Privacy Policy

This Privacy Policy describes how Cosystems, Inc., d/b/a PocketEngines (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with SFR Portfolio Builder (the “Service”). By using the Service, you agree to the collection and use of information as described here.

This Service is intended for use by individual accredited investors, sponsors, and syndicators located in the United States.

1. Definitions

• “Account” means the account created for you to access the Service.
• “Company” refers to Cosystems, Inc., located at 4140 Donald Drive, Palo Alto, CA 94306, USA.
• “Personal Data” means information that relates to an identified or identifiable individual.
• “Content” means the property data, offering memos, market reports, investment criteria, and other materials you upload or enter into the Service.
• “Service” refers to the SFR Portfolio Builder web application.
• “Service Provider” means a third party that processes data on the Company’s behalf to help provide the Service.
• “You” means the individual or entity using the Service.

2. Information We Collect

2.1 Account and Contact Data

When you register for an Account, we collect information such as your name, email address, and phone number (if provided).

2.2 Content You Provide

To provide the Service’s core functionality, we collect the Content you choose to submit, including:

• Offering memos and property description documents (PDFs or other files) you upload;
• Property, market, and investment-criteria data you enter manually;
• Market reports, rent surveys, or broker packages you upload;
• Messages and prompts you send through the AI Market Research chat feature;
• Portfolio and transaction data you record in the Service.

2.3 Usage Data

We automatically collect information about how you interact with the Service, including IP address, browser type and version, device identifiers, pages visited, and time spent on the Service.

2.4 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the Service, e.g. session cookies, analytics (e.g. Google Analytics), and any advertising/marketing pixels. You can control cookies through your browser settings; disabling cookies may limit some functionality. Do Not Track: the Service does not currently respond to browser “Do Not Track” signals.

3. AI Processing and Automated Decision-Making

1. The Service uses artificial intelligence, including a third-party large language model providers including Anthropic, the maker of Claude and others, to extract financial data from documents you upload and to generate analysis, including Fiduciary Filter verdicts (INVEST/CAUTION/REJECT) and 30-year projections.
2. Content you submit for this purpose is transmitted to our AI provider(s), including Anthropic / Claude, solely to generate this Output for you. You agree to the terms and privacy policies of our AI provider’s data-retention and training practices. Contact us at support@pocketengines.com for a list of our AI providers.
3. Fiduciary Filter verdicts and other AI-generated Output are automated assessments based on rules and data you provide; they do not involve human review.

4. How We Use Your Information

We use the information described above to:

1. Provide, operate, and maintain the Service, including generating your Fiduciary Filter verdicts and projections;
2. Manage your Account and authenticate access;
3. Communicate with you about your Account, including service-related and security notices;
4. Send product updates or promotional communications, where you may opt out at any time by using the unsubscribe link in the email or updating your Account preferences;
5. Monitor, analyze, and improve the Service;
6. Comply with legal obligations and enforce this Policy and our Terms of Service;
7. Evaluate or conduct a merger, acquisition, financing, or sale of some or all of our assets.

5. How We Share Your Information

We do not sell your Personal Data. We may share information with:

1. Service Providers, engaged to help operate the Service, including categories such as: cloud hosting and infrastructure providers; the AI provider(s) described in Section 3; email and customer-communication providers; analytics providers; and, if applicable, payment processors.
2. Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.
3. Legal and safety reasons, where required by law, subpoena, or court order, or to protect the rights, property, or safety of Company, our users, or the public.
4. With your consent, for any other purpose you approve.

We do not share Content or Output from one customer’s Account with another customer; each Account’s data is isolated.

6. Data Retention

We retain Personal Data and Content for as long as your Account is active, and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. After your account is closed, we retain your data for 180 days after account closure, after which it is deleted, except where retention is required by law. Usage Data may be retained longer in de-identified or aggregated form for analytics purposes.

7. Data Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect your information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. Your Privacy Rights

8.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

1. Know what Personal Data we have collected, used, disclosed, and (if applicable) sold or shared about you;
2. Delete Personal Data we have collected from you, subject to certain exceptions;
3. Correct inaccurate Personal Data;
4. Opt out of the sale or sharing of Personal Data (Company does not currently sell or share Personal Data as those terms are defined under the CCPA/CPRA);
5. Limit the use of sensitive Personal Data, to the extent applicable;
6. Non-discrimination for exercising any of these rights.

To exercise these rights, contact us at support@pocketengines.com, or have an authorized agent submit a request on your behalf. We will verify your request before responding and will respond within the time required by law (generally 45 days, extendable as permitted).

We also comply with California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), which permits California residents to request information about our disclosure of Personal Data to third parties for direct marketing purposes once per year, and California Business and Professions Code § 22581, which allows California residents under 18 who are registered users to request removal of content they have publicly posted.

8.2 Other US State Residents

If you are a resident of Virginia, Colorado, Connecticut, Utah, or another state with a comprehensive privacy law, you may have similar rights to access, delete, correct, and opt out of certain processing of your Personal Data. To exercise these rights, contact us at support@pocketengines.com.

8.3 Managing and Deleting Your Data

You may update or delete Personal Data and Content directly within the Service where applicable, or by contacting us at support@pocketengines.com. We may need to retain certain information where we have a legal obligation or legitimate business need to do so.

9. Children’s Privacy

The Service is not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 13 (or under 18, for account registration, given the Service is intended for accredited investors). If we learn we have collected Personal Data from a child in violation of this Policy, we will delete it.

10. International Data Transfers

Your information is processed in the United States.

11. Links to Other Websites

The Service may contain links to third-party websites or services not operated by us. We are not responsible for the privacy practices of those third parties, and encourage you to review their privacy policies.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through the Service, and will update the “Last Updated” date above. Continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

support@pocketengines.com 4140 Donald Drive, Palo Alto, CA 94306