Our Privacy Policy

We take your privacy and data very seriously...

Relocity Privacy Statement
Last Updated: December 4, 2023

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We are Relocity, Inc. (“Relocity”). This Privacy Policy describes how we protect your data and respect your privacy.  Any questions or concerns with respect to your data or privacy should be directed to privacy@relocity.com.

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1. APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy applies to Relocity’s websites (including, without limitation, https://www.relocity.com) (the  “Websites”), software, web and mobile applications (the “App(s)”), and related products and services (collectively,  the “Services”), and any other interactions (e.g., sales inquiries, customer support, etc.) you may have with Relocity.  

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This Privacy Policy does not apply to any third party applications or technology that integrate with the Services, or  any other third party products, services, or businesses (“Third Party Services”). While using the Services, you may  be directed to a third party website via links or other references, which may take you to that third party website  (“Third Party Websites”). This Privacy Policy does not apply to you or any other data collected from or provided by  you to Third Party Services or Third Party Websites. You should review such Third Party Services’ or Third Party  Websites’ privacy policy (and such other terms and conditions) to determine how your data will be used before  sharing any Personal Data.

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2. NOTICE TO END USERS

BY VISITING, ACCESSING, OR USING THE SERVICES, OR INTERACTING WITH ANY ASPECT OF  OUR BUSINESS, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY AND EXPRESSLY  CONSENT TO OUR COLLECTION, USE, AND DISCLOSURE OF DATA, INCLUDING PERSONAL  DATA, PROVIDED TO OR OTHERWISE RECEIVED BY US FOR THE PURPOSES AND IN THE  MANNER DESCRIBED IN THIS PRIVACY POLICY AND THE APPLICABLE CLIENT AGREEMENT.

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Relocity provides the Services on behalf of employers (the “Sponsor”) to deliver relocation services to their  relocating employees. If your employer (i.e., your Sponsor) has provided you access to or use of the Services, in  addition to the Terms of Service, a separate agreement between Relocity and its client (whether your Sponsor  directly or through a Relocation Management Company (“RMC”), as applicable (collectively, the “Client”)) may  govern the delivery, access, and use of the Services (the “Client Agreement”), including the terms of processing any  “Client Data,” which is defined in the applicable Client Agreement but generally includes all data, materials, or  other content provided by the Client to Relocity in any form and all data, materials, and other content used,  generated, or stored in connection with the Client’s or its users’ use of the Services, which includes your use of the  Services. The Client procures the Services from Relocity and controls any associated Client Data. Your use of the  Services may be subject to your Sponsor’s or the RMC’s policies, if any, as applicable. If you have any questions  about your Sponsor’s or the RMC’s privacy practices, as applicable, please contact your Sponsor. Relocity is not  responsible for the privacy or security practices of your Sponsor or the RMC, as applicable, which may differ from  those set forth in this Privacy Policy.

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3. DATA WE COLLECT AND RECEIVE

Sometimes you provide us with data about you, sometimes the Client provides us with data about you, and  sometimes data about you is collected by us automatically. To the extent data is associated with an identified or  identifiable natural person and is protected as personal information or personal data under applicable privacy and  data protection laws, it is referred to in this Privacy Policy as “Personal Data.” You acknowledge and agree we may  receive, collect, process, store, access, and disclose your Personal Data to facilitate the provision of the Services in  the manner described in this Privacy Policy and the applicable Client Agreement.

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3.1 Client Data

The Client and its users may routinely submit Client Data to Relocity when using the Services. Client Data is  governed by the applicable Client Agreement. Client Data may include User Information, Hosted Data, or any Client

Data otherwise defined in the applicable Client Agreement. If you have any questions about your Personal Data with  respect to Client Data, please contact your Sponsor.  

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3.1.1 User Information. To create or update a user account for the Services or use certain  features of the Services, you or the Client may provide us with your Personal Data, such as:

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● Authorized User Information

  • Name
  • Age
  • Address
  • Email Address
  • Phone Number
  • Username
  • Password
  • PIN
  • URL
  • IP Address

● Financial Information

  • Bank Account Information
  • Credit/Debit Card Information

● Services Information

  • Reference ID (e.g. Employee ID / Authorization Reference Number)
  • Housing
  • Employee Status (Pre-Hire, New Hire, Existing)
  • Origin Location
  • Destination Country
  • Destination Region (e.g. State)
  • Destination Locality (e.g. City/Town)
  • Destination Date
  • Number of Dependents (i.e. children under 17)

● Client and Employment Information

  • Company Name
  • Hiring Manager
  • Job Title
  • Policy ID (i.e. Program Type)
  • Any other applicable Personal Data that may identify you individually in connection with the Services.

3.1.2 Hosted Data. When you use or interact with the Services, we may collect, process, and  store any data that is created, posted, uploaded, stored, displayed, transmitted, or submitted on or through the  Services (collectively, “Hosted Data”), as a function of rendering the Services. Hosted Data may contain Personal  Data to the extent you disclose Personal Data on or through the Services. Relocity is generally a passive recipient  and takes no active part in collecting or storing Hosted Data. Except to the extent necessary to render the Services or  related support for the Services, Relocity does not purposefully access any Hosted Data. For example, if you  message a personal host, the Services passively processes such messages for the purpose of rendering the Services,  and we will only access such information to the extent necessary to provide the Services and related support for the  Services.

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3.2 Other Information

Relocity may collect Other Information from you related to your usage of the Services and interactions with  Relocity. Other Information may include Metadata, Log Data, Technical Data, Cookie Data, Third Party Services,  and Additional Information Provided to Relocity. If you have any questions about your Personal Data with respect to  Other Information, please contact Relocity at privacy@relocity.com.

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3.2.1 Metadata. When you interact with the Services, metadata is generated that provides  additional context about the Services and the way you use the Services (“Metadata”). Relocity collects aggregated  Metadata of the Services, so that the resulting data and statistics are not personally identifiable to any individual  user.

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3.2.2 Log Data. Like most websites and web-based technology services, our servers  

automatically collect data when you access or use the Services and record it in log files (“Log Data”). The Log Data  may include your Internet Protocol (“IP”) address, Internet service provider (“ISP”), browser type and settings,  information about browser plugins, language preference, default email application, referring/exit websites, operating  system, date and time stamp, cookie data, and certain user activities.  

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3.2.3 Technical Data.

‍Relocity collects technical data, such as information about devices  accessing the Services, including the type of device, device settings, operating system, application software,  peripherals, and unique device identifiers (“Technical Data”). Technical Data does include any Personal Data and  Relocity does not relate any Technical Data to any individual user.  

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3.2.4 Cookie Information.

‍Relocity uses cookies and similar technologies in the Services that  help us collect Other Information. The Services may also include cookies and similar tracking technologies of third  parties, which may collect Other Information about you via the Services. Cookies are small text files sent by us to  your computer or mobile device for later retrieval. They are unique to you or your browser. Session-based cookies  last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies  last until you or your browser delete them or until they expire. We use both session-based and persistent cookies to  help with authentication, security, identifying your preferences, analytics, and otherwise monitoring the functionality  and performance of the Services. Most browsers are initially set to accept cookies. If you do not wish to have  cookies placed on your computer or in local storage, you may adjust your web browser settings to block cookies or  alert you when cookies are sent. However, restricting cookies may impede your ability to use the Services or certain  features of the Services. To learn more about cookies, please visit https://allaboutcookies.org/. To learn more about  Relocity’s use of cookies, please see our Cookies Policy.

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3.2.5 Third Party Services.

‍Third Party Services may be integrated with or made available in  connection with the Services. When enabled, Third Party Services may share certain data with Relocity to effectuate  the integration or offering. You should check the privacy settings and notices of these Third Party Services to  understand what data may be disclosed to Relocity.  

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3.2.6 Additional Information Provided to Relocity.

‍Relocity receives data when submitted on  or through the Services, or if you contact us (e.g., by email, telephone, written correspondence, web based forms, or  otherwise), request support, apply for or take a job with us, contract with us, interact with our social media accounts,  or otherwise communicate with us.  

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3.3 Limited Sensitive Personal Data

Relocity may collect, process, or store on or through the Services certain “Special Categories of Personal Data,”  “Sensitive Personal Information,” or similarly sensitive Personal Data as defined under applicable privacy and data  protection laws (collectively, “Sensitive Personal Data”). Sensitive Personal Data, for the sake of clarity, includes,  without limitation, government-issued identification numbers; financial account numbers; credit or debit card  numbers; any code or password that could be used to gain access to personal accounts; information revealing racial  or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic information;  biometric information; or information concerning mental or physical health, sex life, or sexual orientation. Relocity  collects, processes, and stores only such Sensitive Personal Data required to perform the Services, and limits its use  and disclosure to that reasonably necessary and proportionate for this purpose. Except for any Sensitive Personal  Data expressly identified in Section 3.1.1 “User Information,” Relocity does not intentionally collect, process, or  store, and we request that you do not upload, transmit, or submit on or through the Services any other Sensitive  Personal Data on or through the Services. Relocity is not responsible and will not be liable for any loss or damages  you or another individual may experience due to your unsolicited disclosure of Sensitive Personal Data while using  the Services.  

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3.4 No Children’s Data

The Services are intended for use only by those who are 18 years of age and older. The Services are not directed to  or intended for children without parental or guardian consent. Relocity does not intentionally collect, process, or  store any Personal Data from any person under 13 years of age without verifiable parental consent. In the event we  discover we have inadvertently collected, processed, or stored any Personal Data from a person under 13 years of  age, we will promptly take the appropriate steps to delete such data or seek the necessary verifiable parental consent  for that collection in compliance with the Children’s Online Privacy Protection Act (“COPPA”) or applicable law.

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4. HOW AND WHY WE USE DATA

Client Data will be used by Relocity in accordance with the terms of the applicable Client Agreement, the Client’s  instructions, the Client’s or its users’ use of the Services, which includes your use of the Services, and as otherwise  required by applicable law. The Client may, for example, use the Services to configure settings, access, modify,  share, restrict, export, and remove Client Data and otherwise apply its own policies to the Services.

Other Information will be used by Relocity to perform the Services and related support for the Services, in  furtherance of our legitimate interests in operating our business and providing the Services, or pursuant to your  express consent for a specific purpose. Specifically, Relocity may use Other Information for these purposes and  legal bases:

  • Providing the Services. To provide the Services to you, make available and support delivery of the  Services under the applicable Client Agreement, manage user requests interacting with the Services (e.g.,  login and authentication, remembering settings, etc.), hosting and back-end infrastructure, analyze and  monitor usage, and monitor and address service performance, security, and technical issues.
  • Improving the Services. To improve and optimize the Services, such as to test features, drive product  roadmap and design decisions, and improve quality of data and analytics.
  • Support Services. To respond to support requests and otherwise provide support for and resolve problems  with the Services.
  • Communications. To send technical, administrative, and marketing emails, messages, and other  communications. Service-related technical and administrative communications and notices, such as  maintenance and security announcements, are essential to delivery of the Services and you cannot opt-out.  Marketing communications about new product features, service offerings, and other news about Relocity  are optional and you have the choice whether or not to receive them. You may opt-out from any marketing  communications by following the unsubscribe instructions is any such communication or by contacting us  at privacy@relocity.com.
  • Account Management. To contact for billing, account management, feedback, and other administrative  matters.
  • Security Purposes. To maintain adequate security and help prevent and investigate security issues and  abuse.
  • Legal Obligations. To perform contractual obligations and comply with legal obligations as required by  applicable law, legal process, or regulations.

5. HOW WE SHARE AND DISCLOSE DATA

Except as described in this Privacy Policy or the applicable Client Agreement, Relocity will not disclose your  Personal Data for any purpose other than to the extent necessary to perform the Services and related support for the  Services, unless you expressly consent to any other disclosure. Relocity may share and disclose data with respect to:

  • Client’s Instructions. Relocity will share and disclose Client Data, including Personal Data, in accordance  with the Client’s instructions, including the applicable Client Agreement and the Client’s or its users’ use of  the Services, which includes your use of the Services. Subject to the applicable Client Agreement, Client  Data is generally treated as the confidential information of the Client unless stated otherwise.
  • Client Access. The Client and the Client’s representatives and personnel may be able to access, modify, or  restrict access to your data, including Personal Data. For example, the Client may access and use your  Personal Data for the purposes upon which you shared your Personal Data on or through the Services.
  • Rendering the Services. Relocity employees and contractors may have access to your data on a need to  know and confidential basis to the extent necessary to render the Services and related support for the  Services. For example, you may have access to chat support or be assigned a dedicated personal host and  the Relocity personnel assigned to perform those services may have access to your Personal Data to  perform the Services requested on your behalf and provide a more personalized experience.
  • Third Party Service Providers. Relocity engages third parties to process data in support of delivering the  Services (“Third Party Service Providers”). Relocity may share your data, including Personal Data, with  Third Party Service Providers (e.g., email services, platform hosting, cloud computing services, data  storage and processing facilities, payment processors, etc.) to the limited extent necessary to let them  perform business functions and services for us or on our behalf in connection with the provision of the  Services; provided that such Third Party Service Providers process data in a manner consistent with this  Privacy Policy and applicable privacy and data protection laws and will not use or disclose Personal Data  for any other purpose. For more information about our current Third Party Service Providers, please visit:  https://trust.relocity.com/subprocessors.
  • Third Party Services. Third Party Services may be integrated with or made available in connection with  the Services. When enabled, Relocity may share certain data with such Third Party Services as requested to  effectuate the integration or offering. Third Party Services are not owned or controlled by Relocity and  Third Parties Services that have been granted access to your data may have their own policies and practices  for its collection and use. You should check the privacy settings and notices of these Third Party Services to  understand their privacy practices.
  • Changes to Relocity’s Business. If Relocity engages in a merger, acquisition, bankruptcy, dissolution,  reorganization, sale of some or all of its assets or stock, financing, public offering of securities, acquisition  of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such  activities (e.g., due diligence), Relocity may share or disclose data in connection therewith, subject to  standard confidentiality obligations.
  • Aggregated or De-identified Data. If any data is aggregated or de-identified so it is no longer reasonably  associated with an identified or identifiable natural person, we may use or disclose such aggregated or de identified data for any purpose. For example, we may share aggregated or de-identified data with prospects  or partners for statistical analysis or research purposes or with other service providers to develop or  improve the Services.
  • Enforcement of Agreements. Relocity may disclose data to ensure compliance with and enforce the  applicable Client Agreement and any other contractual or legal obligations with respect to the Services and  our business.  
  • Protection of Rights. Relocity may disclose data to protect and defend our rights and property, including  intellectual property rights, and to ensure compliance with applicable laws and enforce third party rights,  including intellectual property and privacy rights.
  • Legal Compliance. If we are compelled by law, such as to comply with a subpoena, court order, or other  lawful process, or in response to a lawful request by public authorities to meet national security or law  enforcement requirements, Relocity may disclose data if we reasonably believe disclosure is in accordance  with or required by any applicable law, regulation, or legal process.
  • Safety and Security. Relocity may disclose data to protect your safety and security; to protect the safety,  security, and property of your Sponsor or the RMC; or to protect the safety, security, and property of  Relocity and our employees, contractors, agents, and representatives.
  • Your Consent. Relocity may disclose your data to third parties when we have your express consent to do  so.

6. RETENTION

Relocity will retain Client Data in accordance with the terms of the applicable Client Agreement and as otherwise  permitted by applicable law. Relocity may retain Other Information and any other data pertaining to you, including  Personal Data, for as long as necessary for the purposes described in this Privacy Policy, including for the period of  time needed to pursue our legitimate business interests, such as providing the Client and its users with the Services,  conducting audits, resolving disputes, complying with contractual obligations (including but not limited to the  applicable Client Agreement), and complying with (and demonstrate compliance with) legal obligations.  Notwithstanding the foregoing, unless Relocity receives a written request to remove Personal Data earlier, Relocity  generally retains Personal Data in connection with the Services for one (1) year after the Client closes the applicable  individual’s account at completion of the Services, and Relocity promptly deletes or destroys all applicable Personal  Data after the retention period has expired, unless a longer retention period is required or permitted by applicable  laws for legal, auditing, or compliance purposes.  

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7. SECURITY MEASURES

Relocity maintains physical, technical, and administrative procedures to safeguard and secure the data we collect.  We work hard to protect data in our custody and control from loss, misuse, and unauthorized access, use, disclosure,  modification, or destruction. For more information about our security measures, please visit: https:// trust.relocity.com. You provide Personal Data at your own risk. You are responsible for safeguarding your user  account and password. Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure, and  we cannot guarantee that unauthorized access, hacking, data losses, or other breaches will never occur. If you  believe your privacy has been breached, please contact us immediately at privacy@relocity.com.

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8. IDENTIFYING THE DATA CONTROLLER AND DATA PROCESSOR

Privacy and data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of  data. In general, the Client is the controller of Client Data. In general, Relocity is the processor of Client Data and  the controller of Other Information.  

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9. INTERNATIONAL DATA TRANSFERS

Relocity primarily processes and stores data in connection with the Services in the United States. However, the  Services are global and all data, including Personal Data, may be processed and stored in any country where we  have operations or where we engage Third Party Service Providers. We may transfer data, including Personal Data,  to countries outside of your country of residence, which may have privacy and data protection laws that are different  from those of your country. We will take measures to ensure that your Personal Data remains protected to the  standards described in this Privacy Policy and any such transfers comply with applicable privacy and data protection  laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those  other countries may be entitled to access your Personal Data.

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Relocity does not transfer Personal Data from the European Union (“EU”), the European Economic Area (“EEA”),  the United Kingdom (“UK”), or Switzerland to, or process such Personal Data in, a location outside of the  foregoing, without the Client’s prior written consent. However, Relocity may transfer Personal Data from the EU,  the EEA, the UK, and Switzerland to, or process such Personal Data in, the United States where Relocity has  implemented an international data transfer mechanism compliant with applicable data protection and privacy laws,  including the General Data Protection Regulation (“GDPR”), which for example may include an international data  transfer: (i) subject to an adequacy decision by the European Commission; (ii) subject to the Standard Contractual  Clauses for the transfer of Personal Data from Controller to Processor, which are incorporated herein by reference;  (iii) where another appropriate safeguard pursuant to Article 46 of the GDPR applies; or (iv) where a derogation  pursuant to Article 49 of the GDPR applies.

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10. YOUR RIGHTS

Individuals located in certain countries and jurisdictions have certain statutory rights in relation to their Personal  Data. Subject to any exemptions provided by law, you may have the right to exercise your rights and request certain  actions with respect to your Personal Data.

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10.1 General Privacy Rights

The Services are global and Relocity endeavors to comply with all applicable privacy and data protection laws.  Please direct any requests to exercise your rights under applicable privacy and data protection laws to your Sponsor.  For any other requests related to your rights under applicable privacy and data protection laws, please contact us at  privacy@relocity.com. We will consider your request in accordance with applicable laws. To protect your privacy  and security, we may take steps to verify your identity before complying with the request.  

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Relocity is committed to maintain accurate information that you share with us and will use commercially reasonable  efforts to allow you to access your Personal Data. Upon request, we will provide you with information about  whether we hold, or process on behalf of a third party, any of your Personal Data. To request this information or if  you wish to access, modify, or remove your Personal Data, please contact us at privacy@relocity.com. Relocity will  endeavor to respond to all reasonable written requests to access, modify, or remove Personal Data in a timely  manner within thirty (30) days.  

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If you seek to access, modify, or remove Personal Data held or processed by us on behalf of the Client, you should  direct your inquiry to your Sponsor. Upon receipt of a data subject request from your Sponsor or the RMC, as  applicable, we will respond to their request in a timely manner within thirty (30) days.  

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If you consent to receiving communications from a third party, such third party may have its own privacy policy  which will apply to you and you will need to communicate with them directly if you wish to access, modify, or  remove the Personal Data you provided to them, or later decide that you no longer wish to receive such third party’s  communications.

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10.2 Additional Rights for Europe

Individuals located in the EU, the EEA, the UK, and Switzerland have certain statutory rights under the GDPR  regarding their personal data (as defined by the GDPR but for purposes of this Privacy Policy, referred to as  Personal Data). To the extent that Relocity’s processing of your Personal Data is subject to the GDPR, Relocity  relies on its legitimate interests set forth in this Privacy Policy to process your Personal Data. If you are located in  the EU, the EEA, the UK, or Switzerland, you may have the right to exercise additional rights available to you under  the GDPR, including:

  • Right to Erasure (aka “Right to be Forgotten”). You may have a broader right to erasure of Personal  Data that we hold about you, such as, for example, if it is no longer necessary in relation to the purposes for  which it was originally collected or we do not have a legal reason to continue to process and hold it. Please  note, however, that we may need to retain certain information for record keeping purposes, to complete  transactions, or to comply with our legal obligations.
  • Right to Restrict Processing. You may have the right to request that we restrict processing of your  Personal Data in certain circumstances, such as, for example, where you believe that the Personal Data we  hold about you is inaccurate or unlawfully held. We may be permitted to store the data but not further  process it. We may need to keep just enough data to make sure we respect your request in the future.
  • Right to Data Portability. You may have the right to be provided with your Personal Data in a structured,  machine readable, and commonly used format and to request that we transfer the data to another data  controller without effecting the usability of the data.
  • Right to Object to Processing. You may have the right to request that we stop processing your Personal  Data, such as for the purpose of direct marketing, scientific and historical research, or for a task in the  public interest.
  • Right to Lodge a Complaint. You may also have the right to complain to a data protection authority about  our collection and use of your Personal Data. For more information, please contact your local data  protection authority.
  • When rendering the Services to the Client subject to the GDPR, the Client acts as a “controller” and Relocity acts as  a “processor”, and Relocity’s receipt and collection of any Personal Data is completed on behalf of the Client in  order for Relocity to provide the Services.  

Please direct any requests to exercise your rights under the GDPR to your Sponsor. For any other requests related to  your applicable rights under the GDPR, please contact us at privacy@relocity.com. We will consider your request in  accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity  before complying with the request.

10.3 Additional Rights for California

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10.3.1 California Consumer Privacy Act

California residents have certain statutory rights under the California Consumer Privacy Act (“CCPA”) regarding  their personal information (as defined by the CCPA but for purposes of this Privacy Policy, referred to as Personal  Data). To the extent that Relocity’s processing of your Personal Data is subject to the CCPA, Relocity relies on its  

legitimate interests set forth in this Privacy Policy to process your Personal Data. If you reside in California, you  may have the right to exercise additional rights available to you under the CCPA, including:

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  • Right to Access. You may have the right to request disclosure of the categories and specific pieces of  Personal Data collected about you. Upon a verifiable request to access Personal Data, we will promptly  take steps to disclose and deliver, free of charge to you, the Personal Data required to be disclosed. The  information may be delivered by mail or electronically, and if provided electronically, the information shall  be in a portable and, to the extent technically feasible, readily useable format that allows you to transmit  this information to another entity without hindrance. We may provide Personal Data to you at any time, but  shall not be required to provide Personal Data to you more than twice in a 12-month period.
  • Right to Deletion. You may have the right to request the deletion of your Personal Data. Upon a verifiable  request to delete Personal Data, we will promptly delete such Personal Data from our records and direct  any service providers to delete such Personal Data from their records, subject to certain exceptions under  the CCPA.
  • Right to Opt-Out of the Sale of Information. You may have the right to opt-out of the sale of your  Personal Data to third parties. Relocity does not sell your Personal Data to third parties and will never sell  your Personal Data to third parties without your express authorization.  

Relocity will not discriminate against you for exercising your rights under the CCPA. Specifically, if you exercise  your rights, we will not deny you services, charge you different prices for services, or provide you a different level  or quality of services.

When rendering the Services to the Client subject to the CCPA, the Client acts as a “business” and Relocity acts as a  “service provider”, and Relocity’s receipt and collection of any Personal Data is completed on behalf of the Client in  order for Relocity to provide the Services.  

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Please direct any requests to exercise your rights under the CCPA to your Sponsor. For any other requests related to  your applicable rights under the CCPA, please contact us at privacy@relocity.com. We will consider your request in  accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity  before complying with the request.

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10.3.2 California “Shine the Light” Notice

Relocity does not disclose Personal Data to third parties for any third parties’ direct marketing purposes and will not  do so unless you affirmatively consent to such disclosure. Since Relocity provides its California users with notice of  its rights as described above, pursuant to Section 1798.83(c)(2) of the California Civil Code, Relocity complies with  California’s “Shine the Light” law and is not obligated to provide California users with the names and addresses of  

all the third parties that received Personal Data from Relocity for the third parties’ direct marketing purposes during  the preceding calendar year.

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11. ENFORCEMENT

Relocity will actively monitor its relevant privacy and security practices to verify adherence to this Privacy Policy.  Any agents, contractors, service providers, or other third parties subject to this Privacy Policy that Relocity  determines is in violation of this Privacy Policy or applicable privacy and data protection laws will be subject to  disciplinary action up to and including termination of such services. If you believe there has been a violation of this  Privacy Policy or applicable privacy and data protection laws, please contact us immediately at  privacy@relocity.com.

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12. CHANGES TO THIS PRIVACY POLICY

Relocity may change, modify, or update this Privacy Policy from time to time, in whole or in part, in Relocity’s sole  discretion. We encourage you to visit this page at https://www.relocity.com/privacy to stay informed about our  privacy practices and review our most current Privacy Policy. Any changes, modifications, or updates to this Privacy  Policy will become effective immediately upon such posting unless stated otherwise. Your continued use of the  Services constitutes your agreement to be bound by such changes to this Privacy Policy. If you disagree with the  changes to this Privacy Policy, your only remedy is to discontinue use of the Services and request deletion of your  account by contacting us at privacy@relocity.com.

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13. CONTACT RELOCITY

We encourage you to contact us with any questions, complaints, or requests with respect to your Personal Data, this  Privacy Policy, and/or our privacy practices.

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You may contact us at:

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Email: privacy@relocity.com

Relocity, Inc.

Attn: Privacy

10250 Constellation Blvd., Suite 100

Los Angeles, CA 90067

USA