Britehome Privacy Policy

01Overview

Britehome is the trade name used by Aquasition IO LLC ("Britehome," "we," "us," or "our"), a [STATE OF FORMATION] limited liability company operating at britehome.com. This Privacy Policy explains what categories of information we gather, the ways we use and share that information, the safeguards we have in place, and the rights you can exercise over your own data. It covers data we collect from our clients, from visitors to our website, and from individuals whose information passes through our lead-generation operations.

02Information We Collect

2.1 From Clients

During onboarding and the ongoing delivery of services, we gather the following from our clients:

• Full legal name and contact details, including email and phone number
• Registered business name and legal business address
• Employer Identification Number (EIN)
• Designated service areas
• Payment information (handled by third-party payment processors — Britehome does not store full card numbers or CVV codes)
• Campaign preferences, history, and performance metrics
• Records of communication and correspondence with our team

2.2 From Homeowners (Campaign Recipients)

When running SMS marketing campaigns on behalf of a client, we may process the following data about homeowner contacts:

• Name
• Phone number
• Residential address
• Email address, where available
• Response and engagement data from the campaign

This data is used exclusively to deliver lead-generation services to the relevant client. Britehome does not repurpose homeowner contact data for any independent commercial activity.

2.3 Website Visitors

Standard analytics data may be gathered from visitors to britehome.com — including IP address, browser, device type, pages viewed, and time on site — through cookies and third-party analytics tools.

03How We Use Information

We use the data we collect to:

• Deliver, operate, and manage lead-generation services for our clients
• Register and operate 10DLC SMS campaigns on behalf of clients using each client's business identity
• Process payments, billing, and collections
• Communicate with clients about their campaigns, accounts, and service status
• Keep internal records and audit logs for compliance and dispute purposes
• Improve and refine our services, operations, and systems
• Meet our legal and regulatory obligations
• Investigate and defend against potential legal claims

04EIN Usage

Client EINs are gathered solely to register 10DLC SMS campaigns with telecommunications carriers and their authorized aggregators on the client's behalf. EINs are stored under access controls that limit access to authorized Britehome personnel on a need-to-know basis. We do not share EINs with any third party other than the carriers and aggregators required for campaign registration. EINs are never used for any commercial, marketing, or other purpose beyond campaign registration.

05Data Sharing

Britehome does not sell client data or homeowner data to any third party. We may share information as follows:

5.1 Service Providers

We share data with vendors and providers who help us deliver services, including: telecommunications carriers and SMS aggregators (for campaign registration and message delivery); payment processors (for transaction handling); CRM and marketing automation platforms; cloud storage and productivity tools; and data sourcing and analytics providers. These providers are permitted to use shared information only as needed to perform services for Britehome and may not use it for their own commercial purposes.

5.2 International Service Providers and Contractors

Britehome works with service providers and independent contractors located outside the United States. As a result, personal information — including homeowner contact data processed in connection with campaign operations — may be transferred to, stored in, or processed in countries outside the United States, which may have different or less comprehensive data protection laws than your home jurisdiction. When such transfers occur, Britehome takes reasonable steps to implement appropriate contractual and operational safeguards consistent with applicable law. By engaging Britehome's services, Client acknowledges and consents to these international transfers as they relate to service delivery.

5.3 Legal and Regulatory Authorities

We may disclose information to law enforcement, regulators, courts, or other government bodies where required by law, regulation, subpoena, court order, or other legal process, or where we reasonably believe disclosure is necessary to protect our legal rights, the safety of any person, or the integrity of our operations.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, client and operational data may pass to the successor entity, provided the successor takes on obligations consistent with this Privacy Policy.

06SMS Campaign Opt-Out

Homeowners who receive SMS messages through campaigns we operate on behalf of clients may opt out of further communications at any time by replying STOP to any message. Opt-out instructions appear in campaign messaging where applicable law requires. Opt-out requests are processed through our SMS platform and honored promptly, in line with TCPA requirements and carrier rules. Opt-out records are kept in our systems and not overridden. A homeowner who has opted out will not receive further SMS messages tied to a Britehome-operated campaign unless they re-engage on their own.

07Data Security

Britehome maintains commercially reasonable technical and organizational measures designed to protect client and homeowner data from unauthorized access, disclosure, alteration, loss, or destruction. These measures include role-based access controls, secure credential management, vendor screening, and ongoing monitoring of our operational environment. That said, no electronic transmission or storage system is fully secure, and we can't guarantee absolute security of any information. If a data security incident affects your personal information and triggers notification obligations under applicable law, we will notify affected clients as required.

08Data Retention

We retain client information for as long as needed to: deliver and manage services; meet legal and regulatory obligations; resolve disputes; and enforce our agreements. After services end, client data may be retained for up to twenty-four (24) months for compliance and dispute resolution purposes, then securely deleted or anonymized. Homeowner contact data tied to completed or terminated campaigns is retained only for the minimum period required by applicable law and then securely disposed of.

09State-Specific Privacy Rights

9.1 California Residents — CCPA/CPRA

California residents have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share data.
• Right to Delete: request deletion of personal information we hold about you, subject to certain legal exceptions.
• Right to Correct: request correction of inaccurate personal information we hold about you.
• Right to Opt-Out of Sale or Sharing: Britehome does not sell personal information, and we do not share personal information for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: to the extent we process sensitive personal information as defined under the CPRA (such as EINs), use is limited to what's necessary for service delivery and as otherwise permitted by law.
• Non-Discrimination: we will not discriminate against anyone for exercising their CCPA/CPRA rights.

To exercise any of these rights, send a verifiable request to [email protected]. We'll verify your identity before processing any request and respond within 45 calendar days, with up to a 45-day extension where law permits.

9.2 Virginia Residents — CDPA

Virginia residents have rights under the Virginia Consumer Data Protection Act to: access and obtain a copy of their personal data; correct inaccuracies; delete personal data provided by or obtained about them; and opt out of the sale of personal data, targeted advertising, and certain profiling. Contact [email protected] to exercise these rights. We will respond within 45 days.

9.3 Colorado Residents — CPA

Colorado residents have rights under the Colorado Privacy Act to: access, correct, and delete their personal data; obtain a portable copy of their personal data; and opt out of processing for targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects. Contact [email protected] to exercise these rights.

9.4 Texas Residents — TDPSA

Texas residents have rights under the Texas Data Privacy and Security Act to access, correct, delete, and obtain a copy of their personal data, and to opt out of the sale of personal data and targeted advertising. Contact [email protected].

9.5 Connecticut Residents — CTDPA

Connecticut residents have rights under the Connecticut Data Privacy Act to access, correct, delete, and obtain a copy of their personal data and to opt out of certain processing. Contact [email protected].

9.6 Florida — SMS Communications

Our SMS marketing campaigns may be subject to the Florida Telephone Solicitation Act (Fla. Stat. § 501.059). Homeowners in Florida who receive SMS messages through Britehome-operated campaigns may opt out at any time by replying STOP.

9.7 Other State Residents

Residents of states with enacted comprehensive consumer privacy legislation not listed above may have rights similar to those described in this section. Britehome is committed to honoring applicable consumer privacy rights regardless of jurisdiction. Send any privacy-related request to [email protected].

10Your Rights — All Users

No matter where you live, you may submit a request to access, correct, or delete your personal information by emailing [email protected]. Verifiable requests receive a response within 30 days (or 45 days for California residents where additional time is permitted by law). We may ask for reasonable information to verify your identity before processing any request.

11Cookies & Tracking Technologies

britehome.com may use cookies and similar tracking tools for analytics, functionality, and performance purposes. You can control or disable cookies through your browser settings. Britehome does not run cross-site behavioral advertising and does not sell data collected through cookies.

12Children's Privacy

Our services are directed exclusively at business entities and business owners. We do not knowingly collect personal information from anyone under 18. If we discover that we have collected information from a minor, we'll take steps to delete it promptly.

13Changes to This Policy

We may update or modify this Privacy Policy at any time. Material changes will be communicated to clients by email to the address on file or by posting an updated policy at britehome.com with a revised effective date. Continued use of our services after the effective date of any update means you accept the updated policy.

14Governing Law

This Privacy Policy is governed by and interpreted under the laws of the State of [STATE OF FORMATION].

15Contact