Exchango LLC — Privacy Policy

Exchango LLC ("Exchango," "we," "our," or "us") operates the website tryexchango.com and related applications (collectively, the "Platform"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you access or use the Platform.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use the Platform.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you voluntarily provide when you register for an account, complete your profile, submit exchange criteria, upload documents, or communicate with us. This may include:

• Full name, email address, phone number, and mailing address
• Company or entity name
• Real estate license number and supervising broker license number (for broker accounts)
• 1031 exchange criteria, including property type preferences, geographic preferences, equity amounts, and exchange timelines
• Qualified intermediary documentation
• Confidentiality agreements and other transaction documents executed through the Platform
• Any other information you choose to provide in communications with us or other users

1.2 Information Collected Automatically

When you access the Platform, we automatically collect certain technical information, including:

• IP address, browser type, operating system, and device identifiers
• Pages viewed, links clicked, time spent, and session recordings of your interactions with our web applications (see Section 6.1)
• Referring URL and search terms used to reach the Platform
• Cookies and similar tracking technologies (see Section 6 below)

1.3 Information from Third Parties

We may receive information about you from third-party sources, including license verification databases, identity verification services, qualified intermediaries or advisors who invite you to the Platform, and publicly available real estate records.

1.4 Information About Prospective Users

We collect business contact information (such as name, email address, phone number, company, and mailing address) about real estate professionals and property owners who are not yet Platform users. This information comes from public records, public websites, and commercial data providers. We use it only to contact these individuals about the Platform, and we do not sell it. Recipients can opt out of further outreach by using the unsubscribe link in any message or by emailing support@tryexchango.com.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To create and manage your account
• To facilitate anonymous matching between 1031 exchange buyers and licensed brokers
• To verify broker licensing credentials
• To verify buyer 1031 exchange documentation
• To process and facilitate the execution of confidentiality agreements and other transaction documents
• To process payments for broker subscriptions
• To communicate with you about your account, transactions, and Platform updates
• To contact real estate professionals and property owners who may be interested in using the Platform
• To improve, maintain, and optimize the Platform
• To detect and prevent fraud, abuse, or security incidents
• To comply with legal obligations and enforce our Terms of Service

3. How We Share Your Information

3.1 With Other Platform Users

Buyer exchange criteria are shared with registered brokers in anonymized form only. Your identity is not disclosed to any other user unless and until both parties execute a confidentiality agreement through the Platform, except that:

• authorized Exchango personnel may access your information to operate, support, and secure the Platform; and
• a qualified intermediary or advisor admitted to the Platform that has a current or past working relationship with you (for example, one that invited you or confirmed your exchange) may see your identity and exchange details, such as your deadlines, equity amount, and account status.

Broker profiles, including firm name and license information, may be visible to registered buyers.

3.2 With Service Providers

We may share your information with third-party service providers who perform services on our behalf, including payment processing, email delivery, hosting, analytics, license verification, and customer support. These providers are contractually obligated to use your information only as necessary to perform their services and to maintain appropriate security measures.

3.3 For Legal and Compliance Purposes

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on the Platform of any change in ownership or uses of your information.

3.5 With Your Consent

We may share your information for other purposes with your express consent.

3.6 Text Messaging

We do not share your mobile phone number or text-messaging opt-in data with third parties or affiliates for their marketing or promotional purposes. Text messaging originator opt-in data and consent are excluded from every category of sharing described in this Privacy Policy and will not be shared with any third parties, except the text-messaging service providers that deliver our messages.

4. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Transaction records and executed documents may be retained for a minimum of seven (7) years following the completion or termination of a transaction for legal and regulatory compliance purposes.

You may request deletion of your account and personal information by contacting us at the email address provided below. Certain information may be retained as required by law or for legitimate business purposes.

5. Data Security

We implement commercially reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, and regular security assessments.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on the Platform. Cookies are small data files stored on your device that help us remember your preferences, analyze Platform usage, and improve our services.

You can control cookie settings through your browser preferences. Disabling cookies may limit your ability to use certain features of the Platform.

6.1 Session Recording

When you use our web applications (but not our public marketing website at tryexchango.com), including their sign-in, sign-up, and preview pages, we use a session-recording service provided by PostHog, Inc. to record how you interact with the Platform. Recordings capture pages viewed, clicks, scrolling, mouse movements, text displayed on the page, text you type into form fields, and the content of requests the application sends to and receives from our servers. Password fields are masked in your browser and are never captured, and authentication headers are excluded. We use these recordings to diagnose errors, improve usability, and detect fraud or abuse. Recordings are processed by PostHog on our behalf as a service provider, are accessible only to authorized Exchango personnel, are not sold, and are automatically deleted after 30 days.

7. Your Rights and Choices

7.1 Access and Correction

You may access and update your account information at any time by logging into your account. You may also contact us to request access to, correction of, or deletion of your personal information.

7.2 Opt-Out of Communications

You may opt out of receiving promotional communications from us by following the unsubscribe instructions in those messages or by contacting us directly. You may not opt out of transactional or service-related communications. You may opt out of text messages at any time by replying STOP to any message.

7.3 State-Specific Rights

Depending on your state of residence, you may have additional rights under applicable data privacy laws, including the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), or similar state laws. These rights may include the right to know what personal information we collect, the right to request deletion, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination for exercising your privacy rights.

To exercise any of these rights, please contact us using the information provided in Section 11 below. We will respond to verifiable requests within the timeframes required by applicable law.

8. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor, we will take steps to delete that information promptly.

9. Third-Party Links

The Platform may contain links to third-party websites or services that are not owned or controlled by Exchango. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on the Platform with a revised "Last Updated" date and, where required by law, by providing additional notice (such as by email). Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Exchango LLC Email: support@tryexchango.com Address: 303 W 21st St, New York, NY 10011