Privacy Policy and Notice

Last Revised: August 6, 2026

Venn 2014 Ltd. (“Venn”, “we”, “our” or the “Company”, and their cognates) respects the privacy of its clients, users and website visitors, and is committed to protecting the personal information you may share with us or is provided on your behalf (these and any others with respect to whom we collect personal data, shall collectively be referred to as “Clients”, “Users”, “you” or “Data Subjects”).

Venn provides an AI cloud-based platform for multifamily residential operations to support the entire resident lifecycle (the “Services” or “Platform”).

This policy and notice (the “Privacy Policy”) explains how Personal Data is processed in two different contexts:

1. Venn as Controller: this applies when Venn collects and processes Personal Data for its own business purposes, including through our website, sales and marketing activities, customer accounts, support services, billing, security, compliance and other corporate operations.
2. Venn Platform (Venn as Processor): This Part applies to Personal Data processed through the Platform on behalf of property owners, property managers and other Venn clients. In these circumstances, the applicable Client acts as the data controller, while Venn acts solely as the data processor (or service provider under applicable US privacy laws) and processes Personal Data only on the Client's documented instructions. Requests relating to information processed through the Platform should generally be directed to the applicable property owner or property manager.

1. Which information may we collect?

Summary: we collect personal data provided directly by you or our clients, together with technical, device and usage information generated through your use of our Services.

We collect data about you in connection with your transactions with us, or in processing data for our users. We also collect data about website visitors. One type of data collected is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”), as described below.

Personal Data which is being gathered consists of any details which are personally identifiable and which are provided consciously and voluntarily by you, through our Services or your registration and use of our website, by email, or other ways in which you communicate and interact with us. This generally includes your name (first and last), email address, phone number, company, role, country, and online identifiers such as IP address. Depending on your use of the Platform, Personal Data may also include applicant information, leasing application information, identity verification information, screening results (where applicable), apartment or unit information, communications, maintenance requests, visitor and package information, amenity reservations, support requests, payment-related information, uploaded documents, audit logs, authentication records and other information submitted by you or by our client in connection with providing the Services.

Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which our website is used.

You do not have any legal obligation to provide any information to us, however, we require certain information in order to perform contracts, or to provide any Services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the Services.

When Venn provides the Platform on behalf of a client, we process Personal Data solely on the Client's behalf and in accordance with its documented instructions.

Depending on how the Client configures the Platform, the Personal Data processed may include resident and prospective resident information, apartment or unit information, communications, maintenance requests, visitor and package information, amenity reservations, payment-related information, uploaded documents, authentication records, audit logs and other information submitted by users or by the Client in connection with the Services. The categories of Personal Data processed, the purposes of processing and the retention periods are determined by the applicable Client.

2. How do we collect Personal Data of yours on our Services?

Summary: we collect Personal Data directly from you, from our clients and your interactions with us, and automatically through your use of our website, application and Services, including through cookies and similar technologies.

We collect Personal Data when you contact us, request information, register interest in our Services, create or administer a customer account, enter into or perform a contract with us, use our website or Services, or otherwise communicate with us. We also collect Personal Data when you contact our support team, including the information you provide in your communications.

We automatically collect certain technical and usage information when you access or use our website or Services, either directly or through authorized third-party service providers. This may include your Internet Protocol (IP) address, device identifiers, browser type and version, operating system, screen resolution, time zone, URLs, clickstream data, pages viewed, session duration, navigation patterns, and details of your interactions with our support channels. We also use cookies and similar technologies as described below.

Personal Data processed through the Platform may be collected directly from users, provided by the applicable Client, or received through integrations with systems authorized by the Client, such as property management systems, ERP systems, payment providers, applicant screening and identity verification providers, and communication platforms. The Platform may also automatically collect technical and usage information generated through users' interaction with the Platform. Depending on the Client's configuration, the Platform may consolidate such information to provide authorized users with a centralized operational view of resident related information. The Platform may also enable community features, such as announcements, events, discussion groups and resident communications.

3. What are the purposes of Personal Data we collect?

Summary: we process Personal Data to meet our obligations, protect our rights, and manage our business.

We will use Personal Data to provide and improve our Services to our Clients, Users and others and meet our contractual, ethical and legal obligations. All Personal Data will remain accurate complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:

• Carrying out our obligations arising from any contracts entered into between you and Venn and/or any contracts entered into with us and to provide you with the information, support and Services that you request from Venn;
• Verifying and carrying out financial transactions in relation to payments you make in connection with the Services.

Processing which is necessary for the purposes of the legitimate interests pursued by Venn or by a third party of providing an efficient and wide-ranging service to users:

• Notifying you about changes to our Services;
• Contacting you to give you commercial and marketing information about events or promotions or additional products or Services offered by Venn which may be of interest to you;
• Soliciting feedback in connection with the Services;
• Tracking use of Venn Services to enable us to optimize them;
• For security purposes and to identify and authenticate your access to the Services.
• Supporting Client-authorized functionality, including organizing information, improving search functionality and supporting Client service workflows.

Processing which is necessary for compliance with a legal obligation to which Venn is subject:

• Compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, anti-money laundering, and for crime prevention and prosecution in so far as it relates to our staff, users, facilities etc;
• If necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding.

4. Sharing data with third parties

Summary: we share Personal Data with our service providers, partners, and authorities where required.

We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website, and our marketing.

The Platform may integrate with Client-authorized third-party systems, including property management systems, payment providers, notification providers, identity verification services and other operational tools selected by Clients. Personal Data is shared with such providers only as necessary to provide the requested Services.

We periodically add and remove third party providers. At present our third-party providers to whom we may transfer personal data include also the following:

• Website analytics;
• Document management and sharing services;
• User ticketing and support;
• On-site and cloud-based database services;
• CRM software;
• Data security, data backup, and data access control systems;
• Marketing, user acquisition and retargeting platforms;
• Our lawyers, accountants, and other standard business software and partners.

In addition, we may disclose your personal data to third parties if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case personal data will be one of the transferred assets. Likewise, we may transfer personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect our rights, property, or safety, or those of our clients or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For purposes of US privacy state laws, we do not “sell” or ‘share’ personal information, nor do we allow any personal information to be used by third parties for their own marketing. However, we use analytics tools and other technologies, which may be construed as a “sale” under privacy laws to which you may opt-out of. For avoidance of doubt, personal Data shared with third parties shall be strictly anonymous and aggregated, and we transfer and disclose such non-Personal Data to third parties at our own discretion.

5. AI data usage

Summary: we provide AI-assisted features to support our Services while maintaining human oversight and protecting Client Personal Data.

We may provide AI assisted functionality to support the Services, including drafting communications, summarizing applicant and resident interactions, organizing information, improving search functionality, assisting with customer service workflows, and analyzing community content to support property management operations. AI functionality is designed to assist authorized users and improve operational efficiency and is not intended to replace human decision-making or make decisions about individuals.

Client Personal Data processed through AI features is used solely to provide the requested functionality. We do not use Client Personal Data to train our general AI models unless expressly authorized by the applicable Client or otherwise permitted by applicable law. AI-generated outputs are advisory in nature and remain subject to meaningful human review.

6. Where do we store your data?

Summary: we store your Personal Data across multiple locations globally.

We store your Personal Data on servers owned or controlled by us, or processed by third parties on our behalf, by reputable cloud-service providers.

7. International data transfers

Summary: we transfer Personal Data within and to the EEA, USA, Israel and elsewhere, with appropriate safeguards in place.

Personal Data may be transferred to, and stored and processed at, a destination outside its origin. EU Personal data may be transferred outside the European Economic Area (EEA). Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, including entering into contracts that require the recipients to adhere to data protection standards that are considered satisfactory under EU law and other applicable, and that it is treated securely and in accordance with this Privacy Policy. Where required under applicable law, transfers of Personal Data are carried out using recognized transfer mechanisms, including adequacy decisions, the EU Standard Contractual Clauses or other lawful transfer mechanisms. Transfers to Israel are made based on an adequacy ruling by the EU Commission. Transfers to the USA are made based either on an adequacy ruling to members of the data privacy framework, or based on the Standard Contractual Clauses published by the EU Commission. For more information about these safeguards, please contact us as set forth below.

We may transfer your Personal Data outside of the EEA, in order to:

• Store or backup the information;
• Enable us to provide you with the Services and products and fulfill our contract with you;
• Fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
• Facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
• To serve our users across multiple jurisdictions; and
• to operate our affiliates in an efficient and optimal manner.

8. Data retention

Summary: we retain Personal Data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.

Venn will retain Personal Data it processes only for as long as required in our view, to provide the Services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices. Where Venn processes Personal Data on behalf of a Client through the Platform, retention periods are determined by the applicable Client.

Data that is no longer retained may be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our Services are not subject to the deletion procedures in this policy and will be retained by Venn. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten.

9. Services and website data collection and cookies

Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our website, or through your device and browser.

Venn uses cookies, pixel tags and other forms of identification and local storage (together referred to as “tags/files”) to distinguish you from other users of the Website. This helps us to provide you with a good user-experience when you browse the Website and also allows us to improve our Services.

In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files are set by Venn itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.

These tags/files can fall into several categories: (i) those that are necessary for functionality or Services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).

Internet browsers allow you to change your cookie settings, for example to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/how-to-delete-cookies/

Functionality tags/files do not require your consent. For other tags/files, however, we request your consent before placing them on your device. You can allow cookies in your browser settings and using our website cookie management too.

To consult the list of cookies which we use on our website, please check your browser's settings. Instructions: https://www.wikihow.com/View-Cookies.

10. Security and storage of information

Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. Venn implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our website and Services are safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within Venn, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for Venn to fulfill its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.

Venn shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by Venn is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Venn shall promptly take reasonable remedial measures.

11. Data subject rights

Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.

Data subjects with respect to whose data GDPR, or other data protection or privacy laws apply, have rights under applicable laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where Personal Data is provided by a user being the data subject's employer, such data subject rights will have to be effected through that user, the data subject’s employer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Venn employees and staff, with Venn proprietary rights, and third-party rights. As such, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent.

A data subject who wishes to modify, delete or retrieve their Personal Data, may do so by contacting us at privacy@venn.city. Note that we may have to undertake a process to identify a data subject exercising their rights. We may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by us.

Data subjects in the EU and in other locations have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.

12. General

Minors. We do not knowingly collect or solicit information or data from or about children under the age of 16 without parental consent, or knowingly allow children under the age of 16 to register for Venn Services. If you are under 16, do not register or attempt to register for any of the Venn Services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16 without appropriate permissions, we will delete that Personal Data as soon as reasonably practicable without any liability to Venn. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: privacy@venn.city, as soon as possible.

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the Services and website and any information collected in connection with them. We may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available here. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our Services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

Venn aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Venn only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us at privacy@venn.city and we will make an effort to reply within a reasonable timeframe.

Last Revised: August 6, 2026