DIRECT HOMES 2U INC. PRIVACY POLICY

Last Updated: April 21, 2025

This Privacy Policy explains how Direct Homes 2U Inc. ("Direct Homes 2U Inc.," "we," or "us") collects, uses, and discloses information about you. This Privacy Policy applies when you use our investor portal (the "Investor Portal"), Direct Homes 2U Inc. portal (the "Direct Homes 2U Inc. Portal"), and other online products and services that link to this Privacy Policy (collectively, our "Services"), contact our customer service team, engage with us on social media, or otherwise interact with us.

This privacy policy applies to users of the Investor Portal (an "Investor User") and users of our Direct Homes 2U Inc. Portal (an "Direct Homes 2U Inc. User"). Direct Homes 2U Inc. Users are employees or agents of companies who post content on the Direct Homes 2U Inc. Portal (an "Direct Homes 2U Inc."). Investor Users and Direct Homes 2U Inc. Users are referred to collectively and individually as "users" or "you" in this privacy policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, submit or post content through our Services, provide us with feedback on our Services, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, phone number, location information, and any other information you choose to provide.

The types of information we may collect include:

  • Basic user information: We collect information necessary to create your account and provide you the Services. For Investor Users, we collect information such as your name, email address, personal address, personal phone number, profile photo, username and password. For Direct Homes 2U Inc. Users, we may collect additional information about you such as your position within the Direct Homes 2U Inc. and your business contact information such as your business phone number and email address.
  • Communications Data: We collect information about user communications through the Services. For example, Direct Homes 2U Inc. Users and Investor Users can communicate with one another through the Services. To provide this functionality, we collect and store information regarding the chats they make and receive through our Services, including date and time of the chats and content of the communications.
  • Information You Provide to Us: We collect information that you provide to us about yourself and about others such as (a) profile information that you choose to provide to us, like preferences for Direct Homes 2U Inc. content, (b) any audio, video, or other content you upload to the service, (c) information about Direct Homes 2U's, Direct Homes 2U Inc. Users and Investors Users, (d) Direct Homes 2U Inc. reviews, (e) any feedback or suggestions you provide to us about our Services and (f) any other information you choose to provide to us.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

  • Activity Information: We collect information about your activity on our Services, such as pages you interact with, and messages you send.
  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Location Information: We may collect information about the location of your device (at the city and country level) through web analytics software.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from identity verification services, credit bureaus, advertising networks, data analytics providers, and mailing list providers.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer preferences within the Services based on your browsing behavior and activity, such as search histories within the Services.

USE OF INFORMATION

We use the information we collect to administer your account and deliver our Services connecting Direct Homes 2U's and Investor Users. We also use the information we collect to:

  • Provide, maintain, and improve our products and services;
  • Personalize and improve your experience on our Services;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by Direct Homes 2U Inc. and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Personalize the advertisements you see when you use our Services;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Direct Homes 2U Inc. and others;
  • Debug to identify and repair errors in our Services;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.
  • Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • If you are an Direct Homes 2U Inc. User, we share certain information with Investor Users with whom you interact and if you are an Investor User, we may share certain information with Direct Homes 2U Inc. Users with whom you interact;
  • We share certain personal information with other users to facilitate the function of the Services, such as name, email, phone numbers, addresses, and any user entered indications for preferred content.
  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, fraud prevention, customer service, and marketing and advertising.
  • If you submit or post content in a public area of our Services, we share this information publicly on our Services.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Direct Homes 2U Inc., our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Personal information is shared between and among Direct Homes 2U Inc. and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
  • We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We allow others to provide analytics services and serve advertisements on our behalf across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Direct Homes 2U Inc. and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Direct Homes 2U Inc. is headquartered in the United States and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by logging into your account or emailing us at support@directhomes2u.com. If you wish to delete your account, please email us at support@directhomes2u.com, but note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. We use cookies for a variety of uses, such as ensuring you don't lose information if you fill out a form halfway, or for analytics. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from Direct Homes 2U Inc. by following the instructions in those communications or adjusting your subscription settings in your account profile. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or "CCPA" (Cal. Civ. Code § 1798.100 et seq.) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

In the preceding 12 months, beginning with the launch of our Services on [DATE], we have collected the following categories of personal information: identifiers, categories of personal information described in subdivision (e) of Section 1798.80, characteristics of protected classifications under California or federal law, commercial information, internet or other electronic network activity information, geolocation data, audio, electronic, visual, thermal, olfactory, or similar information, professional or employment related information, and inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal InformationCategories of Recipients
IdentifiersCloud storage providers
Categories of personal information described in subdivision (e) of Section 1798.80Analytics providers, cloud storage providers
Characteristics of protected classifications under California or federal lawAnalytics providers, cloud storage providers
Commercial informationCloud storage providers
Internet or other electronic network activity informationAnalytics providers, cloud storage providers
Geolocation dataAnalytics providers, cloud storage providers
Audio, electronic, visual, thermal, olfactory, or similar informationAnalytics providers, Cloud storage providers
Professional or employment related informationCloud storage providers
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumerAdvertisers, Cloud storage providers

Direct Homes 2U Inc. does not sell your personal information. We do not knowingly sell personal information about consumers under the age of 16.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose (2) request deletion of your personal information, (3) opt out of any "sales" of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing at support@directhomes2u.com, or by submitting a request at Contact Us. We will verify your request by asking you to provide information related to your recent interactions with us, such as email verification, password verification, and phone verification, or verification of other submitted information/data. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
  • When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store the data we collect about you for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, support@directhomes2u.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

CONTACT US

If you have any questions about this Privacy Policy, please contact us at support@directhomes2u.com.

By providing Direct Homes 2U Inc. with your information, you agree that your information may be utilized for marketing purpose, shared or sold. You may opt out of the use of your information at any time by emailing us at support@directhomes2u.com or filling out our "Do Not Sell or Share My Information" form.