Privacy Policy

1. Introduction

We take your privacy seriously. As an AI-powered property management platform, we handle sensitive data including personal information, financial records, and property details. This policy is designed to be transparent about our data practices and to comply with applicable privacy laws, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other state privacy regulations.

We do not sell your personal information. We only collect and process data as necessary to provide our property management services.

2. Our Roles & Responsibilities

In providing the Platform, Proprium processes different types of data in different capacities:

• As a business/controller: For our own operational purposes—such as account management, billing, analytics, marketing, and Platform improvements—Proprium determines the purposes and means of processing and acts as a business or controller under applicable privacy laws;
• As a service provider/processor: When property owners or managers use the Platform to manage tenant information, maintenance records, and property-specific communications, we process that data on their behalf in accordance with their instructions. In this context, the property owner or manager acts as the business/controller, and Proprium acts as a service provider or processor;
• Tenant data: Tenant information may be provided by property owners or submitted directly by tenants through the Platform. Property owners are responsible for ensuring they have a lawful basis to share tenant information with us and for complying with applicable privacy obligations to their tenants.

This Privacy Policy describes Proprium's practices when acting as a business/controller. When we act as a service provider/processor, our use of data is governed by our agreements with property owners and managers.

3. Information We Collect

3.1 Information You Provide

• Account information: Name, email address, phone number, mailing address, and login credentials;
• Property information: Property addresses, unit details, lease terms, rental rates, property photos, and property documents;
• Financial information: Bank account details for disbursements, tax identification numbers, and payment preferences;
• Tenant information: Tenant names, contact details, lease agreements, payment history, and communication records that you provide or that tenants submit through the Platform;
• Waitlist information: Name, email, number of properties, and state/location;
• Communications: Messages you send through the Platform, support requests, and feedback.

3.2 Information Collected Automatically

• Usage data: Pages visited, features used, actions taken, time spent on the Platform, and interaction patterns;
• Device information: IP address, browser type and version, operating system, device identifiers, and screen resolution;
• Log data: Access times, referring URLs, error logs, and server performance data;
• Location data: Approximate location based on IP address (we do not collect precise GPS location).

3.3 Information from Third Parties

• Payment processors: Transaction confirmations, payment status, and limited financial data;
• Contractors: Work completion status, invoices, and service records;
• Public records: Property tax records, ownership verification, and other publicly available property data;
• Analytics providers: Aggregated usage statistics and performance metrics.

4. How We Use Your Information

We use the information we collect to:

• Provide our services: Operate the Platform, manage properties, facilitate tenant communications, process rent payments, and coordinate maintenance;
• AI processing: We use your information to operate AI-powered features. We do not use your customer-specific content to train generalized models for other customers unless you explicitly opt in. We may use de-identified and aggregated data to improve our services and AI systems;
• Financial operations: Process rent collection, owner disbursements, contractor payments, and generate financial reports;
• Communication: Send you service-related notifications, account updates, and respond to your inquiries;
• Improvement: Analyze usage patterns to improve the Platform, develop new features, and enhance our AI models;
• Compliance: Monitor for regulatory compliance, enforce our Terms of Service, and comply with legal obligations;
• Security: Detect and prevent fraud, unauthorized access, and other security threats;
• Marketing: Send you information about new features, updates, and promotional offers (with your consent, where required). You can opt out at any time.

5. Lawful Bases for Processing (EEA/UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal information on the following lawful bases:

• Performance of a contract: Processing is necessary to provide the Platform services you have requested or to take steps at your request before entering into a contract;
• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving the Platform, preventing fraud, ensuring security, and conducting analytics, provided these interests are not overridden by your data protection rights;
• Legal obligation: Processing is necessary to comply with applicable legal or regulatory obligations, such as tax and financial reporting requirements;
• Consent: Where required by law, we rely on your consent for certain processing activities, such as marketing communications and non-essential cookies. You may withdraw your consent at any time.

6. AI & Automated Processing

Proprium uses artificial intelligence to provide property management services. Here's how AI interacts with your data:

6.1 What AI Processes

• Tenant messages: AI reads and responds to tenant inquiries, maintenance requests, and general communications on your behalf;
• Maintenance requests: AI analyzes the nature, urgency, and severity of maintenance issues to triage and route them appropriately;
• Financial data: AI processes rent payments, tracks expenses, and generates financial summaries;
• Property data: AI uses property details and lease terms to ensure accurate and context-aware management;
• Compliance data: AI monitors relevant regulations to help flag potential compliance issues.

6.2 How AI Uses Your Data

• AI processes data in real-time to make management decisions within your configured parameters;
• We do not use your property-specific data or customer-specific content to train generalized models for other customers without your explicit consent;
• We may use de-identified and aggregated data to improve AI model accuracy, performance, and service quality;
• You can review AI actions and decisions through your dashboard at any time.

6.3 Automated Decision-Making

Our AI makes automated decisions including maintenance severity classification, contractor selection, and communication drafting. These automated decisions:

• Operate within the approval thresholds and rules you configure;
• Can be reviewed and overridden by you at any time;
• Are logged and auditable through your account dashboard;
• Do not make decisions with significant legal effects without your explicit approval (e.g., eviction proceedings).

Where required by applicable law, you may request human review of certain significant automated decisions.

7. Information Sharing & Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

7.1 Service Providers & Processors

We share information with service providers and processors who act on our behalf to help us provide the Platform, including:

7.2 Third Parties

• Contractors: We share property address, maintenance issue details, and contact information with contractors to dispatch and complete repairs. Contractors are independent third parties, not service providers acting on our behalf;
• Tenants: We share owner-approved communications and property management information with tenants as necessary to provide our services.

7.3 Legal Requirements & Protection

We may disclose your information to legal authorities, government agencies, or other third parties when required by law, court order, subpoena, or legal process, or when we believe in good faith that disclosure is necessary to:

• Comply with legal obligations;
• Protect our rights, property, or safety, or that of our users or the public;
• Detect, prevent, or address fraud, security, or technical issues;
• Enforce our Terms of Service.

7.4 Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, acquisition, sale of company assets, financing, or other business transaction. We will notify you before your data is transferred and becomes subject to a different privacy policy.

8. Third-Party Services

We use third-party services to operate the Platform. These services have their own privacy policies, and we encourage you to review them:

• Payment processing: We use third-party payment processors to handle rent collection, owner disbursements, and contractor payments. Payment card data is processed and stored by our payment processor, not by Proprium directly;
• Cloud hosting: The Platform is hosted on reputable cloud infrastructure providers with industry-standard security certifications;
• Analytics: We use analytics tools to understand how the Platform is used and to improve our services;
• Communication services: We may use third-party services for email delivery, SMS notifications, and push notifications;
• AI model providers: We may use third-party AI services to process certain data. Data shared with AI providers is subject to strict data processing agreements.

We require all third-party service providers to protect your data in accordance with applicable law and our contractual requirements.

9. Cookies & Tracking Technologies

We use cookies and similar technologies to operate the Platform, remember your preferences, and analyze usage.

9.1 Types of Cookies We Use

• Essential cookies: Required for the Platform to function (authentication, security, load balancing). These cannot be disabled;
• Functional cookies: Remember your preferences and settings (language, display preferences);
• Analytics cookies: Help us understand how you use the Platform so we can improve it;
• Marketing cookies: Used to deliver relevant advertisements and measure campaign effectiveness. These are only used with your consent.

9.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. However, blocking essential cookies may impair Platform functionality.

We may recognize browser-based privacy preference signals where required by applicable law. Because there is no universally accepted standard for Do Not Track signals, our response may vary depending on the signal and jurisdiction.

10. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this policy. We delete or de-identify account data after account closure unless retention is required for legal, tax, accounting, fraud prevention, dispute resolution, or other legitimate business purposes described in this policy.

Specific retention periods:

• Account data: Retained for the duration of your account, plus a reasonable period after account closure to allow for reactivation and to fulfill continuing obligations;
• Financial records: Retained for a minimum of 7 years after the transaction date, as required by tax and financial regulations;
• Tenant communications: Retained for the duration of the relevant lease, plus 3 years after the lease ends;
• Maintenance records: Retained for 5 years after completion for warranty and liability purposes;
• Usage and log data: Retained for up to 2 years, then anonymized or deleted;
• Waitlist data: Retained until you are onboarded or request removal.

When data is no longer needed, we securely delete or anonymize it. Anonymized data that cannot be linked back to you may be retained indefinitely for research and improvement purposes.

11. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption: Data is encrypted in transit and at rest where appropriate;
• Access controls: Strict role-based access controls limit who can access your data internally;
• Financial data isolation: Bank account numbers, routing numbers, and payment credentials are stored in PCI DSS-compliant systems and are never accessible to our AI models in raw form;
• Infrastructure security: Our cloud infrastructure is hosted in facilities with industry-standard security certifications;
• Monitoring: Continuous security monitoring, intrusion detection, and incident response procedures;
• Incident response: We maintain an incident response plan and will notify affected users of any data breach in accordance with applicable law.

While we take reasonable measures to protect your data, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.

12. Your Rights & Choices

Depending on your location, you may have some or all of the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you;
• Correction: Request that we correct inaccurate or incomplete information;
• Deletion: Request that we delete your personal information, subject to legal retention requirements;
• Portability: Request your data in a structured, machine-readable format;
• Restriction: Request that we restrict processing of your data in certain circumstances;
• Objection: Object to certain types of processing, including automated decision-making;
• Withdrawal of consent: Withdraw consent for processing where consent is the legal basis;
• Opt out of marketing: Unsubscribe from marketing communications at any time using the link in our emails or through your account settings.

12.1 How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@proprium.ai. Please include:

• Your full name and email address associated with your account;
• A clear description of the request and the right you wish to exercise;
• Any additional information we may need to verify your identity.

We will respond within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request to protect your privacy and security.

12.2 Authorized Agents

You may designate an authorized agent to make privacy requests on your behalf. The agent must provide written authorization, and we may require you to verify your identity directly with us and confirm the agent's authority.

12.3 Appeals

If we deny your privacy request, you may appeal our decision. To appeal, contact us at privacy@proprium.ai within a reasonable time after receiving our decision. We will respond to your appeal within the timeframes required by applicable law. Depending on your jurisdiction, if your appeal is denied, you may have the right to contact your local data protection authority or state attorney general.

12.4 Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

13. California Privacy Rights (CCPA/CPRA)

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

13.1 Right to Know

You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your data.

13.2 Right to Delete

You may request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, ongoing transactions, security purposes).

13.3 Right to Correct

You may request correction of inaccurate personal information.

13.4 Right to Opt Out of Sale or Sharing

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.

13.5 Right to Limit Use of Sensitive Personal Information

We only use sensitive personal information (financial data, government IDs) as necessary to provide our services. You may request that we limit our use of sensitive personal information to what is necessary.

13.6 Authorized Agents

You may designate an authorized agent to make privacy requests on your behalf. The agent must provide written authorization and we may require identity verification.

13.7 Categories of Information

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email, phone, address)
• Financial information (bank account details, payment history)
• Commercial information (property details, transaction records)
• Property-related records (leases, maintenance, tenant information)
• Internet/electronic activity (usage data, log data)
• Geolocation data (approximate, from IP address)
• Inferences drawn from the above categories

14. Other State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable law, including rights to access, correct, delete, obtain a copy of, or opt out of certain processing of personal information.

If you are a resident of Virginia, Colorado, Connecticut, Utah, or another state with comprehensive privacy legislation, you may have rights similar to those described in this Privacy Policy, including the right to:

• Confirm whether we process your personal information and access that information;
• Correct inaccuracies in your personal information;
• Delete personal information you have provided to us;
• Obtain a copy of your personal information in a portable format;
• Opt out of targeted advertising, sale of personal data, and certain profiling activities.

To exercise any available rights, contact us at privacy@proprium.ai.

14.1 Appeal Process

If we deny your privacy request, you may appeal by contacting us at privacy@proprium.ai. We will respond to your appeal within the timeframes required by applicable law. If your appeal is denied, you may have the right to contact your state's attorney general or data protection authority.

15. International Data Transfers

Proprium is based in the United States and primarily serves U.S. property owners. Your data is processed and stored in the United States.

If you access the Platform from outside the United States, your information may be transferred to and processed in the U.S., where data protection laws may differ from those in your jurisdiction.

For users in the European Economic Area (EEA), United Kingdom, or other jurisdictions with data transfer restrictions, we implement appropriate transfer mechanisms and safeguards, such as Standard Contractual Clauses or equivalent measures, where required.

16. Children's Privacy

The Platform is not intended for minors. We do not knowingly collect personal information from children under 13, and we do not permit individuals under 18 to use the Platform.

If we discover that we have collected information from a child under 13, we will delete that information promptly. If you believe a child under 13 has provided us with personal information, please contact us at privacy@proprium.ai.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes:

• We will update the "Last Updated" date at the top of this page;
• We will notify you by email or through a prominent notice on the Platform at least 30 days before the changes take effect;
• For significant changes to how we process your data, we may seek your renewed consent where required by law.

We encourage you to review this policy periodically. Your continued use of the Platform after changes take effect constitutes your acceptance of the updated policy.

18. Contact Information

If you have questions about this Privacy Policy, want to exercise your privacy rights, or have concerns about our data practices, please contact us:

Proprium
Attn: Privacy
Email: privacy@proprium.ai
General inquiries: hello@proprium.ai
Website: proprium.ai

For privacy-specific requests, please use privacy@proprium.ai so we can route your request to the appropriate team and respond within the timeframes required by law.