Privacy Policy

Information You Provide

We collect personal and business information that you provide when you:

• create or manage an account;
• upload documents or data;
• link third-party financial, property, or service accounts;
• communicate with us;
• use interactive features of the Service.

This may include:

• contact information (name, email, phone, address);
• business and investment information;
• property and asset data;
• financial account credentials or tokens;
• service preferences;
• billing and payment data;
• uploaded documents and files.

If you provide us with personal information about another individual, for example a client, co-owner, borrower, or tenant, you confirm that you have the authority to do so and have given any notice or obtained any consent required by law.

Automatically Collected Information

We automatically collect information about your use of the Services, including:

• device and browser details;
• IP address;
• login and usage logs;
• cookie and local storage data;
• the website or ad that referred you to us, including advertising click identifiers;
• interactions with our websites and Services, such as clicks, scrolling, and pages viewed;
• error reports and performance metrics.

This automatic collection may be facilitated by technologies like cookies, web beacons, tracking pixels, SDKs, and similar tools.

Information from Third Parties

We may obtain information about you from:

• third-party service providers;
• partners and affiliates;
• advertising and analytics partners (for example, information about the ad you clicked before visiting us);
• publicly available sources;
• Third-Party Portals that you authorize us to access.

Service Providers and Partners

We may share personal information with third-party service providers and partners who help us operate and improve the Services, including:

• cloud hosting and infrastructure providers;
• payment processors;
• analytics and performance tools;
• advertising and marketing partners, such as Google and Meta, as described in Section 4;
• customer relationship management (CRM) and marketing communication platforms, such as HubSpot, as described in Section 4;
• customer support and communication platforms.

Affiliates and Business Partners

We may share information with SHARE's subsidiaries, affiliates, partners, and service providers as needed to deliver services, enhance functionality, or facilitate commercial relationships.

Third-Party Clients and Offers

When authorized by you, we may share information with:

• lenders, insurers, brokers, and other service providers;
• third parties that provide quotes, terms, or alternative offers;
• partners that help assess or process your data for rate shopping or matching.

We disclose only de-identified or non-identifying property and loan characteristics for the purpose of obtaining indicative pricing. Personally identifying information, account credentials, and uploaded documents are not disclosed to a lender, insurer, broker, or other service provider unless you affirmatively request an introduction, quote, or referral.

Legal and Safety Disclosures

We may disclose data to comply with laws or respond to lawful requests by public authorities, enforce our agreements, protect rights and safety, or in connection with legal proceedings.

Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, user information may be disclosed or transferred as part of the transaction.

Analytics

We use Google Analytics to understand how visitors use our websites and Services, such as which pages are visited, how long visits last, and which site or ad referred a visitor. Google Analytics uses first-party cookies and similar identifiers. Google signals is turned off. For visitors in the United States who have not opted out, our Google tags also allow Google's advertising cookies, and Google may use this data to measure our Google Ads and show our ads to past visitors. Everywhere else, and for anyone who opts out, Google Analytics runs without advertising cookies. In Quebec, the European Economic Area and the United Kingdom it does not run at all.

Advertising and Remarketing

We use advertising services from Google (Google Ads conversion tracking and remarketing) and from Meta Platforms (including the Meta Pixel and the Meta Conversions API). We use these services to measure how well our ads perform and to show our ads to people who have previously visited our websites, on other websites and platforms.

These third-party vendors, including Google and Meta, use cookies (such as Google advertising cookies and Meta cookies) or other identifiers to serve ads based on your prior visits to our websites and to measure ad performance. These advertising tags do not load for visitors who opt out (see Your Advertising Choices and Browser Privacy Signals below).

Information already sent to Google or Meta before you opt out or delete your account is held under their own policies, and we cannot recall it for an individual.

HubSpot

We use HubSpot, our customer relationship management (CRM) platform, to learn which of our marketing leads people to sign up for Pocket:

• On pocketam.ai, HubSpot's tracking code records the pages you visit, using HubSpot cookies set for pocketam.ai and its subdomains.
• When you create a Pocket account, our welcome page on portal.pocketam.ai may load HubSpot's tracking code, which records that page visit with your email address, so HubSpot can connect your new account to the visits it recorded. This happens only shortly after you create the account, not when you sign in later.
• We add to your HubSpot contact record how you first found us (such as the website, ad or campaign that referred you, advertising click identifiers and the first page you visited) and the dates your first property was added and your first document was processed.

None of this happens in Quebec, the European Economic Area or the United Kingdom, or for anyone who opts out (see Your Advertising Choices and Browser Privacy Signals below). For your HubSpot contact record, location means where you last signed in to portal.pocketam.ai from, and an opt-out counts once we can associate it with your account. If you opt out or delete your account, we take steps to remove how you found us and those dates from HubSpot; they may stay on a record under an email address you have since changed. Advertising click identifiers are removed from your contact record 90 days after we collect them. To have the page visits HubSpot recorded deleted, or details removed from a record under an old email address, contact privacy@pocketam.ai.

Separately, when you create a Pocket account, we add your name, email address and organization to HubSpot as a contact, wherever you are and whether or not you opt out.

Your Advertising Choices

You can opt out of personalized advertising and analytics using the following tools:

• Our own opt-out: the Your Privacy Choices page, which stops our advertising tags and HubSpot tracking from loading in your browser;
• Google: Ads Settings / My Ad Center at adssettings.google.com;
• Google Analytics: the opt-out browser add-on at tools.google.com/dlpage/gaoptout;
• Meta: Ad Preferences in your Facebook or Instagram settings, or facebook.com/adpreferences;
• Industry tools: the Network Advertising Initiative opt-out at optout.networkadvertising.org and the Digital Advertising Alliance WebChoices tool at optout.aboutads.info.

Opting out does not mean you will stop seeing ads; the ads you see may be less relevant. You may also be able to manage cookies and tracking preferences via your browser or device settings; blocking some cookies may affect how the Services work.

Browser Privacy Signals

We treat a Global Privacy Control (GPC) signal sent by your browser as a request to opt out of the "sale" or "sharing" of your personal information and of targeted advertising for that browser and, where we can associate it, your account. Because there is no common industry standard for "Do Not Track" signals, we do not currently respond to them.

Additional Rights for U.S. State Residents

Depending on where you live (for example, California, Colorado, Connecticut, Virginia, and other states with comprehensive privacy laws), you may also have the right to:

• opt out of targeted advertising and of the "sale" or "sharing" of your personal information. Our use of advertising cookies and pixels described in Section 4 may be considered "sharing" or "targeted advertising" under some of these laws;
• know the categories of personal information we collect, the sources, the purposes, and the categories of third parties to whom we disclose it, as described in this Policy;
• appeal our decision on your request by replying to our response;
• use an authorized agent to submit a request on your behalf;
• not be discriminated against for exercising any of these rights.

We do not sell personal information for money. To opt out of sharing and targeted advertising, use the "Your Privacy Choices" link in the footer of our website, enable Global Privacy Control in your browser, or contact us using the details below.

Additional Information for Canadian Residents

Our privacy officer is Andrew Kim, CEO, who can be reached at privacy@pocketam.ai.

We store personal information in Canada. Our service providers process it in the United States, and it may be accessible to courts and authorities in those countries.

We respond to requests to access or correct your personal information within 30 days.

You may withdraw your consent, and you may file a complaint with the Office of the Privacy Commissioner of Canada or, if you live in Quebec, the Commission d'accès à l'information du Québec.