Privacy Notice

The information we collect, why we use it, who we share it with, and how we protect it, along with the tools you can use to manage your privacy.

1. INTRODUCTION AND SCOPE

1.1 About This Privacy Policy

This Privacy Policy (“Policy”) describes how HomeFio Technologies Inc., a Delaware corporation (“HomeFio,” “Company,” “we,” “us,” or “our”), collects, uses, stores, shares, and protects information about individuals who access or use our website located at www.homefio.com, our mobile applications, and all related services, tools, features, and functionalities (collectively, the “Platform”).

1.2 Acceptance

By accessing or using the Platform, creating an account, or providing any personal information to HomeFio, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. This Policy is incorporated into and forms part of our Terms of Service. If you do not agree to this Policy, you must not access or use the Platform.

1.3 Scope

This Policy applies to all information collected through the Platform, including information collected online through our website and mobile applications, through email or other electronic communications, and through any other interactions with HomeFio. This Policy does not apply to information collected by third parties, including Lender Partners, even when such third parties are accessed through or linked from the Platform. Third-party services are governed by their own privacy policies.

2. DEFINITIONS

Capitalized terms used in this Policy and not defined herein have the meanings ascribed to them in our Terms of Service. Additionally:

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This includes but is not limited to name, email address, phone number, postal address, IP address, and financial profile information.

“Financial Profile Information” means information you provide through the Platform for the purpose of obtaining mortgage pre-approval offers, including self-reported income range, employment status, employment duration, credit score range, desired purchase price range, desired down payment amount, current debt obligations, and preferred loan type.

“Sensitive Financial Documents” means W-2 forms, pay stubs, bank statements, tax returns, Social Security numbers, and government-issued identification documents. As described in Section 7, HomeFio does not currently collect or store Sensitive Financial Documents, though this may change in the future subject to the notice and consent requirements in Section 7.

“Golden Data” means the standardized data format in which Lender Partners submit pre-approval information to HomeFio, including approval amount, interest rate, monthly payment estimate, closing cost estimate, and available special programs or grants.

“Transaction Data” means information generated in connection with your home purchase activities on the Platform, including Offer Intent records, assigned agent information, real estate contracts, addendums, insurance quotes, communication logs, and closing milestone records.

“Usage Data” means information automatically collected about your interactions with the Platform, including pages viewed, features used, search queries, properties viewed, click patterns, session duration, and navigation paths.

“Device Data” means technical information about the device and connection you use to access the Platform, including device type, operating system, browser type and version, unique device identifiers, IP address, and network information.

3. INFORMATION WE COLLECT

The following table summarizes the categories of information HomeFio collects, examples of each category, and whether collection is required or optional:

CategoryExamplesRequired / Optional
Account InformationFull name, email address, phone number, passwordRequired for registration
Financial ProfileIncome range, employment status, employment duration, credit score range, desired purchase price range, desired down payment amount, current debt obligations, preferred loan typeRequired for pre-approval
Pre-Approval Data (Golden Data)Approval amount, interest rate, monthly payment, closing costs, special programs (received from Lender Partners)Collected automatically from Lender Partners
Property Search DataSearch criteria, saved properties, viewed listings, affordability classifications, search historyCollected automatically during use
Transaction DataOffer Intent records, real estate contracts, addendums, insurance quotes, agent assignments, closing milestonesCollected during transactions
Communication RecordsMessages with agents, Lender Partner communications through Platform, support inquiries, notification historyCollected automatically
Usage DataPages viewed, features used, click patterns, session duration, navigation paths, referral URLsCollected automatically
Device DataDevice type, operating system, browser, IP address, unique device identifiers, network informationCollected automatically
Cookies and TrackingSession cookies, preference cookies, analytics cookies, tracking pixels (see Section 9)Collected automatically; some optional

3.1 Information We Do NOT Collect

Consistent with our current Zero-Knowledge Document Policy (see Section 7), HomeFio does not currently collect, receive, transmit, process, or store:

(a) W-2 forms or other wage and tax statements;

(b) Pay stubs or proof of income documents;

(c) Bank statements or financial account records;

(d) Federal or state tax returns;

(e) Social Security numbers;

(f) Government-issued identification documents (driver’s licenses, passports); or

(g) Full credit reports or detailed credit history.

When the Platform prompts you to provide such documents for mortgage pre-approval, you are redirected directly to the applicable Lender Partner’s secure portal. These documents never pass through HomeFio’s systems.

4. HOW WE COLLECT INFORMATION

4.1 Directly from You

We collect information that you voluntarily provide when you: (a) create an account on the Platform; (b) complete your financial profile for pre-approval purposes; (c) conduct property searches and save listings; (d) submit an Offer Intent; (e) communicate with agents, Lender Partners, or HomeFio support through the Platform; (f) respond to surveys or provide feedback; or (g) contact us directly via email, phone, or other means.

4.2 From Lender Partners

We receive pre-approval information from Lender Partners in Golden Data format after they independently evaluate your creditworthiness. This includes approval amount, interest rate, estimated monthly payment, closing cost estimates, and available special programs or grants. Lender Partners provide this information to HomeFio through secure data transmission for display on the Platform.

4.3 From MLS Data Sources

We receive property listing information from Bright MLS through authorized Internet Data Exchange (IDX) and Virtual Office Website (VOW) data feeds delivered via Repliers.io. This information relates to properties, not to individual users, and is subject to the MLS terms described in Section 8.

4.4 Automatically Through Technology

When you access or use the Platform, we automatically collect Usage Data and Device Data through cookies, web beacons, log files, and similar tracking technologies as described in Section 9.

4.5 From Service Providers

We may receive information about you from our service providers, including analytics providers, customer relationship management systems, and email service providers, in connection with the services they perform on our behalf.

5. HOW WE USE YOUR INFORMATION

HomeFio uses the information we collect for the following purposes:

5.1 Providing and Improving the Platform

(a) Creating and managing your account; (b) distributing your financial profile to Lender Partners for pre-approval evaluation; (c) displaying and comparing pre-approval offers; (d) enabling payment-based property search and displaying Traffic Light affordability indicators; (e) facilitating the Offer Intent and transaction process; (f) assigning and coordinating Lead Advisors and Showing Agents; (g) storing and managing real estate contracts and transaction documents; (h) tracking and displaying transaction milestones; and (i) improving, maintaining, and optimizing Platform performance, features, and user experience.

5.2 Communications

(a) Sending transactional notifications including pre-approval status updates, rate lock alerts, stale data warnings, tour confirmations, Offer Intent acknowledgments, and closing milestone updates; (b) sending administrative messages including security alerts, policy updates, and system notifications; (c) sending marketing communications regarding new features, platform updates, educational content, and promotional offers; and (d) responding to your inquiries, comments, or support requests.

5.3 Security and Fraud Prevention

(a) Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity; (b) protecting the security and integrity of the Platform and our systems; (c) verifying account identity and preventing unauthorized access; and (d) enforcing our Terms of Service and other policies.

5.4 Legal and Regulatory Compliance

(a) Complying with applicable laws, regulations, and legal processes including real estate licensing requirements, RESPA, and state real estate commission regulations; (b) responding to lawful requests from governmental authorities; (c) establishing, exercising, or defending legal claims; and (d) maintaining records required by real estate regulatory authorities.

5.5 Analytics and Research

(a) Analyzing usage patterns and trends to improve the Platform; (b) conducting internal research and development; (c) generating aggregated, de-identified data for business intelligence; and (d) measuring the effectiveness of marketing campaigns and features.

6. HOW WE SHARE YOUR INFORMATION

HomeFio does not sell, rent, or trade your Personal Information to third parties for their marketing purposes. We share your information only in the following circumstances:

6.1 With Lender Partners

When you use the Lender Marketplace, we share your Financial Profile Information with participating Lender Partners for the sole purpose of generating pre-approval offers. By using the Lender Marketplace, you expressly consent to this sharing. Lender Partners are contractually prohibited from using your information for any purpose other than evaluating your pre-approval application and, if selected by you, processing your mortgage loan.

6.2 With Assigned Agents

When you are assigned a Lead Advisor or Showing Agent, we share relevant account information, pre-approval status, property preferences, and transaction details necessary for them to provide you with real estate services.

6.3 With Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Service ProviderPurposeData Shared
Google Workspace (Google Drive)Secure document storage for real estate contracts and transaction documentsReal estate contracts, addendums, insurance quotes
Follow Up BossCustomer relationship management and communication trackingContact information, communication records, transaction status
Repliers.ioMLS data delivery and property search functionalityProperty search queries (no Personal Information)
Bright MLSProperty listing data source with usage trackingUsage tracking data as required by Bright MLS rules
Email Service ProviderTransactional and marketing email deliveryEmail address, name, notification preferences
Analytics ProviderPlatform usage analytics and performance monitoringAggregated Usage Data and Device Data
Hosting ProviderPlatform hosting and infrastructureAll Platform data (encrypted at rest and in transit)

All service providers are contractually obligated to use your information only for the purposes of performing services on our behalf and to maintain the confidentiality and security of your information.

6.4 For Legal Purposes

We may disclose your information if we believe in good faith that disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or enforceable governmental request; (b) enforce our Terms of Service or other agreements, including investigation of potential violations; (c) detect, prevent, or address fraud, security, or technical issues; (d) protect the rights, property, or safety of HomeFio, our users, or the public as required or permitted by law; or (e) respond to claims that any content on the Platform violates the rights of third parties.

6.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, dissolution, sale of all or substantially all of HomeFio’s assets, or similar transaction or proceeding, your information may be transferred as part of the transaction. We will provide notice of any such transfer through the Platform or by email and will require that the acquiring entity honor the terms of this Privacy Policy or provide you with notice of any changes.

6.6 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

6.7 Aggregated and De-Identified Data

We may share aggregated, de-identified, or anonymized data that cannot reasonably be used to identify you for any purpose, including industry research, marketing, analytics, and business development. This data is not considered Personal Information under this Policy.

7. ZERO-KNOWLEDGE DOCUMENT POLICY

As of the effective date of this Policy, HomeFio maintains a strict Zero-Knowledge Document Policy as a core principle of the Platform. This Section describes how this policy currently protects your most sensitive financial information. HomeFio reserves the right to modify this approach in the future as the Platform evolves, subject to the notice and consent requirements described in Section 7.7 below.

7.1 Current Practice

As of the effective date of this Policy, HomeFio’s Platform is designed so that your most sensitive financial documents do not enter HomeFio’s systems at any point in the process. Under this current architecture, there is no database, server, storage system, or transmission pathway within HomeFio’s infrastructure that receives, processes, or stores Sensitive Financial Documents. “Upload Financial Docs” buttons within the Platform redirect you directly to the applicable Lender Partner’s own secure portal.

7.2 Documents That Currently Do Not Touch HomeFio Systems

As of the effective date of this Policy, the following documents are uploaded directly to Lender Partner portals and are not transmitted to, processed by, or stored on HomeFio servers:

(a) W-2 forms and all wage and tax statements;

(b) Pay stubs and all proof of income documentation;

(c) Bank statements, investment account statements, and all financial account records;

(d) Federal and state tax returns and all related schedules;

(e) Social Security numbers and government-issued identification documents; and

(f) Any other documents required by the Lender Partner for underwriting that contain sensitive personal financial data.

7.3 What HomeFio Does Receive and Store

HomeFio receives and stores only the following information related to the lending process:

(a) Self-reported Financial Profile Information: Income range, employment status, credit score range, desired purchase price, and similar summary information you provide directly through the Platform for the purpose of receiving pre-approval offers. This is self-reported summary data, not verified financial documents.

(b) Golden Data from Lender Partners: Approval amount, interest rate, estimated monthly payment, closing cost estimates, and available programs — summary pre-approval terms provided by Lender Partners, not underlying financial documentation.

(c) Verification Status: The date when a Lender Partner last verified your income and financial information, displayed on your user profile as a verification indicator. If not re-verified within 30 days, the Platform displays a “Stale Data” warning. HomeFio does not independently verify this information.

7.4 Transaction Documents HomeFio Stores

HomeFio does store the following real estate transaction documents, which are necessary for closing coordination: (a) real estate purchase contracts and agreements of sale; (b) contract addendums, amendments, and counteroffers; (c) homeowners insurance quotes and binders; and (d) other real estate transaction documents necessary for the closing process. These documents are stored securely using Google Drive integration and are accessible only to you, your assigned agents, and authorized HomeFio personnel.

7.5 Lender Partner Responsibility

The collection, storage, security, and handling of your Sensitive Financial Documents are currently the sole responsibility of the applicable Lender Partner. Each Lender Partner operates under its own privacy policy, security practices, and regulatory obligations. HomeFio is not responsible for the privacy or security practices of any Lender Partner. We encourage you to review the privacy policy of any Lender Partner before submitting documents through their portal.

7.6 Future Changes to Data Collection Practices

As HomeFio’s Platform evolves, we may determine that collecting, processing, or storing certain categories of Sensitive Financial Documents directly on HomeFio systems is necessary or beneficial to improve the Platform’s services, streamline the user experience, or comply with regulatory requirements. Such changes may include, without limitation, direct collection of income verification documents, tax returns, bank statements, government-issued identification, Social Security numbers, or credit information.

If HomeFio begins collecting any category of Sensitive Financial Documents that it did not previously collect, we will:

(a) Update this Privacy Policy to reflect the new data collection practices, including a description of what is collected, how it is used, how it is stored, and with whom it is shared;

(b) Provide prominent notice to all existing users via email and in-app notification at least thirty (30) days before the new collection practices take effect;

(c) Implement commercially reasonable security measures appropriate to the sensitivity of the newly collected data, including encryption at rest and in transit, access controls, and regular security audits;

(d) Obtain your affirmative consent before collecting any new category of Sensitive Financial Document from you, where required by applicable law; and

(e) Clearly distinguish between data categories that are required for Platform use and those that are optional.

7.7 Your Rights Upon Changes

If HomeFio materially changes its data collection practices regarding Sensitive Financial Documents, you will have the right to: (a) review the updated Privacy Policy before the changes take effect; (b) decline to provide any newly requested Sensitive Financial Documents, understanding that certain Platform features or services that depend on such data may become unavailable to you; and (c) close your account if you do not agree to the updated practices, subject to the data retention provisions in Section 11. Your continued use of the Platform after the effective date of any such changes constitutes your acceptance of the updated data collection practices.

8. MLS DATA AND PROPERTY LISTING INFORMATION

8.1 Bright MLS Usage Tracking

In accordance with Bright MLS rules, HomeFio enables Bright MLS’s usage tracking service on the Platform. This service tracks how MLS listing data is accessed and displayed on the Platform. Usage tracking information is provided to Bright MLS as required by its licensing agreement and may include information about which listings are viewed and how listing data is displayed.

8.2 Property Search Activity

HomeFio collects and stores your property search activity, including search criteria, filters applied, properties viewed, properties saved, and affordability classifications assigned by the Traffic Light System. This information is used to personalize your search experience, provide relevant recommendations, and improve Platform functionality.

8.3 MLS Data Restrictions

Property listing data displayed on the Platform is provided by Bright MLS and is subject to copyright protection. This data is for your personal, non-commercial use only. You may not copy, redistribute, scrape, or use MLS data for any commercial purpose. Full terms regarding MLS data use are set forth in our Terms of Service.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Types of Cookies We Use

Cookie TypePurposeDuration
Essential / Strictly NecessaryRequired for Platform operation: authentication, session management, security, and load balancing. The Platform cannot function without these cookies.Session or up to 1 year
Functional / PreferenceRemember your preferences: saved searches, preferred display settings, language, and previous search criteria.Up to 1 year
Analytics / PerformanceCollect aggregated information about how the Platform is used: pages viewed, features used, errors encountered, and performance metrics. Used to improve Platform functionality.Up to 2 years
Marketing / AdvertisingUsed to deliver relevant advertisements and measure advertising campaign effectiveness. May be set by third-party advertising partners.Up to 2 years
Bright MLS MonitoringRequired usage tracking code as mandated by Bright MLS for monitoring IDX/VOW data display compliance.Per Bright MLS policy

9.2 Other Tracking Technologies

In addition to cookies, we may use: (a) web beacons (pixel tags) in emails and on the Platform to track open rates, click-through rates, and usage patterns; (b) log files that automatically record information such as IP address, browser type, referring/exit pages, and timestamps; and (c) local storage technologies to store information locally on your device for performance and functionality purposes.

9.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically set your browser to block or delete cookies, or to alert you when a cookie is being set. However, if you block or delete essential cookies, certain features of the Platform may not function properly. Instructions for managing cookies are typically available in your browser’s help or settings menu.

9.4 Do Not Track Signals

The Platform does not currently respond to “Do Not Track” (DNT) signals transmitted by web browsers. There is no universally accepted standard for how companies should respond to DNT signals. If a standard is adopted in the future, we may update this Policy to describe our response to such signals.

10. DATA SECURITY

10.1 Security Measures

HomeFio implements commercially reasonable administrative, technical, and physical safeguards designed to protect your Personal Information from unauthorized access, disclosure, alteration, and destruction. These measures include:

(a) Encryption of data in transit using TLS/SSL protocols;

(b) Encryption of data at rest on our servers and storage systems;

(c) Access controls limiting data access to authorized personnel on a need-to-know basis;

(d) Regular security assessments and vulnerability testing;

(e) Employee training on data privacy and security practices;

(f) Secure coding practices and code review processes; and

(g) Incident response procedures for detecting and addressing security breaches.

10.2 No Guarantee of Security

While we strive to protect your Personal Information, no method of transmission over the Internet or method of electronic storage is completely secure. HomeFio cannot guarantee the absolute security of your information. Any transmission of Personal Information to us is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

10.3 Breach Notification

In the event of a data breach that affects your Personal Information, HomeFio will notify you and applicable regulatory authorities in accordance with applicable data breach notification laws, including Delaware’s Computer Security Breaches Act (6 Del. C. § 12B-100 et seq.).

11. DATA RETENTION

11.1 Retention Period

HomeFio retains all user information indefinitely. This includes account information, Financial Profile Information, Golden Data, Transaction Data, communication records, Usage Data, and Device Data. Information is retained regardless of whether your account is active, inactive, or terminated.

11.2 Basis for Indefinite Retention

Our indefinite retention policy is based on the following legitimate purposes:

(a) Regulatory Compliance: Real estate brokerages are subject to record-keeping requirements imposed by state real estate commissions, including the Delaware Real Estate Commission. Transaction records must be maintained for periods specified by applicable regulations.

(b) Legal Protection: Real estate transactions can give rise to legal claims years after closing. Retaining complete records protects both HomeFio and our users in the event of disputes, claims, or litigation.

(c) Fraud Prevention: Historical data is essential for detecting and preventing fraud, including mortgage fraud, identity fraud, and other illegal activity.

(d) Business Continuity: Maintaining comprehensive records supports ongoing business operations, regulatory audits, and compliance reviews.

11.3 Account Deactivation

If you request account termination, your account will be deactivated (meaning you can no longer log in or use the Platform), but all associated data will be retained in HomeFio’s systems in accordance with this Section. Deactivated account data is maintained with the same security protections applied to active accounts.

11.4 Sensitive Financial Documents

As of the effective date of this Policy, HomeFio does not receive or store Sensitive Financial Documents (see Section 7), and therefore HomeFio currently has no retention obligations with respect to such documents. Retention of Sensitive Financial Documents is governed by the applicable Lender Partner’s privacy policy and retention practices. If HomeFio begins collecting Sensitive Financial Documents in the future pursuant to Section 7.6, this Policy will be updated to include specific retention periods and handling procedures for such documents.

12. YOUR RIGHTS AND CHOICES

12.1 Account Information

You may review and update your account information at any time by logging into your account on the Platform. You are responsible for ensuring that your account information is accurate and current.

12.2 Communication Preferences

You may opt out of marketing communications at any time by: (a) following the unsubscribe link included in any marketing email; (b) adjusting your communication preferences within your account settings; or (c) contacting us at the address provided in Section 18. Please note that you cannot opt out of transactional communications (such as pre-approval status updates, rate lock alerts, and closing milestone notifications) while maintaining an active account, as these communications are essential to the Platform’s functionality.

12.3 Cookies

You can manage your cookie preferences through your browser settings as described in Section 9.3. Note that blocking essential cookies may impair Platform functionality.

12.4 Data Access and Portability

You may request a copy of the Personal Information we hold about you by contacting us at the address provided in Section 18. We will provide the requested information in a commonly used electronic format within a reasonable time period, subject to verification of your identity and applicable legal limitations.

12.5 Data Deletion

Due to regulatory requirements, legal obligations, and the legitimate business interests described in Section 11.2, HomeFio does not honor general requests to delete user information. To the extent that any applicable law (such as the CCPA, as described in Section 15) grants you a right to deletion, HomeFio will comply with such requests to the minimum extent required by law, while retaining all information that we are permitted to retain under applicable exceptions.

12.6 Right to Know and Correct

You have the right to know what Personal Information HomeFio holds about you and to request correction of any inaccurate information. To exercise these rights, please contact us at the address provided in Section 18.

13. CHILDREN’S PRIVACY

The Platform is not directed to individuals under the age of eighteen (18), and HomeFio does not knowingly collect Personal Information from children under 18. The Platform requires all users to be at least 18 years of age to create an account. If we learn that we have collected Personal Information from a child under 18, we will take reasonable steps to delete such information as soon as practicable. If you believe that we may have collected information from a child under 18, please contact us immediately at the address provided in Section 18.

14. THIRD-PARTY SERVICES AND LINKS

14.1 Third-Party Links

The Platform contains links to third-party websites, services, and applications, including Lender Partner portals, Google Workspace, and other third-party services described in our Terms of Service. This Privacy Policy does not apply to any third-party website, service, or application. We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policy of every website, service, or application that you visit or use.

14.2 Lender Partner Portals

When you click on links to upload financial documents or complete loan applications, you are leaving the HomeFio Platform and entering a Lender Partner’s website or portal. Any information you provide to a Lender Partner is governed by that Lender Partner’s privacy policy and terms of service. HomeFio has no control over and assumes no responsibility for the content, privacy policies, or practices of any Lender Partner portal.

14.3 Social Media Features

The Platform may include social media features (such as share buttons) that enable you to share content on social media platforms. These features may collect your IP address, the page you are visiting on the Platform, and may set a cookie to enable the feature to function properly. Social media features are governed by the privacy policy of the applicable social media platform.

15. STATE-SPECIFIC PRIVACY RIGHTS

15.1 Delaware Personal Data Privacy Act

If you are a resident of Delaware, you may have rights under the Delaware Personal Data Privacy Act (DPDPA), effective January 1, 2025, including the right to confirm whether HomeFio is processing your Personal Information, access your Personal Information, correct inaccuracies, delete certain Personal Information, and obtain a copy of your Personal Information in a portable format. To exercise these rights, contact us at the address in Section 18. HomeFio may retain information as permitted under applicable exceptions, including for compliance with legal obligations, fraud prevention, and exercise or defense of legal claims.

15.2 California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with additional rights regarding your Personal Information, including the right to know, delete, correct, and opt out of the sale or sharing of Personal Information. HomeFio does not sell your Personal Information as defined under the CCPA. To exercise your CCPA rights, contact us at the address in Section 18 or submit a request through the Platform. We will verify your identity before processing your request. HomeFio may retain information as permitted under applicable CCPA exceptions.

15.3 Other State Privacy Laws

Residents of other states with comprehensive privacy legislation (including Virginia, Colorado, Connecticut, Utah, and others) may have additional rights under their respective state laws. HomeFio will comply with applicable state privacy laws to the extent required. To exercise any rights under applicable state law, contact us at the address in Section 18.

15.4 Non-Discrimination

HomeFio will not discriminate against you for exercising your privacy rights. We will not deny you services, charge different prices, or provide a different level or quality of service because you exercise your rights under applicable privacy law.

16. INTERNATIONAL USERS

The Platform is operated from and directed to users in the United States. If you access the Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers and central database are located. The data protection and privacy laws of the United States may differ from those of your country of residence. By using the Platform, you consent to the transfer of your information to the United States and the processing of your information in accordance with this Policy.

HomeFio does not currently target or market the Platform to residents of the European Economic Area (EEA), United Kingdom, or other jurisdictions outside the United States. If you are located in such a jurisdiction and choose to use the Platform, you do so at your own initiative and are responsible for compliance with applicable local laws.

17. CHANGES TO THIS PRIVACY POLICY

HomeFio reserves the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by: (a) posting the revised Policy on the Platform with an updated effective date; (b) sending a notification to the email address associated with your account; or (c) providing other notice as required by applicable law. The “Last Updated” date at the top of this Policy indicates when the most recent revisions were made. Your continued use of the Platform after any changes to this Policy constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect your information.

18. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

HomeFio Technologies Inc.

Attn: Privacy Officer

Dover, Delaware

Email: privacy@homefio.com

Website: www.homefio.com

For privacy-related requests, please include your full name, email address associated with your HomeFio account, a description of your request, and any relevant details. We will respond to verified requests within the time periods required by applicable law.

By using the HomeFio platform, you acknowledge that you have read, understood, and agree to this Privacy Policy.