Privacy

Privacy policy

Your privacy and the protection of your sensitive personal information are important to us. This Privacy Policy applies to B and its affiliates (together, “Hownvestor”, “we,” “us” or “our.”). We have prepared this Privacy Policy to explain how we collect, use, store, protect, and disclose information and data when you use Hownvestor's websites and services. This Privacy Policy also explains your choices for managing information preferences, including opting out of certain uses of your personal information. By accessing or using Hownvestor’s site or services, you consent to the terms of this Privacy Policy. If you have questions or complaints regarding our privacy policy or practices, or if you need assistance in exercising any of your choices under this policy, please contact us. This policy applies to all prospective, current and former Hownvestor customers. Note that, in order to use our services, you must be a EU resident 18 years of age or older.

Information Provided by You

We collect personal information about you that you provide while you use www.Hownvestor.com or any associated websites, desktop or mobile applications. We collect most of this information during the registration and/or application process for tenant screening. Additional information may be gathered during your subsequent use of the site, or when we communicate with you via telephone, email or other means. Certain personal information must be supplied during the tenant screening processes in order to meet our legal obligations, verify your identity, determine eligibility for a lease, protect against fraud, and complete your transaction. The following categories of information may be collected: • Identification data • Financial datas • Localization data • Connection data (IP address, etc.) • Personal characteristics • Physical data • Life habits • Composition of household and family • Hobbies and interests • Affiliations and affiliations • Judicial data • Consumption habits • Data relating to studies and training • Data relating to employment and function • National registry number and social security identification number • Racial or ethnic data • Data on sex life or sexual orientation • Political Views • Religious or philosophical beliefs • Photos / Shots • Recordings / Sound recording • Your employment and income information; • Your bank account and security account information; • Login credentials used to access our site; • Any personal information you provide us In addition, we gather names and email addresses of people who contact us with questions. We collect this information only for the purpose of responding to inquiries. If you use our “refer-a-friend” feature, we will collect information from you in order to process your referral request.

Information Collected From Third Parties

When you check your status for a lease arrangement through Hownvestor, we will collect information from credit intermediaries and other partners to determine your eligibility and assess risks related to your lease application. We collect information from credit intermediaries in order to assess risks associated with your lease application or to provide you with marketing offers. If another company refers you to Hownvestor or assists you in any way in the lease application process, we may collect your information from that company in order to process your application. We also collect bank account information to determine your eligibility and assess risks related to your lease application or to provide you with marketing offers. To authenticate bank accounts, we've integrated a financial technology ("fintech") company that builds connections with thousands of financial institutions. When you enter your online banking credentials, it establishes an encrypted connection with your bank. This token enables us to get the data we need to provide our service without direct access to your bank account or credentials. Please review the end user privacy policy located here. The following categories of information are generally collected: • Your identifying and application information (for example, your name, address, email, telephone number, date of birth, social security number, and employment information); • Your credit score & history; • Your bank account and security account information and up to 24 months of transactions and balances; • Your mortgage information; • Your public LinkedIn profile for your employment and education history; • Public records, including bankruptcy, judgments, liens and payment statuses; • Information from any of your secured creditors about outstanding debts and related collateral.

Information Gathered Based on Your Activity on the Hownvestor Platform

In order to provide services to you, improve our business and maintain records required by law, Hownvestor collects information about your transactions and activity. For tenants, this includes your payment history. For all members, Hownvestor collects information about your computer and your visits to www.Hownvestor.com and any other Hownvestor websites, such as your IP address, geographical location, browser type, referral source, length of visit, button clicks and page views.

Tracking Technologies

Cookies and Web Beacons. Hownvestor and our marketing partners and service providers use technologies such as cookies, beacons, tags, embedded links and scripts, to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis. We use cookies when you sign in to your account to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our site. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of our websites may be limited. Usage Data & Site Activity. Hownvestor also uses local storage to store content information and preferences. Various browsers may offer their own management tools for removing content persisted in the browser’s local storage.

No Unlawful or Prohibited Use/Intellectual Property

You are granted a non-exclusive, non-transferable, revocable license to access and use the Services strictly in accordance with these terms of use. As a condition of your use of the Services, you warrant to Hownvestor that you will not use the Services for any purpose that is unlawful or prohibited by these Terms. You may not use the Services in any manner which could damage, disable, overburden, or impair the Site or other Services, or interfere with any other party's use and enjoyment of the Site or other Services. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available or provided for through the Site or other Services. All content included as part of the Site or other Services, such as text, graphics, logos, images, as well as the compilation thereof, and any software used on the Site or other Services, is the property of Hownvestor or its suppliers and protected by copyright and other laws that protect intellectual property and proprietary rights. You agree to observe and abide by all copyright and other proprietary notices, legends or other restrictions contained in any such content and will not make any changes thereto. You will not modify, publish, transmit, reverse engineer, participate in the transfer or sale, create derivative works, or in any way exploit any of the content, in whole or in part, found on the Site. Hownvestor content is not for resale. Your use of the Site or other Services does not entitle you to make any unauthorized use of any protected content, and in particular you will not delete or alter any proprietary rights or attribution notices in any content. You will use protected content solely for your personal use, and will make no other use of the content without the express written permission of Hownvestor and the copyright owner. You agree that you do not acquire any ownership rights in any protected content. We do not grant you any licenses, express or implied, to the intellectual property of Hownvestor or our licensors except as expressly authorized by these Terms.

Do-Not-Track Signals

Hownvestor does not process or respond to “do not track” signals or other similar signals whereby a visitor to a website requests that it disable collection of information about the visitor’s online activities over time and across different websites.

International Users

The Services are controlled, operated and administered by Hownvestor from our offices within Belgium. If you access the Services from a location outside Belgium, you are responsible for compliance with all local laws. You agree that you will not use the Hownvestor content accessed through the Services in any country or in any manner prohibited by any applicable laws, restrictions or regulations.

How We Use Your Information

Processing Your Transaction If you register as a user/tenant applicant, Hownvestor will use your information to facilitate your lease application request. This may include: • Generating your tenant profile and processing your lease application; • Enabling automatic payments and fund transfers with other financial institutions; • Implementing collection activities as needed; • Implementing eviction activities as needed; • Reviewing your payment history; • Communicating with you concerning your account and transactions; • Addressing any disputes or inquiries you may raise concerning your account We will use your information to run our everyday business and in accordance with applicable law. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, such as recordkeeping, tax reporting requirements, fraud prevention, audit and data integrity.

Maintenance of Your Transaction

When you register on our site you will receive emails that confirm specific actions you requested. These notifications are typically sent to notify you of a change in status, or for legal or security purposes. For example, you will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and the successful submission of tenant lease requests; you will receive notifications regarding certain changes to legal agreements and required tenant and privacy disclosures; and you will receive progress updates on the status of lease requests. These transactional notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. We may also send you responses to emails you send us, if appropriate or applicable. Generally you may not opt out of these service-related emails.

Data Analysis & Optimization

Hownvestor also uses your information to conduct analyses related to our services and our website. We use this information to improve our services and tenant screening model. We also use this information to improve our websites’ usability and to evaluate the success of particular marketing campaigns and other activities.

Optional Communications: Marketing & Surveys

Hownvestor may also use your personal information to select you for certain marketing offers, newsletters, surveys and/or requests for feedback regarding your experience. Hownvestor may use your personal information both to select you for an offer and to communicate that offer to you. Receipt of these communications via email is voluntary. If you do not wish to receive these communications, please reply to sender asking to unsubscribe.

How We Share Your Information

We will share your personal information with nonaffiliates (companies not related by common ownership or control) and among affiliates (companies related by common ownership or control, including but not limited to the three companies covered by this policy) only in the ways that are described in this privacy policy. By law, you are permitted to limit some types of sharing, but not others. Hownvestor shares your information with third parties as permitted by law, including in the following specific ways: • Third Party Service Providers. Hownvestor relies on third party service providers to help us conduct our business and marketing activities, such as maintaining our files and records, offering customer service, sending marketing communications, or facilitating fund transfers. Hownvestor may share your information with such companies, which are authorized to use your personal information only as necessary to provide these services to Hownvestor. Information may also be shared among affiliates for this purpose where one affiliated company provides services to or on behalf of another affiliated company in connection with your account. • Referral Partners. If you were referred to Hownvestor by another company (a “Referral Partner”), Hownvestor will share your information as necessary to honor the terms of its agreement with that Referral Partner and to process your transaction. In some cases, Hownvestor may share with a Referral Partner for that Referral Partner’s own business purposes, such as to analyze and improve its business and provide targeted marketing offers to you. Your rights with respect to this sharing are discussed in the following section. • Affiliates. Hownvestor affiliates, including entities covered by this policy and other companies related by common ownership or control may share your information with each other, including information related to your tenant screening application, for purposes of general business analysis or to present targeted marketing offers to you or others. Your rights with respect to this sharing are discussed in the following section. • Legal Requests & Regulatory Requirements. Hownvestor may also share information with law enforcement or other governmental agencies or officials to comply with any applicable law, regulation, court order, judicial proceeding, legal process or governmental request; or to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability; or in connection with an audit. We may also share or transfer your information to a successor in interest to Hownvestor, which may include, but may not be limited to, a third party in the event of an acquisition, sale, merger or bankruptcy involving Hownvestor. • Sharing of Anonymized Data. Hownvestor may share aggregated and anonymized data sets including your information with third parties, including but not limited to business partners, service providers, and among Hownvestor affiliates. No personally identifiable information will be included in these data sets.

Important Privacy Choices

Consent to information sharing with third party companies (Referral Partners): By accepting this privacy policy, you agree that Hownvestor may immediately begin sharing your information with any third party company that referred you to Hownvestor so that that company may use your information for their own business purposes, including to market to you. For example, if you were referred to Hownvestor by another company through a website link or telephone transfer, Hownvestor may share some of your information, such as the existence and terms of your lease, with that company. You may revoke this consent at any time by following the procedures outlined below. If you revoke consent we will not subsequently share your information with these companies except as necessary to complete the transaction you initiated. Right to restrict information sharing with companies we own or control (affiliates): Hownvestor may share your information among affiliated companies whether or not those companies are covered by this policy. Federal law gives you the right to limit this sharing in certain circumstances, including where it includes information about your tenant eligibility or is used for the purpose of marketing to you. If you would like to opt-out of this type of sharing, please follow the instructions below. We may begin sharing your information related to your tenant eligibility or any information to be used for marketing purposes 30 days from the date that we first provided this notice if you have not opted-out. In order to revoke your consent for information sharing with Referral Partners and/or opt-out of Hownvestor affiliate information sharing, please email us.

Additional Facts About Your Personal Information

How you can change your personal information You can access the personal information you have provided to us by logging in to the [“Settings”] page of your account. As a registered user, you can update your password, email, secret question(s), screen name, phone number or bank account information at any time. If you are registered as a tenant, you may update your mailing address at any time after your tenant profile has originated. To change other information, contact us. We will respond to your request within a reasonable time. We will retain your information as needed to provide you services, comply with our legal obligations, resolve disputes, conduct analysis, audits, or to enforce our agreements or as otherwise required by law. How We Secure Your Information Hownvestor uses significant safeguards, including physical, technical, and operational controls to protect your personal information, both during transmission and once received. Despite these efforts, no security measures, however thorough, are perfect. Accordingly, we do not guarantee the security of the information you provide to us. If you have any questions about the security of your information, you can contact us. Hownvestor equips all servers with an Extended Validation (EV) Secure Socket Layer (SSL) certificate to ensure that when you connect to our websites you can tell that you are actually on our site and that all data entered into the websites are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected. Data security is achieved through technical safeguards that include a combination of a firewall, intrusion detection system, malware detection system, and data loss prevention system. Hownvestor also conducts vulnerability scans of applications and systems regularly. Access to the system is controlled and limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and internal information use policy ensure that only trained and trusted staff are permitted to access personal information. Session time-outs We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended. Protection of Account Numbers When we contact you about your account to confirm a funds transfer, we only reference an access token via the integration. This gives us access to a truncated set of digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Passwords At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. You should always choose a password that is difficult for others to guess and change your password frequently.

Additional Steps You Should Take to Ensure the Security of Your Information

Hownvestor sends important communications regarding your account via email. You should therefore take steps to secure and restrict access to your email account, change your email account password frequently and use strong passwords. You should also be aware of fraudulent emails known as “phishing,” from companies claiming to be Hownvestor and requesting your login information or other account information. Hownvestor will never ask for your login information in an email. When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files. This step is particularly important if you use a computer that is accessed by other people, such as in a public library or Internet cafe. You should install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. You may not include any identifying information in your Hownvestor screen name. We are not responsible for any personal information that you may choose to reveal in your screenname.

Change to this policy

Any updates to the privacy policy become effective when posted on our website. If we make any material changes, we will notify you by email or by providing the revised privacy policy in your account on www.Hownvestor.com. Your continued use of our services or website following the update means that you accept Hownvestor’s updated privacy policy. For additional information, or if you have any questions regarding this policy or the privacy practices at Hownvestor, please submit your questions or comments directly to info@Hownvestor.com This Privacy Policy may not discuss all of your privacy rights, as such rights vary depending on state law. Consult with local agencies for more information. You can also send questions or comments to: info@Hownvestor.com