RAVERA

The AI Operating System for Real Estate

Legal

PRIVACY POLICY

Effective Date: April 20, 2026

This Privacy Policy describes how Ravera Group LLC (“Ravera,” “we,” “us,” or “our”) collects, uses, shares, and protects information that identifies, relates to, describes, or is reasonably capable of being linked to a particular individual or household (“Personal Information”) in connection with the Ravera platform and its related websites, applications, and communications channels (collectively, the “Services”).

This Policy is available in Spanish on request. Please email privacy@ravera.co with the subject line “Spanish Translation Request” to receive a copy.


1. About Ravera and the Scope of This Policy

Ravera is a property management software and CRM platform used by residential real estate operators (“Property Managers” or “Properties”) to manage leasing, applications, residency, payments, maintenance, and resident communications. The Services include AI-assisted communication infrastructure that operates on behalf of Properties across SMS, voice, email, and chat channels. The AI assistant operating under the Ravera brand is referred to in this Policy as the “Ravera AI Assistant.”

Who this Policy covers. This Policy applies to:

  • Prospective renters and applicants who interact with a Property using the Services (for example, by submitting a leasing inquiry, scheduling a tour, or completing a rental application);
  • Current residents of properties managed using the Services;
  • Property Managers and their staff who use the Services to operate their business; and
  • Visitors to ravera.co and other Ravera-controlled websites.

Who this Policy does not cover. This Policy does not govern any third-party websites, applications, or services that you may reach through links in the Services, or any independent uses of your Personal Information by Property Managers outside of the Services. Property Managers are responsible for their own privacy practices, and we encourage you to review the privacy notices of any Property Manager or third party with whom you interact.

By using the Services or providing Personal Information to us, you acknowledge the practices described in this Policy.


2. AI-Assisted Communications, Recording Consent, and TCPA Acknowledgment

The Services use artificial intelligence and machine learning technologies, including the Ravera AI Assistant, which may handle replies to your SMS, voice, email, and chat communications on behalf of a Property. Please read this Section carefully — by using the Services, you provide the consents described below.

2.1 Communication with an AI System

You acknowledge that some or all of your interactions with a Property through the Services may be processed and answered by the Ravera AI Assistant. The Ravera AI Assistant identifies itself as automated upon first interaction in any new conversation thread, and a path to a human agent at the Property is available at any time. If you do not wish to interact with an AI system, you may request a human agent at any time by replying with the word AGENT to any SMS, asking for a human during a voice call, or contacting the Property directly.

2.2 Recording and Monitoring of Communications — Affirmative Consent

You expressly consent to the recording, monitoring, storage, and processing of all communications you conduct through the Services, including SMS messages, voice calls, voicemails, email, chat sessions, and any associated metadata. This consent applies regardless of whether the law of your state or jurisdiction would otherwise require all-party (sometimes called “two-party”) consent for the recording of communications. By initiating, accepting, or continuing any communication through the Services, you provide your express consent to such recording and processing for the purposes described in this Policy, including operating and improving the Services, training and improving our AI systems (using de-identified or aggregated data where feasible), maintaining service quality, ensuring safety, and complying with our legal obligations.

If you do not consent to recording, do not communicate with a Property through the Services. You may end any phone call, SMS thread, or chat session at any time.

2.3 TCPA Consent for Calls and Texts

When you opt in to receive SMS messages, voice calls (including pre-recorded or AI-generated calls), or other communications through the Services, you provide your prior express written consent under the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, to receive such communications from the relevant Property at the phone number you provided, using automated telephone dialing systems, artificial or pre-recorded voice messages, or AI-generated content. Your consent is not a condition of any purchase, rental, or other transaction. You may revoke this consent at any time as described in Section 6 below.

2.4 AI Training and De-Identification

Where we use Personal Information to improve our AI systems, we do so in a manner designed to prevent any individual’s information from being exposed across Properties or to other end users. We rely on de-identification, aggregation, access controls, and contractual restrictions on our model and platform vendors to limit AI-training risks. We do not attempt to re-identify de-identified data and we maintain de-identified data only in de-identified form.


3. Automated Decision-Making and Profiling

Some features of the Services use automated processing or AI to assist with decisions that may affect you, such as lead scoring, application routing, fraud screening, and — where applicable and authorized by the Property — assistance with rental application screening decisions (“Automated Decisions”). Automated Decisions that involve consequential outcomes (including decisions to provide or deny housing) are subject to additional safeguards under applicable law, including the Colorado Artificial Intelligence Act, the California Consumer Privacy Act as amended by the California Privacy Rights Act, and analogous state laws.

You have the right to:

  • Request information about the logic and significance of any Automated Decision that produces legal or similarly significant effects concerning you;
  • Request human review of any Automated Decision that produces legal or similarly significant effects, including a denial of housing or a determination affecting the terms of a rental agreement; and
  • Opt out of profiling for purposes that produce legal or similarly significant effects to the extent provided by applicable law.

Final tenancy decisions are made by Property Managers, who remain responsible under federal and state fair-housing law (including the Fair Housing Act) for ensuring that their decisions — whether or not assisted by AI — comply with anti-discrimination requirements. To exercise the rights in this Section, contact the Property directly or email privacy@ravera.co with the subject line “Automated Decision Review.”


4. Personal Information We Collect

We collect Personal Information directly from you, automatically through your use of the Services, and from third-party sources as described in Section 5. The categories of Personal Information we collect, using categories defined under the California Consumer Privacy Act and similar state laws, include:

4.1 General Categories

  • Identifiers — full name, postal address, email address, phone number (mobile and landline), date of birth, signature, and online identifiers such as IP address, device identifiers, account credentials, and cookie identifiers.
  • Records Information — information described in California Civil Code § 1798.80(e), such as name, signature, contact information, employment information, financial account information, payment card information, bank account information, and similar identifying records.
  • Commercial Information — records of leases, applications, rent payments, maintenance requests, transactions, payment history, and tour and inquiry history.
  • Internet or Network Activity Information — browsing history, search history, interaction with our websites and applications, referring URLs, page views, clicks, and similar usage data.
  • Geolocation Data — approximate location derived from IP address. We do not collect precise device geolocation through the core Services.
  • Audio, Visual, or Electronic Information — voice recordings of phone calls placed to or received by Property numbers operated through the Services, voicemails, photographs and videos you submit (for example, of a maintenance issue), and chat session recordings.
  • Professional or Employment Information — employer name, job title, work contact information, and employment history submitted in connection with a rental application.
  • Inferences — inferences drawn from the categories above to create a profile reflecting preferences, predispositions, behavior, and characteristics relevant to leasing, residency, and account servicing.
  • Sensitive Personal Information — government-issued identifiers such as Social Security number, driver’s license number, and state ID number; financial account information including bank account and routing numbers, payment card numbers, and account login credentials; and the contents of communications transmitted through the Services. We collect Sensitive Personal Information only when required for a specific purpose, such as verifying your identity, processing a rental application, or facilitating a payment.

4.2 Biometric Information

Ravera does not currently collect, process, or store biometric identifiers or biometric information (such as fingerprints, facial geometry, voiceprints, or retina/iris scans) as defined under the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), or analogous state laws. If we introduce features that involve biometric data in the future, we will update this Policy, post a separate biometric notice, and obtain any consents required by applicable law before such collection begins.

4.3 Information Collected for Specific Services

Rental Applications. When you submit a rental application through the Services, we may collect or facilitate the collection of additional information necessary to evaluate your application, including: Social Security number, government-issued identification, employment and income verification, banking and credit information, prior rental history, criminal and housing court records, and references. Where applicable, this information is used to obtain consumer reports and verifications from third-party screening providers operating under the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) and analogous state laws. The screening provider serves as the consumer reporting agency, and you will receive any required disclosures and consent requests from the Property or screening provider before any consumer report is obtained.

Resident Portal and Payments. When you use a resident portal operated through the Services, we collect account credentials, payment information, payment method details (which are tokenized and processed by our payment service provider), maintenance request descriptions and any photos or videos you attach, and your communications with the Property. Payment card information is handled in accordance with the Payment Card Industry Data Security Standard (PCI-DSS) by our certified payment processor.

Voice and SMS Communications. When you call or text a phone number operated through the Services, we collect your phone number, the date and time of the communication, the duration and content of the communication, and any voicemails. We may also collect call metadata such as caller ID information.


5. Sources of Personal Information

We collect Personal Information from the following sources:

  • Directly from you — when you submit information through Ravera-powered websites, application forms, resident portals, voice calls, SMS messages, email, or chat.
  • From Property Managers — when a Property submits or imports information about prospects, applicants, or residents into the Services.
  • From service providers and verification vendors — including identity, credit, employment, and rental-history verification providers that we or a Property Manager engage to support the application process.
  • From public and commercial sources — including public records, marketing data providers, and similar sources used to support marketing of the Services to Property Managers.
  • Automatically through your use of the Services — through cookies, web beacons, server logs, and similar technologies. See Section 10 below.

6. How We Use Personal Information

We use Personal Information for the following purposes:

  • To provide and operate the Services, including processing leasing inquiries and applications, scheduling tours, sending transactional and conversational communications, processing payments, managing maintenance requests, supporting residency, and delivering the resident portal and Property-facing tools.
  • To operate AI features, including generating AI-assisted replies, routing conversations, classifying intents, and surfacing relevant information to you and to the Property.
  • To verify identity and prevent fraud, including confirming applicant identity, detecting suspicious or fraudulent activity, and protecting the integrity of accounts and the Services.
  • To improve the Services, including analyzing how the Services are used, troubleshooting issues, training and improving AI models (using de-identified or aggregated data where feasible), and developing new features.
  • To communicate with you, including responding to inquiries, sending administrative notices, and providing support.
  • To market the Services to Property Managers (this purpose applies to Property Manager and Visitor data only, not to Personal Information of prospects, applicants, or residents).
  • To comply with legal obligations, including responding to lawful requests, retaining records, defending claims, and exercising or defending our legal rights.
  • For business transitions, including in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to the protections of this Policy.

We may de-identify or aggregate Personal Information so that it can no longer reasonably be linked to a particular individual. We may use de-identified or aggregated data for any lawful purpose, and we will not attempt to re-identify it.


7. SMS and Mobile Information — Important Notice

We collect SMS opt-in consent on behalf of Property Managers. The mobile information you provide when opting in to receive text messages from a Property using Ravera, including your phone number and any data collected through the SMS opt-in process, will not be shared with or sold to any third parties or affiliates for marketing or promotional purposes. This includes any third-party lead-generation services. Mobile information is used solely to deliver the messaging program you opted in to, and is shared only with the Property whose program you joined and with the service providers who deliver the messages on the Property’s behalf (such as Twilio).

You may opt out of SMS messages at any time by replying STOP to any message you receive. Reply HELP for support information. Standard message and data rates may apply, and message frequency varies based on your relationship with the Property.

For full SMS program terms, see our Terms and Conditions.


8. How We Share Personal Information

We share Personal Information only as described below. We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising or targeted advertising.

  • Property Managers. Information you submit to a Property through the Services is shared with that Property. The Property is independently responsible for its own use of your Personal Information under its own privacy practices and applicable law.
  • Service Providers. We share Personal Information with vetted service providers who perform functions on our behalf, under contractual obligations to protect Personal Information and use it only as needed to provide their service.
  • Verification and Screening Providers. When required to evaluate a rental application or verify identity, we share Personal Information with third-party vendors that conduct background, credit, employment, and identity verification, in accordance with our agreement with the relevant Property Manager and applicable law (including the Fair Credit Reporting Act).
  • Legal and Compliance Recipients. We may disclose Personal Information to comply with applicable law, lawful requests by public authorities (including for national security or law enforcement purposes), to enforce our agreements, to protect the rights, property, or safety of Ravera, our users, or others, and to defend against legal claims.
  • Business Transitions. We may disclose Personal Information in connection with a merger, acquisition, financing, reorganization, dissolution, sale of assets, or similar transaction. The recipient will be bound by privacy commitments at least as protective as those in this Policy.
  • With Your Consent or at Your Direction. We may share Personal Information with other parties when you direct us to do so or otherwise consent.

9. Retention of Personal Information

We retain Personal Information for as long as needed to provide the Services, comply with our legal obligations (including SMS opt-out records, which we retain for the period required by applicable law and in any event no less than ten years for jurisdictions imposing such requirements), enforce our agreements, defend legal claims, and serve the legitimate business purposes described in this Policy. Retention periods vary by data category and context. When Personal Information is no longer needed, we delete or de-identify it consistent with our retention schedule.


10. Cookies and Similar Technologies

Ravera-controlled websites use cookies and similar technologies (such as web beacons, pixel tags, server logs, and local storage). We use the following categories of cookies:

  • Essential cookies — required for the Services to function, such as authenticating your session, securing form submissions, and remembering your consent choices. These cannot be disabled.
  • Functional cookies — used to remember your preferences and personalize your experience, such as language and display settings.
  • Performance and analytics cookies — used to understand how visitors use our websites so we can improve them. Where required, we obtain consent before placing these cookies.

We do not use cookies for cross-site advertising or for the sale or sharing of Personal Information for cross-context behavioral advertising.

You can control cookies through your browser settings, although disabling certain cookies may affect the functionality of the Services. Our websites do not currently respond to “Do Not Track” browser signals, but we honor the Global Privacy Control (GPC) signal where required by California law and analogous state law.


11. Data Security and Breach Notification

We use commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, use, disclosure, and loss. These include encryption of Sensitive Personal Information at rest and in transit (including AES-256 encryption for sensitive identifiers such as Social Security numbers), role-based access controls, audit logging, vendor due diligence, and regular security review. Our payment processing partner is PCI-DSS Level 1 certified.

In the event of a security incident affecting Personal Information, we will notify affected individuals and applicable regulators in accordance with applicable law and our contractual obligations to Property Managers, including state breach-notification laws.

No method of transmission or storage is fully secure, however, and we cannot guarantee the absolute security of Personal Information.


12. Children

The Services are not directed to children under 18, and we do not knowingly collect Personal Information from children under 18 without parental or guardian consent. If you believe we have inadvertently collected information from a child under 18, please email privacy@ravera.co with the subject line “Personal Information of a Minor” and we will take appropriate steps to delete it.


13. Your Privacy Rights and Choices

Depending on the state where you reside, you may have the following rights regarding your Personal Information:

  • Right to know and access. Request that we disclose the categories of Personal Information we have collected, the categories of sources, the business purposes for collection, the categories of recipients with whom we have shared it, and the specific pieces of Personal Information we hold about you.
  • Right to correct. Request that we correct inaccurate Personal Information we hold about you.
  • Right to delete. Request that we delete Personal Information we have collected from you, subject to the exceptions permitted by applicable law (such as where we need to retain information to provide the Services, complete a transaction, comply with legal obligations, or defend legal claims).
  • Right to data portability. Request a copy of your Personal Information in a portable, structured, and machine-readable format where feasible.
  • Right to opt out of certain processing. Opt out of any “sale” or “sharing” of Personal Information for cross-context behavioral advertising. We do not sell or share Personal Information for these purposes.
  • Right to limit use of Sensitive Personal Information. Request that we limit our use of Sensitive Personal Information to those purposes permitted by applicable law.
  • Right regarding automated decision-making. Where applicable, request information about, request human review of, and opt out of certain Automated Decisions as described in Section 3.
  • Right to opt out of SMS. Reply STOP to any SMS message at any time.
  • Right to non-discrimination. We will not discriminate against you for exercising any of these rights.

13.1 How to Exercise Your Rights

To exercise any of these rights, email us at privacy@ravera.co with the nature of your request and sufficient information for us to verify your identity. As we operate exclusively online, email is our primary intake channel. We may ask for additional information to verify that you are the person about whom we hold the requested Personal Information; we will not use information collected for verification for any other purpose. We will respond within the timeframe required by applicable law (generally 45 days, with possible extensions of an additional 45 days where reasonably necessary, with notice to you).

You are limited to two requests for the right to know per twelve-month period, consistent with the California Consumer Privacy Act and analogous state laws.

13.2 Authorized Agents

You may designate an authorized agent to make a privacy-rights request on your behalf. To do so:

  • The agent must provide us with written, signed permission from you authorizing the agent to act on your behalf, or with a power of attorney granted under California Probate Code §§ 4000–4465 (or analogous state law);
  • We may require you to verify your own identity directly with us; and
  • We may deny a request from an authorized agent who does not submit proof that they have been authorized by you to act on your behalf.

13.3 Right to Appeal

If we decline a privacy-rights request you have made, you may appeal that decision by emailing privacy@ravera.co within a reasonable period after our response and clearly stating “Privacy Rights Appeal” in the subject line. We will respond to appeals within 45 days, including a written explanation of any action taken or our reasons for not taking action. Where the laws of your state permit, you may also have the right to lodge a complaint with your state attorney general or applicable supervisory authority. Texas residents may submit complaints at the Texas Attorney General’s consumer protection portal.

13.4 Note for Residents and Applicants

If you are a resident or applicant interacting with a specific Property through the Services and your request concerns information held by that Property under its own data practices, we will work with the Property to facilitate your request, but you may also wish to contact the Property directly. Our role with respect to certain resident and applicant Personal Information is that of a service provider to the Property, and the Property maintains its own privacy commitments.


14. State-Specific Disclosures

Residents of states with comprehensive consumer privacy laws — including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia — are entitled to the rights described in Section 13 to the extent applicable in their state.

California residents may also designate an authorized agent to make a request on their behalf as described in Section 13.2. We have not “sold” or “shared” Personal Information for cross-context behavioral advertising in the preceding 12 months.

Colorado residents are entitled, beginning June 30, 2026, to additional protections regarding Automated Decisions under the Colorado Artificial Intelligence Act, including pre-deployment notice and an opportunity to correct inaccurate data used in such decisions.


15. International Users

The Services are operated from the United States and are intended for users located in the United States. Personal Information is processed and stored in the United States. If you access the Services from outside the United States, you understand and consent to the transfer of your Personal Information to the United States, where data protection laws may differ from those in your jurisdiction.


16. Changes to This Policy

We may update this Policy from time to time. The most current version will always be posted on this page with an updated “Last Updated” date. Material changes will be communicated through the Services or by email where appropriate. Your continued use of the Services after an update constitutes acceptance of the updated Policy.


17. Contact Us

If you have questions, concerns, or complaints about this Policy or our privacy practices:

Ravera Group LLC

Email: privacy@ravera.co

General support: support@ravera.co

Website: https://ravera.co