Privacy Policy

1. Introduction

MyDemesne (“MyDemesne,” “we,” “us,” or “our”) provides a mobile application and related services (the “App”) that help prospective homebuyers (“Prospects”) understand and improve their readiness to purchase a home, and that connect Prospects with real estate agents and brokerages (“Agents”) who support them through that process. This Privacy Policy explains what information we collect, how we use and share it, the choices available to you, and how we protect your information.

This Policy applies to everyone who uses MyDemesne, including Prospects, Agents, brokerage staff, and visitors to our website. By using the App, you agree to the practices described here. If you do not agree, please do not use the App.

We may update this Policy from time to time. See Section 16 (“Changes to This Policy”) for how we will notify you.

2. Who This Policy Covers and Key Terms

• “Prospect” means an individual using MyDemesne to evaluate and improve their homebuying readiness.
• “Agent” means a licensed real estate professional, brokerage, or brokerage staff member using MyDemesne's agent-facing tools.
• “Personal Information” means information that identifies, relates to, or could reasonably be linked with you.
• “Readiness Signal” means an arbitrary, app-internal estimate (for example, a percentage or stage label) of how well-positioned a Prospect appears to be to buy a home, generated from the goals and tasks the Prospect has completed and the information the Prospect has allowed the App to access. A Readiness Signal has no standardized meaning, value, or use outside the App — it is not a credit score, credit report, official pre-approval, or guarantee of loan eligibility, and is described further in Section 7.

3. Information We Collect

3.1 Information You Provide Directly

• Account and profile information: name, email address, phone number, password (stored in encrypted/hashed form), and similar identifiers.
• Homebuying goals and preferences: target location, budget, timeline, household composition, and similar self-reported information you choose to enter.
• Savings and financial progress information: the amount you've saved toward a home purchase and related self-reported figures, which form the primary basis of your Readiness Signal.
• Credit information (entirely optional): generating your Readiness Signal does not require any credit information at all. If you'd like to factor credit information in, you may choose either to (a) manually enter a credit score number, or (b) upload a full credit report or similar document if you want AI-assisted coaching focused specifically on credit. Neither option is required, and you can use the App fully without providing either. See Section 7 for details on how this information is used.
• Agent and brokerage professional information: for Agents, we collect your name, professional contact information, real estate license number and issuing state, brokerage affiliation, and license verification status. Real estate license numbers are a matter of public record maintained by state licensing authorities, and we may verify the information you provide against publicly available licensing databases.
• Communications: information you provide when you contact us for support, feedback, or otherwise communicate with us.
• Payment-related information: see Section 3.4.

3.2 Information Collected Through Linked Financial Accounts

If you choose to connect a bank or financial account to MyDemesne, we use a third-party financial data connectivity service to facilitate that connection (see Section 8.1). The connection is server-mediated: our backend communicates with the connectivity provider on your behalf to retrieve and process this data into the summaries stored on your device, and stores a secure access token to maintain the connection (see Section 5). Through this connection, we may receive:

• Account holder name and basic account identifiers (for example, account type and the last few digits of an account number);
• Account balances;
• Transaction history necessary to assess savings patterns and readiness indicators.

We do not receive your online banking username or password — authentication happens directly between you and your financial institution (or its connectivity provider), and we never see or store your banking credentials.

You control this connection.Connecting a financial account is optional but is required to access certain features (for example, automated savings tracking). You may disconnect a linked account at any time within the App — which revokes the stored access token at the connectivity provider — and you can manage third-party access to your financial data directly through our financial connectivity provider's own consumer portal.

3.3 Optional Credit Information

Your Readiness Signal does not require any credit information. If you choose to add credit information, you have two options:

• Manual score entry: you may simply type in a credit score number. This requires no document upload and no automated document processing.
• Full credit report upload: if you want deeper, credit-specific coaching, you may instead upload a full credit report or similar document. In this case, we use an automated document-processing service to extract the data points needed to power that coaching (see Section 8.3).

Whichever option you choose (including choosing neither), the choice is entirely yours, and you can change or remove this information at any time. See Section 7 for important details about how this information is used.

3.4 Payment Information

We use a third-party payment processor to handle subscription billing for both Prospects and Agents. We do not store full payment card numbers or bank routing numbers ourselves. Our payment processor may collect billing name, billing address, and payment method details directly, governed by its own privacy policy.

3.5 Information Collected Automatically

• Device and usage information: device type, operating system, app version, crash logs, and general usage patterns (for example, which features you use), collected to maintain, secure, and improve the App.
• Approximate location: if you grant permission, we may use coarse location information (for example, to support location-based loan program eligibility features, such as identifying whether an address is in an eligible rural area for certain loan programs). We do not collect precise GPS location unless you separately enable a feature that requires it, and we will ask for your permission before doing so.
• We do not currently use third-party advertising trackers, and we do not sell your information to data brokers or advertisers.

3.6 Sensitive Information

Depending on the features you use, you may choose to share information that is treated as sensitive under applicable law, including:

• Financial account and transaction information;
• Information relevant to certain government-backed loan programs, such as veteran/military service status (relevant to VA loan features) or property location relevant to rural-development loan eligibility (relevant to USDA loan features);
• Precise geolocation, if you enable that optional feature.

We collect this information only where you choose to provide it or enable the relevant feature, and we use it solely to provide the specific functionality you requested (for example, surfacing loan programs you may be eligible for). We do not use this information for advertising, and we do not share it other than as described in this Policy.

4. How We Use Information

We use the information described above to:

• Create and maintain your account;
• Operate core App features, including readiness tracking, budgeting tools, savings tracking, and educational/coaching guidance;
• Generate and update your personal Readiness Signal (Section 7);
• Connect Prospects with Agents they choose to work with, and support the ongoing relationship between a Prospect and their chosen Agent;
• Process subscription payments;
• Verify Agent professional license information;
• Provide customer support;
• Maintain the security and integrity of the App, detect and prevent fraud or abuse, and enforce our Terms of Service;
• Comply with legal obligations; and
• Improve the App's features and performance, using aggregated or de-identified information where possible.

We do not use your Personal Information to make automated decisions about your eligibility for credit, housing, insurance, or employment, and we do not sell your Personal Information.

5. How Information Is Stored

On your device. The detailed financial information behind your Readiness Signal — your individual transactions, account balances, the contents of any credit report you upload, and the readiness and budget figures the App computes from them — is stored on your own device in an encrypted local database, and is not retained in our databases. The decryption key is generated and held by your device.

Processed by our backend in transit.To connect a financial account and keep it in sync, our backend (not your device alone) communicates with our financial connectivity provider on your behalf: it retrieves your account balances and transaction history, processes them on our servers to produce the summary figures stored on your device, and returns those summaries to the App. During this processing your financial data passes through and is readable by our backend, but we do not store your individual transactions or balances in our databases. To maintain the connection, we securely store an access token issued by the connectivity provider; this token is held only on our servers (never exposed to the App) and is used solely to retrieve your data to provide the App's features. You can revoke it at any time by disconnecting the account (see Section 11).

Sent to our AI provider for the features you use. If you upload a full credit report, its contents are sent to our AI processing provider to extract the data points that power credit coaching (see Section 8.3). To generate your personalized daily coaching, we send summary-level financial figures — such as balances, income and spending summaries, and credit-derived figures — to that provider. We do not send your raw, transaction-by-transaction history for coaching. As described in Section 8.3, our provider does not train its models on your data and retains it only briefly.

What syncs beyond your device. Other than the processing described above, the only information that syncs to our backend for storage is your account profile, your subscription status, and — if you choose to connect with an Agent — your Readiness Signal and related milestone/task progress (see Section 6.1). We do not sync your raw linked financial data or the original contents of any credit document for storage. We rely on reputable third-party infrastructure providers to host this limited information, each of which is contractually required to protect it and use it only to provide services to us.

6. How We Share Information

We do not sell your Personal Information. We share information only as described below.

6.1 With Your Connected Agent

If you choose to connect with an Agent within the App (or accept an invitation from an Agent you already have a relationship with), your connected Agent can see:

• A pseudonymized or initials-based identifier for you within their pipeline view (we limit the personal detail visible to Agents by default);
• Your Readiness Signal and related task/milestone progress, so your Agent can understand where you are in your homebuying journey and support you accordingly. As described in Section 7, this is an arbitrary, app-internal estimate with no standardized meaning or value outside the App.

Your Agent does not receive your linked financial account data, your transaction history, the contents of any document you upload, or any underlying details behind your Readiness Signal — only the resulting estimate and task progress. Readiness Signals are intended to help an Agent who already has, or is establishing, a working relationship with you understand your general progress and coach you accordingly — they are not used by Agents (or by us) to screen, qualify, rank, or decide whether to accept you as a client, and Agents are contractually prohibited from using Readiness Signals for any credit, lending, insurance, employment, or housing-eligibility decision. You may disconnect from an Agent at any time, which ends their visibility into your Readiness Signal going forward.

6.2 With Service Providers

We share limited information with vendors who perform services on our behalf, including financial account connectivity, payment processing, document-data-extraction/AI processing, cloud hosting, customer support tools, and analytics. These providers are contractually restricted to using your information only to provide services to us and not for their own independent purposes. See Section 8 for specific providers.

6.3 Legal and Safety

We may disclose information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of MyDemesne, our users, or the public, or to investigate fraud or security issues.

6.4 Business Transfers

If MyDemesne is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your Personal Information.

6.5 No Current Mortgage-Lead or Credit-Eligibility Sharing

As of the effective date of this Policy, MyDemesne does not share Readiness Signals, credit-document-derived information, or any other Prospect information with mortgage lenders, mortgage brokers, or other parties for the purpose of generating or selling leads, or for any credit-eligibility purpose. If this changes in the future, we will update this Policy, provide advance notice, and obtain any additional consent required by law before doing so.

6.6 With Your Consent

We may share information for other purposes if you direct us to or otherwise consent at the time.

7. Readiness Signals and Credit-Related Information — Important Information

Because this section involves financial and credit-related data, we want to be especially clear about how it works.

• Your Readiness Signal is the App's own estimate, based on your goals, tasks, and the information you've allowed the App to see. It reflects your progress on the goals and tasks you've set within the App, combined with information you've chosen to share — including linked financial data processed by our service to produce the summaries stored on your device (see Section 5) and, if you choose to add it, credit information. It is an internal, app-specific estimate with no standardized scale or meaning outside the App.
• A Readiness Signal does not guarantee pre-approval. It simply suggests that, based on the information available to the App, you may be in a good position to move forward, or it identifies things you might be able to do to get closer to that point. It is not, and should not be relied upon as, an official pre-approval, underwriting decision, or guarantee of any kind.
• Suggestions are yours to accept or decline. Based on your Readiness Signal, the App may offer you daily or periodic suggestions of things you could do to improve your position. You can choose to follow a suggestion, decline it, or ask the App to generate a different suggestion instead. Your choices help inform future suggestions but are used only to support your own coaching experience.
• Credit information is entirely optional, and you choose how much to share. You are never required to provide any credit information to use the App. If you'd like to incorporate credit information into your Readiness Signal, you can simply enter a credit score number yourself — no document upload required. Uploading a full credit report is a separate, optional step available only if you specifically want AI-assisted coaching focused on the details of your credit profile.
• We are not a credit bureau or consumer reporting agency. MyDemesne does not assemble or furnish “consumer reports” as defined under the Fair Credit Reporting Act (FCRA), and the Readiness Signal is not a credit score, credit report, or eligibility determination.
• Readiness Signals are for coaching and pipeline visibility only. A Readiness Signal is designed to help you track your own progress and to help an Agent you are already working with (or choosing to work with) understand where you stand and support your homebuying journey. Readiness Signals are not provided to, or usable by, lenders, insurers, employers, landlords, mortgage brokers, or any other third party for purposes of determining your eligibility for credit, insurance, employment, or housing, and we contractually prohibit Agents from using them for such purposes.
• We do not currently operate a paid lead-referral channel that shares credit-derived information with mortgage brokers or lenders (see Section 6.5).
• Document handling applies only if you choose the full-report option. If you manually enter a credit score, no document is involved. If you instead choose to upload a full credit report, an automated processing service extracts the data needed to power that specific coaching feature (see Section 8.3). We do not retain the original uploaded document in our central systems beyond what is necessary to complete that processing, and we do not use its contents for any purpose other than providing the App's features to you.
• Questions or concerns. If you have questions about how your Readiness Signal or credit-related information is handled, please contact us using the information in Section 17.

8. Third-Party Services We Use

We work with reputable third-party providers to deliver core features. Each provider processes information only as our service provider, under contractual confidentiality and security obligations, and only for the limited purposes described below.

8.1 Financial Account Connectivity

We use a regulated financial data connectivity provider to let you securely link your bank or financial accounts. This provider facilitates the secure exchange of account data and does not give MyDemesne access to your banking credentials. To maintain the link, we securely store an access token issued by this provider; the token is held only on our servers and is used solely to retrieve your data to provide the App's features. This provider has its own privacy policy governing its handling of your data, and offers its own consumer-facing portal where you can review and manage which apps (including MyDemesne) have access to your linked accounts.

8.2 Payment Processing

We use a PCI-compliant third-party payment processor to handle subscription billing. This processor maintains its own security and privacy practices for the payment information it collects.

8.3 Document and AI-Assisted Processing

We use a third-party AI service provider to help extract structured information from documents you choose to upload (such as a full credit report), and to power certain personalized coaching features using summary-level financial and credit-derived figures (not your raw, transaction-by-transaction history). Under our agreement with this provider:

• Your data is processed solely to provide the requested output to the App and is not used to train the provider's underlying AI models;
• Data submitted through this service is retained by the provider only for a short period necessary for security and abuse-monitoring purposes, and is then deleted;
• The provider acts as our service provider/processor and is contractually prohibited from using your information for its own independent purposes.

8.4 Hosting and Infrastructure

We use established cloud infrastructure providers to host the limited backend information described in Section 5, secured using industry-standard encryption in transit and at rest, access controls, and monitoring.

We may update the categories of service providers we use from time to time; material changes will be reflected in updates to this Policy.

9. Data Security

We maintain a written information security program designed to protect your information, including:

• Encryption of sensitive information in transit and at rest;
• Access controls limiting employee and system access to information on a need-to-know basis;
• Multi-factor authentication for administrative access to systems containing your information;
• Regular review of our security practices and those of our service providers;
• An incident response plan for addressing potential security incidents.

No system can be guaranteed 100% secure. If we experience a security incident affecting your information, we will notify you and any required regulators in accordance with applicable law.

10. Data Retention

We retain Personal Information for as long as needed to provide the App's features, comply with our legal obligations, resolve disputes, and enforce our agreements. When you delete your account, we will delete or de-identify your Personal Information within a reasonable period, except where we are required or permitted by law to retain certain information (for example, payment records needed for tax or accounting purposes, or information needed to investigate fraud or abuse).

11. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your Personal Information:

• Right to know/access — request information about, or a copy of, the Personal Information we hold about you;
• Right to delete — request deletion of your Personal Information, subject to certain exceptions;
• Right to correct — request correction of inaccurate Personal Information;
• Right to data portability — request a copy of your Personal Information in a portable format;
• Right to opt out of sale or sharing — we do not sell your Personal Information, and do not “share” it for cross-context behavioral advertising as those terms are defined under applicable law;
• Right to limit use of sensitive information — request that we limit the use of sensitive Personal Information to what is necessary to provide the App;
• Right to non-discrimination — we will not discriminate against you for exercising your privacy rights;
• Right to appeal — if we deny a request, you may have the right to appeal that decision.

How to exercise your rights. You can exercise most of these rights directly within the App's account settings (including disconnecting a linked bank, unlinking from an Agent, and resetting your on-device data), or by contacting us using the information in Section 17. We will respond within the time required by applicable law. We may need to verify your identity before processing certain requests.

Authorized agents. You may designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent's authority and your identity.

12. State-Specific Disclosures

Depending on your state of residence, additional disclosures may apply:

• We do not sell Personal Information and have not done so in the preceding 12 months.
• We do not use or disclose sensitive Personal Information for purposes beyond what is necessary to provide the App's requested features.
• Categories of Personal Information we have collected, by category, generally correspond to those described in Section 3.
• Categories of third parties with whom we share Personal Information generally correspond to those described in Section 6 and Section 8.
• Residents of certain states may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not currently engage in such profiling.

If you are a resident of a state with a comprehensive consumer privacy law and believe additional disclosures apply to you, please contact us using the information in Section 17.

13. Children's Privacy

MyDemesne is intended for use by adults (18 years of age or older) seeking to purchase a home or work in real estate. We do not knowingly collect Personal Information from children under 13. If we learn that we have inadvertently collected information from a child under 13, we will promptly delete it. If you believe a child has provided us with information, please contact us using the information in Section 17.

14. Biometric Information

MyDemesne does not currently collect or use biometric information (such as fingerprint, facial, or voice data) for App functionality, beyond any biometric authentication features provided natively by your device's operating system (such as Face ID or fingerprint unlock), which are processed entirely by your device and are never transmitted to or stored by us. If we introduce features that collect biometric information directly, we will update this Policy, provide notice, and obtain any consent required by applicable law before doing so.

15. International Users

MyDemesne is intended for users located in the United States. If you access the App from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. If we make material changes, we will notify you through the App, by email, or by other reasonable means, and will update the “Last Updated” date above. Your continued use of the App after a change takes effect constitutes acceptance of the updated Policy.

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your Personal Information, please contact us at [email protected].

This Policy is a plain-language statement of how we operate and does not waive any legal rights you have under applicable law.