HIVE PRIVACY POLICY

DRAFT – NOT YET REVIEWED BY COUNSEL. This document is a working first draft prepared for attorney review. It is not legal advice and must not be published or relied on until reviewed and approved by counsel. Items in [BRACKETS] are placeholders. Notes marked [COUNSEL NOTE] are drafting comments and must be removed before publication.

Effective Date: [EFFECTIVE DATE] Last Updated: [LAST UPDATED DATE]

1. Introduction

This Privacy Policy explains how Homes By Hive, Inc. ("Hive," "we," "us," or "our") collects, uses, shares, and protects personal information when you use the Hive mobile app for iOS and Android, the Hive web admin dashboard, our websites, and related services (together, the "Service").

The Service is offered only in the United States and only to people 18 or older. This policy should be read together with our Terms of Service.

The short version:

• We collect what we need to run a real estate listing community: your account, phone number, profile, saved homes, comments, chats, and (for agents) license details.
• We use location only if you allow it, to show maps and nearby listings.
• We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
• When you start a chat with an agent, that agent sees your username, profile, and messages.
• You can delete your account at any time from inside the app.

2. Information We Collect

2.1 Information you give us

2.2 Information collected automatically

2.3 Information from third parties

• MLS and listing data providers (e.g., [ListHub / OTHER PROVIDER]): property listing data, which often includes the listing agent's and brokerage's name, license number, and business contact details.
• License verification sources: state real estate licensing databases and brokerages, to confirm agent license status.
• Service providers: for example, delivery status of SMS verification codes from Twilio, or fraud and security signals.

3. How We Use Information

We use personal information to:

1. Provide the Service – create and manage accounts, show listings and maps, save homes, display comments, enable chats and live tours, and send push notifications you have enabled.
2. Verify identity and licenses – verify phone numbers by SMS and verify agent licenses and brokerage affiliations.
3. Keep the community safe – review reported content, moderate, detect fraud, spam, and abuse, enforce our Terms (including fair housing rules), and suspend or ban accounts.
4. Communicate with you – send verification codes, service and security notices, support responses, and (with your permission where required) updates about new features.
5. Improve and develop the Service – analyze usage, fix bugs, and build new features (such as short-form video and social shopping).
6. Personalize your experience – show nearby listings and recommendations based on your saved homes, searches, and location (if enabled).
7. Comply with law and protect rights – respond to legal requests, comply with MLS/IDX and other contractual obligations, and protect the rights, property, and safety of users, Hive, and others.

We do not use your personal information to make decisions that produce legal or similarly significant effects about you based solely on automated processing.

4. How We Share Information

We do not sell your personal information. We share it only as described below.

4.1 Service providers

We share information with vendors who process it on our behalf under contracts that limit their use of it to providing services to us:

4.2 Agents, when you contact them

When you start a chat with an agent, follow an agent, or otherwise ask to connect, that agent (and, where applicable, their brokerage) receives your username, profile information, and messages, and any contact information you choose to share. Agents are independent of Hive and may use your information under their own privacy practices and applicable law. Our Terms prohibit agents from selling or sharing information they obtain through Hive.

4.3 Other users and the public

• Comments are visible to other users under your username. Your username may be anonymous, but anything you include in the comment itself is visible.
• Agent profiles (name, photo, brokerage, license number and state, service area, bio, certifications) are publicly visible so members can evaluate agents and so agents can meet advertising disclosure requirements. License photos are not shown publicly.
• Live streams are visible to viewers, including your username, comments, and voice or image if you join with audio or video.

4.4 Legal and safety

We may disclose information if we believe in good faith it is necessary to: comply with law, a subpoena, court order, or other legal process; respond to lawful requests by public authorities; enforce our Terms; investigate fraud, security issues, or fair housing violations; or protect the rights, property, or safety of Hive, our users, or the public.

4.5 Business transfers

If Hive is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction, subject to this policy.

4.6 With your consent

We may share information for other purposes with your direction or consent.

4.7 Aggregated or de-identified data

We may share information that has been aggregated or de-identified so that it cannot reasonably be linked to you. We will maintain and use de-identified data without attempting to re-identify it.

5. Your Choices

• Location: Turn location access on or off in your device settings. The app works without it, but nearby and map features will be limited.
• Push notifications: We ask for permission before sending push notifications. You can turn them off in your device settings or in the app's notification settings.
• SMS: We send texts to verify your phone number and secure your account. Message and data rates may apply. [We do not send marketing texts. If we do in the future, we will ask for your separate express consent, and you can reply STOP to opt out at any time.] Your mobile number and SMS consent are not shared with third parties for their marketing purposes.
• Email: You can unsubscribe from non-essential emails using the link in the email. We will still send account and security messages.
• Camera, microphone, and photos: We ask for permission before accessing your camera, microphone, or photo library, and only use them when you choose to upload a photo or join or host a live stream.
• Profile and content: You can edit your profile and delete your comments and uploads in the app.

6. Deleting Your Account

You can delete your account from inside the app at any time:

1. Open the Hive app.
2. Go to Settings > Account > Delete Account [CONFIRM PATH].
3. Confirm deletion.

You can also request deletion on the web at https://homesbyhive.com/#/delete-account or by emailing hello@homesbyhive.com, even if you no longer have the app installed.

When you delete your account, we delete or de-identify your personal information within [30] days, except information we must keep for legal, security, fraud-prevention, or dispute-resolution reasons (see Section 7). Residual copies in backups are deleted on our normal backup cycle of [X] days. Messages you sent to others may remain visible to the recipients [CONFIRM], and comments may be removed or shown as from a "deleted user" [CONFIRM].

7. How Long We Keep Information

We keep personal information only as long as needed for the purposes in this policy, then delete or de-identify it. Our general retention periods are:

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls and row-level security on our database, restricted administrator access to the web dashboard, and [encryption at rest – CONFIRM]. Agent license photos are stored in restricted-access storage and are viewable only by authorized personnel for verification.

No system is completely secure. If we learn of a security breach affecting your personal information, we will notify you as required by law.

9. Cookies and Analytics on the Web Dashboard

Our web admin dashboard and websites use cookies and similar technologies:

• Strictly necessary cookies – to keep you signed in, secure your session, and remember settings. These cannot be turned off.
• Analytics – [we use [ANALYTICS PROVIDER] to understand how the dashboard and website are used and to improve them / we do not currently use analytics cookies – CONFIRM].

We do not use advertising or cross-site tracking cookies. You can control cookies through your browser settings.

Do Not Track and Global Privacy Control: Browsers' "Do Not Track" signals do not have a uniform standard, and we do not respond to them. We do honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information, as required by California law.

10. Children's Privacy

The Service is not intended for anyone under 18, and we do not knowingly collect personal information from children under 13 or from anyone under 18. If we learn that we have collected information from someone under 18, we will delete it and close the account. If you believe a minor has provided us information, contact us at hello@homesbyhive.com.

11. California Privacy Rights (CCPA/CPRA)

This section applies to California residents and supplements the rest of this policy. Terms like "personal information," "sensitive personal information," "sell," and "share" have the meanings given in the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

11.1 Notice at collection

In the past 12 months, we have collected the following categories of personal information, for the business purposes described in Section 3, from the sources described in Section 2, and disclosed them for business purposes to the recipients described in Section 4:

Retention: See Section 7.

11.2 Sensitive personal information

Some information we collect may be considered sensitive personal information under the CCPA, including:

• Precise geolocation (if you enable location services);
• Account log-in credentials (email/phone and password);
• Contents of messages (your in-app chats, where Hive is not the intended recipient); and
• License images and license numbers, which may contain government-issued identifiers or information that could be treated as sensitive.

We use and disclose sensitive personal information only for purposes permitted under the CCPA (Cal. Code Regs. tit. 11, § 7027(m)), such as providing the Service you requested, verifying licenses, ensuring security and integrity, and preventing fraud. We do not use it to infer characteristics about you. Because of this, we do not offer a separate "limit" option; if our practices change, we will provide a "Limit the Use of My Sensitive Personal Information" link.

11.3 Sale and sharing

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. We have not done so in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16.

11.4 Your rights

If you are a California resident, you have the right to:

• Know / Access – request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties to whom we disclose it.
• Delete – request that we delete personal information we collected from you, subject to legal exceptions.
• Correct – request that we correct inaccurate personal information.
• Opt out of sale or sharing – we do not sell or share, but you may still submit a request, and we honor GPC signals.
• Limit use of sensitive personal information – see Section 11.2.
• Non-discrimination – we will not discriminate against you for exercising your rights.

11.5 How to exercise your rights

Submit a request by:

• Emailing hello@homesbyhive.com;
• Using [IN-APP PRIVACY REQUEST FORM / WEB FORM URL]; or
• Calling [TOLL-FREE NUMBER – CONFIRM IF REQUIRED].

We will verify your identity by matching information you provide with information in our records (for example, by confirming access to your account email or phone number). You may use an authorized agent to submit a request on your behalf; we may require proof of authorization and may ask you to verify your identity directly. We will respond within the time required by law (generally 45 days, extendable by 45 days with notice).

11.6 Shine the Light

California Civil Code § 1798.83 lets California residents request information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

11.7 Other U.S. state privacy rights

Depending on where you live, you may have similar rights under other state privacy laws, including the right to access, correct, delete, and obtain a copy of your personal information, and to opt out of targeted advertising, sale, and certain profiling. To exercise these rights, use the methods in Section 11.5. If we deny your request, you may appeal by emailing hello@homesbyhive.com with the subject line "Privacy Appeal."

12. App Store Disclosures

Our privacy practices are also summarized in the Apple App Store "App Privacy" label and the Google Play "Data safety" section. These summaries are intended to be consistent with this policy; if there is any difference, this policy controls.

13. Data Location

The Service is intended for U.S. users. Your information is stored and processed in the United States [CONFIRM Supabase project region and vendor data locations].

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the app, by email, or by other reasonable means before the changes take effect, and update the "Last Updated" date above. Where required by law, we will ask for your consent.

15. Contact Us

If you have questions or requests about this Privacy Policy or our data practices, contact us:

Homes By Hive, Inc. Attn: Privacy 4225 Executive Sq, Suite 600 6011 La Jolla, CA 92037 Email: hello@homesbyhive.com