PRIVACY POLICY

Copilot Software LLC doing business as Homeworks

Effective Date: February 12, 2026

Introduction and Legal Identity

1. This Privacy Policy (“Policy”) describes how Copilot Software LLC doing business as Homeworks (“Homeworks,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information. This Policy applies to visitors of our public website and to authorized users of the Homeworks software platform, a home service customer relationship management system. By accessing our website or using our services, you acknowledge that you have read and understood this Policy.
2. Copilot Software LLC is a limited liability company organized under the laws of the State of Washington. All references to “Homeworks” in this Policy refer to this legal entity.

Governing Law

1. This Policy and any disputes arising from or relating to it shall be governed by and construed in accordance with the laws of the State of Washington, without regard to its conflict of law principles. Except as otherwise provided in specific state carve-out sections of this Policy, the laws of Washington State shall govern all aspects of data collection, processing, and protection under this Policy.

Dispute Resolution

1. Any disputes arising from or relating to this Privacy Policy, including its interpretation, validity, enforceability, or alleged breach, are subject to the dispute resolution provisions set forth in our Terms of Service (available at www.home.works/terms-of-service), which are expressly incorporated herein by reference. By accepting this Privacy Policy, you acknowledge that you have had the opportunity to review the dispute resolution provisions in the Terms of Service and agree to be bound by them.
2. For the complete terms governing dispute resolution, including arbitration procedures, jury trial waivers, and exceptions, please refer to our Terms of Service, available at www.home.works/terms-of-service.
3. Any arbitration provisions applicable to disputes under this Privacy Policy, including any class action waiver, jury trial waiver, and limitations on remedies, are set forth in our Terms of Service and are incorporated by reference to that agreement. You acknowledge that by accepting this Privacy Policy, you are waiving your right to bring disputes in court and to have disputes heard by a jury, except as otherwise provided in the Terms of Service.

Data Ownership

1. Ownership of all customer data, including but not limited to personal information, user-generated content, and persistent property context media uploaded to or processed through the Homeworks platform, resides with the customer at all times. Homeworks does not acquire any ownership interest in customer data by virtue of processing or storing such data.
2. For purposes of service delivery, account management, and technical support, Homeworks acts as a processor and custodian of customer data. In this capacity, Homeworks processes customer data solely in accordance with customer instructions and the terms of applicable service agreements.
3. For purposes of product improvement and service enhancement, Homeworks may act as a controller. Where we process personal data for these purposes, our lawful basis is your consent, which is provided through your acceptance of this Privacy Policy and our Terms of Service. You may withdraw your consent at any time by contacting our Privacy Contact, though this may affect our ability to provide certain features or services. Alternatively, where we rely on legitimate interest, we have conducted a balancing assessment and determined that these interests are not overridden by your fundamental rights and freedoms, given the safeguards we apply (including pseudonymization where feasible and strict access controls). You have the right to object to processing based on legitimate interest.
4. When Homeworks uses customer data for internal purposes such as analytics or product development, including analysis of platform usage patterns, feature interactions, geolocation data, subscription plan information, and account tenure, we rely on the consent you provide through acceptance of this Privacy Policy and our Terms of Service. We may process aggregated or anonymized derivatives of such data without additional consent only where we apply technical and organizational measures that ensure the data cannot be reasonably re-identified and is no longer considered personal data under applicable law. Where we process identifiable or potentially identifiable customer data for purposes beyond service delivery, your consent is provided through your acceptance of this Policy and our Terms of Service, which you may withdraw at any time by contacting our Privacy Contact. We apply appropriate safeguards including data minimization, access restrictions, and retention limits specific to that processing activity.

Categories of Personal Data Collected

1. Homeworks collects personal information in several categories depending on how you interact with our website and services. The following table describes the categories of personal data we collect, the sources of such data, and the purposes for which each category is processed.
2. Table 5.2

Data Sale and Targeted Advertising

1. Homeworks does not sell personal information to third parties. We do not engage in the sale, renting, or leasing of personal information as those terms are defined under the California Consumer Privacy Act, the California Privacy Rights Act, or other applicable state privacy laws.
2. Homeworks does not use personal information for targeted advertising on our website or through our platform. We do not share personal information with third parties for their direct marketing purposes.

Third-Party Sharing

1. Homeworks shares personal information only with third-party service providers who help us operate our platform and deliver our services. We conduct due diligence on all service providers and require them to enter into written agreements that obligate them to protect personal information in accordance with this Policy and applicable law. We disclose personal information to the following specific categories of third parties, exclusively for the limited purposes described below.
2. Table 7.2

All third-party service providers with whom we share personal information are contractually obligated to:

(a) maintain the confidentiality and security of such information using appropriate technical and organizational measures;

(b) use personal information solely for the purposes for which it was disclosed and in accordance with our instructions;

(c) notify us promptly of any security incidents or unauthorized access;

(d) not further disclose personal information to subprocessors without our prior written consent; and

(e) return or delete personal information upon termination of services, except where retention is required by law.

Data Retention Schedule

1. Homeworks retains personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce agreements. The following retention schedule applies to the principal categories of personal information we collect.
2. Table 8.2

When personal information is no longer required under this retention schedule, Homeworks will securely delete or anonymize such information using methods that render it unrecoverable. Deletion requests submitted by users may be limited by legal retention requirements, ongoing disputes, or contractual obligations. Where we are required to retain data despite a deletion request, we will notify you of the reason for continued retention and the expected retention period. Such data will be isolated from active processing systems, marked for restricted access, and protected by enhanced technical and organizational controls to prevent unauthorized access or use. We will delete the data as soon as the retention obligation expires.

Security Measures

1. Homeworks implements technical, administrative, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Our security program includes the following measures:
2. Encryption. All personal information is encrypted in transit using industry-standard Transport Layer Security (TLS) protocols. Data at rest, including persistent property context media, is encrypted using AES-256 encryption or equivalent.
3. Access Controls. Access to personal information is restricted to authorized personnel on a need-to-know basis. We employ role-based access controls, unique authentication credentials, and multi-factor authentication for systems containing sensitive data.
4. Geographically Diverse Backups. Customer data is backed up to geographically diverse data centers located within the United States. All backup data centers are SOC 2 Type II certified or equivalent. Backup systems are designed to ensure business continuity and data recovery in the event of system failure or disaster, with recovery time objectives (RTO) and recovery point objectives (RPO) specified in our service level agreements.
5. Security Assessments. Homeworks conducts regular security assessments, including vulnerability scanning and penetration testing, to identify and remediate potential security weaknesses.
6. Incident Response. Homeworks maintains a data breach response plan and will notify affected individuals and regulators as required by applicable lawin the event of a security incident involving personal information. Under Washington law (RCW 19.255.010), we will provide notice without unreasonable delay and in no event later than thirty (30) days after discovery of a breach affecting Washington residents. Notice will include the nature of the breach, the types of information involved, steps we are taking to address the breach, and contact information for further inquiries.
7. The security measures described in this section are consistent with the data security commitments set forth in our SaaS Agreement. For enterprise customers, additional security specifications may be set forth in Exhibit C (Data Security) of the applicable service agreement.

Business Transfers, Mergers, and Acquisitions

1. In the event of a merger, acquisition, reorganization, bankruptcy, asset sale, or other business transition involving all or a portion of Homeworks, personal information may be transferred to the acquiring entity or successor. We will provide notice to affected users in advance of such transfer.
2. If the acquiring entity intends to use personal information in a manner materially different from the uses described in this Policy at the time of collection, we will provide you with the opportunity to opt out of such transfer. You may exercise this opt-out right by contacting our Privacy Contact (see Section 14) within thirty (30) days of receiving notice of the proposed transfer. If you opt out, we will delete your personal information to the extent permitted by law and the requirements of the transaction.

Consumer Rights

1. Depending on your jurisdiction of residence, you may have certain rights with respect to your personal information. These rights may include the right to access, correct, delete, and restrict processing of your personal information, as well as the right to data portability and the right to object to processing. Specific rights for California and Washington residents are described in the state-specific carve-out sections of this Policy.
2. Submitting Requests: To exercise your privacy rights, you must submit a verifiable request through one of the f o l l o w i n g m e t h o d s : b y e m a i l t o privacy@copilotcrm.com; or by mail to our Privacy Contact address (see Section 14). We do not accept requests submitted solely through telephone or text message. However, if you have a disability that prevents you from submitting a request through our standard methods, please contact us to discuss reasonable accommodations.
3. To verify your identity, we may require you to provide information that matches information we have on file, such as your email address, account credentials, or other identifying information. For requests submitted on behalf of another individual, we require written authorization from the data subject or legal documentation establishing the requestor’s authority.
4. Response Timeline: We will acknowledge receipt of your request within ten (10) business days. We will respond to verified requests within forty-five (45) calendar days from receipt, or such shorter period as required by applicable law. If we require additional time, we will notify you of the extension and the reasons for the delay.
5. Limitations on Requests: We may deny a request in whole or in part if fulfilling the request would: (a) violate applicable law or legal obligation; (b) interfere with regulatory investigations or legal proceedings; (c) impair the delivery of services you have requested; (d) compromise the security or integrity of our systems; or (e) violate the rights of other individuals.
6. Appeals: If we deny your request, you may appeal our decision by submitting a written appeal to our Privacy Contact within thirty (30) days of receiving our response. Your appeal must include a description of the original request, the reason for the denial, and the basis for your appeal. We will respond to appeals within forty-five (45) calendar days, or such shorter period as required by applicable law. If you are not satisfied with the outcome of the appeal, you may contact the applicable regulatory authority.

Cookies and Tracking Technologies

1. Homeworks uses cookies and similar tracking technologies on our website and platform. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information.
2. Types of Cookies We Use: Homeworks uses the following categories of cookies on our website and platform. Each category serves a distinct function, and your ability to opt out varies depending on whether the cookie is essential to service delivery. We will obtain your consent before placing non-essential cookies on your device, in accordance with applicable law.
3. 1. Strictly Necessary Cookies. These cookies are essential for the operation of our website and enable core functionality such as security, network management, and account access. You cannot opt out of these cookies.
4. 2. Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings. If you disable these cookies, some features may not function properly.
5. 3. Analytics Cookies. We use analytics cookies to understand how visitors interact with our website, including which pages are visited, how long visitors spend on each page, and how visitors navigate the site. This information helps us improve our website and services. Homeworks uses Google Analytics for this purpose. When we use Google Analytics, data may be transferred to and processed by Google LLC in the United States and other countries. You can learn more about Google's privacy practices at https://policies.google.com/privacy and opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.
6. Homeworks does not use advertising or targeting cookies. We do not serve behaviorally targeted advertisements on our website.
7. Managing Cookies: You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. The specific steps vary by browser; consult your browser’s help documentation for instructions. You may also opt out of analytics cookies by visiting the Network Advertising Initiative opt-out page at www.networkadvertising.org/ choices or the Digital Advertising Alliance opt-out page at www.aboutads.info/choices.
8. Please note that disabling cookies may affect the functionality of our website and your ability to access certain features.

Children’s Privacy

1. The Homeworks website and services are primarily designed for use by businesses and their adult employees. However, we recognize the importance of encouraging young entrepreneurs and have established the Copilot Teen Giveback Program. This program is available to individuals between the ages of 13 and 17 who can provide valid documentation proving their age and the legal registration of their business. For participants under the age of 18, we obtain verifiable parental or guardian consent through acceptance of this Privacy Policy and our Terms of Service, in accordance with applicable privacy laws including COPPA and Washington state law. Eligible participants will receive free access to the Copilot Starter Monthly plan until their 18th birthday.
2. In accordance with the Children’s Online Privacy Protection Act (COPPA) and Washington state law, we do not knowingly collect personal information from children under the age of thirteen (13) without verifiable parental consent. If we become aware that we have inadvertently collected personal information from a child under thirteen, we will take immediate steps to delete such information from our systems.
3. If you believe that a child under thirteen has provided personal information to Homeworks, please contact our Privacy Contact (see Section 14) so that we can investigate and delete the information as appropriate.
   

Contact Information and Privacy Inquiries

1. For questions, concerns, or requests regarding this Policy or our privacy practices, please contact our Privacy Contact:
2. Copilot Software LLC
   1370 Admiral Pl
   Ferndale, WA 98248 USA
   Email: privacy@copilotcrm.com
3. For disputes that cannot be resolved through direct communication, please refer to the dispute resolution provisions set forth in our Terms of Service.
   

Policy Updates

1. Homeworks may update this Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated Policy on our website with a new effective date. For changes that materially affect your rights or the processing of your personal information, we will provide at least thirty (30) days' advance notice through email or in-app notification, depending on your relationship with Homeworks, except where applicable law requires affirmative consent.
2. Your continued use of our website or services after the effective date of an updated Policy constitutes acceptance of the updated terms. Where applicable law requires affirmative consent for material changes, we will obtain your express consent before the changes take effect. We encourage you to review this Policy periodically. It is your responsibility to maintain current contact information with Homeworks to ensure you receive notices of Policy changes.
   

Additional Disclosures for California Residents

1. This section provides additional information for California residents pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”).
2. Categories of Personal Information: In the preceding twelve (12) months, Homeworks has collected the following categories of personal information as defined under Cal. Civ. Code Section 1798.140: (a) identifiers; (b) personal information categories listed in Cal. Civ. Code Section 1798.80(e); (c) commercial information; (d) internet or other electronic network activity information; (e) geolocation data; (f) audio, electronic, visual, or similar information (including property context media); and (g) professional or employment-related information. The sources and purposes of collection are described in Section 5 of this Policy. We have not sold personal information in the preceding twelve (12) months.
3. Sale and Sharing of Personal Information: As of the date of this Policy, Homeworks does not sell personal information as defined under the CCPA. Homeworks does not share personal information for cross-context behavioral advertising. Because we do not currently sell or share personal information, we do not offer an opt-out mechanism for such activities. If our practices change, we will update this Policy at least thirty (30) days in advance and provide appropriate notice and opt-out mechanisms as required by law.
4. Sensitive Personal Information: Homeworks may collect the following categories of sensitive personal information as defined in Cal. Civ. Code Section 1798.140(ae): precise geolocation data. We use sensitive personal information only for purposes permitted under Cal. Civ. Code Section 1798.121, including to provide the services you request. We do not use sensitive personal information for purposes that would require an opt-out mechanism under the CCPA.
5. California Consumer Rights California residents have the following rights under the CCPA:
6. RIGHT TO KNOW. You have the right to request that we disclose the categories of personal information collected, the sources of collection, the business or commercial purpose for collection, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected about you.
7. RIGHT TO DELETE. You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.
8. RIGHT TO CORRECT. You have the right to request correction of inaccurate personal information.
9. RIGHT TO OPT OUT. You have the right to opt out of the sale or sharing of your personal information. Because Homeworks does not sell or share personal information, this right is not applicable.
10. Right to Limit Use of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to uses necessary to provide the services you request. Because Homeworks uses sensitive personal information only for such purposes, this right is not applicable.
11. Right to Nondiscrimination. You have the right not to receive discriminatory treatment for exercising your CCPA rights.
12. To exercise these rights, please contact us using the methods described in Section 11 of this Policy. You m a y s u b m i t r e q u e s t s b y e m a i l i n g privacy@copilotcrm.com. We will respond to verifiable requests within 45 days, or notify you if we require additional time (up to 90 days total) as permitted by law. We will verify your identity before responding to your request using methods reasonably designed to confirm the requestor's identity, which may include matching data points you provide with information we maintain. You may designate an authorized agent to submit requests on your behalf. To designate an authorized agent, you must provide the agent with written authorization signed by you, or provide the agent with power of attorney pursuant to California Probate Code sections 4000 to 4465. We may also require you to verify your identity directly with us and confirm that you provided the authorized agent permission to submit the request.
13. Financial Incentives: Homeworks does not offer financial incentives or price or service differences related to the collection, retention, sale, or deletion of personal information.
14. Data Retention: Homeworks retains personal information for the periods described in Section 8 of this Policy.
    

Additional Disclosures for Washington State Residents

1. This section provides additional information for Washington State residents pursuant to applicable Washington privacy laws, including the Washington My Health My Data Act (Chapter 19.373 RCW).
2. Consumer Health Data: The Washington My Health My Data Act (RCW 19.373.010 et seq.) imposes obligations on entities that collect, process, or share “consumer health data,” defined in RCW 19.373.010(4) to include information that identifies or is reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.
3. Although Homeworks is a business-to-business service provider that primarily processes job documentation and property information, property context media (such as photographs and videos) uploaded by authorized users may incidentally capture information that could be considered consumer health data under Washington law. Homeworks instructs its users not to intentionally capture health-related information and provides guidance on minimizing incidental capture of such data. For example, photographs or videos of job sites may inadvertently depict medical equipment, accessibility modifications, medications, or other health-related information about property occupants.
4. 4. To the extent Homeworks collects, processes, or stores any consumer health data as defined under the Washington My Health My Data Act, we obtain valid authorization from consumers in accordance with RCW 19.373.020(2) before collecting such data, and we provide the following disclosures:
5. Categories of Consumer Health Data. Homeworks may incidentally collect visual information related to health status through property context media (photographs and videos of work sites).
6. Purpose of Collection. Such data is collected solely for job documentation, quality assurance, and risk mitigation purposes related to property services. Homeworks does not intentionally collect consumer health data, does not collect consumer health data for health-related purposes, and does not provide health care services or products.
7. Third-Party Sharing. Homeworks does not share consumer health data with third parties except: (a) with service providers and contractors who are bound by contractual obligations to protect such data and use it only for providing services to Homeworks (e.g., cloud storage providers); (b) as required or permitted by law; or (c) with your express consent.
8. Sale of Consumer Health Data. Homeworks does not and will not sell consumer health data. RCW 19.373.030(1) prohibits the sale of consumer health data without valid authorization that meets the requirements of RCW 19.373.020(2). Homeworks does not engage in any such sales and will not do so in the future.
9. Washington Consumer Rights: Washington residents have the right to: (a) confirm whether Homeworks is processing their consumer health data; (b) access their consumer health data; (c) request deletion of their consumer health data; (d) withdraw consent to the collection or sharing of their consumer health data; and (e) appeal any denial of these rights. To exercise these rights, please follow the procedures described in Section 11 of this Policy. We will respond to verified requests within 45 days as required by RCW 19.373.030(3). If we deny your request in whole or in part, we will provide you with a written explanation and information about how to appeal the decision.
10. Washington State Consumer Protection: Nothing in this Policy limits any rights you may have under the Washington Consumer Protection Act (Chapter 19.86 RCW) or other applicable Washington state laws.
    

Severability

If any provision of this Policy is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. Any invalid, illegal, or unenforceable provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable while preserving its original intent.

Last Updated: February 13, 2026

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