Privacy Policy.

Introduction

Syndeo Holdings ("we," "our," or "us") respects your privacy. This Privacy Policy describes how we collect, use, and share information when you visit our websites, use our real estate portal or billing pages, communicate with us, or access data services (including skip tracing outputs).

Information We Collect

Information You Provide

• Account and profile information (name, email, phone, role, organization).
• Payment and billing details (processed by our payment partners).
• Support requests, feedback, and communications.
• Content you upload or submit through the Services.

Information We Collect Automatically

• Log and device data (IP address, browser type, device identifiers, pages viewed, timestamps).
• Usage data about how you interact with the Services (features used, clicks, session duration).
• Diagnostic and performance data to maintain reliability and security.

Information From Third Parties

• Data partners and public sources (e.g., property records, phone/email/ownership data, skip tracing results, professional licenses) to provide or verify Service outputs.
• Service providers that support authentication, analytics, payments, communications, or compliance.

How We Use Information

• Provide, secure, and improve the Services, including analytics and troubleshooting.
• Deliver skip tracing outputs and other data services you request.
• Communicate with you about your account, updates, security alerts, and support.
• Enforce terms, detect fraud or abuse, and protect the rights and safety of users and the public.
• Comply with legal obligations and respond to lawful requests.
• With your consent or as permitted by law, send marketing or educational content (you can opt out at any time).

How We Share Information

• With service providers who help us operate the Services (e.g., hosting, analytics, communications, payment processing, data enrichment, and compliance tools).
• With professional advisors (lawyers, auditors) under confidentiality obligations.
• To comply with law, legal process, or lawful requests from authorities.
• In connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality.
• With your consent or at your direction.

We do not sell personal information for monetary consideration.

Service Providers and Sub-Processors

We engage third-party service providers ("sub-processors") to assist us in operating the Services. These providers process personal information on our behalf and are contractually required to protect it consistent with this Privacy Policy and applicable law. Categories of sub-processors we currently use include:

• Cloud Hosting & Infrastructure: Providers that host our application servers, databases, and related infrastructure process account data, usage logs, and service outputs in the course of delivering the Services.
• Payment Processing: Our payment processor handles payment card information and related transaction data for subscription billing and fraud detection. We do not store full payment card numbers.
• Email & Communications: Transactional email and notification providers process email addresses and message content to deliver account notifications, support communications, and system alerts.
• Analytics: Analytics service providers collect aggregated, anonymized usage data (page views, session duration, feature interactions) to help us understand how the Services are used and improve reliability and features. These providers do not receive directly identifying personal information beyond IP addresses (which may be anonymized or truncated).
• AI Processing: When you use AI-assisted features (such as deal analysis or property insights), relevant data may be sent to a third-party AI processing provider. That provider processes this data under a data processing agreement with us as a processor and is not permitted to use your data to train its models. See the Automated Decision-Making section for more detail.
• Property Data Providers: Third-party data providers supply property records, ownership information, AVM estimates, and related data. We retrieve this data at your direction when you conduct property searches. These providers operate under their own privacy practices; data we retrieve from them is processed under data processing agreements and used solely to fulfill your requests.
• Skip Tracing Research: We engage third-party research and data fulfillment services to obtain contact information in connection with skip tracing requests. These providers process the property addresses and owner identifiers you submit and return contact results. Their use of your submitted data is governed by data processing agreements with us.

We do not authorize our sub-processors to use or disclose personal information except as necessary to perform services for us or as required by law. Sub-processors are selected based on their ability to provide sufficient guarantees of appropriate technical and organizational data protection measures. A current list of key sub-processors is available upon request by contacting us at contact@syndeoholdings.com.

Data Processing Agreements: Enterprise customers or API users who require a formal Data Processing Agreement (DPA) — for example, in connection with GDPR, CCPA, or other applicable data protection laws — may request our standard DPA by contacting us at contact@syndeoholdings.com. The DPA governs how we process personal data on your behalf in your capacity as a data controller, and supplements this Privacy Policy.

Cookies and Tracking

We use cookies and similar technologies to keep you signed in, remember preferences, measure performance, and protect the platform. For details and your choices, please see our Cookie Policy. You can manage cookies through your browser settings; some features require essential cookies to function.

Data Security

We implement technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All connections to our Services are protected using TLS (Transport Layer Security) encryption. We do not support unencrypted HTTP connections to authenticated or data-bearing endpoints.
• Encryption at Rest: Sensitive data stored in our systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal information is restricted to employees, contractors, and service providers who need it to perform their job functions. We maintain role-based access controls and regularly review access privileges.
• Monitoring and Logging: We monitor our systems for anomalies, unauthorized access attempts, and potential security incidents. Access to sensitive data is logged for audit purposes.
• Vendor Security: We evaluate the security practices of our service providers and require them to maintain appropriate safeguards through contractual obligations.

No security measure is perfect or impenetrable. We cannot guarantee the absolute security of your information. If you suspect unauthorized access to your account or our systems, contact us immediately at contact@syndeoholdings.com.

Data Retention

We retain information for as long as necessary to deliver the Services, comply with legal obligations, resolve disputes, and enforce agreements. As a general guide:

• Account information: Retained for the duration of your account plus up to 3 years after closure for legal and compliance purposes.
• Transaction and billing records: Retained for at least 7 years for tax, accounting, and dispute resolution purposes.
• Skip tracing and property search logs: Retained for the duration of your account plus up to 2 years for compliance and dispute resolution.
• Support and communications records: Retained for up to 3 years.
• Server logs and diagnostic data: Generally retained for up to 12 months.

Retention may be extended where required by applicable law, ongoing legal proceedings, or legitimate business need.

Your Choices and Rights

• Access, correct, or delete certain account information by contacting us.
• Opt out of marketing emails by using unsubscribe links or contacting us.
• Manage cookies via browser settings and the options described in our Cookie Policy.
• Request a portable copy of personal information you have provided to us by contacting us at the address below. We will provide data in a commonly used, machine-readable format where technically feasible.
• Request that we honor applicable privacy rights under your local laws; we will respond in accordance with legal requirements.

You are responsible for honoring opt-out requests and legal requirements when you use data obtained through the Services.

FCRA Notice

Syndeo Holdings is NOT a consumer reporting agency as defined by the Fair Credit Reporting Act (FCRA). Data outputs from the Services — including skip tracing results, contact information, and property records — are not consumer reports and may not be used for employment screening, credit determinations, insurance underwriting, tenant screening, or any other FCRA-regulated purpose. See the full FCRA Notice and Disclaimer in our Terms of Service.

California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) grant you additional rights:

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for collection and use, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we hold about you, subject to certain exceptions (e.g., information needed to complete a transaction, comply with law, or detect security incidents).
• Right to Correct: You may request correction of inaccurate personal information we hold about you.
• Right to Opt Out of Sale or Sharing: We do not sell personal information for monetary consideration, and we do not share personal information for cross-context behavioral advertising. No opt-out is currently required; if this changes, we will update this Policy and provide a "Do Not Sell or Share" link.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information for purposes beyond what is necessary to provide the Services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA/CPRA rights.

To submit a verifiable consumer request, contact us at contact@syndeoholdings.com. We will verify your identity and respond within 45 days as required by law (extendable by an additional 45 days with notice). You may designate an authorized agent to make requests on your behalf; we may require proof of the agent’s authority.

Shine the Light: California Civil Code § 1798.83 permits California residents to request information about personal information disclosed to third parties for direct marketing. We do not share personal information with third parties for their direct marketing purposes.

Texas Residents (TDPSA)

The Texas Data Privacy and Security Act (TDPSA), effective July 1, 2024, grants Texas residents additional rights with respect to their personal data. If you are a Texas resident, you have the following rights subject to certain exceptions and conditions:

• Right to Know / Access: You may request to confirm whether we are processing personal data about you and to access that data.
• Right to Correct: You may request correction of inaccurate personal data we hold about you, taking into account the nature of the data and the purposes for which it is processed.
• Right to Delete: You may request deletion of personal data you have provided to us or that we have obtained about you, subject to legal exceptions.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a portable, readily usable format.
• Right to Opt Out of Targeted Advertising: We do not currently engage in targeted advertising as defined by the TDPSA. If this changes, we will update this Policy and provide an opt-out mechanism.
• Right to Opt Out of Sale of Personal Data: We do not sell personal data for monetary consideration. If our practices change, we will update this Policy and provide a "Do Not Sell My Personal Data" link.
• Right to Opt Out of Profiling: We do not engage in profiling that produces legal or similarly significant effects on individuals. If this changes, we will update this Policy.
• Right to Non-Discrimination: We will not discriminate against you for exercising any TDPSA rights.

To submit a privacy request under the TDPSA, contact us at contact@syndeoholdings.com with the subject line "Texas Privacy Request." We will respond within 45 days. We may extend the response period by an additional 45 days where reasonably necessary with prior notice. If we decline to act on your request, we will provide reasons and instructions for submitting an appeal. If you are unsatisfied with our response to an appeal, you may contact the Texas Attorney General's office.

Sensitive Data: We do not process sensitive categories of personal data (as defined by the TDPSA, including racial or ethnic origin, religious beliefs, health data, biometric identifiers, precise geolocation, or data about minors) without your consent, except as required by law.

Automated Decision-Making and AI-Assisted Features

Some features of the Services use artificial intelligence and automated processing to assist with analysis, scoring, and recommendations. Specifically:

• AI-Assisted Analysis: We use third-party large language model services to generate deal summaries, property insights, and scoring recommendations based on data you provide or that we retrieve on your behalf. These outputs are advisory in nature and do not constitute final decisions.
• No Solely Automated Legal Decisions: We do not make solely automated decisions that produce legal or similarly significant effects on individuals without human review. AI-generated outputs are tools to assist users — not final determinations.
• Data Sent to AI Providers: When you use AI-assisted features, relevant data (such as property details, notes, and financial figures) may be sent to our AI service providers for processing. These providers process data under data processing agreements with us and are not permitted to use your data to train their models without consent. We do not send sensitive personal information about third-party individuals to AI providers without appropriate safeguards.
• Your Choices: Where technically feasible, AI-assisted features may be optional. Contact us if you have questions about which features involve automated processing.

Other U.S. State Privacy Rights

Several U.S. states have enacted privacy laws that may grant residents additional rights. If you are a resident of the states listed below, the following applies in addition to the general rights described in this Policy:

Virginia (VCDPA)

Under the Virginia Consumer Data Protection Act, Virginia residents have the right to: (1) confirm whether we process personal data about you and access that data; (2) correct inaccuracies in your personal data; (3) delete personal data you provided or we obtained about you; (4) obtain a portable copy of your data in a commonly used format; (5) opt out of targeted advertising, sale of personal data, and profiling for decisions that produce legal or similarly significant effects. We do not sell personal data, engage in targeted advertising (as defined by the VCDPA), or use profiling that produces legal or similarly significant effects. To exercise your rights, contact us at contact@syndeoholdings.com. We will respond within 45 days; if we deny your request, we will explain why and describe how to appeal. If you are unsatisfied with our appeal response, you may contact the Virginia Attorney General.

Colorado (CPA)

Under the Colorado Privacy Act, Colorado residents have rights to access, correct, delete, and obtain a portable copy of personal data we hold about them, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities as defined by the CPA. To exercise your rights, contact us at contact@syndeoholdings.com with the subject line "Colorado Privacy Request." We will respond within 45 days, extendable by an additional 45 days with notice. Unresolved appeals may be submitted to the Colorado Attorney General.

Connecticut (CTDPA)

Under the Connecticut Data Privacy Act, Connecticut residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Connecticut Privacy Request" in the subject line. We will respond within 45 days. If you are unsatisfied with our response or appeal, you may contact the Connecticut Attorney General's office.

Utah (UCPA)

Under the Utah Consumer Privacy Act, Utah residents have the right to confirm whether we process personal data about you, access that data, delete personal data you provided to us, and obtain a portable copy of data you provided. You also have the right to opt out of targeted advertising and sale of personal data. We do not engage in such activities. Contact us at contact@syndeoholdings.com with "Utah Privacy Request" in the subject line to exercise your rights.

Nevada (SB 220)

Nevada residents have the right to opt out of the sale of their personal information to third parties. We do not sell personal information as defined under Nevada law. If you are a Nevada resident and wish to submit a request or inquiry, you may contact us at contact@syndeoholdings.com with "Nevada Privacy Request" in the subject line.

Oregon (OCPA)

Under the Oregon Consumer Privacy Act (effective July 1, 2024), Oregon residents have the right to confirm whether we process personal data about them and access that data, correct inaccuracies, delete personal data provided by or obtained about them, obtain a portable copy in a commonly used format, and opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant effects. We do not engage in such activities as defined by the OCPA. To exercise your rights, contact us at contact@syndeoholdings.com with "Oregon Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with notice. If we deny your request, we will explain why and provide appeal instructions. Unresolved appeals may be submitted to the Oregon Attorney General.

Montana (MCDPA)

Under the Montana Consumer Data Privacy Act (effective October 1, 2024), Montana residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Montana Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with notice. Unresolved appeals may be submitted to the Montana Attorney General.

Delaware (DPDPA)

Under the Delaware Personal Data Privacy Act (effective January 1, 2025), Delaware residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling that produces significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Delaware Privacy Request" in the subject line. We will respond within 45 days. Unresolved appeals may be submitted to the Delaware Department of Justice.

Iowa (ICPA)

Under the Iowa Consumer Data Protection Act (effective January 1, 2025), Iowa residents have the right to confirm whether we process personal data about them, access that data, delete personal data they provided to us, obtain a portable copy, and opt out of the sale of personal data and profiling that produces significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Iowa Privacy Request" in the subject line. We will respond within 90 days.

Nebraska (NDPA)

Under the Nebraska Data Privacy Act (effective January 1, 2025), Nebraska residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Nebraska Privacy Request" in the subject line. We will respond within 45 days. Unresolved appeals may be submitted to the Nebraska Attorney General.

New Hampshire (NHPDPA)

Under the New Hampshire Privacy Act (effective January 1, 2025), New Hampshire residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "New Hampshire Privacy Request" in the subject line. We will respond within 45 days. Unresolved appeals may be submitted to the New Hampshire Attorney General.

New Jersey (NJDPA)

Under the New Jersey Data Privacy Act (effective January 15, 2025), New Jersey residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data (including sharing for valuable consideration other than monetary), and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "New Jersey Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with notice. Unresolved appeals may be submitted to the New Jersey Division of Consumer Affairs.

Tennessee (TIPA)

Under the Tennessee Information Protection Act (effective July 1, 2025), Tennessee residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Tennessee Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 60 days with notice. Unresolved appeals may be submitted to the Tennessee Attorney General.

Maryland (MODPA)

Under the Maryland Online Data Privacy Act (effective October 1, 2025), Maryland residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. The MODPA also requires that we limit collection and processing of personal data to what is reasonably necessary for the disclosed purposes. We apply data minimization principles throughout our data handling practices as described in this Privacy Policy. To exercise your rights, contact us at contact@syndeoholdings.com with "Maryland Privacy Request" in the subject line. We will respond within 60 days. Unresolved appeals may be submitted to the Maryland Attorney General.

Minnesota (MCDPA)

Under the Minnesota Consumer Data Privacy Act (effective July 31, 2025), Minnesota residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Minnesota Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with notice. Unresolved appeals may be submitted to the Minnesota Attorney General.

Indiana (ICDPA)

Under the Indiana Consumer Data Protection Act (effective January 1, 2026), Indiana residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Indiana Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with notice. Unresolved appeals may be submitted to the Indiana Attorney General.

Rhode Island (DPDPA)

Under the Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026), Rhode Island residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling with significant effects. We do not engage in such activities. To exercise your rights, contact us at contact@syndeoholdings.com with "Rhode Island Privacy Request" in the subject line. We will respond within 45 days. Unresolved appeals may be submitted to the Rhode Island Attorney General.

Kentucky (CDPA)

Under the Kentucky Consumer Data Protection Act (effective January 1, 2026), Kentucky residents have the right to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant effects. We do not engage in such activities as defined by the CDPA. To exercise your rights, contact us at contact@syndeoholdings.com with "Kentucky Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with prior notice. If we decline to act on your request, we will provide reasons and instructions for submitting an appeal. Unresolved appeals may be submitted to the Kentucky Attorney General.

Washington (WA CDPA)

Under the Washington Consumer Data Privacy Act (WA CDPA, effective July 31, 2025), Washington residents have the right to: (1) confirm whether we process personal data about you and access that data; (2) correct inaccuracies in your personal data; (3) delete personal data you provided or that we obtained about you; (4) obtain a portable copy of personal data in a commonly used, machine-readable format; and (5) opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant effects. We do not engage in such activities as defined by the WA CDPA. To exercise your rights, contact us at contact@syndeoholdings.com with "Washington Privacy Request" in the subject line. We will respond within 45 days, extendable by an additional 45 days with prior notice. If we deny your request, we will explain why and provide instructions for submitting an appeal. Unresolved appeals may be submitted to the Washington State Attorney General's office.

Florida (FDBR)

The Florida Digital Bill of Rights (FDBR, effective July 1, 2024) applies to businesses that meet certain revenue and data processing thresholds (generally, controllers with annual global revenues exceeding $1 billion that meet specified data processing thresholds). Syndeo Holdings does not currently meet those thresholds and the FDBR does not presently apply to us. If our circumstances change, we will update this Policy and provide the applicable rights and opt-out mechanisms.

Residents of other states with applicable privacy laws may also contact us to exercise any rights available under their local law. We will respond in accordance with applicable legal requirements, including providing an appeal mechanism and referring unresolved appeals to your state's Attorney General or applicable supervisory authority where required by law.

International Users

The Services are operated in the United States. If you access the Services from outside the United States, your information may be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your jurisdiction. We take appropriate measures to protect your personal information in connection with such transfers.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following legal bases as applicable: (a) contractual necessity (Article 6(1)(b) GDPR) — to perform a contract with you or take pre-contractual steps at your request; (b) legitimate interests (Article 6(1)(f) GDPR) — for fraud prevention, security, service improvement, and communications, where your fundamental rights do not override those interests; (c) legal obligation (Article 6(1)(c) GDPR) — to comply with applicable laws and regulatory requirements; and (d) consent (Article 6(1)(a) GDPR) — where we have asked for and you have provided consent for specific processing activities.

International Data Transfers: When we transfer personal data from the EEA, UK, or Switzerland to the United States or other third countries, we use appropriate safeguards to ensure an adequate level of protection. These safeguards may include: (i) Standard Contractual Clauses (SCCs) approved by the European Commission; (ii) the UK International Data Transfer Addendum (IDTA) for transfers from the UK; or (iii) other legally recognized transfer mechanisms. Where we rely on SCCs or equivalent mechanisms, copies are available upon request by contacting us at contact@syndeoholdings.com.

Under applicable law, you may have rights to access, rectify, erase, restrict, or object to processing of your personal data, and to data portability. You may also have the right to withdraw consent at any time (without affecting prior lawful processing) and the right to lodge a complaint with your local data protection supervisory authority (for EEA residents, the authority in your EU member state; for UK residents, the Information Commissioner's Office; for Swiss residents, the Federal Data Protection and Information Commissioner). Contact us at contact@syndeoholdings.com to exercise these rights.

Data Breach Notification

We maintain reasonable technical and organizational safeguards to protect personal information. In the event of a security incident that constitutes a reportable breach of personal information under applicable law, we will:

• Notify Affected Users: We will notify affected users whose personal information was involved in the breach by email to the address on their account and/or via a prominent notice on the Services, within the timeframes required by applicable law.
• Notify Regulatory Authorities: Where required by applicable law — including within 72 hours of becoming aware of a qualifying breach under the EU General Data Protection Regulation (GDPR) or UK GDPR for notifications to the relevant supervisory authority, or within applicable timeframes under U.S. state breach notification laws — we will notify the appropriate regulatory authority.
• U.S. State Laws: For users in states with mandatory breach notification laws (including Texas, California, and other states), we will comply with the applicable timeframes and content requirements for breach notification.
• Scope of Notice: Notification will describe the nature of the breach, the categories of personal information involved, the likely consequences, and the measures taken or proposed to address the breach, to the extent required by and consistent with applicable law.

Not all security incidents rise to the level of a reportable breach. We will assess each incident and take action consistent with our legal obligations and reasonable best practices.

Children’s Privacy

The Services are intended for adults aged 18 and older and are not directed to children under 18. We do not knowingly collect personal information from individuals under 18 years of age. If you believe that someone under 18 has provided us with personal information, please contact us at contact@syndeoholdings.com and we will take steps to delete that information promptly.

COPPA: We do not knowingly collect personal information from children under 13 as defined by the Children’s Online Privacy Protection Act (COPPA). California Residents (Under-16 Opt-In): We do not sell or share the personal information of consumers under 16 years of age, consistent with the California Consumer Privacy Act. Because the Services require users to be at least 18, we do not knowingly process data of individuals under 16. If we learn we have collected data from someone under 16, we will delete it and not sell or share it.

Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date reflects the latest changes. For material changes — including changes that substantially alter how we collect, use, or share your personal information, or that reduce your rights — we will provide at least 14 days' advance notice by posting a prominent notice on the Services or by sending an email to the address associated with your account before the changes take effect. For non-material changes (such as clarifications or corrections), changes are effective when posted. Your continued use of the Services after changes take effect constitutes acceptance of the updated policy. If you do not agree to material changes, you may close your account before the effective date.