Privacy Policy

Updated April 9, 2021

This “Privacy Policy” describes the privacy practices of Skylight Financial Services, Inc. and our subsidiaries and
affiliates (collectively, “Baselane”, “we”, “us”, or “our”) in connection with the www.baselane.com website, and any other website that we own or control and
which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to
individuals with respect to their information. Baselane may provide additional or supplemental privacy policies to
individuals for specific products or services that we offer at the time we collect personal information. These
supplemental privacy policies will govern how we may process the information in the context of the specific product
or service. 

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or
otherwise includes the following, which may vary depending on whether you use the Service as a Landlord or Tenant:

  • Business and personal contact information, such as your first and last name, email and mailing addresses, physical address (if different from your mailing address), addresses of rental properties you operate and/or inhabit, phone number, and, if applicable, your professional title and company name.
  • Content you choose to upload to the Service, such as text, images, audio, video, and documentation you upload to the Service, which may include personal information to the extent you upload materials containing personal information, along with the metadata associated with the files you upload.
  • Profile information, such as your username and password that you may set to establish an online account with us.
  • Registration information, such as information that may be related to a service or an account you register for.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic Information, such as your city, state, country of residence, postal code, and age.
  • Financial information, such as your stated income, historical values of properties you have purchased, current values of identified properties you have purchased, mortgage balance and payment information, economic standing, financial account numbers and balances, and payment card information.
  • Government-issued identification numbers, such as a national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license of state ID number), and an image of the relevant identification card.
  • Transaction information, such as information about payments to and from you, information about payments from Tenant, bank accounts used for specific transactions, transaction history, including transaction dates and transaction amounts, and details of services you have purchased from us or other parties through our Service.
  • Usage information, such as information about how you use the Service and interact with us or other users through our Service.  Usage information can include, without limitation, information associated with content or information you upload to the Service or otherwise submit to us, as well as information you provide when you use any interactive features of the Service.
  • Marketing information, such as your preferences for receiving communications from us, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we collect from landlords (“Landlords”) about tenants (“Tenants”). In some cases,
Landlords may also provide information about Tenants, which may include personal information, including:

  • Business and personal contact information, such as Tenant’s first and last name, email and mailing addresses,
    physical address, phone number, and, if applicable, Tenant’s professional title and company name.
  • Demographic Information, such as Tenant’s city, state, country of residence, postal code, and age.
  • Transaction information, such as information about payments from Tenant to Landlord, including transaction dates
    and transaction amounts.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance
    with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for our company on social
media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms.
When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to
your interactions and their collection, use and processing of your personal information. You or the platforms may
provide us with information through the platform, and we will treat such information in accordance with this Privacy
Policy.

If you choose to login to the Service via a third-party platform or social media network, we may collect
information from that platform or network. For example, this information may include your Facebook username, user
ID, demographic information, and groups and networks to which you belong (e.g., school, workplace), or information
related to your Google account if you use Google’s single sign on (SSO) feature (more information on Google’s SSO
feature is provided below). You can read more about your privacy choices in the “Third party platforms or social
media networks” portion of the “Your Choices” section.

Information we obtain from other third parties. We may receive personal information about you from
third-party sources. For example, Tenants or Landlords may refer you to us, such as if you have expressed interest
to them in learning specifically about our products or services, or the types of products or services we offer, or a
business partner may share your contact information with us if you have expressed interest in learning specifically
about our products or services, or the types of products or services we offer. We may obtain your personal
information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or
mobile device, and activity occurring on or through the Service, including but not limited, your computer or mobile
device operating system type and version number, manufacturer and model, device identifier (such as the Google
Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited
before browsing to our website, general location information such as city, state or geographic area; information
about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or
screen, navigation paths between pages or screens, information about your activity on a page or screen, access
times, and length of access; and other personal information. Our service providers and business partners, such as
Facebook, Inc., Google LLC, Segment.Io, Inc., and Intercom, Inc. may collect this type of information over time and
across third-party websites and mobile applications.
On our webpages, this information is collected using
cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as
“Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely
identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are
used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than
cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was
accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or
engagement with our emails and to compile statistics about usage of our websites.

We may also use Flash LSOs on our website to collect and store information about your use of our website. Unlike
cookies, Flash LSOs cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on
your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using
the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global
Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or
limit acceptance of Flash LSOs may reduce or impede the functionality of Flash applications that we may use in
connection with our website.
Web browsers may offer users of our websites or mobile apps the ability to disable
receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites
may not function correctly. Please see the “Targeted online advertising” section for information about how to
exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Referrals

Users of the Service may have the opportunity to refer other users or contacts to us (e.g. a Landlord may be able
to refer tenants to the Tenant version of the Service), including through the functionality made available through
the Service. You are solely responsible for ensuring you have all necessary consents to provide any and all personal
information you submit to Baselane for the purpose of Baselane contacting the applicable individual or entity in
accordance with this Privacy Policy, and are solely responsible for the submission of all personal information you
provide to Baselane including through the Service. You may only submit a referral or otherwise provide personal
information if you have permission to provide the referral’s or applicable individual’s contact information to us so
that we may contact them.

How We Use Your Personal
Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at
the time of collection:

To operate the Service. We use your personal information to:

  • provide, operate and improve the Service
  • facilitate transactions you conduct with other users of our Service
  • provide information about our products and Service
  • establish and maintain your user profile on the Service
  • facilitate your login to the Service via third-party identity and access management providers, such as Facebook
    and Google SSO
  • enable security features of the Service, such as by sending you security codes via email, and remembering
    devices from which you have previously logged in
  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and
    support and administrative messages
  • understand your needs and interests, and personalize your experience with the Service and our communications
  • provide support and maintenance for the Service
  • to respond to your requests, questions and feedback

For research and development. We analyze use of the Service to improve the Service and develop new
products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications. We may send you Baselane-related marketing
communications as permitted by law. You will have the ability to opt-out of our marketing and promotional
communications as described in the Opt out of Marketing section below.

To display advertisements. We work with advertising partners to display advertisements online.
These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service
or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see
the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from
government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and
disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate
to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal
claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter
against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or
share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or
de-identified data from your personal information and other individuals whose personal information we collect. We
make personal information into anonymous, aggregated or de-identified data by removing information that makes the
data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with
third parties for our lawful business purposes, including to analyze and improve the Service and promote our
business.

How We Share your Personal
Information

We do not share your personal information with third parties without your consent, except in the following
circumstances or as described in this Privacy Policy:

Other Users of the Service. We may provide functionality that enables you to interact with other
users of the Service and disclose information to other users of the Service. For example, if you link your Account
on the Service with a particular property or Tenant on the Service, the users of that property (which may include
Landlords) or Tenant Account may see your profile information, as well as any documents shared with that Tenant in
connection with that Tenant’s applicable lease. We do not control how other users or third parties use any personal
information that you make available to such users.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and
affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and
individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting,
analytics, email delivery, marketing, and database management services). These third parties may use your personal
information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are
prohibited from using or disclosing your information for any other purpose.

Third-party platforms and social media networks. If you have enabled features or functionality
that connect the Service to a third-party platform or social media network (such as by logging in to the Service
using your account with the third-party, providing your API key or similar access token for the Service to a
third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the
personal information that you authorized us to share. We do not control the third party’s use of your personal
information.

Stripe. Baselane uses Stripe, Inc. (“Stripe”) as the third-party service provider for payment
services (e.g., card acceptance, merchant settlement, and related services). By making payment through the Services,
you agree to be bound by Stripe’s Privacy Policy (available as of the Privacy Policy effective date here) and hereby consent and authorize Baselane and Stripe to share any
information and payment instructions you provide with one or more Third Party Service Provider(s) to the minimum
extent required to complete your transactions.

Plaid. Baselane uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By
using our Service, you grant Baselane and Plaid the right, power, and authority to act on your behalf to access and
transmit your personal and financial information from the relevant financial institution. You agree to your personal
and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy
Policy (available as of the Privacy Policy effective date here).

Zillow. Baselane uses Zillow Group, Inc. (“Zillow”) to retrieve and provide certain data related
to residential real estate and mortgages, such as valuation data and mortgage rates. By using the Services, you
agree to be bound by Zillow’s Privacy Policy (available as of the Privacy Policy effective date here) and hereby consent and authorize Baselane and
Zillow to share any information required for your use of the Services.

Intercom. Baselane uses Intercom, Inc. (“Intercom”) to provide a conversational, messenger-based
experience for customer support. By using the Services, you agree to be bound by Intercom’s Privacy Policy
(available as of the Privacy Policy effective date here) and
hereby consent and authorize Baselane and Intercom to share any information required for your use of the Services.

Professional advisors. We may disclose your personal information to professional advisors, such as
lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render
to us.

For compliance, fraud prevention and safety. We may share your personal information for the
compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or
assets, including your personal information, in connection with a business transaction (or potential business
transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets,
or in the event of bankruptcy or dissolution.

Your Choices

Access or Update Your Information. If you have registered for an account with us, you may review
and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by
following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. You may continue to receive service-related and other
non-marketing emails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use
cookies and similar technologies to track your browsing activity over time and across the Service and third party
websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser
settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your
browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear
your browser web storage.

Targeted online advertising. Some of the business partners that collect information about users’
activities on or through the Service may be members of organizations or programs that provide choices to individuals
regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising
Initiative by clicking here or the Digital Advertising
Alliance by clicking here. Please note that we also may work with companies that
offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to
engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated
with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be
relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are
included in this list, so you may still receive some cookies and tailored advertisements from companies that are not
listed.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the
online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more
about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your
personal information, or where we need your personal information in order to provide the Service to you, if you do
not provide this information when requested (or you later ask to delete it), we may not be able to provide you with
our services. We will tell you what information you must provide to receive the Service by designating it as
required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Service via a
third-party platform or social media network, you may have the ability to limit the information that we may obtain
from the third-party at the time you login to the Service using the third-party’s authentication service or
otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s
platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our
ability to access certain information from a third-party platform or social media network, that choice will not
apply to information that we have already received from that third-party.

Other sites, mobile
applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third
parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In
addition, our content may be included on web pages or in mobile applications or online services that are not
associated with us. We do not control third party websites, mobile applications or online services, and we are not
responsible for their actions. Other websites, mobile applications and services follow different rules regarding the
collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other
websites, mobile applications and online services you use.

Security practices

The security of your personal information is important to us.  We employ a number of organizational, technical
and physical safeguards designed to protect the personal information we collect.  However, security risk is
inherent in all internet and information technologies and we cannot guarantee the security of your personal
information. 

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal
information may be transferred to the United States or other locations outside of your state, province, or country
where privacy laws may not be as protective as those in your state, province, or country.  

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy,
we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if
required by law will, also provide notification of changes in another way that we believe is reasonably likely to
reach you, such as via e-mail (if you have an account where we have your contact information) or another manner
through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon
implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases,
your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the
terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to [email protected].

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying
the categories of personal customer information which we share with our affiliates and/or third parties for
marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a
California resident and would like a copy of this notice, please submit a written request to us via email at [email protected]. You must put the statement “Your California Privacy
Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for
notices that are not labeled or sent properly, or do not have complete information.

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