SeniorCRE™ Privacy Policy

Effective Date: February 23, 2026

Last Updated: February 23, 2026

Please read this Privacy Policy carefully.

By accessing or using the SeniorCRE™ platform (the "Platform" or "Services"), you acknowledge and agree to the data practices described in this Privacy Policy.

This Privacy Policy describes how SeniorCRE, LLC ("SeniorCRE," "we," "us," or "our") collects, uses, discloses, and safeguards information when you use:

• Web applications and dashboards
• Operator platform (clinical, staffing, operations, analytics)
• Marketplace and deal room tools
• Mobile applications and APIs
• Investor, broker, and vendor portals

This Policy applies to operators, brokers, investors, vendors, business users, residents' representatives (where applicable), and website visitors.

1. Information We Collect

1.1 Information You Provide

Account Information

• Name, email, phone number
• Company name, role, job title
• Business contact information

Professional Information

• Licenses, credentials, certifications
• Verification documents

Property & Transaction Data

• Listings, financials, occupancy, NOI/EBITDA
• Offering memoranda and deal documents
• Transaction terms and communications

Payment Information

• Billing details and payment information
• Payment data is processed by third-party PCI-compliant processors

Communications

• Messages, uploads, files
• Support requests and chat logs

Identity Verification

• Government identification
• Tax or accreditation documentation (where required)

Healthcare / Operational Data (Operator Customers)

• Resident and operational information
• Care documentation, eMAR, staffing, and community data
• Subject to HIPAA where applicable and where a Business Associate Agreement (BAA) is in place

1.2 Information Collected Automatically

• IP address and device identifiers
• Browser type and operating system
• Usage activity and feature interactions
• Session data and authentication tokens
• Performance metrics and error logs
• Approximate location based on IP

1.3 Information from Third Parties

• Identity verification providers
• Market data and property data sources
• Public records and licensing databases
• Analytics and infrastructure providers
• Third-party integrations authorized by you

2. How We Use Information

2.1 Service Delivery

• Create and manage accounts
• Operate platform features and workflows
• Facilitate transactions, listings, and communications
• Generate dashboards, analytics, and reports

2.2 Platform Improvement and Development

• Improve functionality and performance
• Conduct testing and product development
• Detect security threats, fraud, or abnormal activity

2.3 Communications

• Account notifications and service updates
• Security alerts
• Billing communications
• Customer support
• Marketing communications (opt-out available)

2.4 Legal and Compliance

• Enforce Terms of Service and EULA
• Respond to legal requests and regulatory obligations
• Protect the security and integrity of the Services

3. Aggregated and De-Identified Data

SeniorCRE may create and use aggregated, anonymized, or de-identified data derived from Customer information to:

• Improve and operate the Services
• Develop benchmarking and industry analytics
• Train and enhance algorithms and AI models
• Produce market intelligence and commercial data products

Such data will not identify any individual or specific customer organization.

4. Information Sharing and Disclosure

We do not sell personal information.

We may disclose information:

4.1 With Your Authorization

• When you participate in transactions, listings, or workflows
• When you enable integrations or sharing features

4.2 Service Providers

We use trusted vendors for:

• Cloud hosting and infrastructure
• Payment processing
• Communications and messaging
• Analytics and monitoring
• Identity verification

These providers process data on our behalf under contractual safeguards.

4.3 Marketplace Participants

Transaction-related data may be shared with relevant brokers, buyers, sellers, operators, or vendors involved in a specific workflow.

4.4 Legal Requirements

We may disclose information:

• To comply with law, regulation, subpoena, or court order
• To protect against fraud, security threats, or abuse
• To enforce our agreements

4.5 Business Transfers

Information may be transferred in connection with a merger, acquisition, financing, restructuring, or sale of assets.

5. Data Security

We implement administrative, technical, and physical safeguards designed to protect information, including:

• Encryption in transit and at rest
• Access controls and authentication measures
• Role-based permissions
• Security monitoring and incident response

No system is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain information for as long as necessary to:

• Provide the Services
• Maintain operational and transaction records
• Comply with legal, regulatory, and audit requirements

Operational and transaction records may be retained for up to seven (7) years or longer if required by law.

Upon account closure, data is deleted or anonymized within a reasonable period unless retention is legally required.

7. Your Privacy Choices and Rights

Depending on your jurisdiction, you may have the right to:

• Access your information
• Correct inaccurate data
• Request deletion (subject to legal obligations)
• Opt out of marketing communications

Requests may be submitted to: privacy@seniorcre.com

8. HIPAA and Healthcare Information

If you use the Platform to process Protected Health Information (PHI):

• A Business Associate Agreement (BAA) must be executed
• SeniorCRE implements safeguards consistent with HIPAA security requirements
• Customers are responsible for clinical accuracy and regulatory compliance

If no BAA is in place, PHI should not be stored or transmitted through the Platform.

9. Cookies and Tracking

We use cookies and similar technologies for:

• Authentication and session management
• Preferences and functionality
• Performance and analytics

You may control cookies through your browser settings.

10. International Data Transfers

Information may be processed in the United States or other jurisdictions where our service providers operate. Appropriate contractual safeguards are used where required.

11. Children's Privacy

The Services are not intended for individuals under 18, and we do not knowingly collect personal information from minors.

12. Third-Party Links

The Services may contain links to third-party sites. We are not responsible for their privacy practices.

13. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via:

• Email notification
• Platform notice
• Updated revision date

Continued use of the Services constitutes acceptance of the updated Policy.

14. Contact Information

Privacy Officer

SeniorCRE, LLC

5050 Quorum Drive, Suite 700

Dallas, Texas 75254

Email: privacy@seniorcre.com

Support: support@seniorcre.com

© 2026 SeniorCRE™