Privacy Policy

About this Privacy Policy

This Privacy Policy provides information on how Placeey Inc. collects and processes your personal data when you visit or use our website, devices, services, social media, online and applications that reference this Privacy Policy. It sets out what we do with your personal data and how we keep it secure and explains the rights that you have in relation to your personal data. This Privacy Policy explains Placeey’s processing practices. Where applicable law requires consent for a particular activity, Placeey will request that consent separately and will provide a method to withdraw it.

Placeey Inc. is committed to protecting the personal data of Users in accordance with the Data Protection and Privacy Act, Cap. 97 and the Data Protection and Privacy Regulations 2021 (the “DPPA”-Uganda).

By accessing or using Placeey Inc. or by submitting any personal data to us, you acknowledge and agree that we may collect, process, store, use, and (where necessary) disclose your personal data strictly in accordance with the DPPA and any regulations or guidelines made thereunder.

We shall process personal data only:

1. lawfully, fairly and in a transparent manner;
2. for specified, explicit and legitimate purposes and not in a manner incompatible with those purposes;
3. in a manner that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurately and, where necessary, kept up to date;
5. in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and
6. in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

You have the rights conferred on data subjects under the DPPA, including (where applicable) the right to access, rectification, erasure, restriction of processing, data portability, and to object to processing, as well as the right to lodge a complaint with the relevant supervisory authority

Agents Listing on Behalf of Property Owners

In many cases, the individual who lists a property on the Platform (an agent or broker) is not the same person as the registered property owner. Placeey's identity verification (KYC) directly identifies and verifies the agent, who is the Platform's User and who agrees to this Privacy Policy on their own behalf. The owner's name and property details are provided by the agent, not collected directly from the owner, solely for the purpose of verifying property ownership against the relevant government land registry. Agents listing on behalf of an owner are required to represent that they are authorized to list the property and that they have informed the owner that the owner's name and property information will be used for this verification purpose.

1. The Data We Collect About You

We collect, use, store, and transfer only the personal information reasonably necessary to operate the Platform, verify users and properties, process payments, communicate with Users, prevent fraud, comply with law, and improve the Platform as described below. We do not permit unrelated third parties to use personal information for their own marketing purposes.

1.1. Information You Provide

You provide us with your personal data when you register your personal details on our website. The personal data we collect includes:

Account registration: name, email address, phone number, country of residence, password.

Seller and Developer identity verification: government-issued identification (National ID or passport), passport-size photograph, physical address, business information (for developers).

Property listing information: property details, descriptions, photographs, title deed copies and topography copies, verification documents, contact information.. Where reasonably feasible, Placeey will record the verification result and promptly delete or irreversibly redact the underlying identification image once verification is complete. If retention of the image is necessary, Placeey will document the purpose, restrict access, and apply the shortest reasonably necessary retention period.

Billing information: subscription tier selection. Payment card details are processed and stored by Stripe, our payment processor. Placeey does not store, access, or process your card details directly.

Communications: messages, feedback, and support requests you send to us.

1.2. Information Collected Automatically

Device and browser information: IP address, browser type, operating system, device identifiers.

Usage data: pages visited, features used, search queries, listing interactions, time spent on the Platform.

Analytics data: collected through consent-gated analytics tools to understand Platform usage and improve our services.

1.3. Information from Third Parties

1. Payment processing data from Stripe (transaction status, subscription status — not card details).
2. Verification results from government land registries and verification partners, as part of the title-verification process.

How We Use Your Information

We use the information we collect to:

1. Operate, maintain, and improve the Platform.
2. Process account registration and identity verification.
3. Process subscription payments and billing.
4. Conduct title verification and property verification services.
5. Display property listings and seller profiles to Buyers.
6. Send notifications, including verification status updates, subscription reminders, and listing expiry alerts.
7. Detect and prevent fraud, abuse, and violations of our Terms of Service.
8. Respond to your inquiries and provide customer support.
9. Analyze Platform usage to improve features and user experience.
10. Comply with legal obligations.

3. How We Share Your Information

We do not sell your personal information to third parties. We share information only in the following circumstances:

3.1. With Other Users

1. Seller and Developer profile information (name, photo, bio, contact details, listing information) is displayed to Buyers as part of the marketplace. Buyer contact details are not displayed publicly.
2. Buyer identity is shared with a Seller only when the Buyer creates an account and requests access to the Seller's contact details.

3.2. With Service Providers

We share information with trusted third-party service providers who assist us in operating the Platform, including:

1. Stripe — for payment processing. Stripe's privacy policy governs their handling of your payment data.
2. Resend — for transactional email delivery.
3. Verification partners (Anchors) — limited property and seller information necessary to conduct title verification.
4. Hosting and infrastructure providers — for secure data storage and Platform operation.

3.3. For Legal Reasons

We may disclose your information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect the rights, property, or safety of Placeey, our Users, or the public.

3.4. Business Transfers

If Placeey is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.

4. Data Security

Placeey uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against accidental loss and unauthorized access, use, alteration, or disclosure. These safeguards include:

1. Encryption of identity documents in transit and at rest within Placeey-controlled production storage. Temporary processing, backups, and service-provider handling are subject to documented security and retention controls.
2. Role-based access controls restricting who can view sensitive information.
3. Two-factor authentication required for Seller, Developer, and Admin accounts.
4. Payment card details handled exclusively by Stripe's PCI-compliant infrastructure and never stored on Placeey servers.
5. Regular monitoring of systems for unauthorized access.

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

5. Data Retention

General account information will ordinarily be deleted or anonymized within 90 days after account closure. Identity-verification records may be retained for up to 12 months after closure where reasonably necessary for fraud prevention, dispute handling, or legal compliance. Transaction and tax records will be retained for the period required by applicable law. Placeey may retain particular records longer when subject to a legal hold, regulatory request, or unresolved dispute. Where reasonably feasible, Placeey will record the verification result and promptly delete or irreversibly redact the underlying identification image once verification is complete. If retention of the image is necessary, Placeey will document the purpose, restrict access, and apply the shortest reasonably necessary retention period.

6. International Data Transfers

Placeey Inc. is based in the United States. Placeey transfers personal information internationally only where necessary to provide the Platform and subject to applicable legal safeguards. Depending on the jurisdiction, these safeguards may include adequacy decisions, Standard Contractual Clauses, contractual protections with service providers and verification partners, transfer assessments, access controls, encryption, and data minimization. Placeey does not rely solely on continued use of the Platform as consent to recurring international transfers.

7. Your Rights

Depending on your jurisdiction, you may, in writing, exercise the following rights:

1. Access: request a copy of the personal information we hold about you.
2. Correction: request that we correct inaccurate or incomplete information.
3. Deletion: request that we delete your personal information, subject to legal retention requirements.
4. Portability: request a copy of your data in a structured, machine-readable format.
5. Objection: object to certain uses of your personal information.

To exercise any of these rights, please contact us using the information in Section 11 below. We will respond to your request within 30 days

8. Cookies and Tracking

The Platform uses cookies and similar technologies to improve user experience and collect analytics data. Analytics cookies are consent-gated — they are only activated after you provide consent. You can manage cookie preferences through your browser settings. Essential cookies (required for the Platform to function, such as authentication and session management) do not require separate consent.

9. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on the Platform with the updated effective date. Material changes will be communicated to registered Users via email or in-app notification at least 14 days before taking effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated policy.

11. Contact Information

For questions about this Privacy Policy or to exercise your data rights, please contact: privacy@placeey.com, or by mail to Placeey Inc., 160 Alewife Brook Pkwy #1487, Cambridge, MA 02138, USA.

1. Accountability

Placeey Inc. has designated a Privacy Officer responsible for the organization's compliance with Canadian privacy law. The Privacy Officer is accountable for all personal information in Placeey's possession or custody, including information transferred to third parties for processing.

Privacy Officer: Esther Namukasa
Email: privacy@placeey.com
Mailing Address: Placeey Inc., 160 Alewife Brook Pkwy #1487, Cambridge, MA 02138, USA

2. Identifying Purposes

Placeey collects personal information from Canadian users for the following purposes:

1. To create and manage user accounts, including identity verification for sellers and developers.
2. To process subscription payments and verification fee transactions through Stripe.
3. To facilitate property listing, verification, and buyer-seller connection services.
4. To communicate with users regarding their accounts, listings, verification status, and subscription renewals.
5. To detect and prevent fraud, misrepresentation, and platform abuse.
6. To improve the Platform through consent-gated analytics.
7. To comply with applicable legal obligations.

The purpose for collecting personal information will be identified at or before the time of collection. If. Placeey identifies a new purpose for using previously collected information, we will seek fresh consent before using the information for that new purpose, unless the new use is required or permitted by law.

3. Consent

Placeey obtains meaningful consent for the collection, use, and disclosure of personal information. The form of consent (express or implied) depends on the sensitivity of the information and the reasonable expectations of the individual.

Express consent is obtained for:

1. Collection and storage of government-issued identification documents (National ID, passport).
2. Sharing seller contact information with registered buyers.
3. Transferring personal information to verification partners (Anchors) in East African jurisdictions.
4. Activation of analytics cookies and tracking technologies.

Implied consent applies to information reasonably required to fulfill a transaction or service the user has requested (for example, processing a subscription payment through Stripe).

3.1 Withdrawal of Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time by contacting the Privacy Officer at privacy@placeey.com. Upon receiving your withdrawal request, Placeey will inform you of the likely consequences (for example, if you withdraw consent for identity verification, your seller account may be suspended). Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4. Limiting Collection

Placeey limits the collection of personal information to what is necessary for the identified purposes. We do not collect personal information indiscriminately and do not use deceptive or misleading practices to collect information.

5. Limiting Use, Disclosure, and Retention

Personal information is used and disclosed only for the purposes for which it was collected, except with the consent of the individual or as required by law.

Personal information is retained only as long as necessary to fulfill the identified purposes:

1. Account information: retained for the duration of the active account plus 12 months following closure.
2. Identity verification documents: encrypted at rest, retained for the duration of the active account plus 12 months following closure, then permanently deleted.
3. Transaction records: retained for 7 years to comply with tax and financial reporting obligations.
4. Analytics data: retained in anonymized form; no personal identifiers are stored beyond the active
5. session unless consent is provided.

6. Accuracy

Placeey takes reasonable steps to ensure that personal information is accurate, complete, and up to date for the purposes for which it is used. Users can update their personal information at any time through their account settings. If you believe information we hold about you is inaccurate, you may request correction by contacting the Privacy Officer.

7. Safeguards

Placeey protects personal information with security safeguards appropriate to the sensitivity of the information, including:

1. Encryption of identity documents at rest and in transit (AES-256 or equivalent).
2. Two-factor authentication required for all seller, developer, and administrator accounts.
3. Payment card details processed exclusively by Stripe's PCI DSS-compliant infrastructure. Placeey never stores, processes, or has access to card numbers.
4. Role-based access controls restricting employee and contractor access to personal information on a need-to-know basis.
5. Regular review of security practices to address emerging threats.

8. Openness

Placeey makes information about its privacy policies and practices readily available. This Privacy Policy and its addenda are published on the Platform and accessible without requiring an account or login.

Upon request, the Privacy Officer will provide:

1. The name and contact information of the Privacy Officer.
2. A description of the types of personal information held and a general account of its use.
3. A description of the types of organizations to which personal information may be disclosed.
4. A copy of this Privacy Policy and any applicable addenda.

9. Individual Access

Upon written request and verification of identity, you have the right to:

1. Know what personal information Placeey holds about you.
2. Receive a copy of that information in a commonly used electronic format.
3. Know how your information has been used and to whom it has been disclosed.
4. Request correction of any inaccurate or incomplete information.

Placeey will respond to access requests within 30 days. In limited circumstances, access may be refused where permitted by law (for example, information subject to solicitor-client privilege, or information that would reveal personal information about another individual).

10. Challenging Compliance

You have the right to challenge Placeey's compliance with Canadian privacy law by contacting the Privacy Officer. Placeey will investigate all complaints promptly and take appropriate measures to address any deficiencies.

If you are not satisfied with Placeey's response, you have the right to file a complaint with the Office of the;

Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca

11. Cross-Border Transfers

Placeey Inc. is based in the United States. Your personal information may be transferred to, stored, and processed in the United States and in the countries where our verification partners operate (currently Kenya, Uganda, Tanzania, and Rwanda).

By using the Platform, you consent to the transfer of your personal information to these jurisdictions, which may have different data protection laws than Canada. Placeey ensures that personal information transferred outside Canada receives a comparable level of protection through contractual safeguards with service providers and verification partners.

The following third-party service providers may process your personal information outside Canada:

1. Stripe (payment processing) — United States.
2. Resend (transactional email delivery) — United States.
3. Amazon Web Services (hosting and data storage) — United States / EU.
4. Verification partners (Anchors) — Kenya, Uganda, Tanzania, Rwanda.

12. Breach Notification

In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm to any individual, Placeey will:

1. Notify the affected individuals as soon as feasible.
2. Report the breach to the Office of the Privacy Commissioner of Canada.
3. Maintain a record of the breach for a minimum of 24 months.

"Significant harm" includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on a credit record, and damage to or loss of property.

13. Automated Decision-Making

Placeey does not currently use automated decision-making systems that produce legal or similarly significant effects on individuals. If automated decision-making is introduced in the future, Placeey will provide affected users with an explanation of the decision, the factors considered, and an opportunity to challenge the outcome.

14. Provincial Privacy Laws

Users located in Quebec are additionally protected by Quebec's Act respecting the protection of personal information in the private sector (Law 25), which includes requirements for privacy impact assessments, explicit consent for cross-border transfers, data portability, and disclosure of automated decision-making.

Where Law 25 imposes stricter obligations than PIPEDA, Placeey complies with Law 25. Users located in British Columbia and Alberta are additionally protected by their respective Personal Information Protection Acts (PIPA). Placeey complies with these provincial statutes where applicable.

15. Consumer Privacy Protection Act (CPPA)

Canada's federal government is expected to enact the Consumer Privacy Protection Act (CPPA) to replace PIPEDA. The CPPA will introduce stronger enforcement mechanisms, including fines of up to CAD $25 million or 5% of gross global revenue. Placeey is monitoring this legislation and will update this addendum and its privacy practices to comply with the CPPA upon enactment.

1. Controller

Placeey Inc., 160 Alewife Brook Pkwy #1487, Cambridge, MA 02138, USA, is the controller of personal data processed through the Platform for the purposes described in this addendum. Contact: privacy@placeey.com.

2. EU/UK Representative

Because Placeey offers services to individuals located in the European Economic Area and the United Kingdom, Placeey has designated the following representatives pursuant to Article 27 GDPR and Article 27 UK GDPR:

EEA Representative: [Name, address, and email]
UK Representative: [Name, address, and email]

Individuals located in the EEA or UK may contact the applicable representative regarding Placeey’s processing of their personal data or the exercise of their data-protection rights.

3. Purposes and Legal Bases for Processing

Placeey processes personal data of EEA/UK Users for the purposes set out in the “How We Use Your Information” section of the main Privacy Policy. The legal bases relied on under Article 6 GDPR are:

1. Performance of a contract: account registration, identity verification of Sellers and Developers, property listing and verification services, and processing subscription and verification-fee payments.
2. Legitimate interests: preventing fraud and misleading listings, maintaining marketplace integrity and platform security, and improving the Platform, balanced against the interests and fundamental rights of individuals.
3. Consent: activation of non-essential analytics cookies (currently consent-gated Google Analytics) and, once introduced, advertising technologies such as Meta Pixel. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
4. Legal obligation: compliance with financial recordkeeping, tax, sanctions, court-order, regulatory, and other obligations specifically applicable to Placeey. Placeey will rely on this basis for identity verification only where a particular law requires Placeey to conduct that verification. Otherwise, identity and property verification are processed as necessary to perform the services requested by the User and, where applicable, for Placeey’s legitimate interests in preventing fraud and protecting marketplace integrity.

4. Recipients of Personal Data

In addition to the recipients described in “How We Share Your Information” in the main Privacy Policy, EEA/UK Users’ personal data may be processed by the following categories of recipient:

1. Verification partners (Anchors) in Kenya, Uganda, Tanzania, and Rwanda, who receive the limited property and seller information described in Section 6.1 of the Terms of Service, for the sole purpose of registry verification.
2. Payment processing (Stripe), transactional email delivery (Resend), and hosting, database, file storage, and content-delivery infrastructure (Amazon Web Services), as described in Part D below.
3. Consent-gated website analytics (Google Analytics).
4. Once activated, advertising measurement and targeting (Meta Pixel) — not yet in use as of this addendum.

5. International Data Transfers

Placeey is based in the United States, and its hosting infrastructure (Amazon Web Services — database, file storage, and content delivery) is located in the European Union (Ireland). Personal data of EEA/UK Users is transferred to, and processed in, the United States and in the East African countries where Placeey’s verification partners (Anchors) operate. These transfers are made on the following bases:

1. Transfers to Amazon Web Services are governed by AWS’s GDPR-aligned data processing terms, which incorporate the EU Standard Contractual Clauses (SCCs).
2. Transfers to Stripe are governed by Stripe’s Data Processing Agreement, which incorporates the EU Standard Contractual Clauses via Stripe’s Data Transfers Addendum, and additionally invokes Stripe’s self-certification under the EU-U.S., Swiss-U.S., and UK Extension to the Data Privacy Framework.
3. Transfers to Resend are governed by Resend’s Data Processing Addendum, which incorporates the EU Standard Contractual Clauses for transfers out of the EEA and UK (with corresponding provision for Swiss transfers), and states that Resend separately complies with the EU-U.S. Data Privacy Framework and its UK Extension.
4. Transfers to Google (for Google Analytics) are governed by Google’s data processing terms, which incorporate the EU Standard Contractual Clauses; Google LLC has also self-certified under the EU-U.S. Data Privacy Framework.
5. Once activated, transfers to Meta for advertising measurement and targeting would be governed by Meta’s European Data Transfer Addendum, which relies on the EU Standard Contractual Clauses; Meta Platforms Ireland Limited has also self-certified under the EU-U.S. Data Privacy Framework.
6. Each Anchor that processes personal data on Placeey’s behalf must enter into written terms addressing documented instructions, confidentiality, security, permitted subprocessors, data-subject requests, breach notification, return or deletion of data, audit cooperation, and applicable international-transfer safeguards. Placeey will separately determine whether any Anchor acts as an independent controller under local law.

Where Placeey relies on Standard Contractual Clauses or another Article 46 transfer safeguard, Placeey assesses the circumstances of the transfer and implements supplementary contractual, organizational, or technical measures where reasonably necessary. Where a recipient maintains a current certification under an applicable Data Privacy Framework, Placeey may also rely on or consider that certification as an additional transfer safeguard. Placeey periodically reviews its transfer mechanisms and will update them if applicable law or an adequacy determination changes.

6. Data Retention

Personal data is retained in accordance with Section 5 (Data Retention) of the main Privacy Policy: account and identity verification data for the duration of the active account plus 12 months following closure; general account information deleted or anonymized within 90 days of account closure, subject to legal retention requirements; and transaction records retained for 7 years to comply with financial and tax obligations.

7. Your Rights Under the GDPR

Where the GDPR or UK GDPR applies to you, you have the right to:

5. Access: obtain confirmation of whether Placeey processes your personal data, and a copy of that data.
6. Rectification: request correction of inaccurate or incomplete personal data.
7. Erasure: request deletion of your personal data, subject to legal retention requirements.
8. Restriction: request that Placeey limit the processing of your personal data in certain circumstances.
9. Portability: receive personal data you have provided in a structured, commonly used, machine-readable format.
10. Objection: object to processing based on legitimate interests, including profiling, and to processing for direct marketing purposes at any time.
11. Withdraw consent: withdraw consent at any time where processing is based on consent, without affecting prior lawful processing.
12. Lodge a complaint: with the data protection supervisory authority of your habitual residence, place of work, or the place of the alleged infringement.

To exercise these rights, contact privacy@placeey.com. Placeey will respond within one month, extendable by a further two months for complex requests, as permitted by the GDPR.

8. Automated Decision-Making

Placeey does not use automated decision-making or profiling that produces legal or similarly significant effects on individuals. Property verification is performed by Anchors, who conduct a manual check against the relevant government lands registry, not by an automated system. If Placeey introduces automated risk-scoring, fraud-detection tooling, or any other automated decision-making process in the future, this section will be updated accordingly.

9. Cookies and Consent

As described in Section 8 (Cookies and Tracking) of the main Privacy Policy, non-essential cookies — including Google Analytics and, once introduced, Meta Pixel — are only activated after obtaining consent from EEA/UK Users, consistent with the GDPR and the ePrivacy Directive/UK PECR. Essential cookies required for authentication and session management do not require separate consent.

1. Applicability

Placeey is subject to the CCPA/CPRA only if it meets at least one of three statutory thresholds: (a) global annual gross revenue exceeding $26.625 million; (b) annually buying, selling, or sharing the personal information of 100,000 or more California consumers, households, or devices; or (c) deriving 50% or more of annual revenue from selling or sharing personal information. Placeey does not currently meet any of these thresholds. Threshold (b), however, is a data-volume measure rather than a revenue measure, and can be met through website analytics traffic alone as Placeey's California user base grows, independent of revenue or transaction activity. Placeey monitors this threshold on an ongoing basis. This notice is included proactively, so that California-specific privacy practices are already in place before any threshold is met.

2. Categories of Personal Information We Collect

In the twelve months preceding the effective date of this addendum, Placeey has collected, or may collect, the following categories of personal information, as defined by the CCPA, from California residents:

1. Identifiers: name, email address, phone number, physical address, government-issued numbers, and account credentials.
2. Commercial information: subscription tier, transaction and billing history, and listing activity.
3. Internet or other electronic network activity: pages visited, features used, search queries, and device/browser information, collected through consent-gated analytics and, once active, advertising technologies.
4. Geolocation and property data: property location, plot, and ownership information submitted as part of a listing.
5. Sensitive personal information: government-issued identification documents (National ID or passport) and title deed page scans submitted for identity and property verification. See Section 7 below.

3. Sources of Personal Information

Directly from you, when you register an account, list a property, or upload verification documents; automatically, through cookies and analytics technologies; and from third parties, including payment status information from Stripe and verification results from government lands registries and verification partners, as described in the main Privacy Policy.

4. How We Use Personal Information

Placeey uses personal information for the purposes described in the “How We Use Your Information” section of the main Privacy Policy, including operating the Platform, verifying identity and property listings, processing payments, communicating with you, detecting fraud, and improving the Platform through consent-gated analytics.

5. Disclosure of Personal Information

In the twelve months preceding the effective date of this addendum, Placeey has disclosed the categories of personal information described in Section 2 to the following categories of third parties, for the business purposes described in the main Privacy Policy:

1. Other Users of the Platform (Seller/Developer profile and listing information disclosed to Buyers, as described in Section 3.1 of the main Privacy Policy).
2. Service providers: Stripe (payment processing), Resend (transactional email), Amazon Web Services (hosting, database, and storage), and Google Analytics (consent-gated website analytics).
3. Verification partners (Anchors) in Kenya, Uganda, Tanzania, and Rwanda, for the limited purpose of registry verification.
4. Government lands registries, as part of the verification process you request.
5. Once activated, Meta Platforms, for advertising measurement and targeting — not yet in use as of this addendum.

6. Sale or Sharing of Personal Information

Placeey does not sell personal information for monetary consideration. Placeey does not currently share personal information for cross-context behavioral advertising, because no advertising technology is active on the Platform. Should Placeey activate Meta Pixel or any similar advertising technology in the future, that activity will constitute "sharing" personal information under the CPRA, and Placeey will implement a "Do Not Sell or Share My Personal Information" mechanism — including automatic detection and honoring of the Global Privacy Control signal — before or at the time such technology is activated.

7. Sensitive Personal Information

Government-issued identification documents and title deed page scans collected for verification purposes may constitute "sensitive personal information" under the CPRA. Placeey collects and uses this information solely to verify user identity and property ownership, and does not use it to infer characteristics about any individual. California residents have the right to limit the use of sensitive personal information to purposes necessary to provide the services they have requested. Because Placeey does not use or disclose sensitive personal information for any purpose beyond identity and property verification, Placeey does not currently offer a separate "Limit the Use of My Sensitive Personal Information" link, as no additional use requiring such a mechanism exists at this time. If Placeey's use of sensitive personal information expands beyond verification purposes, this section will be updated and the corresponding mechanism will be implemented. Placeey’s service providers and verification partners may process Sensitive Personal Information only on Placeey’s documented instructions and solely for identity verification, property verification, security, fraud prevention, or legal compliance. They may not sell, share, retain, profile, infer characteristics from, or use such information for advertising or their own independent commercial purposes.

8. Your California Privacy Rights

Subject to certain exceptions, California residents have the right to:

1. Know: what personal information Placeey has collected, used, disclosed, and (if applicable) sold or shared about you.
2. Delete: request deletion of personal information Placeey has collected from you, subject to legal retention requirements described in the main Privacy Policy.
3. Correct: request correction of inaccurate personal information.
4. Opt out: of the sale or sharing of personal information (see Section 6).
5. Limit use: of sensitive personal information (see Section 7).
6. Non-discrimination: Placeey will not discriminate against you for exercising any of these rights.

9. How to Exercise Your Rights

You may submit a request by emailing privacy@placeey.com. Placeey will verify your identity before responding and will respond within 45 days, extendable by an additional 45 days where reasonably necessary. You may designate an authorized agent to submit a request on your behalf, subject to identity and authorization verification.

10. Financial Incentives

Placeey does not currently offer any financial incentive, discount, or different level of service in exchange for the collection, sale, or retention of personal information.

11. Shine the Light

Placeey does not share personal information with third parties for those third parties’ own direct marketing purposes.

12. Contact Information

For questions about this addendum or to exercise your California privacy rights, contact privacy@placeey.com, or write to Placeey Inc., 160 Alewife Brook Pkwy #1487, Cambridge, MA 02138, USA.