Privacy Rights Request Policy

Overview

Stilly Ventures, Inc. respects the privacy rights of individuals and provides mechanisms for eligible individuals to exercise privacy rights that may be available under applicable laws. This policy should be read together with our Privacy Policy, Cookie Policy, and Terms of Service.

These rights may also apply to individuals who submit early access requests, waitlist requests, beta applications, support requests, or other communications.

Available Privacy Rights

Depending on applicable law and the nature of the request, individuals may have the right to request:

• Access: information about personal information collected, categories of information collected, sources, purposes of processing, and categories of disclosures.
• Correction: correction of inaccurate personal information.
• Deletion: deletion of personal information, subject to legal, operational, security, and account administration exceptions.
• Data portability: a copy of certain personal information in a portable format where applicable. Data portability requests may be fulfilled using commonly used electronic formats where technically feasible.
• Consent withdrawal: withdrawal of previously granted consent where consent is the legal basis for processing.
• Opt-out rights: opt out of certain processing activities where required by applicable law.

Individuals who submitted an early access request may request deletion of that request, subject to applicable legal, security, and operational requirements.

How to Submit a Request

Privacy requests may be submitted through:

• The Privacy Rights Request page.
• The Contact Us page or in-app Contact Us feature by selecting the Privacy topic.
• Email to propio_privacy@stillyventures.com.

Please include your full name, email address, type of request, and a clear description of what you are asking us to review. If your request relates to an early access request, beta application, waitlist record, PropioLedger account, company, rental, property, renter, cookie preference, or consent record, include any context you can provide, such as company name, property address, phone number, alternate email address, Consent ID, or other relevant identifiers.

Identity Verification

Before fulfilling a request, Stilly Ventures, Inc. may verify the identity and authority of the requester. Verification methods may include account authentication, email verification, review of matching records, review of submitted request details, and additional information reasonably necessary to verify identity.

If identity or authority cannot be verified, we may decline or limit the request. Information collected for verification is used for verification and request handling purposes.

Authorized Agents

Where permitted by law, requests may be submitted through an authorized representative. Stilly Ventures, Inc. may require documentation demonstrating authorization and may still require the individual to verify their identity directly where allowed.

Limitations and Exceptions

Certain privacy rights are subject to legal exceptions. Requests may be denied or limited when information is necessary for:

• Security, abuse prevention, or fraud prevention.
• Legal compliance, tax obligations, accounting obligations, or financial recordkeeping.
• Contract enforcement, dispute resolution, or exercise or defense of legal claims.
• Account administration, backup integrity, operational reliability, or other lawful purposes.

Early access requests, waitlist records, beta invitation records, and onboarding records may be retained as reasonably necessary to administer the beta program, evaluate requests, maintain security, prevent abuse, and document participation history.

Tenant, Renter, and Customer-Controlled Information

Many PropioLedger users are landlords, property owners, or property operators who may store information relating to renters, tenants, occupants, vendors, owners, and other third parties. In certain circumstances, Stilly Ventures, Inc. acts as a service provider or processor on behalf of the customer that submitted the information.

In many cases, PropioLedger acts as a service provider or processor for customer-controlled information rather than the original collector of that information.

Requests relating to renter, tenant, or customer-controlled records may need to be directed to the account holder, rental owner account, or property operator that originally collected the information. We may refer requesters to the appropriate account holder where required or appropriate.

Response Time

We aim to respond within the timeframes required by applicable law. Our internal privacy workflow tracks a 45-calendar-day response target for privacy rights requests. Response times may vary depending on applicable jurisdiction, complexity of the request, verification requirements, and applicable exceptions. If additional time is needed, we may notify the requester.

Fees

Privacy requests are generally provided free of charge. However, where permitted by law, Stilly Ventures, Inc. may charge a reasonable fee or decline requests that are excessive, repetitive, or manifestly unfounded.

Appeals

Where applicable law provides appeal rights, individuals may submit an appeal regarding a denied request. Appeals should be submitted through the Contact Us process or by emailing propio_privacy@stillyventures.com, and should clearly identify the original request, the date submitted, and the basis for appeal.

Do Not Sell or Share

PropioLedger does not currently sell personal information and does not currently share personal information for cross-context behavioral advertising. Additional information is available on the Do Not Sell or Share My Personal Information page.

Global Privacy Control

PropioLedger recognizes and honors valid Global Privacy Control (GPC) browser signals where applicable. Users may also manage preferences through Cookie Preferences.

Changes to This Policy

Stilly Ventures, Inc. may update this Privacy Rights Request Policy from time to time. Material changes may be communicated through website notices, application notices, email communications, or other reasonable methods.

Contact Information

Questions regarding privacy rights may be submitted through the Contact Us functionality available through PropioLedger, the Contact Us page, or by emailing propio_privacy@stillyventures.com. Additional contact information is available in the Terms & Policies Center.