PRIVACY POLICY FOR HOAFILING LLC

Effective date: 11/01/2024

This Privacy Policy (“Policy”) outlines how HOA INC, a Delaware Corporation (“we,” “our,” or “us”), collects, uses, shares, and manages personal information. It also describes the rights and options available to individuals regarding their personal information.

By accessing and using our Services (as defined below), you agree to the practices outlined in this Policy. Your use of our Services, and any related privacy concerns, is governed by this Privacy Policy and our Terms of Service which also include provisions on limitations of liability and dispute resolution.

I. SCOPE OF THIS POLICY

This Policy applies to personal information collected through our website (the “Site”) located at www.file.hoalife.com, and related services (collectively, the “Services”). However, it does not cover information collected in other ways, such as job applications or employee data. Processing of personal information related to our business clients is governed by the agreements with those clients and their data handling policies.

II. INFORMATION WE COLLECT

We collect personal information from you directly, automatically through your interaction with our Services, and from third-party sources. Where allowed by law, we may combine this information.

(a) Information You Provide Directly:
The personal information we collect depends on your use of our Services and interactions with us. Generally, we collect the following:

• Contact Information: This includes your name, company name, business email address, number of employees, and any other details you choose to provide when you engage with our Services.
• Company Identifier Numbers and Beneficial Owner Details: For FinCEN reporting, we collect details such as your company name, address, tax identification numbers, and beneficial owners’ personal information. This information is solely for filing FinCEN reports and is not used for marketing purposes.
• Account Information: When you create an account with us, we collect details like your name, company name, business email address, and password.
• Communications and Interactions: We maintain records of our communications with you, including contact details and responses.
• Feedback and Surveys: If you participate in our surveys or provide feedback, we collect and store this information.
• Marketing and Promotions: We may collect information such as your email, name, phone number, and preferences related to marketing communications.
• Event Participation: Information related to your registration and participation in events or webinars we host or sponsor.
• Business Development Information: We collect information about vendors, business partners, and agents, including contact details and communications, for business development purposes.

(b) Information Collected Automatically:
We, along with third-party providers, automatically gather personal information about your usage of the Site, including:

• Device and Browsing Information: This includes your IP address, browser type, operating system, language, device type, and browsing activity.
• Activity and Usage Information: This includes details about your interactions with our Services, such as clicks, searches, and time spent on the Site.
• Location Information: We may collect general location information through your IP address.

(c) Information from Other Sources:
We may obtain personal information from business partners, customers, data analytics providers, government entities, public databases, and vendors.

III. USE OF PERSONAL INFORMATION

We use personal information for the following purposes:

• Service Provision and Support: To manage your account, provide technical support, and ensure the smooth operation of our Services.
• FinCEN Reporting: To facilitate FinCEN reporting on beneficial ownership information.
• Analytics and Improvement: To analyze how our Services are used, improve our offerings, and conduct research.
• Communication: To respond to inquiries, send updates, and provide information about changes to our Services and policies.
• Marketing and Advertising: To send promotional content and advertise our Services.
• Surveys and Research: To conduct market research and user satisfaction surveys.
• Event Management: To handle event registration and participation.
• Security and Legal Compliance: To protect our Services, enforce our rights, comply with legal obligations, and manage internal operations.

IV. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information as follows:

• Service Providers: To vendors and service providers who perform functions on our behalf.
• Customers: To customers as necessary for administering our Services.
• Marketing and Analytics Partners: To third-party companies for marketing, advertising, and analytics.
• Affiliates: To our corporate affiliates and agents.
• Business Partners: To business partners involved in offering our Services.
• Business Transactions: In connection with mergers, acquisitions, or other business transactions.
• Legal Compliance: To comply with legal obligations, respond to legal processes, and protect rights.
• Aggregate Information: For research, development, and other purposes using aggregated or de-identified data.
• Other Disclosures: As necessary for other purposes not covered above, with notification and consent where required.

V. COOKIES AND TRACKING TECHNOLOGIES

We and third parties use cookies, pixel tags, and similar technologies to collect information about your interactions with our Site and Services. This information is used for analytics, marketing, and to enhance your experience.

• Cookies: These are small data files stored on your device that help us track and customize your experience on our Site.
• Pixel Tags: These are small graphics embedded in web content that track usage and help manage content.
• Third-Party Analytics: We use tools like Google Analytics to understand how our Services are used.

For more information on cookies and how to manage them, please see our Cookie Policy.

VI. YOUR PRIVACY CHOICES

You have options to manage your personal information and preferences:

• Cookie Management: Adjust your browser settings to block or delete cookies.
• Marketing Preferences: Opt out of marketing emails via the unsubscribe link.
• Account Information: Access and update your account information through your account settings.

VII. CHILDREN’S PRIVACY

Our Services are not intended for children, and we do not knowingly collect information from children. If you believe we have collected information from a child, please contact us immediately.

VIII. INTERNATIONAL DATA TRANSFERS

Your information may be transferred and processed in countries other than your own, where data protection laws may differ.

IX. EXTERNAL LINKS AND FEATURES

Our Site and Services may contain links to third-party websites. This Policy does not apply to those sites, and we are not responsible for their practices.

X. SECURITY MEASURES

We implement measures to protect personal information from unauthorized access and other risks. However, no security system is foolproof.

XI. POLICY UPDATES

This Policy may be updated from time to time. Please review it periodically for changes.