Privacy Policy

This Privacy Notice for Threshold Technology LLC (doing business as RentEngine) (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at ops@rentengine.io.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more detail using the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some information may be considered “special” or “sensitive” in certain jurisdictions, including biometric data. We process sensitive personal information only when necessary with your consent or as otherwise permitted by applicable law.

Do we collect biometric data? In connection with identity verification and fraud prevention, we may collect biometric identifiers such as a scan of facial geometry or a voiceprint. We do so only after providing written notice and obtaining written consent. We never sell biometric data and retain it only as described in our Biometric Data Retention Policy.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of third parties, subject to the restrictions in this notice — including that biometric data is shared only with our identity-verification provider.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. HOW DO WE HANDLE BIOMETRIC DATA?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

9. HOW LONG DO WE KEEP YOUR INFORMATION?

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

11. DO WE COLLECT INFORMATION FROM MINORS?

12. WHAT ARE YOUR PRIVACY RIGHTS?

13. CONTROLS FOR DO-NOT-TRACK FEATURES

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

15. DO WE MAKE UPDATES TO THIS NOTICE?

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register on the Services, express interest in our products and Services, participate in activities on the Services, or otherwise contact us. The personal information we collect may include: names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; contact or authentication data; billing addresses; debit/credit card numbers; social security numbers; driver’s license information; income; residence history; employment history; vehicle information; date of birth; and any other information you provide voluntarily.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process certain categories of sensitive information, which may include financial data, government identifiers such as social security numbers, and biometric data. Our collection and handling of biometric data is described in Section 4 (“How Do We Handle Biometric Data?”).

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and associated security code. All payment data is handled and stored by Stripe. Their privacy notice is at http://www.stripe.com/privacy.

Social Media Login Data. We may provide you the option to register using an existing social media account. If you do, we will collect certain profile information as described in “How Do We Handle Your Social Logins?” below.

Information automatically collected

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services, including log and usage data, device data, and location data. This information is primarily needed to maintain the security and operation of our Services and for internal analytics and reporting.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services and to update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, data providers, and social media platforms. We do not obtain biometric data from third-party sources.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, including: to facilitate account creation and authentication; to deliver our Services; to respond to inquiries and provide support; to send administrative information; to fulfill and manage orders; to enable user-to-user communications; to request feedback; to send marketing communications consistent with your preferences; to protect our Services, including fraud monitoring and prevention; to verify identity; to evaluate and improve our Services; to comply with legal obligations; and to share with owners, property management companies, customers, real estate agents, showing agents, and partners so that prospective tenants can find housing.

Biometric data is processed only for the limited purpose of identity verification and fraud detection, as described in Section 4. It is not used in any tenant-screening decision, credit evaluation, or background-check scoring.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and with the categories of third parties described below.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with include: Affiliate Marketing Programs; AI Platforms; Cloud Computing Services; Communication & Collaboration Tools; Data Analytics Services; Data Storage Service Providers; Finance & Accounting Tools; Government Entities; Order Fulfillment Service Providers; Payment Processors; Performance Monitoring Tools; Product Engineering & Design Tools; Retargeting Platforms; Sales & Marketing Tools; Testing Tools; User Account Registration & Authentication Services; Website Hosting Service Providers; Ad Networks; Social Networks; Credit Bureaus; Tenant Screening Providers; Background Check Providers; and Independent Contractors and Real Estate Agents.

Biometric data exception. Notwithstanding the categories of third parties listed above, biometric information is disclosed only to our identity-verification service provider, which processes it solely on our behalf under written contract. We do not sell, lease, trade, or otherwise profit from biometric data, and we do not disclose it to advertising networks, social networks, data brokers, credit bureaus, tenant-screening providers, or background-check providers.

We may also share personal information in connection with business transfers; when we use Google Maps Platform APIs; with our affiliates (who must honor this Privacy Notice); with business partners; and with other users where you make information public through the Services.

4. HOW DO WE HANDLE BIOMETRIC DATA?

In Short: We collect biometric data only to verify identity and prevent fraud, only after notice and consent, and we never sell it.

In connection with identity verification and fraud prevention in our prescreening and rental-application services, we may collect biometric identifiers — such as a scan of facial geometry derived from a self-captured image compared against a government-issued ID, or a voiceprint. Data derived from these identifiers is also treated as biometric data.

Notice and consent. We do not collect, capture, or otherwise obtain biometric data unless we first provide written notice of the collection, the specific purpose, and the retention term, and obtain your written consent, which may be provided by electronic signature.

Purpose limitation. We use biometric data solely to verify your identity and detect fraud.

No sale. We do not sell, lease, trade, or otherwise profit from your biometric data.

Limited disclosure. We disclose biometric data only to our identity-verification service provider, which processes it solely on our behalf under written contract prohibiting any further disclosure, sale, or use. We do not otherwise disclose it except with your consent, to complete a transaction you request, or as required by law.

Retention and destruction. We retain biometric data only as long as necessary to fulfill the verification and fraud-detection purpose, and we permanently destroy it when that purpose is satisfied or within three years of your last interaction with us, whichever occurs first, in accordance with our publicly available Biometric Data Retention Policy.

Security. We protect biometric data using a reasonable standard of care within our industry, and at least as protective as that used for other confidential and sensitive information we maintain.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of information you share with third parties we link to or who advertise on our Services but are not affiliated with us.

The Services may link to third-party websites, services, or applications not affiliated with us. We do not guarantee and are not liable for any such third parties. Their data collection is not covered by this Privacy Notice; review their policies directly.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and similar technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services, for security, functionality, analytics, and advertising. To the extent these are deemed a “sale” or “sharing” under applicable US state laws, you can opt out as described in Section 14. Specific information is set out in our Cookie Notice. We may share information with Google Analytics; you can opt out at https://tools.google.com/dlpage/gaoptout.

7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (“AI Products”), provided through third-party AI service providers including Google Cloud AI, OpenAI, Anthropic, Microsoft Azure AI, Amazon Web Services (AWS) AI, NVIDIA AI, Adobe Sensei, and IBM Watson. Your input, output, and personal information may be shared with and processed by these providers to enable your use of our AI Products.

Biometric data is not shared with general-purpose AI service providers for model training or other AI purposes. Any facial-geometry or voiceprint processing occurs solely through our identity-verification provider for the limited purpose described in Section 4.

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you register or log in using a social media account, we may access certain information about you.

Where you register or log in using third-party social media account details, we receive certain profile information from your provider, which may include your name, email address, and profile picture. We use this information only as described in this Privacy Notice. We do not control other uses of your information by your social media provider.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information only as long as necessary for the purposes in this Privacy Notice, unless otherwise required by law. Biometric data is subject to a separate, shorter mandatory schedule.

We will keep your personal information only as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. Except for biometric data, no purpose in this notice will require us to keep your personal information longer than the period during which you have an account with us.

Biometric data is an exception to the general retention period above. We do not retain biometric data for the life of your account. We permanently destroy biometric data when the verification and fraud-detection purpose is satisfied or within three years of your last interaction, whichever occurs first, as set out in our Biometric Data Retention Policy.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or, if that is not possible (for example, because it is stored in backup archives), securely store and isolate it from further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission or storage technology can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18, nor knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor consenting to their use. If we learn we have collected personal information from a user under 18, we will deactivate the account and take reasonable measures to promptly delete the data. Contact ops@rentengine.io with any concerns.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your state of residence.

Withdrawing your consent. If we are relying on your consent to process your personal information, you may withdraw it at any time by contacting us. This will not affect the lawfulness of processing before withdrawal. Where you withdraw consent to biometric processing, we will cease collection and destroy existing biometric data in accordance with our Biometric Data Retention Policy.

Opting out of marketing. You can unsubscribe at any time via the unsubscribe link in our emails, by replying STOP or UNSUBSCRIBE to SMS, or by contacting us. We may still send service-related messages.

Account Information. You may review or change your account information or terminate your account by contacting us. Upon termination we will deactivate or delete your account, though we may retain some information to prevent fraud, troubleshoot, assist investigations, enforce our terms, and/or comply with legal requirements.

If you have questions about your privacy rights, email ops@rentengine.io.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. No uniform standard for recognizing DNT signals has been finalized, so we do not currently respond to them. If a standard is adopted that we must follow, we will inform you in a revised version of this Privacy Notice.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of certain states may have rights to access, correct, delete, or obtain a copy of their personal information, and to opt out of certain processing.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and details about the personal information we maintain, correct inaccuracies, obtain a copy of, or delete your personal information, and to withdraw consent. These rights may be limited by applicable law.

Categories of Personal Information We Collect

Over the past twelve (12) months we have collected the following categories of personal information: A. Identifiers; B. Personal information under the California Customer Records statute; C. Protected classification characteristics; D. Commercial information; E. Biometric information (a scan of facial geometry and/or voiceprints, collected for identity verification); F. Internet or other network activity; G. Geolocation data; H. Audio, electronic, sensory, or similar information; I. Professional or employment-related information; J. Education information; K. Inferences; and L. Sensitive personal information.

Retention of biometric information (Category E). Unlike other categories, biometric information is not retained for the life of your account. It is destroyed when the verification purpose is satisfied or within three years of last interaction, whichever occurs first. See our Biometric Data Retention Policy.

No sale or sharing of biometric information. We do not sell or share (including for targeted advertising) your biometric information. Biometric information is disclosed only to our identity-verification service provider for the limited purpose of identity verification and fraud detection.

We only collect sensitive personal information as permitted by law or with your consent. You may have the right to limit the use or disclosure of your sensitive personal information.

Your Rights

Subject to applicable law, you may have the right to: know whether we process your personal data; access your personal data; correct inaccuracies; request deletion; obtain a copy; non-discrimination for exercising your rights; and opt out of targeted advertising, sale of personal data, or certain profiling. Depending on your state, you may also have rights to obtain lists of third parties to whom we disclosed or sold data, to limit use of sensitive data, and to opt out of processing through voice or facial recognition features.

How to Exercise Your Rights

To exercise these rights, submit a data subject access request, email ops@rentengine.io, or use the contact details below. You may designate an authorized agent, subject to verification. If we decline your request, you may appeal by emailing ops@rentengine.io.

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top. If we make material changes, we may notify you by prominently posting a notice or sending a direct notification.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, email ops@rentengine.io or contact us by post at:

Threshold Technology LLC

66 W Flagler St

Suite 900 PMB 11531

Miami, FL 33130, United States

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on applicable law, you may have the right to request access to the personal information we collect, details about how we processed it, correct inaccuracies, or delete your personal information, and to withdraw consent. To request review, update, or deletion, submit a data subject access request or contact ops@rentengine.io.