Privacy Policy

Last Updated: September 8, 2025

At Passive, the privacy of our users and visitors are very important to us. The purpose of this privacy policy is to provide you with a description of the types of personal information (also, "PII") we collect about you when you use our Services (defined below) and how we use that information. This Privacy Policy only applies to personal information collected about you while you are accessing or using the Services. By registering to use the Services or otherwise accessing the Services, you accept this Privacy Policy, certify that you have reviewed it, and serves as a written release from you authorizing us to use your PII according to the terms of this privacy policy. IF YOU DO NOT AGREE WITH ANY OF THE TERMS SET FORTH HEREIN, PLEASE DO NOT USE THE SERVICES OR REGISTER TO USE THE SERVICES.

In this document, references to "Passive", "Company", "we" "us" or "our" means Passive Financial Services, Inc., a Delaware corporation, "you" or "your" means the users of or visitors to our website and Services, "Privacy Policy" means this privacy policy, and "Services" means our applications, websites, content, and products and services. "Terms" means our Terms of Service available at joinpassive.com/terms.

1. How Do We Collect Information, What Do We Collect and How Do We Use It?

We collect and store information that you voluntarily provide to us as well as data related to your use of the Services. Below is a more specific list of the personal information we collect and how we use it with your consent. You may be asked additional questions regarding items on this list to ensure we have your consent to collect and use your personal information for specific purposes.

Email Address. When you voluntarily provide us with your email address, we collect your email address from which your identity is or may be discernible.

Account Creation. If you establish an account on the Services, we may collect your name, email address, billing and/or mailing address, job title, employer or your business's name, phone number, Social Security Number, date of birth and other information to support your use of the Services.

Payment and Transactional Data. When you pay for use of certain areas or features of the Services, if applicable, our payment processor, the applicable app store, and Passive collects the financial information required to process your payments, including name, payment card information, bank account number, billing information. In addition to this Privacy Policy and our Terms, information related to your payments or purchases is also processed according to such app store's services agreement and privacy policy.

Property and Lease Information. If you are a User of the Service, we may collect information about the lease for which your use of the Service relates, including, without limitation, the property address, name of tenant, name of landlord, lease term information, security deposit amount, and last month's rent amount.

Social Networking Services Data. We have pages on social media sites like our Slack channel, Facebook, Instagram, YouTube, Twitter, TikTok, and LinkedIn ("Social Media Pages"). When you interact with our social media Pages, we will collect PII that you elect to provide to us, such as your contact details. In addition, the companies that host our social media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Government ID Data. We may ask for a government-issued ID or other information that uniquely identifies you for certain Services or at certain times, including when setting up, activating, or verifying your account, verifying your identity, fraud prevention, or as required by law. Forms of government identification include a picture of your driver's license, date of birth, your taxpayer identification, or social security number.

Biometric Identifiers. We may also request biometric identifiers, such as a scan of your retina, iris, or face geometry during account set up, log in, or otherwise solely for the purpose of verifying your identity and fraud prevention.

Support Requests. When you contact us for support, we may collect personal information as part of the support process, including but not limited to your name, username, address, telephone number, mobile number, email address, and other information from which your identity is or may be discernible.

Entity Access. If you are an entity who purchased access for the use of the Services for users (as opposed to an individual user), we may also require that you provide us with contact information for administrators or finance personnel as part of the setup and provision of services to you and your users.

Surveys and User Research. We may send you surveys or contact you with questions to provide us with feedback on our Services. We collect any responses that you provide. Participation in surveys or research tasks is elective and does not affect your access to the Services.

In addition, we may collect certain information and data related to your use of the Services (see "What Are Cookies and How Do We Use Them?" below). Such information may include the date and time of your visit, information about your usage of, and interaction with, our software, the Services, the IP address of your computer or mobile device, your computer or mobile device browser information, the internet address that you visited prior to and after reaching the Services, the name of the domain and host you used to access the internet, the type of mobile device you use, your mobile device's unique device ID, the features of the Services which you accessed, and correspondences between you and us. We may also use cookies and web beacons to track your interaction with the Services, and to customize our Services for you.

2. Information Third-Parties Provide About You

We may receive information about you from the landlord or tenant that has initiated use of the Services, the app store from where you download the App, your employer or organization, business contacts, friends and other third-parties, such as when they submit information to us about you or when they post content on the Services. Additionally, we may supplement the information we collect with records from third-parties for a variety of purposes, including to obtain consumer reports from consumer reporting agencies, help us correct or supplement our records, enhance our ability to serve you, to help prevent or detect fraud, to tailor our content and ads to you, and to offer you opportunities that may be of interest to you.

To the extent we combine information we receive from those sources with your PII, the combined information will be treated as PII under this Privacy Policy, unless we have disclosed otherwise. In no other circumstances will this Privacy Policy apply to information we receive about you from third-parties.

3. Interactions with Third-Party Sites

The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party site or application. The use of this functionality may involve the third-party providing information to us. If we offer and you choose to use this functionality, the third-party service may send PII about you to us. If so, we will treat it as PII under this Privacy Policy since we are collecting it as a result of your interaction on our Site.

In addition, we may provide third-party sites' interfaces or links on the Services to facilitate sending a communication from the Services. For example, we may use third parties to facilitate emails, advertising, or postings. These third parties may retain any information used or provided in any such communications and these third parties' practices are not subject to our Privacy Policy. We may not control or have access to your communications with or through these third parties, and we are not responsible for their practices. You should review the applicable third-party privacy policies before using such tools.

4. How Do We Use Information We Collect?

Our primary purpose in collecting information is to provide you the Services. We may use the information you provide to us for other purposes as follows:

Provision of Services. We may use and disclose your PII and usage information to support the delivery of our services on the Services.

Support the Services. We may use the information you provide us to provide any customer support you request, including troubleshooting problems, and monitor such requests, and to inform you about updates to the Services.

Improve the Services. We may use the information you provide us to customize, measure, and improve the Services, including through data analysis, testing, research, statistical and survey processes.

Enforce Rights. We may use the information you provide us to enforce your and our rights (including payment for the Services in the case of paying users) and protect you against fraud.

Marketing Purposes. We occasionally may contact you about new product and features. You may remove your name from our mailing lists to stop receiving these emails.

If you have any questions regarding the foregoing, or our privacy practices, you may contact us at support@joinpassive.com.

5. Can We Use De-Identified Information?

In addition to the uses of personal information above, we may remove the identifiable parts of your information to create de-identified forms ("De-identified Information"). De-identified Information may be compiled with other data in aggregated forms. We use this De-identified Information in the following ways:

Disclosure for Business Purposes. We may also license, sell, or otherwise share De-identified Information with clients, partners, investors, and contractors for any purposes related to our business practices.

Services Improvement. We may use De-identified Information for product improvement including to the Services as well as share it with third parties to evaluate their products or services.

Research. We may use De-identified Information for research whether scientific, marketing, or business in nature. This research may be made public through publication such as within a scientific journal.

6. How Do We Share the Information We Collect?

We do not sell, rent, trade, or otherwise transfer personally identifiable information to third parties who are not our affiliates or service providers without your consent to do so (if you are a tenant or landlord then we do share relevant information between these parties). By using the Services, you accept and agree that we can share your PII as provided in this Privacy Policy. We may disclose PII: to our affiliated companies, carriers, third party service providers and/or agents, as reasonably necessary to provide you with the Services you have requested; as required by law or legal process; in response to lawful requests for information by governmental agencies, such as law enforcement authorities, authorized to request such information; to enforce our contractual agreements, including investigation of potential violations thereof; to help detect and prevent potentially illegal acts and violations of our policies and to otherwise protect our interests; to help detect and prevent harm to persons or property or otherwise to protect public safety; to third parties that perform functions on our behalf, including, but not limited to, third parties that host or operate our Services, analyze data, perform email list management services, provide customer service, or provide public relations and marketing services and who may be paid by us for the provision of those products and services that use your PII; and to vendors of products and services that are offered through the Services.

As with any other business, it is possible that in the future we could sell or buy subsidiaries or business units. In any such transaction, as well in the event all or substantially all of our assets are acquired by a third party, personal information of our users will generally be one of the transferred assets. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party.

Information collected by or sent to us may be stored and processed in any country in which we and our affiliates, subsidiaries, or service providers maintain facilities. We reserve the right to transfer your personal information outside of the country where you reside and/or from which you use our Services. By using our Services, you consent to any such transfer of information outside of your country.

7. How Long Is Your PII Kept by Us?

We will retain your personal information for as long as reasonably necessary to: provide the use of our Services; invoice charges and to maintain records until invoices cannot be lawfully challenged and legal proceedings may no longer be pursued; communicate with you regarding other services that we offer; comply with applicable laws, regulations, and court orders; enforce our contractual agreements; or fulfill any of the purposes for which we collected the personal information as listed in this Privacy Policy.

Biometric information that is collected, stored, and used shall be destroyed (a) when the initial purpose for collecting or obtaining such identifiers or information has been satisfied, such as the termination of your account, or (b) within 3 years of your last interaction with us, whichever occurs first unless otherwise required by law.

8. What Are Cookies and How Do We Use Them?

A "Cookie" is a simple text file stored on your computer or device for use by a browser. Certain features may only be available through the placement of a cookie. We may use "cookies" to assist in data collection and to track visitor usage and trends to help us better serve you. The use of cookies is a standard practice among internet web sites; most internet browsers permit a user to accept, decline or delete cookies. We may use persistent cookies to make it easier for you to navigate the Services. Specifically, we may use persistent cookies to track whether you are logged into the Services. A persistent cookie may remain on your local device for an extended period of time. You can remove persistent cookies by following directions provided in your internet browser's "help" function. We may set a persistent cookie to store how you came to the Services and what items you interact with during your visit. Persistent cookies also enable tracking and targeting the interests of our users to enhance their experience on the Services. If you reject cookies, you will still be able to view contents through the Services, but your ability to use some areas of the Services may be limited. Some of our business partners (e.g., analytical tracking software providers) may use cookies and tracking technologies on the Services. We have no access to or control over these cookies or tracking technologies. This Privacy Policy covers the use of cookies on our Services and does not cover the use of cookies or tracking technologies by any such business partner.

9. How Do We Protect Your PII?

We follow commercially accepted industry standards, but no less than a reasonable standard of care, to protect the personal information submitted to or collected by us, both during transmission and once we receive it. Biometric Information is stored, transmitted, and protected from disclosure all in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other personal information. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of your personal information, we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. Considering the foregoing, your use and access of the Services is at your own risk. If you have any questions about security of our Services, please contact us in the manner set forth under the heading "How Can You Contact Us?" below.

10. Can Children Use the Services?

The Services is intended for the use of users who are at least 18 years of age. The Services are not directed to persons under the age of 18. We do not knowingly collect or solicit information from, market to or accept services from persons under the age of 18 years old. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to remove such personal information.

11. How Far Does Our Responsibility Extend?

This Privacy Policy applies to the Services that are owned and operated by us. The Services and our communications to you may contain links to other third-party sites that may offer products or services that our users might find useful. These third-party sites may request information from you. In such instances, the collection and use of your personal information will be governed by the privacy policy applicable to that third party site. We do not and cannot control the privacy policies, contents or links that appear on these third-party sites. We encourage you to review the privacy policies of any third-party sites or services before providing any of them with your personal information. We accept no responsibility or liability for other third-party sites or services.

12. How Can You Access or Amend Your PII (Right of Opt-Out, Access and Correction)?

You have the right to view, correct, complete, or remove your personal information. Upon and subjection to verification of your identity, we will respond to requests to view, correct, complete, or remove your personal information within a reasonable time.

We will make all reasonable efforts to accommodate requests to delete personal information unless it is required by law or for any lawful business purpose, and always will delete any personal information that we are required by applicable law to delete at your request.

You can help us maintain the accuracy of your information by notifying us of any changes to your personal information as soon as possible. Your rights to access, change, or delete your personal information are not absolute. We may deny you such rights when required by law or if the request would likely reveal personal information about a third party.

To request opt-out, review, modification or removal of personal information, you should submit a written request to us at: support@joinpassive.com.

13. Your California Privacy Rights

Under the California Consumer Privacy Act of 2018 ("CCPA"), California residents have certain rights relating to collection, use, and sharing of their personal information for companies that do a minimum amount of business in or with California residents.

We do not meet the minimum necessary requirements to be subject to the CCPA. However, we also do not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale if required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow us to retain and use certain personal information notwithstanding your deletion request. You may also send your request to us by contacting us at the address below under "How can you contact us?".

Separate from the CCPA, California's Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties' direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed below.

Also, California Civil Code Section 1798.83 permits customers who are California residents and who have provided us with "personal information" (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us in the manner set forth under the heading "How can you contact us?".

14. Do Not Track

Certain web browsers and other devices you may use to access the Services may permit you to submit your preference that you do not wish to be "tracked" online. We do not currently commit to responding to these submissions, in part, because no common industry standard for "Do Not Track" has been adopted by industry groups, technology companies, or regulators. We will make efforts to monitor developments around Do Not Track browser technology and the implementation of a standard. For information about Do Not Track, please visit: www.allaboutdnt.org.

15. Can European Users Use the Services?

Our Services are hosted in the United States and generally subject to laws of the United States. If you are visiting our web site or using our Services from outside the United States, you may be transferring your personal data (PII under this Privacy Policy) into the United States, whether you intentionally submit your personal data to us or not (for instance, we may passively collect information about you). Many regions, such as the European Union, have data collection protections that differ from U.S. law.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set forth below.

Passive is the controller responsible for the personal data we collect and process from users in the United Kingdom and European Economic Area ("EEA").

We will make reasonable efforts to provide you with information about your personally data held by us, to allow you to verify that the information is accurate and relevant for the purposes for which we collected it, and to correct or remove any information that is incorrect, or opt-out of collecting or storing that information. To request opt-out, review, modification or removal of personal data, you should submit a written request to us at support@joinpassive.com. Our compliance with the foregoing may be limited by the need to retain information for legal or other compliance purposes.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

16. Can This Privacy Policy Be Modified?

Each time you use or access the Services, the current version of the Privacy Policy will apply. Accordingly, when you use the Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version. We will occasionally update this Privacy Policy to reflect changes in our Services and/or business practices. You are encouraged to check regularly for any changes to this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of user information collected in the past without the consent of affected users. You agree that your continued use of the Services shall constitute your acceptance of the Privacy Policy as revised.

17. What Law Applies To This Privacy Policy?

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, without giving effect to any principles of conflict of law. If you are outside of the United States, your information will be processed and stored in the United States and you consent to such processing and storage under the laws of the United States.

18. How Can You Contact Us?

To contact us with your questions or comments regarding this Privacy Policy or our information collection and dissemination practices, please contact us at: support@joinpassive.com.