Privacy Policy

Effective Date: May 11, 2026

This Privacy Policy describes how HousingIntellect, a product of Altus Compliance LLC, a Georgia limited liability company (collectively, "HousingIntellect," "we," "us," or "our"), collects, uses, discloses, and protects information in connection with the website located at housingintellect.io, the platform located at app.housingintellect.io, and any related services (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you submit through the Services, including:

• Identity and contact information (name, email address, telephone number)
• Professional information (company, job title, role)
• Portfolio details (unit counts, programs managed, geographic markets)
• Communications you send to us
• Information you provide when requesting a demonstration, requesting pricing, or subscribing to communications
• Account credentials if you register for the platform

1.2 Information Collected Automatically

When you interact with the Services, we automatically collect certain technical information:

• IP address and approximate geographic location derived from IP address
• Device identifiers, operating system, browser type and version
• Referring and exit URLs, pages and content accessed, timestamps
• Usage patterns and interactions with the Services
• Information collected through cookies and similar technologies (see Section 8)

1.3 Customer Data

If your organization is a customer of HousingIntellect, you may upload or transmit data to the platform on behalf of your organization, including but not limited to tenant compliance records, household information, income and asset documentation, certification records, and program-specific compliance data (collectively, "Customer Data"). HousingIntellect processes Customer Data solely on behalf of the customer organization as set forth in the applicable Master Services Agreement and Data Processing Agreement. This Privacy Policy does not govern Customer Data; the customer organization controls Customer Data and is responsible for its lawful collection and use.

1.4 Information from Third Parties

We may receive information about you from third-party sources, including business partners, marketing platforms, and publicly available sources, where permitted by applicable law.

2. How We Use Information

We process personal information for the following purposes:

2.1 To Provide and Operate the Services

• Authenticating users and managing accounts
• Delivering the features and functionality you request
• Providing customer support and responding to inquiries
• Communicating about service updates, changes, and security

2.2 To Improve and Develop the Services

• Analyzing usage patterns and performance
• Developing new features and products
• Conducting research and analytics
• Maintaining and improving security

2.3 To Communicate with You

• Sending administrative, technical, and security-related communications
• Sending marketing communications where permitted by law (you may opt out at any time)
• Responding to your requests and inquiries

2.4 To Protect Legal Rights and Comply with Law

• Detecting, preventing, and addressing fraud, security incidents, or violations of our Terms of Service
• Complying with legal obligations, court orders, and regulatory requirements
• Establishing, exercising, or defending legal claims

2.5 With Your Consent

For purposes not described above, we will obtain your consent before processing.

3. Legal Bases for Processing (EEA and UK Residents)

If you are in the European Economic Area, United Kingdom, or other jurisdictions requiring identification of a legal basis, we process personal information based on:

• Performance of a contract to which you are party
• Compliance with legal obligations
• Our legitimate business interests, where not overridden by your rights
• Your consent, where required

4. Disclosure of Information

We do not sell personal information. We disclose personal information only as follows:

4.1 Service Providers

We engage third-party service providers to perform functions on our behalf, including cloud hosting, analytics, email delivery, customer relationship management, payment processing, and security monitoring. Service providers access personal information only as necessary to perform their functions and are bound by confidentiality and data protection obligations.

4.2 Affiliates

We may share personal information with Altus Compliance LLC and its affiliates for the purposes described in this Privacy Policy.

4.3 Legal and Regulatory Disclosures

We may disclose personal information when required by applicable law, in response to lawful requests from public authorities, to comply with legal process, or to protect the rights, property, or safety of HousingIntellect, our customers, or others.

4.4 Business Transactions

In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, personal information may be transferred as part of the transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.

4.5 With Your Consent

We may disclose personal information for other purposes with your consent.

5. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit and at rest, role-based access controls, network security measures, and regular security assessments.

Despite these measures, no method of transmission or storage is completely secure. We cannot guarantee absolute security of personal information.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including for the duration of any account or customer relationship, plus any additional period required by applicable law, regulation, or our legitimate business interests including dispute resolution and enforcement of agreements.

Customer Data is retained pursuant to the terms of the applicable Master Services Agreement.

7. Your Privacy Rights

Subject to applicable law and any applicable exceptions, you may have the following rights regarding personal information we hold about you:

• Right to access and obtain a copy of your personal information
• Right to correct inaccurate or incomplete personal information
• Right to request deletion of personal information
• Right to object to or restrict certain processing
• Right to data portability
• Right to withdraw consent where processing is based on consent
• Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at info@housingintellect.io. We will respond within the time period required by applicable law. We may verify your identity before fulfilling your request.

7.1 California Residents

Under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), California residents have the right to:

• Know what categories of personal information we collect, the sources of that information, the purposes for collection, and the third parties with whom we share it
• Request deletion of personal information, subject to exceptions
• Correct inaccurate personal information
• Opt out of the sale or sharing of personal information (we do not sell or share personal information as defined under California law)
• Limit use of sensitive personal information
• Non-discrimination for exercising privacy rights

To submit a request, contact info@housingintellect.io. You may also designate an authorized agent to act on your behalf.

7.2 Other State Privacy Laws

Residents of states with comprehensive consumer privacy laws (including but not limited to Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) may have similar rights. Contact info@housingintellect.io to exercise applicable rights.

8. Cookies and Tracking Technologies

We use cookies and similar technologies as described in our Cookie Policy. You may manage cookie preferences through your browser settings or our cookie consent interface.

9. International Data Transfers

HousingIntellect is based in the United States. If you access the Services from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Services, you consent to such transfer. Where required by applicable law, we implement appropriate safeguards for international transfers.

10. Children's Privacy

The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without verified parental consent, we will delete that information.

11. Third-Party Links and Services

The Services may contain links to third-party websites and services that we do not operate. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third party before providing personal information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting the updated Privacy Policy with a revised Effective Date or by other reasonable means. Your continued use of the Services after the updated Privacy Policy takes effect constitutes your acceptance of the changes.

13. Federal Housing Program Data

13.1 HUD-Regulated Data

The HousingIntellect platform may process data related to federally regulated affordable housing programs, including but not limited to data subject to:

• The Privacy Act of 1974 (5 U.S.C. § 552a)
• HUD Handbook 4350.3 confidentiality requirements
• HUD Tenant Rental Assistance Certification System (TRACS) data handling rules
• HUD Enterprise Income Verification (EIV) system restrictions and confidentiality requirements
• Section 8, Section 202, Section 811, RAD, and PBRA tenant data confidentiality requirements
• Low-Income Housing Tax Credit (LIHTC) tenant file confidentiality under Internal Revenue Code Section 42 and applicable state housing finance agency requirements

13.2 Customer Responsibility for Regulated Data

When customers upload tenant files, certifications, household information, or other federally regulated data to the platform, the customer organization remains the responsible party for compliance with applicable federal and state housing program privacy requirements. HousingIntellect processes this data as a service provider under the direction of the customer pursuant to the applicable Master Services Agreement and Data Processing Agreement.

13.3 EIV Data Restrictions

Customers acknowledge that EIV data is subject to specific federal restrictions on use, disclosure, and storage. Customers are responsible for ensuring their use of the platform complies with EIV data handling requirements. HousingIntellect does not retrieve, process, or store EIV data directly from HUD systems; any EIV-related information present in the platform is uploaded by the customer and remains the customer's responsibility under applicable HUD rules.

13.4 Reporting Obligations

Customers acknowledge that federal housing program participation may require reporting to HUD, state housing finance agencies, and other regulatory bodies. The platform may generate reports to facilitate such reporting, but customers retain sole responsibility for accuracy of submitted reports and compliance with applicable reporting obligations.

13.5 Health-Related Information and HIPAA

The HousingIntellect platform is designed for affordable housing compliance, not for the storage or processing of protected health information ("PHI") as defined under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Customers should not upload PHI to the platform unless a specific Business Associate Agreement ("BAA") has been executed between HousingIntellect and the customer's organization.

For Section 811 properties, Permanent Supportive Housing, senior housing partnerships with healthcare providers, or other contexts where health-related information may be present in tenant files, customers must:

• (a) Notify HousingIntellect prior to uploading any data that may constitute PHI;
• (b) Execute a Business Associate Agreement if PHI will be processed through the platform;
• (c) Limit health-related information in tenant files to the minimum necessary for affordable housing program compliance.

In the absence of an executed BAA, customers represent and warrant that data uploaded to the platform does not constitute PHI under HIPAA.

13.6 Fair Housing Act Compliance

The HousingIntellect platform supports compliance-related workflows but is not designed to make tenant selection, eligibility, or housing decisions on behalf of customers. Customers remain solely responsible for compliance with the Fair Housing Act, the Equal Credit Opportunity Act, applicable state fair housing laws, and any other anti-discrimination requirements.

14. Contact Us

For questions, requests, or complaints regarding this Privacy Policy or our privacy practices:

HousingIntellect™ (Patent Pending)
A product of Altus Compliance LLC
Atlanta, Georgia
Email: info@housingintellect.io