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Privacy Principles

Effective Date: January 1, 2020 

This Privacy Policy only applies to web sites which are owned, controlled and/or operated by or on behalf of CREATE BUILD OPTMIZE Inc. (“Create Build Optimize” or “we,” “our,” or “us”) and other affiliated entities controlled by or under common control with Create Build Optimize (however accessed and/or used, whether via personal computers, mobile devices or otherwise, collectively, the “Web Sites”), or other interactive features or protocols (including, without limitation, mobile sites and widgets) that are owned or operated by CREATE BUILD OPTIMIZE and are available through the Web Sites or that interact with the Web Sites and post this Privacy Policy.

The purpose of this Privacy Policy is to disclose to you the information we may collect through the Web Sites, how we may collect it, how we use that information and with whom we may share it, as well as other information regarding this information.

    1. What Types of Information do the Web Sites Collect?

We collect information, including personal information, directly or automatically from you when you use our Web Sites and from other third-party sources.  As used in this Privacy Policy, “personal information” is information that could be reasonably used to identify you personally.

You can access, delete and control certain uses of your information as set forth in the “What Are My Options?” and “Privacy Rights for California Residents and Other Specific Jurisdictions” sections below.

Information about our data collection during the prior 12 months is further described below.

Information You Provide To Us. Providing us with information about yourself is your choice, and you can always choose not to provide certain information (but then you may not be able to take advantage of some of the Web Sites’ features). We may ask you to provide us with certain categories of information such as:

      • Personal contact information, such as your name, e-mail address, cell phone number and physical address, which we use to respond to your inquiries, provide you with requested products or services and send you information and marketing related to the services we provide you
      • Demographic information, such as gender, age, zip code, or similar information to analyze the use of and improve our Web Sites, and provide you advertising tailored to your interests;
      • Registration Information, such as User name, password, and CREATE BUILD OPTIMIZE account numbers, which we use to create and maintain your account, provide you with requested services and identify you as a user of our Web Sites;
      • Information about your interests, which we use to provide you with information about related products and services that may be of interest to you;
      • Communications preferences, such as which newsletters you would like to receive, which we use to send you information and marketing related to the services we provide you;
      • In limited circumstances, payment and identity verification information, such as credit card number, social security number or comparable national identifiers, and driver’s license number or another applicable national identification number, which we use only as necessary for completing a particular transaction or fulfilling a service (e.g., payment for advertising services or awarding prizes to contest winners) or as otherwise required by law;
      • Information provided when using interactive online features, which we use to enable you to participate in such features that we provide through our Web Sites; and
      • Correspondence you send to us, which we use to reply to inquiries we receive from you.

We may collect this information through various forms and in various places on the Web Sites and may collect it through e-mail, mobile devices or other technologies when you submit information, communicate, or otherwise interact with us. We may also collect this information from you offline, including via facsimile, mail, or in person. See “How Does CREATE BUILD OPTIMIZE Use the Information It Collects Pursuant to this Privacy Policy?” for more information on how we use the information we collect from you.

Information About You From Other Sources. Where permitted by applicable law, we may collect information about you from other sources and add it to the information that you provide to us through the Web Sites, such as:

        • Name, postal address, and telephone number;
        • Demographic data;
        • If you access third-party services (such as Facebook, Google or Twitter) through the Web Sites, or if you access a Web Site via a third-party service, your username and password for those services and other information available about or collected from you on those services;
        • Your interests and purchase behavior;
        • Publicly-observed data, such as activities on blogs, videos, and other online postings; and
        • Other navigation data, such as web sites visited and advertisements viewed or clicked on

Please note that all of the information we collect about you may be combined, including to help us tailor our communications to you and to develop rich online content and services across the Web Sites. This privacy policy does not cover the practices of third parties, including those that may disclose information to CREATE BUILD OPTIMIZE. If we combine information we receive from those other sources with personal information we collect through the Web Sites, we will apply this Privacy Policy to any personal information received, unless we have disclosed otherwise.

    1. Other Information Collected When You Visit the Web Sites

In addition to any personal information or other information that you choose to provide to us on the Web Sites, we and our third-party service providers may use a variety of technologies that automatically or passively collect certain web site usage information whenever you visit or interact with the Web Sites. This information may include:

      • Online identifiers including your Internet Protocol (IP) address, browser type, operating system;
      • Unique identifiers, including mobile device identification numbers that can identify the physical location of such devices in accordance with applicable law;
      • Internet activity information including the page served, the time, web sites you visited before and after visiting the Web Sites, Web pages and advertisements you view and links you click on within the Web Sites;
      • Information collected through cookies, web beacons, and other technologies;
      • Information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded; and
      • Standard server log and device information.

Information collected through these passive means may not directly identify you or may be associated with you. In addition, using your IP address, a customer id number, or some other unique identifier for the particular device you use to access the Internet may be collected. Whenever the information is associated with you, it will be treated as personal information.

We may use this web site usage information, collected by us or third parties, for a variety of purposes including to enhance or otherwise improve the Web Sites.

The methods that may be used to collect this information, and the purposes for doing so, include the following:

Cookies. Cookies are information files that our Web site may place on your device to provide extended functionality and to personalize your experience at our Web Site. We may use cookies (and similar technologies, such as clear gifs and web beacons) for a number of purposes. For example, we may use cookies to track usage patterns on the Web site and we may use cookies when we conduct polls and sweepstakes to limit multiple responses and registrations or to tracking usage of our emails and Web site. Or, we may use cookies to record registration and personalization information, enabling you to save your user name and password. We do not store any information that directly identifies you in cookies, but we may link the cookie to any other information we collect. You may disable cookies using your browser’s preferences, but some features of the Web Sites may not function properly or may operate slowly if you disable the cookies. You should consult with your browser’s provider/manufacturer if you have any questions regarding disabling cookies.

Mobile Device Identifiers. Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such device information if you access the Web Sites through mobile devices. Certain features of our Web Sites may require collection of mobile phone numbers and we may associate that phone number to mobile device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we or our third-party service providers may receive this information.

IP Addresses: An IP address is a number that is assigned to your device or network when you are on the Internet. When visitors request pages from our Web Site, our servers log the visitor’s IP address. We may collect IP addresses for a variety of internal purposes, such as system administration, to report aggregate information to our business partners or to audit the number of visits to different pages on our Web Site.

    1. Information You Disclose Publicly

If you volunteer information or create a public profile in the course of your participation in our community features such as forums, chat rooms or other forms of public communication and interaction (“Web Site Forums”) or submit comments, photographs, text or other content to us (“User Generated Content”), it may be published online or offline (including on-air, on a CD or DVD, through wireless distribution and transmission of soft copies, or any other media or format currently existing or hereafter developed), and we may publish your name, voice, likeness, and other personal information in connection with publishing the content or a portion of the content, and we may use the content and any excerpt from the content in connection with advertising, marketing, publicity, and promotional activities. Please be aware that when you share personal information in a public Web Site Forum, we cannot ensure the security of that information and it will be publicly available and you may receive unsolicited messages from other parties. Please exercise caution when disclosing personal information through the Web Site Forums. Your use of any Web Site Forum and submission of any User Generated Content is subject to our

Terms of Use. Please note that the terms of this paragraph shall not apply to User-Generated Content within the CREATE BUILD OPTIMIZE platform. CREATE BUILD OPTIMIZE is a password protected interactive sales environment, within which User Generated Content, including proposals, artwork, approvals, text, comments, photographs, contracts and all other uploaded or other shared or submitted content shall not be published online or offline or otherwise shared except as may otherwise be set forth in our Terms of Use, or in any offline contract entered into by you and CREATE BUILD OPTIMIZE (“Contract”), to which Contract the terms hereof shall at all times be subject.

    1. How Does CREATE BUILD OPTIMIZE Use the Information It Collects Pursuant to this Privacy Policy?

We only use payment and identity verification information that you provide to us, such as credit card numbers, CREATE BUILD OPTIMIZE account numbers, contract numbers, and invoices, or national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., payment for advertising services or awarding prizes to contest winners) or as otherwise required by law.

We generally use other information we collect about you to:

        • Fulfill your requests for products, services, and information, including to send you electronic newsletters, authorize a purchase, and complete a transaction that you have requested;
        • Enable you to participate in features such as surveys, polls, sweepstakes, and message boards;
        • Provide you with electronic newsletters, information, special offers and promotional materials on behalf of the Web Sites, companies within our corporate family, and third parties, in accordance with applicable law;
        • Analyze the use of the Web Sites and information about visitors to the Web Sites to understand and improve our service offerings and, in accordance with our sharing policies discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
        • Customize the content you see when you visit the Web Sites;
        • Develop and provide advertising tailored to your interests;
        • Prevent potentially prohibited or illegal activities; and
        • For any other purposes disclosed to you at the time, we collect your information or pursuant to your consent.
    1. How Does CREATE BUILD OPTIMIZE Share the Information?

We are committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. Except as otherwise disclosed at the time you provide your information, the following outlines the ways in which your information may be shared with others:

With Your Consent. With your consent, we may share your contact information with third-party business partners. For example, the Web Sites may offer free access to relevant services if you agree to have your information shared with third parties so they can contact you about related products and services.

Authorized Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of the Web Sites, such as customer support, clearing and processing credit card payments, e-mail and text message deployment, suppression, merge and de-duplication services, data processing business analytics, marketing and data processing, and to provide special products or services that you have requested. These third parties are allowed to use your personal information for the purpose of performing such functions.

Sweepstakes, Contests, and Promotions. We may offer sweepstakes, contests, and other promotions through the Web Sites that may require registration. If you choose to enter a sweepstakes, contest or other promotion, subject to the terms and conditions of such promotion, your personal information may be disclosed to third parties who help design administer and implement such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and aggregated analysts and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.

Administrative and Legal Reasons. We may also transfer and disclose user information, including personal information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Web Sites’ Terms of Use or other policies applicable to the Web Sites or to protect the personal safety, rights, property or security of any individual. We may also use IP address or other device identifiers (discussed above) to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.

Other CREATE BUILD OPTIMIZE Businesses. We may share information we collect about you within the family of CREATE BUILD OPTIMIZE Web Sites and with other CREATE BUILD OPTIMIZE-affiliated entities, so we can provide you with information about products and services that might interest you.

Business Transfers. CREATE BUILD OPTIMIZE shares the information collected through the Web Sites with and among the Web Sites, and may share the information with its subsidiaries and affiliates. We may buy or sell a company, some of a company’s assets, a Web Site or Web Sites or several of the companies in our corporate family may merge with one another, be otherwise reorganized or be acquired by another company. If we complete such a corporate transaction, we may transfer some or all of your information and we reserve the right to disclose and transfer user information, including personal information, in connection with corporate transactions and other corporate changes.

Legal Requirements. We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations, such as FCC requirements.

Protect our Web Sites and users. We may disclose information to protect and defend the legal rights, interests, and safety of the Web Sites, other CREATE BUILD OPTIMIZE affiliates, subsidiaries, and their employees, agents, and contractors (including enforcing our agreements); to protect the safety and security of users of the Web Sites and members of the public; and as otherwise disclosed in our Terms of Use.

    1. Sales of Information

We do not sell your personal information to third parties but may transfer your personal information to others as described in this Privacy Policy.

    1. What are My Options?

You can choose to enjoy content and features on the Web Sites without directly providing us with any information about you; however, as described above, some information may automatically be collected or may be requested so that you can take advantage of certain features and services offered on the Web Sites. The Web Sites may contain web pages through which you can edit and update the personal information you have provided to us through registration with one or more of the Web Sites and which may allow you to change your marketing preferences. You may also opt-out of receiving marketing communications or other communications from a particular web site of service by following the instructions contained in any such communication when you receive them. Please note that if you maintain an account with the Web Sites (i.e. CREATE BUILD OPTIMIZE  accounts), we reserve the right to send you certain communications relating to your account such as administrative and service announcements if they relate to your account, and these transactional account messages are not affected if you choose to opt-out from marketing e-mails. When you edit your personal information or change your preferences, information that you remove may persist internally for CREATE BUILD OPTIMIZE administrative purposes. However, if you have used any communication features of the Web Sites to publicly disclose information, such as a blog or wiki board posting, these communications cannot generally be removed, subject to the “Privacy Rights for California Residents and Other Specific Jurisdictions” and “A Note to Parents About the Privacy of Children” sections below.

    1. Privacy Rights for California Residents and Other Specific Jurisdictions

If you reside in California or in a jurisdiction that provides similar rights, under CCPA or applicable law, you have specific rights regarding your personal information. This section describes the rights that you have under CCPA, or other state laws as applicable, and explains how to exercise those rights.

      • Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, and Deletion Rights”), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:
      • The categories of personal information we collected about you.
      • The categories of sources from which the personal information is collected.
      • Our business or commercial purpose for collecting or selling that personal information.
      • The categories of third parties with whom we share that personal information.
      • The specific pieces of personal information we collected about you
      • Right to Request Deletion. 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 verifiable consumer request (see “Exercising Access, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
      • Exercising Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a request to us by doing one of the following:

Emailing us at Createbuildoptimize@gmail.com

Contacting us at (949) 627 – 0948

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. If you use an authorized agent to make a request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us. You may also make a request on behalf of your minor child.

The request should include your contact information (including name, address, email address, and phone number) and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  In addition, we ask that you provide us with the following information to allow us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative:  whether you are a “CREATE BUILD OPTIMIZE Insider” or otherwise receive marketing communications from us; whether you or your business has purchased advertising from CREATE BUILD OPTIMIZE; whether you are or your business is a current or former Create Build Optimize real estate partner/landlord (if yes, please also provide the relevant property address if different from your contact information); and, if you are an authorized representative, confirmation that you have been authorized to act in such capacity.

We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.

In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period.

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

      • Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:
      • Denying you goods or services.
      • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      • Providing you a different level or quality of goods or services.
      • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
    1. A Note to Parents about the Privacy of Children

The Web Sites are general audience web sites. We do not knowingly collect any personal information from children younger than the age of thirteen (13) on the Web Sites and we will delete any information later determined to be from a user younger than thirteen (13). If you are under 13 years of age, do not send any information about yourself to CREATE BUILD OPTIMIZE.

    1. Third-Party Content and Links to Other Web Sites

Our Web Sites may contain content that is supplied by a third party, and we may provide certain information that does not directly identify individuals about the number of users that access the third party’s content or those third parties may directly collect web site usage information when web pages from a Web Site are served to your browser. In addition, when you are on the Web Sites you may be directed to other sites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third-party sites. For example, if you “click” on a banner advertisement, the “click” may take you off the Web Sites onto a different web site. This includes links from advertisers, sponsors, and partners that may use the Web Sites’ logo as part of a co-branding agreement. These other web sites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a web site that is linked from our Web Sites, you should consult that web site’s privacy policy before providing any personal information.

    1. Consent to Transfer

CREATE BUILD OPTIMIZE is headquartered in the United States and has affiliate offices and partners in other countries. Please be aware that the information you provide to us or that we obtain as a result of your use of the CREATE BUILD OPTIMIZE Web Sites may be collected in your country and subsequently transferred to the United States or another country in accordance with applicable law. The privacy and data protection laws in another country may not be equivalent to such laws in your country of residence. By using and participating in any CREATE BUILD OPTIMIZE Web Site or providing us with your information, you consent to the collection, international transfer, storage, and processing of your information.

    1. Security

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Web Sites but we cannot ensure or warrant the security of any information you transmit to us. Please refer to the U.S. Federal Trade Commission’s web site for information on how to protect yourself from identity theft.

    1. Changes to the Privacy Policy

By using the Web Sites, you acknowledge your agreement and consent to the terms of this Privacy Policy. We may change our Privacy Policy from time to time. Any modifications to our Privacy Policy will be reflected by the “Effective Date” or “Last Modified Date” on this Privacy Policy. CREATE BUILD OPTIMIZE Inc. will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information unless you consent to the new or revised policy.

    1. Questions; Comments

Questions regarding this privacy statement should be sent to us via email (Createbuildoptimize@gmail.com) or by mail to the address set forth above.. We endeavor to read every message submitted and do our best to reply. We may also file your comments to improve the Web Site or review and discard the information. Please note that information will not necessarily receive a response. We will not use any such information you provide to contact you for marketing purposes unrelated to your request.