PRIVACY POLICY

This Privacy Policy for ROA Realty Solutions LLC (doing business as Propese) (“we,” “us,” or “our”), describes how and why we access, collect, store, use, and share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://www.propese.com or any website of ours that links to this Privacy Policy;
• Use Propese, a real estate software platform that provides property research, market data analysis, lead management, skip tracing, and data-driven decision-making tools for real estate investing and related business purposes; or
• Engage with us in other related ways, including any marketing or events.
• Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have questions, please contact us at support@propese.com.

1. INFORMATION WE COLLECT

1.1 Personal Information You Provide

We collect personal information that you voluntarily provide when you register for the Services, express interest in our products, participate in activities on the Services, or otherwise contact us. This may include:

• Names, phone numbers, email addresses, and mailing addresses
• Usernames and passwords
• Billing and payment information (processed and stored by our payment processors, Stripe and Klarna)
• Contact preferences and communication history
• Business or professional information, including company name, role, and real estate license information
• Any other information you choose to provide
• Sensitive Information. We process certain categories of sensitive information as necessary to provide the Services, including financial data (payment card information, which is transmitted directly to our payment processors). We do not collect racial or ethnic origin, religious beliefs, sexual orientation, or health information.
• 1.2 Information Collected Automatically

When you access the Services, we automatically collect certain information, including:

• Device and Usage Data: IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, time and date of visits, clickstream data, and search queries within the Services.
• Geolocation Data: We may collect approximate geolocation data based on your IP address. We may also collect precise geolocation data (GPS coordinates) from your mobile device if you grant permission through your device settings. You can revoke this permission at any time.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to collect information about your interactions with the Services. For more information, see Section 6 (Cookies and Tracking Technologies) below.
• 1.3 Information Collected from Third-Party Sources

We collect information from third-party sources in connection with our Services, including:

• Skip Tracing and Data Enrichment Providers: We obtain property owner contact information (names, telephone numbers, email addresses, mailing addresses) and property data from third-party data aggregators, public records databases, and data brokers. This information is made available to our users through our skip tracing features.
• Public Records: We collect property records, tax records, mortgage records, deed transfers, and other public filings from county assessors, recorders, and other government sources.
• Marketing Partners: We may receive information from marketing partners and advertising networks.
• Important: The personal information of property owners accessed through our skip tracing features is sourced from third-party data providers and public records. We are not the original source of this data, and we do not verify its accuracy. Our use and provision of this data is governed by our agreements with our data providers and applicable law.

2. HOW WE USE YOUR INFORMATION

We process your personal information for the following purposes:

• To provide and maintain the Services, including account creation and management, subscription processing, and delivery of skip tracing results, property data, and analytics.
• To process payments and transactions, including subscription billing, refund processing, and fraud prevention.
• To provide skip tracing and data enrichment services, including the aggregation, processing, and delivery of property owner contact information and property records from third-party sources.
• To communicate with you, including sending service notifications, updates, security alerts, billing reminders, and responses to your inquiries.
• To improve and personalize the Services, including analyzing usage patterns, conducting research and development, and optimizing platform functionality.
• To market and advertise our Services, including sending promotional communications (with your consent where required by law).
• To protect our Services and users, including monitoring for fraud, abuse, security threats, and violations of our Terms of Service.
• To comply with legal obligations, including responding to lawful requests, enforcing our agreements, and complying with applicable laws and regulations.

3. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information in the following situations and with the following categories of third parties:

• 3.1 Service Providers and Processors
• Payment Processors: We share payment information with Stripe, Inc. (https://stripe.com/privacy) and Klarna, Inc. (https://www.klarna.com/us/legal/) to process transactions. Your payment information is transmitted directly to these processors and is subject to their respective privacy policies.
• Skip Tracing and Data Providers: We share limited information with third-party data aggregators and providers to facilitate skip tracing, data enrichment, and property data services.
• Cloud Hosting and Infrastructure: We use third-party cloud hosting providers to store and process data in connection with the Services.
• Analytics and Performance Monitoring: We share usage data with analytics providers to help us understand how users interact with the Services and to improve performance.
• Customer Support: We may share information with third-party customer support tools to respond to your inquiries.
• Email and Communication: We share information with email service providers to send transactional and marketing communications.
• 3.2 Business Transfers
• We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• 3.3 Legal Requirements
• We may disclose your information where required to do so by law, regulation, or legal process, including in response to a subpoena, court order, or government request.
• 3.4 Protection of Rights
• We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our Terms of Service, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation in which we are involved.
• 3.5 With Your Consent
• We may share your personal information for other purposes with your specific consent.

4. THIRD-PARTY WEBSITES

The Services may contain links to third-party websites and services that are not operated by us. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policy of every site you visit.

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies (pixels, web beacons, and local storage) to collect and store information about your interactions with the Services. These technologies serve the following purposes:

• Strictly Necessary Cookies: Required for the operation of the Services, including user authentication, session management, and security.
• Performance and Analytics Cookies: Help us understand how users interact with the Services and identify areas for improvement.
• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences.
• Advertising and Targeting Cookies: Used to deliver relevant advertisements and track the effectiveness of advertising campaigns.
• You can manage your cookie preferences through your browser settings. Note that disabling cookies may affect the functionality of the Services.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements.

Specifically:

• Account Information: Retained for the duration of your active account and for a period of three (3) years following account deletion or termination, as necessary for legal compliance, dispute resolution, and enforcement of our Terms of Service.
• Transaction and Billing Records: Retained for a minimum of seven (7) years as required by tax and accounting regulations.
• Usage Data and Analytics: Retained in identifiable form for up to twenty-four (24) months, after which it is anonymized or aggregated.
• Skip Tracing Activity Logs: Records of your skip tracing queries and results are retained for two (2) years for compliance monitoring and dispute resolution purposes.
• Communications: Support tickets and correspondence are retained for two (2) years following resolution.
• When retention is no longer necessary, we will securely delete or anonymize your personal information in accordance with applicable law.

7. DATA SECURITY

We implement commercially reasonable organizational and technical security measures to protect your personal information, including encryption of data in transit (TLS/SSL), access controls, and regular security assessments. However, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, and you transmit information to us at your own risk. If we become aware of a security breach affecting your personal information, we will notify you and applicable regulatory authorities as required by law, including the Texas Identity Theft Enforcement and Protection Act (Tex. Bus. & Com. Code Ch. 521).

8. INFORMATION FROM MINORS

The Services are not intended for persons under the age of eighteen (18). We do not knowingly collect personal information from minors. If we learn that we have collected personal information from a person under eighteen (18), we will take steps to delete that information promptly. If you believe a minor has provided us with personal information, please contact us at support@propese.com.

9. YOUR PRIVACY RIGHTS

Depending on your location, you may have certain rights regarding your personal information under applicable privacy laws. These rights may include:

• Right to Know/Access: The right to request information about the categories and specific pieces of personal information we have collected about you.
• Right to Delete: The right to request deletion of your personal information, subject to certain exceptions.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: The right to opt out of the sale or sharing of your personal information for targeted advertising purposes.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
• Right to Data Portability: The right to receive your personal information in a portable format.
• To exercise any of these rights, please contact us at support@propese.com or submit a request through our website. We will verify your identity before processing your request and will respond within the timeframe required by applicable law.
• Account Information: You can review, update, or terminate your account at any time by logging into your account settings or by contacting us. Upon account termination, we will deactivate your account but may retain certain information as required by law or for legitimate business purposes.

10. DO-NOT-TRACK SIGNALS

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting. There is no uniform technology standard for recognizing and implementing DNT signals. As such, we do not currently respond to DNT browser signals. If a standard for online tracking is adopted that we must follow, we will inform you about that practice in a revised version of this Privacy Policy.

11. UNITED STATES RESIDENTS — STATE-SPECIFIC PRIVACY RIGHTS

11.1 Categories of Personal Information Collected

The following table identifies the categories of personal information we collect, as classified under applicable state privacy laws:

11.2 Disclosure of Personal Information

We have disclosed personal information to third parties for business purposes in the preceding twelve (12) months in the following categories:

• Category A (Identifiers): Shared with payment processors, analytics providers, cloud hosting providers, and skip tracing data providers
• Category B (Personal Information): Shared with payment processors
• Category D (Commercial Information): Shared with payment processors and analytics providers
• Category F (Internet/Network Activity): Shared with analytics providers
• Category G (Geolocation Data): Shared with analytics providers
• 11.3 Sale and Sharing of Personal Information
• We do not sell personal information as traditionally defined (i.e., for monetary consideration). However, certain data sharing activities, such as the use of advertising cookies or sharing data with advertising partners for cross-context behavioral advertising, may constitute “selling” or “sharing” under certain state privacy laws (e.g., CCPA/CPRA). We will honor opt-out requests as described in Section 9 of this Privacy Policy.
• 11.4 State-Specific Rights

Residents of the following states may have additional rights under their respective state privacy laws. Please contact us at support@propese.com to exercise these rights:

• California: CCPA/CPRA (Cal. Civ. Code §1798.100 et seq.) — right to know, delete, correct, opt out of sale/sharing, limit use of sensitive personal information, non-discrimination
• Texas: Texas Data Privacy and Security Act (TDPSA, Tex. Bus. & Com. Code Ch. 541) — right to access, delete, correct, opt out of sale/targeted advertising/profiling, data portability
• Colorado: Colorado Privacy Act (CPA, C.R.S. §6-1-1301 et seq.)
• Connecticut: Connecticut Data Privacy Act (CTDPA, Conn. Gen. Stat. §42-515 et seq.)
• Virginia: Virginia Consumer Data Protection Act (VCDPA, Va. Code §59.1-575 et seq.)
• Oregon: Oregon Consumer Privacy Act (OCPA)
• Montana: Montana Consumer Data Privacy Act
• Delaware: Delaware Personal Data Privacy Act
• Iowa: Iowa Consumer Data Protection Act
• Indiana: Indiana Consumer Data Protection Act
• Tennessee: Tennessee Information Protection Act
• Florida: Florida Digital Bill of Rights
• Nebraska, New Hampshire, New Jersey, Kentucky, Minnesota, Utah: Applicable state privacy laws
• If you are a resident of a state with a privacy law not listed above, please contact us and we will make reasonable efforts to accommodate your privacy rights.

12. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised “Last Updated” date at the top of this Privacy Policy. If we make material changes, we will notify you by posting the updated Privacy Policy on the Site and, where required by applicable law, by email to the address associated with your account. We encourage you to review this Privacy Policy periodically.

13. CONTACT US

If you have questions or comments about this Privacy Policy, or if you wish to exercise your privacy rights, please contact us at:

• ROA Realty Solutions LLC d/b/a Propese
• 1910 Pacific Ave Suite 2000 - 2286 Dallas, TX 75201
• United States
• Phone: (469) 838-6134
• Email: support@propese.com
• If you wish to submit a data subject access request, please email us at support@propese.com with the subject line “Privacy Rights Request.” We will verify your identity and respond within the timeframe required by applicable law (generally thirty (30) to forty-five (45) days).

14. HOW TO REVIEW, UPDATE, OR DELETE YOUR DATA

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at support@propese.com.