PRIVACY POLICY

Annum,Inc. (“Annum,” “we,” “us,” or “our”) is committed to protecting your privacy.This Privacy Policy describes how we collect, use, disclose, and safeguard yourpersonal information when you use the Annum Member App (the “App”), available on iOS (Apple App Store) and Android (Google Play Store), to access housing benefits, financial tools, AI-assisted guidance, and referral services offered through your employer, nonprofit partner, municipality, or housing program.

By downloading, installing, or using the App, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the App.

We may update this Privacy Policy from time to time to reflect changes in our datapractices or applicable law. If we make material changes, we will notify you through the App or by email prior to the changes taking effect. Your continued use of the App following notice of any update constitutes your acceptance of the revised Privacy Policy.

1.    Information We Collect

a.    Information You Provide Directly

When you create anaccount or use the App, we may collect the following categories of personal information:

i.     Full name, email address, and phone number

ii.     Employment status and employer information

iii.     Household size and income range,where required for program eligibility

iv.     Housing status, housing needs, andpreferences

v.     Documents uploaded by you, such aspay stubs, leases, and utility bills

b.     Information We Collect Automatically

When you use the App,we automatically collect certain technical and usage information, including:

i.     Device information, such as IPaddress, device type, and operating system

ii.     App usage data, including screensvisited, features accessed, and forms completed

iii.     Location data, only where you have enabled location services and such data is required for local program matching

iv.     Crash reports and performance diagnostics

c.    Informationfrom AI Interactions

When you interact withour AI-powered housing assistant (the “Assistant”), we collect the messages andprompts you submit, the responses generated on your behalf, and context shared during your session for the purpose of personalizing your experience. See Section 5 for additional disclosures regarding our AI services.

d.    Information from Partner Organizations

Annum works with municipalities, community-based organizations (“CBOs”), and employers(collectively, “Partners”) that refer residents to the App or enroll them inprograms. Where a Partner shares your information with us, that Partner is acting as an independent data controller, and its own privacy policy govern show it collected and disclosed your data to us. We encourage you to review the privacy policy of any Partner organization that referred you to Annum.

Categories of information we may receive from Partners include:

i.     Contact information provided by a case manager or employer human resources department

ii.     Referral context, such as program type or household circumstances

iii.     Eligibility or enrollment data frombenefit programs

e.    Information We Derive

We may draw inferencesfrom the information we collect. For example, we may infer your approximatelocation from your IP address or infer household composition from demographicdata you provide.

2.    How We Use Your Information

We use the personal information we collect for the following purposes:

i.     To match you with relevant housing assistance programs and resources

ii.     To enable applications or referrals to third-party services, such as lenders or service providers

iii.     To facilitate enrollment in Partner-sponsored benefit programs

iv.     To operate our AI-powered housing assistant in response to your inquiries

v.     To send transactional andservice-related emails, including account confirmations, program updates, andsecurity alerts

vi.     To analyze App usage for purposes of improving performance and features

vii.     To provide customer support andrespond to your inquiries

viii.    Todetect, investigate, and prevent fraudulent or unauthorized activity

 ix.     To comply with applicable legal, regulatory, and contractual obligations

3.    How We Share Your Information

a.    Sale of Personal Information

We do not sell yourpersonal informationto third parties, and we have not done so at any time. We do not disclose yourpersonal information to third parties for their own independent marketing purposes.

Note Regarding Analytics: Certain analytics tools we use, including Google Analytics and Firebase Analytics, may constitute the “sharing” of personal information underthe California Privacy Rights Act (CPRA) even in the absence of monetaryconsideration. You may opt out of these technologies as described in Section 7 or by transmitting a Global Privacy Control (GPC) signal through your browser.

b.    Permitted Disclosures

We disclose your personal information only in the following circumstances:

i.     Technology Service Providers: We disclose personal informationto vendors and service providers that support the operation of the App,including hosting, email delivery, analytics, and AI services, pursuant to written agreements that include confidentiality and data protection obligations. A complete list of our service providers is set forth in Section 4.

ii.     Partner Organizations: We disclose personal information to the municipality, CBO, or employer that referred you or enrolled you in aprogram. Partners access only information relevant to their respective programthrough our portal and may export data associated with their programs. We disclose only the minimum information necessary to support program delivery.

iii.     Housing and Financial ServiceProviders: We may disclose personal information where you request a referral to, or opt into,financial assistance programs, mortgage products, or other housing services.

iv.     Legal Compliance: We may disclose personalinformation where required by applicable law, regulation, subpoena, or courtorder, or where we determine in good faith that disclosure is necessary toprotect the rights, safety, or property of Annum, our users, or the public.

v.     Business Transfers: We may disclose personalinformation in connection with a merger, acquisition, or sale of all orsubstantially all of our assets, subject to appropriate confidentiality protections.

vi.     With Your Consent: We may disclose personal information to third parties where you have provided your express consent.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We do not attempt to re-identify such information.

4.    Third-Party Service Providers

The following third-party service providers process personal information on our behalf pursuant to written data processing agreements:

i.     Google Firebase: Our primary backend infrastructure,including database (Firestore), authentication, file storage, and crash reporting. Hosted on Google Cloud infrastructure that is SOC 2 compliant.

ii.     Google Analytics and FirebaseAnalytics: App and website usage analytics. Data is pseudonymized where technically feasible. You may opt out through your device advertising settings or by transmitting a GPC signal.

iii.     OpenAI: Provides the underlying technologyfor our AI-powered housing assistant. We have configured our account to opt out of OpenAI’s use of our data for training its foundational models. See Section5.

iv.     SendGrid (Twilio): Transactional and service-related email delivery.

v.     Apple App Store and Google PlayStore: Appdistribution. Each platform independently collects certain device and download information pursuant to its own privacy policy.

We will update thi Section prior to engaging any additional service provider that processes personal information.

5.    AI-Powered Housing Assistant

Our AI-powered housing assistant is built on application programming interfaces (APIs) provided by OpenAI. The following disclosures apply:

i.     The Assistant does not retain conversation history between sessions by default.

ii.     Responses generated by theAssistant are AI-generated and do not constitute legal, financial, or housing advice. Users should consult a qualified professional before making anymaterial decisions based on information provided through the Assistant.

iii.     We have configured our account with OpenAI to opt out of the use of user conversations for training OpenAI’s foundational models, consistent with our data processing agreement with OpenAI.

iv.     We may use aggregated,de-identified conversation data solely for purposes of improving the performance of the Assistant within the Annum platform.

v.     Users who wish to opt out of havingtheir interactions used for internal improvement purposes may submit a request to help@annumhousing.com.

6.    Email Communications

We send transactionalemails in connection with your account and program participation, includingaccount confirmations, program updates, and security alerts. Where you haveprovided consent, we may also send promotional communications regarding Annumfeatures and programs.

You may withdrawconsent to receive promotional emails at any time by following the unsubscribeinstructions included in any such communication. Withdrawal of consent does notaffect our ability to send non-promotional, service-related communications.

7.    Cookies and Tracking Technologies

The App and our website use the following categories of tracking technologies:

i.     Essential: Technologies that are strictlynecessary for the App to function, including authentication and sessionmanagement. These technologies cannot be disabled without impairing corefunctionality.

ii.     Analytics: Technologies that collectaggregated, pseudonymized data regarding how users interact with the App,including screens visited, features used, and error rates. We use GoogleAnalytics and Firebase Analytics for this purpose. You may opt outthrough your device advertising settings, through the Google Analytics opt-outbrowser add-on available at tools.google.com/dlpage/gaoptout, or bytransmitting a Global Privacy Control (GPC) signal.

iii.     Functionality: Technologies that enable the App toremember your preferences and settings. These technologies may be disabled, butdoing so may impair certain App features.

8.    Data Security and Retention

a.    Security Measures

We maintainadministrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, ordestruction, including:

i.     Encryption of data at rest and intransit using TLS 1.2 or higher

ii.     Role-based access controls limiting access to personal information to authorized personnel

iii.     Infrastructure hosted on Google Cloud, which maintains SOC 2 compliance

No data transmission orstorage system can be guaranteed to be completely secure. Users are responsiblefor maintaining the confidentiality of their account credentials.

b.    Data Breach Notification

In the event of a security incident involving personal information, we will notify affected users and applicable regulatory authorities in accordance with applicable law, including within 72 hours of discovery for users whose data is subject to the GDPR, and as expeditiously as required for California residents under California Civil Code Section 1798.82.

c.    Retention

We retain personalinformation for as long as necessary to provide the services described in this Privacy Policy or to fulfill our legal and contractual obligations. Accounts that have been inactive for more than 12 months may be subject to data deletionor anonymization, subject to any applicable legal hold requirements.

Users may request deletion of their account and associated personal information at any time by contacting help@annumhousing.com.

9.    Privacy Rights

Depending on your state of residence, you may have some or all of the following rights with respect to your personal information:

i.     Right to Know and Access: You may request confirmation ofwhether we process your personal information and access to the personal information we maintain about you.

ii.     Right to Correct: You may request correction ofinaccurate personal information we maintain about you.

iii.     Right to Delete: You may request deletion ofpersonal information we hold about you, subject to certain legal exceptions.

iv.     Right to Data Portability: You may request a copy of personal information you have provided to us in a portable and, to the extent technically feasible, readily usable format.

v.     Right to Opt Out of Sale or Sharing: We do not sell your personal information. To opt out of the sharing of personal information through analytics technologies, see Section 7.

vi.     Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this Section.

vii.     Right to Appeal: If we deny a privacy rights requestyou submit, you may appeal our determination by contacting us athelp@annumhousing.com with the subject line “Privacy Rights Appeal.” We will respond within the period required by applicable law and provide a written explanation of our decision. Where your appeal is denied, we will identify the relevant state Attorney General or supervisory authority to whom you may submit acomplaint.

b.    Submitting a Request

To exercise any of therights described above, please submit a written request to help@annumhousing.com. Your request should include your full name, the emailaddress associated with your account, and a description of the right you wish to exercise. We will verify your identity prior to processing your request andwill respond within 45 days of receipt, with one 45-day extension available upon notice where reasonably necessary.

c.    Authorized Agents

You may designate anauthorized agent to submit privacy rights requests on your behalf. To do so,you must provide written authorization for the agent to act on your behalf,along with sufficient information to verify your identity. We reserve the rightto deny requests from agents who do not provide adequate proof of authorization.

10.  Children’s Privacy

The App is not directed to individuals under the age of 16. We do not knowingly collect personal information from minors without verified parental or guardian consent. If you believe we have inadvertently collected personal information from a minor, please contact us at help@annumhousing.com and we will take prompt steps to delete such information.

11.  Users Outside the United States

Annum is headquarteredin the United States. The App is intended for use by individuals located withinthe United States. If you access the App from outside the United States, yourpersonal information may be transferred to and processed in the United States, which may have data protection laws that differ from those of your country of residence. By using the App, you consent to such transfer and processing.

12.  Do Not Track and Global Privacy Control

Our App and website donot respond to browser-level Do Not Track (DNT) signals. We do, however, recognize the Global Privacy Control (GPC) opt-out preference signal as a validmechanism for opting out of the sharing of personal information for analytics purposes under applicable California law.

13.  Accessibility

Individuals withdisabilities who are unable to access this Privacy Policy in its current formatmay contact us at help@annumhousing.com to request a copy in an alternativeformat.

14.  Contact Information

Questions, concerns, or requests regarding this Privacy Policy or our data practices should be directed to:

Annum, Inc.

Attn: Privacy Officer

Email:  help@annumhousing.com

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