitor and evaluate your performance and to ensure compliance with our policies (including time and attendance) and applicable law;
7. to recognize, reward and empower you;
8. to provide references;
9. to administer our applications, software and electronic systems;
10. to facilitate and expedite dispatches and service calls, including as may be based on the specific location of a contractor;
11. to improve satisfaction and performance;
12. to process claims;
13. to provide services you or others request;
14. to complete transactions you have requested or upon which you assist;
15. to provide you with an account and manage your account;
16. to respond to communications from you;
17. to notify you about updates to our websites, business or services;
18. to measure and improve our business, services and performance;
19. to perform analyses on data we have collected, such as market analyses, trends and other research;
20. to process, provide and administer surveys, events and special promotions;
21. to provide, administer and utilize our social media pages and websites;
22. to compare information and identification for accuracy and verify it, including for identification purposes;
23. to anonymize or otherwise protect your data;
24. to prevent potentially fraudulent, prohibited or illegal activities;
25. to protect the safety and security of our workforce, guests, property and assets (including controlling and facilitating access to and monitoring activity on and in our premises and activity using our computers, devices, networks, communications and other assets);
26. to otherwise manage all aspects of your relationship with us, including but not limited to establishing, maintaining and terminating a business relationship, general operations, and administrative, financial and human resources related purposes; and
27. as otherwise may be described to you when collecting your Personal Information or as otherwise set forth in this Notice or the Frontdoor Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes as compared to those described in this Notice without first, (a) with respect to collection, providing you notice of such collection and (b) with respect to use, providing you notice of such use and receiving your explicit consent to such use. In addition, we do not currently collect or use “Sensitive Personal Information” (as that term is defined under the CPRA).

Retention of Personal Information

We will keep your Personal Information during the period of your relationship with us and, after that period ends, for as long as is necessary in connection with both our and your legal rights and obligations. This may mean that we keep some types of Personal Information for longer than others. We use the following criteria to determine how long to retain Personal Information: (a) our relationship with you, and the goods or services we provide to you or that you provide to us or our consumers; (b) any laws or regulations that we are required to follow; (c) whether we are or may be in a legal or other type of dispute with each other or any third party; (d) the type of information that we hold about you; (e) whether we are asked by you or any regulatory authority to keep your Personal Information for a valid reason, or if we may need to provide it for any legal reasons; and (f) technical considerations and feasibility, and the level of protections in place for your Personal Information.

Sharing Personal Information for a Business Purpose

We share your Personal Information for a legitimate business purpose with the following categories of third parties:

1. Service providers, including third parties used to manage aspects of your relationship with us (including, lawyers, bankers and accountants) and to effectuate the uses of Personal Information as set forth herein (“Service Providers”);
2. Frontdoor’s subsidiaries and affiliates (“Affiliates”); and
3. Third parties to whom you or your agents instruct or authorize us to disclose your Personal Information in connection with the relationship (or prospective relationship) you have with Frontdoor (“Authorized Parties”).

When we disclose Personal Information for a business purpose to a Service Provider, we enter into a written contract with the applicable Service Provider that, among other items, (a) describes the services to be provided, (b) requires such Service Provider to keep any Personal Information we have disclosed thereunder confidential and (c) prohibits such Service Provider from using such Personal Information for any purposes except to provide those services explicitly set forth in the contract. 

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose to the following third parties:

 

1. Identifiers and identifying items

   Categories of Third Parties

   Service Providers

   Affiliates

   Authorized Parties

2. Internet or other electronic network activity

   Categories of Third Parties

   Service Providers

   Affiliates

3. Sensory data

   Categories of Third Parties

   Service Providers

   Affiliates

   Authorized Parties

4. Geolocation data

   Categories of Third Parties

   Service Providers

   Affiliates

   Authorized Parties

5. Professional or employment-related information

    Categories of Third Parties

   Service Providers

   Affiliates

   Authorized Parties

6. Inferences drawn from other Personal Information

   Categories of Third Parties

   Service Providers

   Affiliates

Sales of Personal Information

In the preceding twelve (12) months, we have not sold or shared (as that term is defined in the CPRA) your Personal Information.  In addition, we will not sell or share your Personal Information during any time period in which this Notice does not set forth instructions with respect to your “right to opt-out” of the sale and sharing of your Personal Information.

Your Rights and Choices

The CPRA provides you with specific rights regarding your Personal Information.  This section describes your rights (and certain of our duties) under the CPRA and explains how to exercise those rights.

 

General Duties

Under the CPRA, we have general duties that relate to your Personal Information.  For example, as further described in this Notice, and subject to certain exceptions, we must (a) allow you to access your Personal Information upon request, (b) delete your Personal Information upon request, (c) correct inaccurate Personal Information upon request, (d) not use Personal Information for purposes that are incompatible with the disclosed purpose for which such Personal Information was collected, (e) provide you information on how long we intend to retain your Personal Information, (f) not retaliate against you for exercising your rights relating to Personal Information and (g) implement reasonable security procedures and practices to protect your Personal Information from unauthorized access, disclosure or use.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information.  Once we receive and confirm your Verified Request (as defined below), we will disclose to you:

 

1. all categories of Personal Information we have collected about you since January 1, 2022 (unless you request a more recent date);
2. all categories of sources from which we have collected Personal Information about you during the applicable time period;
3. our business or commercial purpose for collecting, selling or disclosing, as applicable, such Personal Information;
4. the categories of third parties with whom we have shared any such Personal Information for a business purpose, organized in a list (which such list shall be separate from the list detailing the third parties to whom any such Personal Information was sold) that shows the categories of any such Personal Information we shared with each category of third party (or, if we have not shared any such Personal Information, we shall disclose the same);
5. the categories of third parties to whom we have sold any such Personal Information, organized in a list (which such list shall be separate from the list detailing the third parties to whom any such Personal Information was shared for a business purpose) that shows the categories of any such Personal Information sold to each category of third party (or, if we have not sold any such Personal Information, we shall disclose the same); and
6. the specific pieces of Personal Information we have collected about you (also called a data portability request) during the applicable time period.

 

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your Verified Request, we will remove (and direct our Service Providers to remove) such Personal Information from our records, unless an exception applies.

 

We may deny your deletion request to the extent that retaining the Personal Information is necessary for us or our Service Providers to:

 

1. comply with federal, state, or local laws, rules, or regulations;
2. comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities;
3. cooperate with law-enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws, rules, or regulations;
4. investigate, establish, exercise, prepare for, or defend legal claims;
5. provide a product or service requested by you or perform a contract to which we are both party;
6. prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any illegal activity;
7. 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, and meets certain other criteria;
8. identify and repair technical errors that impair existing or intended functionality; or
9. perform internal uses that are reasonably aligned with your expectations based on your business relationship with us.

 

If it is necessary for us to retain certain information, we will inform you of the basis for such retention in response to your request.  For example, as a provider of home service plans, we may retain, for internal purposes, certain information relating to the service you have performed on our customers’ homes.

 

You may also control certain uses of your Personal Information by opting out of marketing communications as described in the “Choice and Opt Out” section of the Frontdoor Privacy Policy available at www.frontdoor.com/contractor-privacy-policy.

 

Right to Correct

You have the right to request that we correct any Personal Information held about you by us that is inaccurate. Once we receive and confirm your Verified Request (as defined below), we will use commercially reasonable efforts to correct any inaccurate Personal Information (and direct our Service Providers to correct such inaccurate Personal Information) and will inform you as to whether we have complied with your correction request. 

 

Exercising Access, Data Portability, Deletion and Correction Rights

To exercise the access, data portability, deletion or correction rights described in this Notice, please submit a verifiable request to us (a “Verified Request) by either:

 

1. emailing us at (a) contractorprivacy@frontdoor.com if you are a service contractor or (b) californiab2bprivacy@frontdoor.com if you are a real estate agent; or
2. calling us toll-free at (a) (844) 850-1055 if you are a service contractor or (b) (833) 919-4760 if you are a real estate agent.

 

Only you, or someone legally authorized to act on your behalf (an “Authorized Agent”), may make a Verified Request related to your Personal Information.  To designate an Authorized Agent, please email us at (a) contractorprivacy@frontdoor.com if you are a service contractor or (b) californiab2bprivacy@frontdoor.com if you are a real estate agent, or write us at:

 

Legal Department

Attention:  Privacy Coordinator

Frontdoor, Inc.

3400 Players Club Parkway, Suite 300

Memphis, TN 38125

 

A Verified Request must describe your request with sufficient detail such that the Verified Request allows us to properly understand, evaluate and respond to it.  In addition, your Verified Request must provide sufficient information that allows us to reasonably verify you are the individual about whom we collected Personal Information or an Authorized Agent of such individual, which such verification may include:

 

1. residency verification;
2. verification of first name, last name, phone number, business address, unique business partner number, phone number or email;
3. re-verification through phone, email or other communication mediums (in particular, if a request to delete is made online); and
4. with respect to Authorized Agents, (a) a signed authorization from the applicable individual evidencing such designation and (b) verification of such individual’s identity in accordance with the verification methods applicable to other individuals.

 

We cannot respond to a request to provide you with, or delete, Personal Information if we cannot verify (a) your identity, (b) a purported agent’s identity or authority to make the request or (c) that the requested Personal Information relates to you.  If we deny your Verified Request, we will inform you and explain the basis for such denial in writing.

 

We will only use Personal Information provided in a Verified Request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to each Verified Request within forty-five (45) days of our receipt of such Verified Request (and we will confirm receipt of such Verified Request within ten (10) days of our receipt thereof).  If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.  We will deliver our written response to your Verified Request by mail or electronically.

 

For data portability requests, we will select a format in which to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to a Verified Request unless such Verified Request is excessive, repetitive or manifestly unfounded.  If we determine that a Verified Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Right to Appeal

In the event we deny a Verified Request, you have the right to seek an appeal of that decision.  To appeal a decision, please email (a) contractorprivacy@frontdoor.com if you are a service contractor or (b) californiab2b2privacy@frontdoor.com if you are real estate agent, and include “Privacy Appeal” in the subject line.  Within sixty (60) days of our receipt of your appeal request, we will inform you of any action taken or not taken in response to your appeal.  If you remain unsatisfied with our decision, you may contact your state’s attorney general via the contact information provided here.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CPRA.  Unless permitted by the CPRA, we will not:

1. deny you goods or services;
2. charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
3. provide you a different level or quality of goods or services; or
4. suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notwithstanding the foregoing, we may offer you certain financial incentives permitted by the CPRA that may result in different prices, rates or quality levels.  Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.  We do not currently offer any financial incentive programs relating to Personal Information. 

Other Privacy Rights

The CPRA does not limit your rights under existing privacy legislation or regulation.  As such, you may request certain information about our disclosures of certain categories of Personal Information to third parties for direct marketing purposes.  All requests for such disclosure must be submitted to the Privacy Coordinator at the address set forth below. 

Changes to Our Notice

We reserve the right to amend this Notice at our discretion and at any time in accordance with applicable law.  If we make any material changes to this Notice or how we handle your Personal Information, you will know either because (a) the Effective Date of this Notice will change or (b) we will provide you with a copy of the updated Notice that includes an updated Effective Date.

Contact Information

If you have any questions or comments about this Notice, the ways in which Frontdoor collects and uses your Personal Information or your choices and rights regarding such collection and use under California law, please email us at (a) contractorprivacy@frontdoor.com if you are a service contractor or (b) californiab2bprivacy@frontdoor.com if you are a real estate agent, or contact us at:

Postal Address:

Legal Department
Attention: Privacy Coordinator
Frontdoor, Inc.
3400 Players Club Parkway, Suite 300
Memphis, TN 38125