Privacy — Newly Renovated Inc.

NEWLY RENOVATED INC.

Version 2.0 - CPRA / CCPA Compliant - Updated March 13, 2026

Effective Date: March 13, 2026

CSLB Contractor License No. 1127199 (Class B - General Building Contractor)

By using the NRI website or submitting personal information to NRI, you acknowledge and agree to the practices described in this Policy.

RELATED LEGAL DOCUMENTS

This Privacy Policy should be read in conjunction with:

ï Website Terms of Use - governs your legal relationship with this Site [www.newlyrenovated.com/terms]

ï Cookie Policy - complete inventory of cookies and tracking technologies [www.newlyrenovated.com/cookies]

1. SCOPE AND APPLICABILITY

This Privacy Policy ("Policy") describes how Newly Renovated Inc., a California corporation ("NRI," "we," "us," or "our"), collects, uses, retains, discloses, and protects personal information in connection with: (a) the NRI website at www.newlyrenovated.com and all associated subdomains and pages (the "Site"); (b) NRI's marketing and business development communications; and (c) NRI's professional residential construction and renovation services delivered pursuant to a written Home Improvement Contract ("HIC").

This Policy applies to all users of the Site and to all individuals who provide personal information to NRI, whether as prospective clients, active clients, real estate agent referral partners, or general visitors. This Policy does not apply to personal information collected by third-party websites linked from the Site.

2. DEFINITIONS

For purposes of this Policy:

ï "Personal Information" means information that identifies, relates to, describes, or could reasonably be linked to a particular consumer or household, as defined under Cal. Civ. Code ß 1798.140. It excludes de-identified or aggregated information.

ï "Sensitive Personal Information" means the subset defined under Cal. Civ. Code ß 1798.121, including government-issued identification numbers, financial account credentials, and precise geolocation data.

ï "Sale" means disclosing Personal Information to a third party for monetary or other valuable consideration, as defined under Cal. Civ. Code ß 1798.140(ad).

ï "Sharing" means disclosing Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary consideration.

ï "Service Providers" means third parties that process Personal Information on NRI's behalf under a written contract prohibiting use of that information for independent purposes.

3. CATEGORIES OF PERSONAL INFORMATION COLLECTED

NRI collects the following categories of Personal Information as defined under Cal. Civ. Code ß 1798.140:

A. Identifiers

Name, postal address, email address, telephone number, and IP address. Collected when you submit an inquiry form, contact NRI directly, or visit the Site.

B. Property and Project Information

Residential property address, ownership status, property condition descriptions, renovation history, photographs and videos of the property submitted for project scoping. Collected when you engage NRI for a quote or construction services.

C. Financial Information

Payment information for construction milestones, processed exclusively through PCI-DSS compliant third-party processors. NRI does not store raw financial account credentials. Project budget and contract amounts are also collected.

D. Commercial Information

Records of construction services requested or received, Home Improvement Contract history, and project correspondence.

E. Internet or Electronic Network Activity Information

Browser type, operating system, device type, pages visited, time on page, referring URL, and interaction data collected automatically through cookies and analytics tools. See the Cookie Policy at www.newlyrenovated.com/cookies for the complete named inventory.

F. Geolocation Data (Limited)

Non-precise geolocation inferred from IP address to confirm that a visitor is within NRI's California service area. NRI does not collect GPS-level geolocation data.

G. Professional Information

Real estate license number, brokerage affiliation, and professional contact details for licensed real estate agents who engage NRI as referral partners.

4. HOW NRI COLLECTS PERSONAL INFORMATION

ï Directly from you: when you submit a project inquiry form, request a quote, execute a Home Improvement Contract, upload property photographs, or contact NRI by telephone or email.

ï Automatically through the Site: via cookies and analytics technologies described in the Cookie Policy at www.newlyrenovated.com/cookies.

ï From real estate agent referral partners: licensed California real estate agents may provide NRI with a property owner's contact information to schedule a project consultation.

ï From publicly available sources: NRI may verify property ownership through public county assessor records and the California Department of Real Estate public license database.

5. PURPOSES FOR WHICH NRI USES PERSONAL INFORMATION

ï To respond to project inquiries and schedule on-site consultations;

ï To prepare, deliver, and negotiate project proposals and Home Improvement Contracts;

ï To coordinate and manage residential construction projects, including communication with licensed trade subcontractors;

ï To process payments for services rendered;

ï To obtain required building permits from California municipal authorities;

ï To maintain project records for a minimum of ten (10) years, consistent with the construction defect statute of repose under Cal. Code Civ. Proc. ß 337.15;

ï To maintain financial records for a minimum of seven (7) years for tax and audit compliance;

ï To communicate with you by telephone, email, or SMS/text message regarding your inquiry or active project, subject to your communications consent under applicable law;

ï To analyze and improve Site performance using aggregated and de-identified analytics data;

ï To send marketing communications, subject to your right to opt out; and

ï To comply with applicable federal, California state, and local laws and legal process.

NRI does not use Personal Information for automated decision-making or profiling that produces legal or similarly significant effects without human review.

6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

A. No Sale of Personal Information

NRI does not sell Personal Information to third parties for monetary consideration.

B. Service Providers

NRI discloses Personal Information to Service Providers solely to perform services on NRI's behalf. Current categories include: project management software vendors; cloud document storage and electronic signature platforms; payment processors; website hosting and security providers; email and SMS communication platforms; website analytics providers (named in the Cookie Policy); and licensed trade subcontractors engaged for project execution.

C. Real Estate Agent Referral Partners

NRI may share limited project status information with the licensed California real estate agent who introduced NRI to a property owner client, solely to coordinate the construction project with the property's listing schedule, and only where the property owner has not objected. This disclosure does not constitute a "sale" or "sharing" for cross-context behavioral advertising under the CPRA. NRI does not disclose Personal Information to agents for their independent marketing purposes.

D. Legal Compliance

NRI may disclose Personal Information to government authorities, including local building departments, the CSLB, and law enforcement, when required by law, regulation, court order, or legal process.

E. Business Transfers

In the event of a merger, acquisition, or sale of NRI's assets, Personal Information may be transferred to the successor entity subject to equivalent privacy protections.

7. COOKIES AND TRACKING TECHNOLOGIES

NRI uses cookies and similar tracking technologies on the Site. The complete inventory of cookies, named third-party providers, retention periods, and opt-out mechanisms is set forth in the NRI Cookie Policy at www.newlyrenovated.com/cookies, incorporated into this Policy by reference.

In summary, the Site uses: (a) essential cookies required for Site functionality; (b) analytics cookies (Google Analytics 4, Hotjar) to measure Site traffic and user behavior; (c) functionality cookies to remember user preferences; and (d) marketing and targeting cookies (Google Ads/Tag Manager, Meta Pixel) to support NRI's advertising efforts.

NRI honors Global Privacy Control (GPC) signals transmitted by your browser as an opt-out of the sharing of Personal Information for cross-context behavioral advertising, consistent with Cal. Civ. Code ß 1798.135. Upon receipt of a valid GPC signal, NRI will disable applicable non-essential third-party tracking cookies.

8. DATA RETENTION

ï Project records and HIC files: minimum ten (10) years from substantial completion, per Cal. Code Civ. Proc. ß 337.15.

ï Financial records: minimum seven (7) years for tax and audit compliance.

ï Pre-contract inquiry records: two (2) years from date of inquiry if no contract is executed.

ï Analytics data: per the retention settings of applicable third-party analytics providers, as described in the Cookie Policy.

ï Marketing records: until opt-out, after which contact information is maintained on a suppression list only.

9. YOUR CALIFORNIA PRIVACY RIGHTS (CPRA)

California residents have the following rights under the CPRA (Cal. Civ. Code ß 1798.100 et seq.):

A. Right to Know

To request disclosure of the categories and specific pieces of Personal Information NRI has collected, the sources, the business purposes, and the third parties to whom information was disclosed.

B. Right to Delete

To request deletion of your Personal Information, subject to exceptions under Cal. Civ. Code ß 1798.105 (including retention required for active contracts or legal obligations).

C. Right to Correct

To request correction of inaccurate Personal Information NRI maintains about you.

D. Right to Opt Out of Sale or Sharing

To opt out of the sharing of Personal Information for cross-context behavioral advertising, you may: (i) enable a GPC signal in your browser; (ii) submit a request through the dedicated Do Not Sell or Share form at www.NewlyRenovated.com/privacy-request; or (iii) manage cookie preferences through NRI's cookie consent banner.

E. Right to Non-Discrimination

NRI will not discriminate against you for exercising your CPRA rights.

F. How to Submit a Request

Submit a verifiable consumer request through any of the following methods:

ï Dedicated Privacy Request Form (required method for Do Not Sell or Share): www.NewlyRenovated.com/privacy-request

ï Email: Hello@NewlyRenovated.com (subject: "California Privacy Rights Request")

ï Telephone: (415) 626-8180

NRI will respond within forty-five (45) calendar days, extendable by an additional forty-five (45) days with notice. Identity verification may be required.

10. CALIFORNIA "SHINE THE LIGHT" DISCLOSURE

California Civil Code ß 1798.83 ("Shine the Light" law) permits California residents to request, once per calendar year, information about the categories of personal information NRI has shared with third parties for their direct marketing purposes during the preceding calendar year, and the names and addresses of those third parties.

NRI may share certain personal information (such as name and contact information) with licensed real estate agent referral partners who may use such information for their own professional marketing activities. If you are a California resident and wish to submit a Shine the Light request, please email Hello@NewlyRenovated.com with the subject line "California Shine the Light Request," or write to NRI at 650 5th Street, Suite 410, San Francisco, CA 94107. NRI will respond within thirty (30) days of receiving a verified request.

11. NOTICE OF FINANCIAL INCENTIVES

From time to time, NRI may offer promotions, referral credits, or other incentives to users who provide personal information such as their name, email address, or telephone number (for example, in connection with a referral program or promotional offer). Participation in any such program is entirely voluntary and requires an opt-in.

Where NRI offers a financial incentive in connection with the collection or use of personal information, NRI will provide a separate, program-specific notice at the time of enrollment disclosing: (a) the material terms of the incentive; (b) the categories of Personal Information involved; and (c) how to opt in and opt out. The value of any incentive offered will be reasonably related to the value of the Personal Information collected, taking into account the cost of collection, storage, and administration. You may withdraw from any financial incentive program at any time by contacting Hello@NewlyRenovated.com.

As of the Effective Date of this Policy, NRI does not operate a standing financial incentive program tied to the collection of personal information.

12. SECURITY

NRI implements reasonable physical, technical, and administrative security measures to protect Personal Information from unauthorized access, disclosure, alteration, and destruction. No transmission over the Internet can be guaranteed one hundred percent (100%) secure. In the event of a breach triggering notification obligations under Cal. Civ. Code ß 1798.29 or ß 1798.82, NRI will provide required notifications in accordance with California law.

13. CHILDREN'S PRIVACY

The Site and NRI's services are intended solely for adults 18 years of age or older. NRI does not knowingly collect Personal Information from children under 13. If you believe a child has submitted Personal Information through the Site, please contact Hello@NewlyRenovated.com immediately.

14. INTERNATIONAL DATA TRANSFERS

NRI is headquartered in San Francisco, California, and primarily processes Personal Information within the United States. However, certain third-party Service Providers engaged by NRI - including Google LLC (Google Analytics, Google Ads), Meta Platforms, Inc. (Meta Pixel), and Hotjar Ltd. - may store or process data on servers located outside the United States, including in the European Union and other jurisdictions.

By using this Site and submitting Personal Information to NRI, you acknowledge that your information may be transferred to and processed in the United States or other countries whose data protection laws may differ from those of your jurisdiction. Where required by applicable law, NRI relies on appropriate transfer mechanisms (such as Standard Contractual Clauses) to govern international transfers of personal data.

15. THIRD-PARTY LINKS

The Site may contain links to third-party websites for reference or convenience. NRI does not control such third-party sites and is not responsible for their privacy practices. Inclusion of a link does not constitute NRI's endorsement of that third party.

16. CHANGES TO THIS POLICY

NRI reserves the right to modify this Policy at any time. Material changes will be reflected by an updated Effective Date. Your continued use of the Site following a revised Effective Date constitutes acknowledgment of the updated Policy. Archived versions of prior policies are available upon request.

17. CONTACT INFORMATION

Newly Renovated Inc.

Attn: Privacy Inquiries

650 5th Street, Suite 410, San Francisco, CA 94107

Email: Hello@NewlyRenovated.com

Telephone: (415) 626-8180

Privacy Request Form: www.NewlyRenovated.com/privacy-request

Newly Renovated Inc. - Privacy Policy - Version 2.0 | CSLB License No. 1127199