DOC Vault Inc. dba HOA Doctor(R) (the “Company”) and/or Hoadoctor.com and/or the Company’s website, products,  services, email, social media, software and any other related digital components, values the privacy of  the individual and has created this policy (“Privacy Policy”) to demonstrate its firm commitment to  transparency about how the Company treats the information of its users of in conjunction with the  Company’s cloud-based Civic Trust-Tech community association review application (“Application”).  The Application, Features and any other services or products we may offer from time to time (as  defined herein below) constitute the “HOA Doctor Services.” Because the Company gathers important  information from our users, the Company has established this Privacy Policy as a means to  communicate the Company’s information gathering and dissemination practices. The Company  reserves the right to change this Privacy Policy in accordance with the terms herein and reflected in the  Terms of Service. 

Definitions 

For the purposes of this Privacy Policy: 

Account means a unique account or profile created for You to access the HOA Doctor Services. Affiliate means an entity that controls, is controlled by or is under common control with a  party, where “control” means ownership of 50% or more of the shares, equity interest or other  securities entitled to vote for election of directors or other managing authority.  Company (referred to as either “the Company,” “We,” “Us” or “Our” in this Agreement) refers  to DOC Vault Inc. dba HOA Doctor(R). 

For the purpose of the GDPR, the Company is the Data Controller. 

Country refers to: United States 

Device means any device that can access the HOA Doctor Services such as a computer, a  cellphone, or a digital tablet. 

Sale means selling, renting, releasing, disclosing, disseminating, making available, transferring,  or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s  personal information to another business or a third party for monetary or other valuable  consideration. 

Service refers to the HOA Doctor Services. 

Service Provider means any natural or legal person who processes the data on behalf of the  Company. It refers to third-party companies or individuals employed by the Company to  facilitate the Service, to provide the Service on behalf of the Company, to perform services  related to the Service or to assist the Company in analyzing how the Service is used. For the  purpose of the GDPR, Service Providers are considered Data Processors. 

Third-party Social Media Service refers to any website or any social network website through  which a User can log in or create an account to use the HOA Doctor Services. 

Usage Data refers to data collected automatically, either generated by the use of the Service or  from the Service infrastructure itself (for example, the duration of a page visit). You means the individual accessing or using the Service, or the company, or other legal entity  on behalf of which such individual is accessing or using the Service, as applicable. 

What information do we collect? 

We collect information from you when you register for an Account on the HOA Doctor Services or fill  out a form. We will collect any and all information that you input, including but limited to: Contact  Information (legal name, address (in your Neighborhood), confirmation of whether your Community is  managed by a Property Manager, profile photo, phone number and/or email address); Payment 

Information Data; Location (Neighborhood); Contacts (Accessing User Address Book Data); Search  History (Information About Searches Performed In The App Data); Identifiers (User ID Data and  Device ID Data); and Diagnostics (Crash Data and Performance Data). 

We may also collect your billing information, such as billing name and address, bank account number,  routing number and in some instances a credit card number and/or other identifier that permits the  physical or online contacting of a specific individual, depending on your activities while on the HOA  Doctor Services.  

What we use information for 

Any of the information we collect from you may be used in one of the following ways: to personalize  your experience (your information helps us to better respond to your individual needs); to improve the  HOA Doctor Services (we continually strive to improve our offerings based on the information and  feedback we receive from you); to improve customer service (your information helps us to more  effectively respond to your customer service requests and support needs); to send periodic emails. We  can also use your information to monitor and assemble analytics pertaining to an individual’s use of the  HOA Doctor Services. The Company may use the information that we collect to setup the Accounts  for registered users and may also use the information to send information regarding our company or  partners, such as promotions and events. The email address you provide may be used to send you  occasional company news, updates, related product or service information, etc. If at any time you  would like to unsubscribe from receiving future emails, please reply to the Company email and request  that your email address be removed from the list. 

We will not sell, trade, or otherwise transfer to outside parties your personally identifiable information;  except that certain information may be transferred as a necessary function of an API or other similar  software function. We may also release your information when we believe release is appropriate to  comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.  User email addresses may be sold to or otherwise shared with third parties for marketing  purposes; provided, however that the Company may assign any and all personal customer information  to a successor entity should the Company be the subject of a merger, acquisition or any other similar  such transaction in which the control of the Company substantially changes. Individual records may at  times be viewed or accessed only for the purpose of resolving a problem, support issue, or as may be  required by law. Of course, registered users are responsible for maintaining the confidentiality and  security of their user registration and password. The Company may aggregate data, including  demographic or other general user data, together in an anonymous fashion to generate reporting for  internal analysis or distribution as it sees fit and may, at its sole discretion, choose to offer such  reporting for promotional purposes and/or monetary gain. The Company may also track and analyze  non-identifying and aggregate usage and volume statistical information from our visitors and customers  and provide such information to third parties. 

Third party links/transactions 

Occasionally, at our discretion, we may include or offer third party products or services on the  HOA Doctor Services, including through the implementation of advertisements, including  “Vendors” as defined in the Terms of Service. These third party sites have separate and  independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of the HOA Doctor  Services and welcome any feedback about these sites. 

Furthermore, when Users interact with one another Users’ emails, first and last names and other info  may be transferred to other affiliated third party businesses. The Company shall under no  circumstances be responsible for what buyer/seller or other affiliated third party businesses do with  Users’ information. 

California Online Privacy Protection Act Compliance 

Because we value your privacy we have taken the necessary precautions to be in compliance with the  California Online Privacy Protection Act. We therefore will not distribute your personal information to  outside parties without your consent. 

Residents of the State of California, under certain provisions of the California Civil Code, have the  right to request from companies conducting business in California a list of all third parties to which the  company has disclosed certain personally identifiable information as defined under California law  during the preceding year for third party direct marketing purposes. You are limited to one request per  calendar year. In your request, please attest to the fact that you are a California resident and provide a  current California address for our response. You may request the information in writing at DOC Group  LLC, ATTN: LEGAL, ___________________ and admin@Hoadoctor.com. 

Childrens Online Privacy Protection Act Compliance 

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we  do not collect any information from anyone under thirteen (13) years of age. The HOA Doctor  Services, products and services are all directed to people who are at least thirteen (13) years old or  older. 

Online Privacy Policy Only 

This online Privacy Policy applies only to information collected through the HOA Doctor Services and  not to information collected offline. 

Changes to our Privacy Policy 

If we decide to change our Privacy Policy, we will post those changes on this page.  

Public Forums 

We may offer chat rooms, message boards, bulletin boards, or similar public forums, where you and  other users of the HOA Doctor Services can communicate. The protections described in this Privacy  Policy do not apply when you provide information (including personal information) in connection with  your use of these public forums. We may use personally identifiable and non-personal information  about you to identify you with a posting in a public forum. Any information you share in a public  forum is public information and may be seen or collected by anyone, including third parties that do not  adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any  information you choose to publicly post or share through the HOA Doctor Services. 

Keeping Your Information Secure  

We have implemented security measures we consider reasonable and appropriate to protect against the  loss, misuse and alteration of the information under our control. Please be advised, however, that while  we strive to protect your personally identifiable information and privacy, we cannot guarantee or  warrant the security of any information you disclose or transmit to us online and are not responsible for  the theft, destruction, or inadvertent disclosure of your personally identifiable information. In the unfortunate event that your “personally identifiable information” (as the term or similar terms are  defined by any Applicable law requiring notice upon a security breach) is compromised, we may notify 

you by email (at our sole and absolute discretion) to the last email address you have provided us in the  most expedient time reasonable under the circumstances; provided, however, delays in notification may  occur while we take necessary measures to determine the scope of the breach and restore reasonable  integrity to the system as well as for the legitimate needs of law enforcement if notification would  impede a criminal investigation. From time to time we evaluate new technology for protecting  information, and when Appropriate, we upgrade our information security systems.  

Contact and Opt-Out Information  

You may contact us as at admin@Hoadoctor.com if: (a) you have questions or comments about our  Privacy Policy; (b) wish to make corrections to any personally identifiable information you have  provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from  us or our affiliated companies; or (d) wish to withdraw your consent to sharing your personally  identifiable information with others. We will respond to your request and, if Applicable and  Appropriate, make the requested change in our active databases as soon as reasonably practicable.  Please note that we may not be able to fulfill certain requests while allowing you access to certain  benefits and features of the HOA Doctor Services.  

Sole Statement  

This Privacy Policy as posted on the HOA Doctor Services is the sole statement of our privacy policy  with respect to the HOA Doctor Services, and no summary, modification, restatement or other version  thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised  policy to the HOA Doctor Services.

GDPR PRIVACY POLICY 

Legal Basis for Processing Personal Data under GDPR 

We may process Personal Data under the following conditions: 

Consent: You have given Your consent for processing Personal Data for one or more specific  purposes. 

Performance of a contract: Provision of Personal Data is necessary for the performance of an  agreement with You and/or for any pre-contractual obligations thereof. 

Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to  which the Company is subject. 

Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of  another natural person. 

Public interests: Processing Personal Data is related to a task that is carried out in the public  interest or in the exercise of official authority vested in the Company. 

Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate  interests pursued by the Company. 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the  processing, and in particular whether the provision of Personal Data is a statutory or contractual  requirement, or a requirement necessary to enter into a contract. 

Your Rights under the GDPR 

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You  can exercise Your rights. 

You have the right under this Privacy Policy, and by law if You are within the EU, to: • Request access to Your Personal Data. The right to access, update or delete the information We  have on You. Whenever made possible, you can access, update or request deletion of Your Personal  Data directly within Your account settings section. If you are unable to perform these actions  yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal  Data We hold about You. 

Request correction of the Personal Data that We hold about You. You have the right to have  any incomplete or inaccurate information We hold about You corrected. 

Object to processing of Your Personal Data. This right exists where We are relying on a  legitimate interest as the legal basis for Our processing and there is something about Your  particular situation, which makes You want to object to our processing of Your Personal Data on  this ground. You also have the right to object where We are processing Your Personal Data for  direct marketing purposes. 

Request erasure of Your Personal Data. You have the right to ask Us to delete or remove  Personal Data when there is no good reason for Us to continue processing it. 

Request the transfer of Your Personal Data. We will provide to You, or to a third-party You  have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please  note that this right only applies to automated information which You initially provided consent for  Us to use or where We used the information to perform a contract with You. 

Withdraw Your consent. You have the right to withdraw Your consent on using your Personal  Data. If You withdraw Your consent, We may not be able to provide You with access to certain  specific functionalities of the Service.

Data Retention Policy 

We will retain Your personal information only for as long as necessary to fulfill the purposes for which  it was collected, including to satisfy any legal, accounting, or reporting requirements. The criteria used  to determine our retention periods include: 

1. Purpose Fulfillment: We will keep personal information for as long as You maintain an active  Account or as needed to provide the HOA Doctor Services You have requested. 2. Legal and Regulatory Obligations: We may retain personal information where retention is  necessary to comply with our legal obligations, resolve disputes, enforce agreements, or meet  tax, accounting, or other regulatory requirements. 

3. Business Needs: We may retain personal information for a limited period after account closure  to address complaints, maintain business records, and improve our services. 

4. Technical and Security Requirements: We may retain backup copies and system logs  containing personal information for a limited period as part of our disaster recovery,  cybersecurity, and business continuity programs. 

When retention is no longer required, we will delete, anonymize, or otherwise securely dispose of  personal information in accordance with applicable law. In some cases, we may anonymize personal  information so that it can no longer be associated with an identified or identifiable individual; in that  case, we may use such information indefinitely without further notice to You. 

Exercising of Your GDPR Data Protection Rights 

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us.  Please note that we may ask You to verify Your identity before responding to such requests. If You  make a request, We will try our best to respond to You as soon as possible. You have the right to  complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more  information, if You are in the European Economic Area (EEA), please contact Your local data  protection authority in the EEA.

U.S. STATE PRIVACY RIGHTS 

If you are a resident of California, Colorado, Connecticut, Virginia, or any other U.S. state with a  comprehensive consumer privacy law, you may have certain rights with respect to your personal  information, subject to applicable law. These rights may include: 

1. Right to Know and Access: You have the right to request that we disclose the categories and  specific pieces of personal information we have collected about you, the sources of that  information, the purposes for which we use it, and the categories of third parties with whom we  share it. 

2. Right to Delete: You have the right to request that we delete personal information we have  collected from you, subject to certain exceptions (such as to complete a transaction, detect  security incidents, comply with law, or other internal uses reasonably aligned with your relationship with us). 

3. Right to Correct: You have the right to request that we correct inaccuracies in your personal  information, taking into account the nature of the information and the purposes of the  processing. 

4. Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or sharing of  your personal information with third parties, including for cross-context behavioral advertising.  “Sale” may include the exchange of personal information for monetary or other valuable  consideration. “Sharing” may include the disclosure of personal information for targeted  advertising. You may exercise this right at any time by contacting us using the methods  described below. 

5. Right to Limit the Use of Sensitive Personal Information: In some states, you may have the  right to limit our use or disclosure of sensitive personal information to only those uses  necessary to provide the requested services or as otherwise permitted by law. 

6. Right to Data Portability: You may have the right to obtain a copy of the personal information  you provided to us in a portable and, to the extent technically feasible, readily usable format  that allows you to transmit the information to another entity without hindrance. 

7. Right to Non-Discrimination: We will not discriminate against you for exercising any of the  rights described in this section. 

How to Exercise Your Rights 

You may exercise any of these rights by: 

• Emailing us at: admin@Hoadoctor.com 

• Mailing us at: DOC Vault Inc. dba HOA Doctor(R), ATTN: LEGAL, 3129 E Camelback Rd #413 Phoenix, AZ 85016 

We will verify your identity before processing your request and may require additional information to  do so. If we deny your request, we will explain the basis for the denial. In certain states, you may  appeal our denial by following the instructions provided in our response. 

Authorized Agents (California Residents) 

If you are a California resident, you may designate an authorized agent to make a request on your  behalf. We will require the authorized agent to provide proof of your written permission, and we may  also require you to verify your own identity directly with us.

Notice of Collection 

We collect the categories of personal information described in the “What information do we collect?”  section of this Privacy Policy. We collect and use these categories for the purposes described in the  “What we use information for” section. 

Additional Information for California Residents 

For purposes of the CCPA/CPRA, the categories of personal information we may collect include: 

• Identifiers (e.g., name, email address, device ID) 

• Contact information (e.g., mailing address, phone number) 

• Commercial information (e.g., transaction history) 

• Internet or other electronic network activity (e.g., browsing history, interactions with our  services) 

• Location data (e.g., general location, Neighborhood) 

• Professional or employment-related information (if provided) 

• Inferences drawn from the above to create a profile reflecting preferences or characteristics 

We may “sell” or “share” these categories of personal information, as those terms are defined under  applicable law, to the extent described in this Privacy Policy. 

This Privacy Policy was last revised on August 28, 2025.