Multi-State Privacy Rights Notice

1.States Covered by This Notice

This Notice describes rights and disclosures applicable to residents of the following states (in addition to California, which is covered in Section 6A of our Privacy Policy):

Praedium monitors developments in additional states and will update this Notice as new laws take effect.

2.Roles Under State Law

For purposes of these laws, Praedium generally acts as a “processor” (or equivalent) on behalf of brokerage and agent customers, who act as “controllers” of personal data submitted to the Services. Where Praedium acts as a controller (for example, regarding our own account holders and our marketing contacts), this Notice and our Privacy Policy describe the basis for our processing.

3.Categories of Personal Information

We collect the categories of personal information described in Section 1 of our Privacy Policy and Section 6A (Notice to California Residents). Categories include identifiers, account credentials, professional and licensing information, transaction information, and internet activity information. Where a user chooses to enter them into a contact record, categories may also include financial details such as budget, pre-approval status, or mortgage balance.

We do not knowingly collect or process “sensitive data” as defined under these laws (for example, racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data, precise geolocation, or data from a known child). Customers should not enter such data into the Services.

4.Your Rights

Subject to verification and applicable exceptions under your state’s law, you generally have the right to:

• a. Confirm whether we process your personal data and access that data;
• b. Correct inaccuracies in your personal data;
• c. Delete your personal data;
• d. Obtain a portable copy of your personal data in a commonly used, machine-readable format;
• e. Opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects;
• f. Opt out of the processing of your sensitive data, or provide consent before such processing (depending on the state).

5.How to Exercise Your Rights

To exercise any right described above, submit a request to:

Email: privacy@praediuminsights.com
Subject: State Privacy Rights Request — [Your State]
Include: Your name, account email, state of residence, and the right you wish to exercise.

We will acknowledge receipt within ten (10) business days where required, verify your identity using information already in our possession or by reasonable additional verification, and respond within forty-five (45) days. We may extend the response period by an additional forty-five (45) days where reasonably necessary, with notice to you.

6.Authorized Agents

You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization (such as a signed permission, power of attorney, or other documentation acceptable under applicable state law) and may verify your identity directly.

7.Appeals

If we decline to take action on your request, you may appeal our decision by replying to our response email or by sending a new email to privacy@praediuminsights.com with the subject line “Privacy Request Appeal.” We will respond to your appeal within sixty (60) days (or such shorter period as required by your state’s law) with a written explanation of any action taken or not taken in response to the appeal.

Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, New Jersey, Delaware, New Hampshire, Tennessee, Minnesota, and Maryland have the right to contact their state attorney general (or comparable regulator) if our response to an appeal is unsatisfactory:

• Virginia AG: https://www.oag.state.va.us
• Colorado AG: https://coag.gov
• Connecticut AG: https://portal.ct.gov/AG
• Texas AG: https://www.texasattorneygeneral.gov
• Oregon DOJ: https://www.doj.state.or.us
• Montana DOJ: https://dojmt.gov
• New Jersey Division of Consumer Affairs: https://www.njconsumeraffairs.gov
• Delaware DOJ: https://attorneygeneral.delaware.gov
• New Hampshire DOJ: https://www.doj.nh.gov
• Tennessee AG: https://www.tn.gov/attorneygeneral
• Minnesota AG: https://www.ag.state.mn.us
• Maryland AG: https://www.marylandattorneygeneral.gov

8.Non-Discrimination

We will not deny you services, charge different prices, or provide a different level of service because you exercised any of the rights described above, except as expressly permitted by your state’s law.

9.Nevada, Washington, and Other States

Nevada residents may submit a verified request to opt out of any future sale of personal information to privacy@praediuminsights.com, even though we do not currently sell personal information.

Residents of Washington and Nevada with health-related data should note that we do not knowingly process consumer health data within the meaning of the Washington My Health My Data Act or similar laws.

Residents of states without comprehensive privacy laws may still submit requests through the contact methods above; we will evaluate and respond on a case-by-case basis consistent with our general privacy principles.

10.Changes

We may update this Notice from time to time. Material changes will be communicated through the Services or via email.

11.Contact

Privacy questions and rights requests: privacy@praediuminsights.com
General support: support@praediuminsights.com

Praedium Insights LLC
https://praediuminsights.com