Otso, Corp. (“Otso” “we” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy.

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Introduction

Please note that by participating in the Program as a landlord or a tenant, visiting or using https://otso.io/ (the “Site”) or the various related services, features, functions, software, applications, websites, and networks associated with the Program (together with the Program, the Site, collectively, the “Otso Services”), you are accepting the practices described in this privacy policy. This privacy policy is incorporated by reference into the Terms of Service that govern your participation in and your access and use of the Site and the other Otso Services (the “Terms”).

This policy describes the types of information we may collect from you or that you may provide when you access or use the Site, the other Otso Services, or any of the other features, functions, services, and products, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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Scope of Policy

This policy applies to information we collect or may collect:

• In accessing and using the Site.
• When running credit and financial checks on potential tenants.
• In registering to use and to create an account.
• In accessing other Otso Services.
• In e-mail, text, and other electronic messages sent through the Site and the other Otso Services.
• When you send any content through the Site or any of the other Otso Services.
• Through services provided to us or to you by third-party companies, agents, or contractors.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Otso or any third party; or
• Any third party, including through any application or content that may be accessible from the Site or any of the other Otso Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to participate or use any of the other Otso Services. By participating or accessing or using any of the Otso Services, you agree to this privacy policy. This policy may change from time to time. Your continued participation in the use of the Site and/or any of the other Otso Services, after we make changes, is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Minors Under the Age of 18

None of the Otso Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site, the Program, or the other Otso Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of the Otso Services or any of its features or register on the Site, use any of the interactive or public comment features of any of the Otso Services, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name, username you may use, or any pictures of you. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at contact@otso.io.

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Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about participants in the Program and users of the Site and the other Otso Services, including:

• Information by which you may be personally identified, such as name, telephone number, and e-mail address (“personal information”);
• Credit and financial information when running checks on potential tenants;
• We may collect credit history, income details, and account balances. We only use the information directly relevant to determining your eligibility in applications for our clients
• Payment and billing information;
• Content that you provide in connection with our platform;
• Information that you provide by registering or creating accounts to participate;
• Information that you provide by filling in forms or applications on or through the other Otso Services;
• Information that you provide in connection with support that you may need;
• When you connect financial accounts via third-party services like Plaid, we ensure that only the required financial data is accessed. Any additional data outside the underwriting process will not be collected or stored.
• Information that is about you but individually does not identify you, such as IP address and date and time of visit;
• Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
• Details of transactions you carry out through the Program.

We collect this information:

• Directly from you when you provide it to us (especially as it relates to PII and always aligns with consent best practices.)
• Non-PII as you automatically as you navigate through or use the Site or the other Otso Services.
• From third parties, such as our customers, business partners, and other third parties that provide us or you with certain services.
• We implement physical, electronic, and procedural safeguards to protect your financial data in compliance with the GLBA and applicable state laws. These measures ensure your data’s security during collection, storage, and processing.

Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and, in some cases, record such calls for staff training or quality assurance purposes.

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Landlords and/or Designated Persons can upload and share lease agreements, financial reports, electronic documents, and files (collectively, the “Shared Documents”) through Otso’s portal process. Any information in a Shared Document to which Otso has access will only be used in accordance with this privacy policy, the Terms, and the other agreements associated with participation.

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Use of Cookies and Other Tracking Technologies

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.

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Third-party Responsibilities and Services

We may use or partner with other third-party companies, agents, or contractors for various purposes in connection with our business and operations (“Service Providers”), including financial backing for the Program, accessing banking and other financial information, billing and payments, sending emails and texts, chatbots, support, relationship building, the marketing and growth of our business, and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Service Providers to enable them to perform these responsibilities and to provide these services. Many Service Providers have adopted their own privacy policies, which are not subject to control by Otso. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect, and disclose your information.

The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service. Also, if you click on a link to a third-party website, such third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of the Otso Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

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Google Analytics

We use “Google Analytics” to collect information about the use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve the Program, the Site, and its related features, functionality, and performance. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

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HubSpot

We utilize HubSpot for marketing automation. HubSpot sets cookies that track a user’s interaction with our Site. HubSpot also tracks browser-provided information such as inferred region, IP address, and return visits. Users remain anonymous unless the user has provided personal data through the submission of a form or clicks through to our site from a link in a HubSpot email. For more information, please see HubSpot’s Privacy Policy.

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How We Use Your Information

We use the information that we collect about you or that you provide to us, including any personal information:

• To provide you with Otso Services and the other products and services that you request from us.
• To provide the Site and the content that is on it to you.
• Running credit and financial checks.
• To process and complete transactions, including application, registration and processes for participation in the Program.
• To provide technical and other support to you.
• To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, our customers, and our select partners.

• To enable Service Providers to perform certain responsibilities and provide certain services in connection with Otso Services and our business and operations.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your application or account (s)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to the Otso Services.
• To enhance the safety and security of all of the Otso Services.
• To verify your identity and prevent fraud or other unauthorized or illegal activity.
• To enable marketing, remarketing, and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and online behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you.
• To perform targeted and other advertising on third-party websites.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.

Some of the information that we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Site and the other Otso Services, and to deliver a better and more personalized service, including enabling us to:

• Estimate our audience size and better understand usage patterns.
• Store information about your preferences, enabling us to customize the Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Site.

Data Security

Otso Corp. takes the security of your personal information seriously. We implement and maintain administrative, technical, and physical safeguards that are designed to protect your information from unauthorized access, disclosure, or destruction. Our data security practices are aligned with the requirements of the Gramm-Leach-Bliley Act (GLBA) and SOC 2 standards, ensuring that we adhere to industry-leading practices in data protection. You can learn more about both our standards and our strict compliance measures for our vendors, employees and third-parties in our Trust Portal.

• Encryption: We use encryption methods to protect sensitive information transmitted online, such as personal and financial data.
• Access Controls: Access to your personal information is restricted to those employees, agents, and contractors who need to know that information to operate, develop, or improve our services.
• Monitoring and Testing: We regularly monitor our systems for possible vulnerabilities and attacks and test our security measures to ensure they are effective.

Data Retention and Transfer

We may store any information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents, or Service Providers. If you participate or access or use the Site or any of the other Otso Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Otso and you. By allowing Otso to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

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Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To Service Providers, contractors, and other third parties that we use to support the Otso Program and the other Otso Services and our business.
• To a potential or actual buyer, assignee, or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Otso’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Otso about users of the Site is among the assets that may be or are actually transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply the Terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Otso, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
• Promotional Offers from Otso: If you do not wish to have your e-mail address/contact information used by Otso to market or otherwise promote our own or third parties’ products or services, you can opt out through the unsubscribe mechanism at the bottom of the applicable email or text message. This opt-out does not apply to information provided to Otso as a result of a service or product purchase, warranty registration, product service experience, or other transactions.
• Marketing Communications (CAN-SPAM Compliance): In accordance with the CAN-SPAM Act, all marketing communications from Otso will include a clear option to opt-out of future communications. We will promptly honor all opt-out requests.

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt-out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

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Accessing and Correcting Your Information

You may change, correct, or delete any personal information that you have provided to us by contacting us at contact@otso.io or through our chatbot.

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Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to contact@otso.io or write to us at: Otso Corp, 1790 Hughes Landing Blvd, Suite 400, The Woodlands TX 77380, USA.

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Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal information that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes. Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the Site, the Program, or any of the other Otso Services, means that you agree to be bound by such changes.

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Survival

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer participating in the Program or using the Site or any of the other Otso Services.

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