Privacy Policy

1. Overview & Data Controller

This Privacy Policy explains how Rung™ Technologies, LLC, a Wyoming limited liability company (“Rung™,” “we,” “us,” or “our”), collects, uses, protects, and discloses information when you use our mobile application, website, and associated services (collectively, the “Services”).

By using our Services, you acknowledge and consent to the data collection and usage practices described in this Privacy Policy.

2. Information We Collect

To provide you with automated equity-building, banking integration, and credit reporting, we collect the following categories of information:

• Identity & Contact Information: Legal name, email address, telephone number, and residential mailing address.
• Regulatory Verification Information (CIP / KYC): Date of birth, Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN), and government identification documents required to clear anti-money laundering and securities issuance regulations.
• Lease & Tenancy Data: Residential address, apartment or unit number, lease start and expiration dates, monthly rent amount, and property management affiliation.
• Banking & Financial Data: Tokenized bank credentials, routing numbers, account balances, and transaction history used exclusively to schedule micro-investment contributions and verify on-time rent payments.
• Web Server Logs & Security Telemetry: Standard HTTP request headers, IP address, device type, browser specifications, and timestamps collected automatically for infrastructure stability, DDoS mitigation, and fraud defense.
• Consented Diagnostic Telemetry & Navigational Analytics: When you provide prior affirmative express consent through our cookie controls, we collect standard navigational telemetry (such as page load speeds, interface clicks, scrolling milestones, and error reports) to troubleshoot technical defects. Sensitive personal identifiers, passwords, and banking numbers are masked client-side at the browser level prior to any transmission and are never recorded.

3. How We Use Your Information

We use collected information strictly to fulfill our core services and comply with applicable laws:

• Micro-Investment Execution: Initiating automated contributions timed alongside your rental schedule into real property shares.
• Securities Issuance & Cap Table Maintenance: Transmitting necessary investor records to regulated asset-holding platform partners and registered transfer agents to issue fractional ownership units in property Special Purpose Vehicles (SPVs).
• Credit Bureau Rent Reporting: Formatting and delivering verified on-time rent payment records under CDIA Metro 2 standards to major credit reporting agencies via authorized data furnisher partners.
• Tax Reporting: Providing annual Schedule K-1 tax documents generated from property distributions.
• Fraud Prevention, Cybersecurity & Diagnostics: Detecting suspicious account activity, protecting against unauthorized logins, and resolving application defects.

4. Third-Party Sharing & Confidential Service Providers

We share information solely with essential service providers who operate under confidential service provider agreements and are prohibited from using your data for secondary purposes:

• Regulated Asset-Holding & Transfer Agent Partners: To issue, manage, and register fractional real estate shares, distribute investor tax forms, and coordinate secondary liquidity windows.
• Authorized Credit Bureau Reporting Data Furnishers: To process and furnish on-time rent reporting records to Experian, TransUnion, and Equifax under the Fair Credit Reporting Act (FCRA).
• Licensed Payment & Banking Partners: To tokenize bank accounts, verify available balances, process automated ACH micro-investments, and disburse cash distributions securely.
• Regulated Identity Verification & KYC Providers: To authenticate government identity credentials and fulfill federal Customer Identification Program (CIP) obligations.
• Telecommunications & SMS Providers: To deliver transactional multi-factor authentication (MFA) codes, security alerts, and service notices.
• Diagnostic Telemetry Providers: Under strict express consent and client-side masking, to analyze aggregated technical performance and error metrics.
• Property Managers & Landlords: We share community participation metrics (e.g. confirming that a resident in Unit 104 is enrolled in Rung™) to coordinate lease renewal incentives. We never share personal banking balances, credit card numbers, or personal portfolio values with landlords.
• Legal & Regulatory Authorities: When disclosure is mandatory pursuant to valid subpoena, court order, or applicable securities or banking regulations.

5. Cookies, Local Storage & Prior Express Consent Controls

We use cookies and local storage tokens to deliver our Services safely and reliably:

• Strictly Necessary Cookies: Essential for user authentication, security verification, session management, and CSRF protection. These cannot be disabled as the site cannot function without them.
• Performance Diagnostics & Session Analytics: Used solely to detect application bugs, measure page load performance, and optimize user navigation workflows. These tools are strictly gated by Prior Express Consent. They do not execute on page load and will only initialize if you affirmatively click “Accept All” on our consent banner.

You may update your consent preferences or withdraw consent at any time by clearing your browser storage or adjusting your browser cookie settings.

6. Security Safeguards & Client-Side Data Masking

We employ bank-grade technical, administrative, and physical safeguards to protect your personal information:

• All network communications are encrypted in transit using Transport Layer Security (TLS 1.3).
• Sensitive data, including government identifiers and financial tokens, is encrypted at rest using AES-256 standards.
• Bank account credentials are tokenized and securely handled without raw banking passwords ever being stored on our servers.
• All form inputs across the platform are tagged with client-side masking attributes (data-clarity-mask="true" and data-fs-mask="true") ensuring that text typed into input fields is obfuscated locally at the browser level prior to any diagnostic transmission.
• Access to personal data is restricted to authorized personnel on a strict least-privilege basis.

7. California Privacy Rights (CCPA / CPRA & CIPA Safe Harbor Disclosures)

This section provides specific disclosures for California residents under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and California wiretapping and pen-register statutes (Cal. Penal Code §§ 631, 638.51):

8. Your General Privacy Rights & Data Choices

Regardless of where you reside, Rung™ provides you with comprehensive control over your personal data:

• Access & Portability: You may request a copy of the personal data we hold about you.
• Correction: You may update or correct inaccurate personal details directly within your profile settings.
• Deletion: You may request deletion of your account and associated personal data, subject to mandatory statutory retention periods required by federal tax, anti-money laundering, and securities regulations.
• Opt-Out of Marketing: You may unsubscribe from promotional notifications and emails at any time via the unsubscribe link or account preferences.

9. Contact Us

For questions, requests, or privacy inquiries regarding your personal data or this Privacy Policy, please contact our privacy compliance team: