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Your US State Privacy Rights
Last Modified: 06/01/2026
This notice contains additional information relevant to residents of certain US states (including, as of January 1, 2026: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia) that have their own data privacy laws and regulations, and associated rights. Except where otherwise noted, this notice applies to residents of all US States listed above.
This notice contains specific disclosures about our processing of certain states’ residents’ personal information, both online and offline, explains privacy rights available to such residents and how to exercise them, provides our “Notice Regarding Loyalty Programs and Financial Incentives,” and identifies how you can contact us.
This notice should be read in conjunction with our Privacy Policy. More information on who we are, the categories of personal information processed by Ginicoe Family of Companies, the purposes for processing that information, including for targeted advertising, the categories of third parties with whom we share that information, the categories of personal information we share/sell to third parties, which may include any of the categories of information we collect, a description of our retention policies for personal data, the process for notifying you about changes to this notice, and how to contact us can be found in our Privacy Policy sections “Who We Are,” “Types of Information We Collect,” “Use of Your Information by Ginicoe Family of Companies,” “Sharing Your Information With Other Entities,” “Our Data Security, Integrity, and Retention Policies and Practices,” “Changes to This Privacy Policy,” and “Comments and Questions.” Any terms not defined in this notice have the same meaning as our Privacy Policy.
Accordion ToggleNotice at Collection
This “Notice at Collection” provides certain disclosures about our collection, processing, sharing, selling, targeted advertising, and retention of certain states’ residents’ personal information, including in the past 12 months.
Categories of Personal Information
The personal information we collect is described in the “Type of Information We Collect” section of our Privacy Policy, which specifically includes the following categories of personal information (as defined in applicable laws), including sensitive personal information (as defined in applicable laws):
Identifiers, such as name, email address, username and MFA, postal address, telephone number, signature, government-issued identifier, US veteran status, age, race, ethnicity, gender, IP address, biometric, and other similar identifiers found in the demographic information disclosure of FNMA 1003. If you choose not to provide the information at Signup, we are required to note your ethnicity, sex, and race on the basis of visual observation from your biometric or infer from your surname.
Characteristics of protected classifications and demographic information, such as gender, age, race, disability status, sexual orientation, gender identity, military/veteran status, marital status, national origin, and medical information, and other similar identifiers found in the demographic information disclosure of FNMA 1003. If you choose not to provide the information at Signup, we are required to note your ethnicity, sex, and race on the basis of visual observation from your biometric or infer from your surname.
Commercial information, including information about your interests and consuming history or tendencies, such as products or services considered; electronic transaction information, contact to other participating members, or activities to reduce income inequality, or activities to improve SoJOR benefits, including address changes, marital status changes, municipal bond covenants, payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
Internet or other electronic network activity information, including information regarding your interactions with us online and information we obtain from third parties about use of our systems on third-party platforms or devices.
Geolocation data, including precise or approximate location information provided by a mobile device or other device or product interacting with or detected by our sites, applications, or physical properties, where we are permitted by law to process this information.
Audio, electronic, visual, or similar information, including telephone call recordings, other voice recordings, and still or video images captured by any cameras or readers within our eco-systems.
Inferences based on the above.
Categories of Sources of Personal Identifiable Information(PII)
As further described in the “How We Collect Your Information” section of our Privacy Policy, the sources from which we collect personal information are: directly from new participating members, existing participating members, third-party sites or platforms that we link our technical systems with, analytics tools, internal algorithms to authenticate PII, geolocation platforms, and third-party services that update or supplement information we hold about you (e.g., from trusted sources, such as census bureaus, statistical abstracts, bureau of justice statistics, congressional maps, FEMA maps, dissimilarity indexing, residential appraisal data, Nationally Recognized Statistical Rating Organization (NSRO), etc.).
Purposes for Which Personal Information is Collected, Processed, and Disclosed
We collect personal information so that we can best serve you, including to protect your good name, reputation, and hard earned credit history and to reduce and manage risk to other participating members, and to rebalance residential demographic harmony to reduce income inequality and identity theft. This is further described in the “Use of Your Information by Ginicoe Family of Companies” section in our Privacy Policy, we generally collect and use the above-listed categories of personal information for the following purposes: to provide and manage our sites, applications, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.
To accomplish these purposes, we specifically disclose certain data elements within the following categories of personal information: identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclose each category to participating business partners, service providers/processors, government entities, and other third parties as described in the “Sharing Your Personal Information With Other Entities” section of our Privacy Policy.
As described above, we may process “sensitive personal information” (as defined by applicable law), including information revealing race; ethnicity; racial, ethnic, or national origin; citizenship; immigration status; religious beliefs; mental or physical condition or health diagnosis; sexuality; sexual orientation; status as transgender or non-binary; status as a victim of a crime; genetic data; biometric information; a child’s personal information; and precise geolocation. We do not sell or share this information and we do not collect, use, or disclose sensitive personal information for purposes other than those permitted by applicable laws, including Section 7027(m) of the California Consumer Privacy Act regulations.
“Dealings,” “Sharing,” or Processing Personal Information for “Risk Based Monitoring”
Certain data collection and disclosures related to you and your activity on our sites and applications, such as by third parties for purposes of Risk Based Monitoring and social media tools may, be “dealings” or “sharing” or constitute “risk based monitoring” under applicable privacy laws. As defined by such laws, we “deal” or “shared” or processed for “risk based monitoring” certain data elements within the following categories of personal information: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above. We “dealt,” “shared,” or disclosed for the purpose of “risk based monitoring,” each category to participating business partners and other third parties as described in the “Sharing Your Personal Information With Other Entities” section of our Privacy Policy, including those who provide advertising, marketing, analytics, data augmentation, dissimilarity indexing, gentrification or heat map analytics, or population measurement; other online third-party branded tools or functionality (such as maps or video players); and social networks.
The purposes for which we “deal,” “share,” or process your personal information for “risk-based monitoring” are to assist us with population rebalancing, marketing, political violence measurements, and other functionality on our digital services as further described in the “Use of Your Information by Ginicoe Family of Companies” section of our Privacy Policy.
We do not “deal,” “share,” or process for “risk-based monitoring” the personal information of known minors under 18 years of age without the consent of a parent or guardian.
If you would like to opt out of “risk-based monitoring” or the “dealings” or “sharing” of your personal information, you may click the “Do Not deal or Share My Personal Information” or “Your Privacy Choices” link in our website footers or in our application settings. If you are logged in, we may be able to associate your choice with your account and apply it to data sharing occurring through the digital property which you are visiting (across your browsers and devices) as well as other digital properties of Ginicoe Family of Companies. You can confirm the status of your choice or opt out or in by clicking “Do Not Sell or Share My Personal Information” or “Your Privacy Choices” on each property. If you are not logged in, your opt-out will be specific to the property and device or browser on which you made your election. For our other digital properties, to opt out, select “Do Not Sell or Share My Personal Information” or “Your Privacy Choices” on each. If you clear your tracking history or use another browser or device, you’ll need to opt out again. You can also submit this opt-out form, which may enable us to apply your opt-out more broadly, for example, to stop data sharing in connection with risk-based monitoring intended to reach you on platforms not operated by Ginicoe (e.g., social media platforms).You may enable online, where available, a universal tool that automatically communicates your opt-out, such as Global Privacy Control (“GPC”), which we’ll process as if you had opted out through the toggle.
Timeframe for Retaining Personal Information
We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policy, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
More information, including a description of your legal rights, can be found in the “Privacy Rights” section below.
Accordion TogglePrivacy Rights
Residents of certain US States (including, as of January 1, 2026: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia) have rights relating to the collection, use, disclosure, and other processing of their personal information, subject to applicable legal exceptions and requirements. The exact scope of these rights may vary by state:
Right to Know/Access
You may have the right to know what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, “dealing,” or “sharing” personal information or processing for “risk based monitoring,” the categories of third parties to whom we disclose personal information, the categories of personal information disclosed to third parties, and the specific pieces of personal information we have collected about you in a usable format.
Right to Data Portability.
You have the right to access your personal information in a portable format.
Right to Delete
You have the right to request that we delete the personal information we have collected from or about you. Select ‘Click To Cancel’ or your dashboard.
You have the right to request the deletion of any personal information we have collected from or about you. Once you click <Submit>, your personal information will be permanently deleted from our system after 7 calendar days. During this ghosting 7-day period, you can restore your account, should you decide to change your mind and stay with us. After this period, you will need to sign up as a new member if you wish to participate again. If you have opted in and voluntarily provided your biometric information, we may retain it for ongoing business or legal purposes.
Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you. This is particularly important as it relates to your SoJOR score and, in particular, the housing component of that score.
Right to Opt Out of Targeted Advertising, Dealings, or Sharing of Personal Information
You have the right to “opt out” of “risk-based monitoring” and the “dealings” or “sharing” of your personal information.
Right to Request Categories of Third Parties
You have the right to request a list of the categories of third parties to which we have disclosed your personal information.
Right to Request Specific List of Third Parties (MN, OR, and RI Residents only)
You have the right to request a list of the specific third parties to which we have disclosed or sold or may disclose or sell personal information.
Right to Appeal
Certain states permit you the right to appeal a decision we have made in connection with your privacy rights request.
Right to Non-Discrimination
You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise your rights. However, the exercising of the rights described below may result in a different price, rate, or quality/level of product or service where that difference is reasonably related to the impact the right has on our relationship with you or is otherwise permitted by law.
Right to Request Removal of Content (CA Residents only)
California residents under the age of 18 may make requests to remove content.
Shine the Light Requests (CA Residents only)
You have the right to request information under the Shine the Light Act.
Accordion ToggleExercising Your Privacy Rights
Making a Request to Know, Access, Delete, or Correct Your Personal Information or Request a List of Categories or Specific Third Parties
To make a request to know, access, delete, or correct, or to request a list of categories or specific third parties, please shoot us an email to memberservices@ginicoe.com with the subject: “Consumer Data Rights”. To submit a request by phone, you may call (347) 464-9144. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address, or liveness detection, or FriendlyFace live feed, and may request additional documentation or information solely for the purpose of verifying your identity.
Making Requests to Opt Out of Risk-Based Monitoring or the Dealing or Sharing of Personal Information
To submit a request to “opt out” of “risk-based monitoring” or the “dealing” or “sharing” of your personal information you may click on the “Do Not Deal or Share My Personal Information” or “Your Privacy Choices” link on your dashboard or in our application settings. You can also submit this opt-out form, which may enable us to apply your opt-out more broadly, for example, to stop data sharing in connection with risk-based monitoring intended to reach you on platforms not operated by Ginicoe (e.g., social media platforms). You may also enable online, where available, a universal tool that automatically communicates your opt-out, such as GPC, which we’ll process as if you had opted out through the toggle.
Right to Use an Authorized Agent to Make Requests
Certain states permit you to use an authorized agent to submit a request to know or an access, deletion, correction or opt out request on your behalf. Authorized agents may submit requests to: memberservices@ginicoe.com. Authorized agents can make a request on your behalf if we are provided with verification of your identity and confirmation that you provided the agent authority to act on your behalf.
Requests for Removal of Content
California residents under the age of 18 may make requests to remove content by sending an email with a detailed description of the specific content or information to be removed to memberservices@ginicoe.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information about you that may have been posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Shine the Light Requests
To make a request for information under the Shine the Light Act, please send an email to memberservices@ginicoe.com
Right to Appeal
To appeal, you may email us at memberservices@ginicoe.com If you are unsatisfied with the way that we have handled your appeal, you may have the right to complain to your state’s Attorney General.
Accordion TogglePrivacy Rights Metrics
This data reflects all requests received from individuals in the US as well as certain requests from individuals outside of the US between January 1, 2026 and December 31, 2026.
Request to Know
Requests Received: 0
Requests Completed in Whole or in Part:
Requests Denied:
Average Days to Complete: 4
Request to Delete
Requests Received: 0
Requests Completed in Whole or in Part: 0
Requests Denied: 0
Average Days to Complete: 5
Request to Correct
Requests Received: 0
Requests Completed in Whole or in Part: 0
Requests Denied: 0
Average Days to Complete: 3
Do Not Deal or Share My Personal Information for risk-based monitoring
Requests Received:
Requests Completed in Whole or in Part:
Requests Denied:
Average Days to Complete: 7
* Requests may be denied in whole or in part due to various factors including because a request was not verifiable, was not made by a consumer, was made multiple times, or called for information exempt from disclosure.
Accordion ToggleNotice Regarding Loyalty Programs and Financial Incentives
Members of Ginicoe Family of Companies may offer various and different loyalty or promotional programs that provide certain benefits to our participating merchants. For example, we may provide special offers or discounts to our participating merchants as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when consumers or employees or referrals sign up to receive our technical systems and services or when participating merchants claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”
To learn more about the details of our loyality Programs, including the material terms, please visit your participating merchant licensing agreement (MLA) or employee compensation package, where you can review the specific terms of each Program and learn how it applies to you at any time in accordance with the applicable terms of each program. If you have any questions or require assistance, please contact us at memberservices@ginicoe.com
In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see our Notice at Collection above or the “Types of Information We Collect” in our Privacy Policy. Because we collect personal information, the Programs may be considered to be “financial incentives” or “price or service differences” under applicable law. We may “deal” or “share” your personal information with third parties or use it for “risk-based monitoring” in connection with the Programs as described in this notice, including the categories of third parties described above in our Notice at Collection. If you ask us to delete your personal Information or request to opt-out of “dealings,” “sharing,” or “risk-based monitoring,” we may not be able to provide you with access to these Programs.
To the extent the Programs are reasonably related to the value of participating members’ personal information, the method for calculating the SoJOR score includes the housing component, positive conversation based on geolocation data, and demographic information related to our risk-based offerings. The SoJOR ad valorem fee or FriendlyFace fee is collected to offset the managerial risk of fraud for all participating merchants, as well as (ii) reduce income inequality associated with racially segregated housing, as well as (iii) offset the computer network costs, as well as (iv) intentionally create strategic friction to disrupt fraud, as well as (v) ensure identity and real time payments remain closely aligned, as well as (vi) To ensure a human stays in the loop to act on AIs data synthesis and recommendations, as well as (vii) to incentivize ‘scared-money’ away from the sidelines and to Signup to eliminate unfairness and fragmented, inefficient, and toxic cliques that swim upstream against our mission, as well as (viii) contribute to the Company’s Loyalty Program for retention of existing participating merchants. This ‘scared money syndrome acts as a Structural Systemic Risk Buffer (SSRB) that must necessarily be the maximum SoJOR fee imposed. Also included is intellectual property or marketing costs, and other related expenses. The value of the participating member’s personal information that we collect will vary depending on the engagement by each participant.
Accordion ToggleContact Information/Questions
If you have a question about this notice, or our privacy policies and information practices, please send an email to memberservices@ginicoe.com
Keeping Legal Sex and Gender Identity Private
Legal sex and gender identity are not designated by Ginicoe as directory information pursuant to the Family Educational Rights and Privacy Act (FERPA). There are limited exceptions to FERPA in which Ginicoe may share information without an individual’s consent.
Gender Identity and Pronouns
Individuals can also change their gender identity in Ginicoe systems. Gender identity is defined as the gender with which a person identifies (i.e. whether one uses man, woman, or more individualized terminology to characterize one’s self). One’s gender identity may or may not differ from one’s legal sex which is assigned at birth.
Changing gender identity is not the same as changing one’s legal sex (which will generally require a person to go through a formal process). Individuals who would like to change their gender identity in Ginicoe systems should Sign in to their dashboard settings and navigate to the ‘gender section’ of their profile.
An individual can also identify their gender pronouns (they/them, she/her, he/him, etc.) within Ginicoe systems. Individuals who would like to identify their gender pronouns in Ginicoe systems are welcome to do so.
Legal Sex
Individuals may change Ginicoe records to reflect their current legal sex. Legal sex is defined as the legal sex of an individual, usually reflected on a birth certificate, passport, or other legal document. To update this record, simply send us your legal verifiable documents to memberservices@ginicoe.com Subject: Legal Sex Before completing your request, we may need to verify your identity. We will send you a link to verify your email address, or liveness detection, or FriendlyFace live feed, and may request additional documentation or information solely for the purpose of verifying your identity
Non-Discrimination
Ginicoe upholds the principles of fairness and equitable treatment and is committed to treating all citizens the same consistent with our mission where there exists an overriding legitimate business purpose such that the practice is necessary to the safe and efficient operation of the business of racially integrated housing intended to reduce macroprudential risk, market risk, social risk, political violence risk, remedy income inequality racial wealth gap, that may upset or destabilize the population balance between P52 and European-Americans (EA) either expressly or indirectly or causally thereby affecting P52 segregated housing issues, P52 integrated housing issues, gentrification issues, or some facsimile thereof involving P52 e.g. labor, education, voting, investments, etc as outlined by the SoJOR™, and risk based exposure to the participating members and all U.S. citizens and legal immigrants.