Privacy Policy

1. Introduction

Settilo LLC ("Company," "we," "us," or "our"), a Wyoming limited liability company, operates a neighborhood analytics platform (the "Service") that provides personalized neighborhood reports and life-quality assessments for home buyers in the United States.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our Service, or interact with us in any way. Please read this policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Information We Collect

2.1 Information You Provide Directly

• —Account Information: Name, email address, and password when you create an account.
• —Payment Information: Billing address, payment card details, and transaction history. Payment processing is handled by third-party processors; we do not store full credit card numbers.
• —Search and Preference Data: Addresses you search, neighborhoods you explore, lifestyle preferences you input (commute requirements, family size, activity preferences, budget parameters), and any natural language descriptions of your living situation.
• —Report Purchases: Records of neighborhood reports you purchase or generate.
• —Communications: Messages you send us through contact forms, email, or customer support channels.

2.2 Information Collected Automatically

• —Device and Browser Information: IP address, browser type and version, operating system, device identifiers, and screen resolution.
• —Usage Data: Pages viewed, features used, search queries, click patterns, time spent on pages, and navigation paths.
• —Location Data: Approximate geographic location derived from your IP address. We do not collect precise GPS location unless you explicitly enable it.
• —Cookies and Similar Technologies: See Section 6 and our Cookie Policy for details.

2.3 Information from Third-Party Sources

• —Public Data Sources: We aggregate publicly available data from government databases, including U.S. Census Bureau, American Community Survey (ACS), state and federal education databases, and other public records to generate our neighborhood analytics.
• —API Providers: We may receive data from mapping, geolocation, and analytics API providers to enhance our Service.
• —Analytics Providers: We receive aggregated analytics data from third-party tools that help us understand Service usage patterns.

3. How We Use Your Information

• —Service Delivery: To generate personalized neighborhood reports, process search queries, and deliver the core functionality of our platform.
• —Personalization: To tailor neighborhood recommendations and "Life Reality Layer" simulations based on your stated preferences and lifestyle inputs.
• —Payment Processing: To process purchases of neighborhood reports and manage your billing.
• —Communication: To send you order confirmations, respond to inquiries, and provide customer support.
• —Service Improvement: To analyze usage patterns, identify bugs, improve features, and develop new functionality.
• —Security: To detect fraud, enforce our Terms of Service, and protect the safety and integrity of our platform.
• —Legal Compliance: To comply with applicable laws, regulations, and legal processes.
• —Marketing (with consent): To send promotional communications about new features, reports, or services, where you have opted in.

Important: We do not use your personal data to make housing-related decisions. Our Service provides informational analytics only and is not used for lending, insurance underwriting, tenant screening, or any purpose covered under the Fair Credit Reporting Act (FCRA).

4. Legal Bases for Processing

• —Contract Performance: Processing necessary to deliver the Service you purchased or requested.
• —Legitimate Interest: Processing for our legitimate business interests, such as improving the Service, preventing fraud, and conducting analytics, where these interests are not overridden by your rights.
• —Consent: Where you have given explicit consent, such as for marketing communications.
• —Legal Obligation: Processing required to comply with applicable law.

5. Sharing and Disclosure

We do not sell personal information. We may share limited data with analytics and advertising partners as described herein. We may share your information in the following limited circumstances:

• —Service Providers: With vendors who assist in operating our platform (hosting, payment processing, email delivery, analytics). These providers are contractually obligated to protect your data and use it only for the services they provide to us.
• —Legal Requirements: When required by law, subpoena, court order, or governmental regulation; or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
• —Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change.
• —With Your Consent: In any other circumstances where you have provided explicit consent.

We do not share individual user data with real estate agents, brokers, lenders, landlords, or insurance companies unless you explicitly authorize such sharing.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect usage information and improve the Service. For a detailed explanation, see our Cookie Policy.

Categories of cookies we use:

• —Strictly Necessary Cookies: Required for the Service to function (authentication, security, load balancing).
• —Functional Cookies: Remember your preferences and settings.
• —Analytics Cookies: Help us understand how the Service is used.
• —Marketing Cookies (optional): Used only with your explicit consent to deliver relevant content.

7. Third-Party Services and APIs

Our Service integrates with third-party APIs and services. When you use our Service, data may be processed by these third parties in accordance with their own privacy policies. Key categories include: mapping and geolocation providers, payment processors, analytics platforms, and cloud infrastructure providers.

8. Data Retention

• —Account Data: Retained while your account is active and for 30 days after deletion request.
• —Purchase and Transaction Records: Retained for 7 years to comply with tax and accounting obligations.
• —Usage and Analytics Data: Retained in aggregated, anonymized form indefinitely; identifiable usage logs are deleted after 24 months.
• —Communication Records: Retained for 3 years after the last interaction.

When personal information is no longer needed, we securely delete or anonymize it.

9. Data Security

We implement commercially reasonable technical and organizational safeguards to protect your personal information, including encryption of data in transit (TLS/SSL) and at rest, access controls and authentication mechanisms, regular security assessments and vulnerability scanning, and secure coding practices and code reviews.

No method of electronic storage or internet transmission is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security.

10. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

• —Access: Request a copy of the personal data we hold about you.
• —Correction: Request that we correct inaccurate or incomplete data.
• —Deletion: Request that we delete your personal data, subject to certain legal exceptions.
• —Portability: Request your data in a structured, machine-readable format.
• —Opt-Out of Marketing: Unsubscribe from marketing emails at any time by clicking the "unsubscribe" link or contacting us.
• —Cookie Preferences: Manage cookie settings through your browser or our cookie consent tool.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 45 days (or as otherwise required by law).

11. State-Specific Privacy Rights

11.1 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• —Right to know what personal information we collect, use, and disclose.
• —Right to delete personal information we hold about you.
• —Right to opt-out of the sale or sharing of personal information. We do not sell your personal information. We may share limited data with analytics and advertising partners as described in this Privacy Policy. You have the right to opt out of such sharing.
• —Right to non-discrimination for exercising your privacy rights.
• —Right to correct inaccurate personal information.
• —Right to limit the use and disclosure of sensitive personal information.

To submit a request, contact us at [email protected]. We may need to verify your identity before processing your request.

11.2 Virginia, Colorado, Connecticut, Utah, and Other States

Residents of states with comprehensive privacy legislation (including but not limited to Virginia VCDPA, Colorado CPA, Connecticut CTDPA, and Utah UCPA) may have similar rights to access, correct, delete, and opt-out. We honor these rights regardless of your state of residence.

11.3 "Do Not Sell or Share My Personal Information"

In compliance with the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), we provide California residents with the ability to opt out of the sale or sharing of their personal information.

How to opt out:

• —Click the "Do Not Sell or Share My Personal Information" link available in the footer of every page on our website.
• —Submit a request via email to [email protected] with the subject line "CCPA Opt-Out Request."
• —Adjust your preferences through our Cookie Preferences tool, which controls sharing of data with analytics and advertising partners.

Upon receiving a valid opt-out request, we will cease sharing your personal information with third-party analytics and advertising partners within 15 business days. We will not ask you to re-authorize sharing for at least 12 months after your opt-out request. You do not need to create an account to exercise this right.

11.4 "Do Not Track" Signals

Our Service currently does not respond to "Do Not Track" browser signals, as there is no industry-standard protocol for such signals. However, you can manage tracking through our Cookie Preferences tool and the "Do Not Sell or Share My Personal Information" opt-out described above.

12. Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to promptly delete such information. If you believe a child has provided us with personal data, please contact us immediately.

13. International Data Transfers

Our Service is operated in the United States and is intended for users located in the United States. If you access the Service from outside the United States, please be aware that your data will be transferred to, stored, and processed in the United States. By using the Service, you consent to such transfer.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. For significant changes, we will provide more prominent notice (such as an email notification or in-app banner). Your continued use of the Service after any changes constitutes acceptance of the updated policy.