CÔTA VERA – PRIVACY POLICY

This Privacy Policy has been compiled to better serve those who are concerned with how their Personal Information is being used online. Personal Information as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

This Privacy Policy applies to HomeFed Corporation’s Côta Vera website, located at www.cotavera.com (the “Site“), and any applications (e.g., iPhone applications, iPad applications, Android applications, etc.) offered by HomeFed Corporation in conjunction with the Site (collectively the “Services”).  Your privacy is important to us and we have prepared this Privacy Policy to explain how we collect, use, and protect Personal Information (defined below) and Non-Personal Information (defined below) when you use the Services and your choices for managing your information preferences.  By using the Services, you signify your assent to this Privacy Policy and the HomeFed Terms of Use posted here. If you do not agree with the content of this Privacy Policy, it is your choice whether you want to use our Services.

Managing Information Preferences

We will not disclose Personal Information to third parties for their direct marketing purposes without your consent.  If, after providing consent, you want to opt out of having your Personal Information disclosed to third parties for their direct marketing purposes, please let us know by sending us an email at HomefedMarketing@hfc-ca.com. If you want to stop receiving marketing communications from third parties with whom we have disclosed your Personal Information, please contact the third parties directly with this request.

You may request that we correct, update, or change your Personal Information at any time by contacting us at:

HomeFed Marketing Department
Attn:  Website Administrator
1903 Wright Place, Suite 220
Carlsbad, CA 92008
Email: HomefedMarketing@hfc-ca.com

Information you choose to Submit

We collect information that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”). The following discusses the categories of Personal Information we collect, the sources we collect information from, and the business or commercial purposes for which we use your Personal Information.

In general, we may share Personal Information with entities controlling, controlled by, or under common control with HomeFed Corporation.  In the event that HomeFed Corporation is merged, sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction.

1. When You Visit Our Site

We may collect the following categories of Personal Information directly from your activity on our Site:

• Geolocation information, such as your IP address, which links to the region you live in.
• Inferences and preferences, such as the Services you prefer, your communications preferences, and other inferences drawn.
• Internet and network information, as described in the section on Cookies. If you visit our Site we automatically collect information about your browsing and search history, interaction with the features of our Site, and responses to advertisements.

We use this information to operate our Site, improve and customize our Services, understand how we can exceed your expectations, and evaluate the effectiveness of our marketing and advertisements.

We share some of this Personal Information with our service providers who provide services such as data analytics and lead generation. We may also share some of your Personal Information with our marketing providers so they can help us audit the quality and effectiveness of advertisements, serve our advertisements or marketing material, and provide similar services.

2. When You Request More Information or Sign Up for a User Account

When you request more information about our available properties, or sign up for an account, we may collect the following categories of Personal Information directly from you through our forms:

• Contact information such as your name, address, telephone number, zip code, and email address.
• Your preferences and budget for purchasing a home.
• Any other information about your home buying decision you choose to share with us.

We use this information to contact you about Côta Vera properties we believe you might be interested in. We may also contact you about other HomeFed properties depending on your preferences. When you request, we may also use this Personal Information to subscribe you to newsletters, and enter sweepstakes, contests, or other promotions. Finally, we may use this information for any other purposes you consent to.

We share this Personal Information with third parties such as home builders and developers only when you allow us to do so by checking the available box(es). These third parties use your Personal Information to contact you about purchasing a home.

3. When You Interact with Us Through Social Media

When you interact with us through our social media profiles we may collect the following categories of Personal Information directly from you or from the social media platform itself:

• Your name, social media handle, and demographic information.
• Pictures of you and others you choose to share with us by tagging our social media profiles or using specific hashtags.

We use this Personal Information, with your prior consent, to showcase our community and properties.

Other than when we share it publicly on our social media profiles or Site, we do not share this Personal Information with others.

4. From Our Service Providers or Other Third Parties

We may collect Personal Information about you from our Service Providers or other third parties and combine it with information collected directly from you. We collect this information from persons or entities whom we believe trustworthy and whom we have asked to confirm that their privacy practices are consistent with ours (“Service Providers”).

Our Cookie Policy

Our Site uses cookies, web beacons, and similar tracking technologies (“Cookies”) to provide, customize, evaluate, improve, and secure our services. A Cookie is a small piece of text that is placed on your website browser when you visit a website. Some Cookies are only stored temporarily and destroyed each time you close your web browser. Our Site also uses persistent Cookies, which do not delete when you close your browser and may collect and store data for a set period of time after you’ve left our Site. You can find out more about Cookies in general and how they work at Cookiepedia.

How We Use Cookies

We use Cookies for the following purposes:

• Website Functionality. Cookies help us run our Site securely and enable basic functions like page navigation.
• Performance and Analytics. Cookies help us analyze how you interact with our Site. These cookies enable us to monitor and improve website performance, services, and your experience.
• Advertisements. Cookies allow us to deliver advertisements that are meaningful to you. Our third party advertising partners may use Cookies to build a profile of your interests, deliver relevant advertising on other websites, and measure the efficiency of the advertisements.

2.2. How to Manage Cookies

If you wish to prevent Cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, certain features on our website may not work. For more information on how you can customize your browser’s Cookie setting please visit the link to your web browser below:

• Google Chrome
• Safari
• Internet Explorer
• Mozilla Firefox

California Rights

If you reside in California and you are not a job applicant, employee, or employee of another company interacting with us, you may have additional rights over your Personal Information. “Personal Information” under California law is information that identifies, describes, or is reasonably capable of being associated with you or your household. Personal Information does not include publicly available information in government records or any data that has been deidentified, aggregated, or otherwise anonymized.

Requesting More Information. You may have the right to request information about how we have treated your Personal Information in the past 12 months including:

• The categories of Personal Information we collected;
• The categories of sources from which we collected that information;
• Our business or commercial purpose for collecting that information;
• The categories of third parties with whom we shared that information; and
• The specific pieces of Personal Information we collected about you.

Requesting Access. You may have the right to receive a copy of your Personal Information that we have collected about you in the past 12 months. You may exercise this right twice per 12-month period.

Requesting Deletion. Under certain conditions, you may have the right to request that we delete your Personal Information. However, we may decline to process this request if we believe we have an applicable exception under the law.

Third-Party Marketing and Selling. California law requires notice and an opportunity to opt-out from certain disclosures of Personal Information considered to be a “sale” as defined in the CCPA. In the previous 12 months we have not sold Personal Information. Our Site is not intended for use by individuals under the age of 18. Accordingly, we do not knowingly collect, disclose, or sell information from individuals under 16 years old.

Disclosure for a Business Purpose. In the previous 12 months we have disclosed certain data from the following categories of Personal Information to the specified categories of recipients for one or more business purposes:

• All Personal Information – disclosed to our Service Providers to assist with performing services on our behalf (marketing and web-hosting).
• Contact information – disclosed to our business partners to provide customer service.

Exercising Your Rights. If you want to exercise any of these rights, please submit a request at:

• homefedmarketing@hfc-ca.com Email: HomeFedMarketing@hfc-ca.com

For all requests submitted via email, please clearly state that the request is related to “Your California Privacy Rights” and provide your name, mailing address, phone number, and email where you may be reached.

Verification. Before we can respond to your request, we must first verify your identity using your Personal Information. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial. In order to verify your identity we need you to provide us with the following: the name, mailing address, phone number, and email address you provided when you created an account or requested additional information.

Designating an Authorized Agent. You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf. If necessary, we may also require you to verify your identity before we disclose Personal Information to your Authorized Agent.

Do Not Track. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our Site does not recognize “Do Not Track” browser signals.

No Discrimination. We will not unlawfully discriminate against you for exercising any of these rights.

Public Areas

Please be advised that, whenever you voluntarily post information to any community or interactive areas of the Services, such information can and may be accessed by the public.  This means that any person or entity with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Third-Party Services

Through the Services, you may elect to access third-party services and applications, such as Facebook and other social networks.  When you do so, you may be able to import information from those other services and applications and share content with those services.  Some of those third-party services may also provide us with information from your accounts which may enable us to enhance and personalize your use of the Services.  If you elect to enable or use such third-party services or applications on the Services, the information you share with such third-party services and applications will be subject to their privacy policies and your privacy settings for such services. However, to the extent we collect Personal Information directly from you on third-party services and use it on our Site, your Personal Information will be subject to our Privacy Policy and Terms of Use.

Children’s Privacy Statement.

We do not knowingly collect Personal Information from children under the age of 13.  If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.

Data Storage & Access

HomeFed Corporation is based in California. All Personal Information collected by us will be stored and accessed in the United States.  As such, it will be subject to laws of the United States.

Legal Disclaimer

Nothing in this Privacy Policy restricts our ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer Personal Information as part of a merger or acquisition, dissolution, or in the event of bankruptcy or any other transaction in which a third party assumes control of all or part of HomeFed Corporation.

Privacy Policy Changes

HomeFed Corporation may, in its sole and absolute discretion, change this Privacy Policy from time to time. HomeFed Corporation will post a copy of the Privacy Policy as changed on the Site.  Your continued use of the Services constitutes your agreement to abide by the Privacy Policy as changed.  If you object to any such changes, your sole recourse shall be to cease using the Services.

Last Updated: 4/21/21